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MVO Nederland

Voor een duurzame economie moet het huidige systeem op de schop.

Lobbying Activity

Response to Circular Economy Act

5 Nov 2025

MVO Nederland welcomes the opportunity to contribute to the European Commissions public consultation on the Circular Economy Act (CEA). The CEA represents a crucial step in strengthening and improving the supply and demand for high-quality, recycled materials, and ensuring that Europes economy becomes both circular and competitive. MVO Nederland is the largest business network for sustainable and circular entrepreneurship in the Netherlands, representing over 2,000 companies across sectors including textiles, plastics, manufacturing, and construction. Together, we work toward a climate-neutral and circular economy by 2050. For the transition to succeed, the Act must be directly linked to high-quality job creation and technological innovation in circular industries. In the Netherlands, leading circular companies in textiles and plastics are under severe pressure. They face rising costs, unstable demand, and unfair competition from ultra-fast fashion and low-quality imports that do not meet EU sustainability standards. These businesses want to lead the transition, yet they are constrained by regulatory uncertainty and a lack of harmonised data and definitions. The Digital Product Passport (DPP) is therefore the key instrument to make circularity measurable, traceable, and enforceable. By linking the DPP to concrete and verifiable information on product composition, repairability, and recyclability, the EU can turn circular principles into practical business conditions. Our input is made up out of 9 key points, each including an expanded description in the file in the appendix: Make the Digital Product Passport (DPP) mandatory and interoperable across all sectors Ensure DPPs include verifiable data on quality, repairability, recyclability, and material composition Establish a European Circular Leverage Mechanism (Circular Transition Fund) Publish the DPP for textiles no later than January 2027 with clear timelines for implementation Set strict ecodesign requirements for durability, repairability, and lifetime extension Require design for disassembly and replaceable components Introduce an EU-wide ban on the incineration of recyclable materials Use public procurement to prioritise durable, reusable, and high-quality products Expand Extended Producer Responsibility (EPR) past waste-management Concluding, the circular industry calls for swift implementation of the Circular Economy Act through clear timelines and sector-specific pilot programmes for SMEs and industry councils. Early testing will help identify practical challenges, reduce administrative burdens, and build confidence among frontrunners. The Commission should include a mandatory evaluation clause to assess progress on key indicators such as material efficiency, circularity performance, and market uptake. A transparent, data-driven review process will ensure accountability and enable continuous improvement, helping Europe move from ambition to measurable results in its circular transition.
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Meeting with Fabien Gehl (Head of Unit Trade)

22 Oct 2025 · Meeting with MVO on the state of play of the CEPA

Meeting with Lara Wolters (Member of the European Parliament, Shadow rapporteur)

25 Jun 2025 · Omnibus

Meeting with Martin Hojsík (Member of the European Parliament)

12 Jun 2025 · Sustainable entrepreneurship, nature restoration

Meeting with Frans Timmermans (Executive Vice-President) and Stichting IUCN Nederlands Comité and

3 Mar 2020 · Green Deal, forests and support by business

Meeting with Daniel Calleja Crespo (Director-General Environment)

7 Jun 2016 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

30 Mar 2015 · Circular economy

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

30 Mar 2015 · Circular Economy

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

30 Mar 2015 · Circular Economy Package