CO₂ Value Europe’s Policy Team has submitted a response and position paper to the European Commission’s consultation on the upcoming Circular Economy Act, a crucial legislative initiative designed to strengthen the EU single market for waste and secondary raw materials.
While the proposal rightly focuses on recycling, waste reduction and industrial symbiosis, Carbon Capture and Utilisation (CCU) remains notably absent from the conversation, a major oversight in the EU’s ambition to build a truly circular and defossilised economy.
CCU: Circular by Nature, Essential for Europe’s Defossilisation
CCU is circular by design. It converts captured CO₂ into valuable products such as fuels, chemicals and building materials, keeping carbon in the loop instead of releasing it into the atmosphere. CCU complements recycling and reuse efforts, offering a pathway to reduce dependence on virgin fossil feedstocks and close the carbon cycle across industrial value chains.
Major global organisations, including the IPCC, IEA, G7 and World Economic Forum, have all recognised CCU as a key lever for achieving climate neutrality and circularity. At the EU level, initiatives such as the Clean Industrial Deal, the Industrial Carbon Management Strategy and the EU Chemicals Industry Transition Pathway also highlight the need to activate CCU technologies at scale.
Our Three Core Policy Asks
To unlock CCU’s full potential in building a circular carbon economy, CO₂ Value Europe is calling on the European Commission to include the following measures in the Circular Economy Act:
🔵 Create a legal definition for “circular carbon feedstocks.”
This definition should encompass recycled, bio-based and captured carbon feedstocks, recognising them as essential inputs for sustainable industrial production.
🔵 Set binding targets for circular carbon content.
- I) By 2035, at least 10% of feedstocks used in chemical and downstream industries (plastics, solvents, fertilisers, pharmaceuticals, packaging, etc.) should come from captured carbon; II) By 2035, at least 30% of total feedstocks should come from circular carbon sources overall.
🔵 Introduce separate NACE codes for fossil-based and non-fossil-based feedstocks and products, ensuring proper recognition, traceability and policy support for circular solutions.
A Defining Moment for Europe’s Circular Economy
The Circular Economy Act represents a once-in-a-mandate opportunity for Europe to expand its definition of circularity. Focusing solely on recycling is not enough, as it addresses only part of the challenge.
CCU must be recognised as a fundamental part of the circular economy, enabling industries to defossilise production, reuse carbon emissions and build a more resilient and competitive European industrial base.
The technology is here, mature and delivering results. Excluding CCU from future circularity legislation would be a missed opportunity.
Read more:
Find our position paper here.
Find our response to the consultation here.
