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Document 52023AE3270

Opinion of the European Economic and Social Committee on the communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on a revised monitoring framework for the circular economy (COM(2023) 306 final)

EESC 2023/03270

OJ C, C/2024/889, 6.2.2024, ELI: (BG, ES, CS, DA, DE, ET, EL, EN, FR, GA, HR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)


European flag

Official Journal
of the European Union


Series C



Opinion of the European Economic and Social Committee on the communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on a revised monitoring framework for the circular economy

(COM(2023) 306 final)



Cillian LOHAN


European Commission, 29.6.2023

Legal basis

Article 114 of the Treaty on the Functioning of the European Union

Section responsible

Section for Agriculture, Rural Development and the Environment

Adopted in section


Adopted at plenary


Plenary session No


Outcome of vote



1.   Conclusions and recommendations


This Monitoring Framework is an improvement on the previous framework, but still needs to go further in specific areas highlighted in this opinion.

2.   Support


It is essential to have a Monitoring Framework for effective and practical implementation, and to ensure that Circular Economy Monitoring continues to move in the right direction.


The European Economic and Social Committee (EESC) recognises that a lack of comparable data in some areas, across Member States, limits the Monitoring Framework.


Data is now much more accessible via the website. New indicators include a Circular Materials Use Rate and use of Waste Per Capita, representing an improvement over using waste indicators linked to GDP. The export of waste is now monitored, as are circular competitiveness and green innovation.


New indicators are welcome, for example a consumption footprint, a material footprint for manufacturing, and one on packaging waste. The inclusion of transport in the footprint of production activities is also positive.

3.   Critique


Consultation in designing the new Monitoring Framework was not sufficient and did not make best use of the existing active networks — notably the European Commission’s partnership platform with the EESC — the European Circular Economy Stakeholder Platform (1). This network of networks and knowledge sharing platform, is designed to feed into the implementation of the Circular Economy — its highly active Coordination Group of stakeholders was not consulted.


Consultations should be facilitated by a fund to support stakeholders to fully engage in the process, and to ensure high quality submissions.


The EESC itself, as a consultative body to the EU institutions and with its strong track record in Circular Economy (CE) and internal expertise, was not consulted. It is regrettable that the EESC had to request to draft an opinion on this matter.


The importance of eco-design in driving systemic change and achieving a Circular Economy is well documented and reflected in the most current Circular Economy Action Plan and Eco Design legislation. Monitoring of design is insufficient. As an example, the issuing of Cradle to Cradle Certified® could be monitored as a non-profit audited certification.


The CE is not just about material flows, but rather the complex relationships between raw materials, production and consumption, and the people involved in those processes, plus the societal behaviours and practices associated with working and living in the economy. This social aspect is not sufficiently monitored. Social indicators could include access and affordability, human development, ethical and fair trade, health and safety, consumer behaviour.


In a Circular Economy there is no waste, but rather by-products which have a use and can be transformed or repurposed. New terminology is needed to move beyond classifying everything as waste, and to help identify and monitor these by-products as secondary raw materials.

4.   Recommendations


Monitoring circular business models (such as reuse, repair, refurbishment, platforms for sharing, second hand selling premises and platforms) and measuring the size of their market share, would be useful indicators.


The life expectancy of products should be included to assist in eliminating planned obsolescence and drive circular design.


Data on SMEs minimising waste in their business models is already available, and should be used as an indicator (2).


A headline indicator of waste going to landfill and incineration should be included to monitor remaining non circular practices. Measured specific waste streams should extend to all sectors, including construction, textiles, electronics etc., and not just measure recycling rates in these sectors.


Monitoring other types of waste originating from the linear economy such as pollutants in soil, air and water, including microplastics, should be included. Food production monitoring should also be included where data is available.


Fossil fuel subsidies should be monitored as a public funding measure that is used to support non circular energy production.


Transparency along the supply chain is required and is useful in a Circular Economy (CE). Materials passports could be monitored to assist in this and, in the future, Digital Product Passports can offer even more comprehensive data. This will assist in validating claims of circularity.


There is a welcome headline figure for employment in the CE, but it is a matter of urgency to monitor the figures with a breakdown that will help understanding. This includes a breakdown according to gender, age, salary etc. It is also important to monitor labour accidents per sector.


An indicator on skills (human capital component) is required to identify gaps, inform training and education programs and ensure capacity within the market (3).


The website associated with the Monitoring Framework is useful, has improved and should be maintained. A new website, hosted by the Commission using Eurostat data, mapping out the goals and targets and indicating how close to achieving them we are, would be very useful in order to stimulate action and drive for achieving such targets.


The Circular Economy is a practical way of generating prosperity and wealth, in the context of a well-being economy. This further supports the move away from the narrow focus of GDP. Monitoring should be linked to SDGs and complement the positions taken by EESC on ‘Beyond GDP’ (4).

Brussels, 25 October 2023.

The President of the European Economic and Social Committee

Oliver RÖPKE


(2)  Flash Eurobarometer 456: SMEs, resource efficiency and green markets — Data Europa EU.

(3)  EESC Study on Europe's Circular Economy and its Pact for Skills: working together for an inclusive and job-rich transition?

(4)  Opinion of the European Economic and Social Committee on ‘Beyond GDP measures for a successful recovery and a sustainable and resilient EU economy’ (own-initiative opinion) (OJ C 152, 6.4.2022, p. 7), Opinion of the European Economic and Social Committee on ‘The sustainable economy we need’ (own-initiative opinion) (OJ C 106, 31.3.2020, p. 1).


ISSN 1977-091X (electronic edition)