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Circular Economy Action Plan: EU experience in promoting sustainable management of Municipal Solid Waste
REEI 2022/02/17

The EU Circular Economy Action Plan (here-in-after referred to as Action Plan) is one of the key measures to implement their Green New Deal [1]. This action plan would have a fundamental impact on the EU's economic growth and the way resources are used. According to the policies and directives issued by the EU under the Action Plan in recent years, the Action Plan focuses on several major areas such as product design, sustainable consumption and municipal solid waste management (here-in-after referred to as solid waste management). This article focuses on the future potential impact of specific policies and directives that were gradually implemented under the Action Plan on solid waste management in the EU.

Proposals adopted by the European Commission varies, including regulations, directives, communication, etc.; the timeline for proposal implementation also  varies, while the discussion is based on an overview of EU's existing and future proposals on solid waste management with the implementation of the Action Plan in 2021-2022, the impact of the new policy on cross-border transport of waste in the EU and the sustainable development of solid waste management is discussed in detail. While China's municipal solid waste production is still growing rapidly, the understanding of EU's regulatory experience will help promote the low-carbon development of solid waste management in China.

From waste management hierarchy to waste management strategy under the Action Plan

The EU issued its "European Waste Framework Directive" (75/442/CEE) as early as 1975, , which has been revised several times since then. In the 2008 version, the far-reaching inverted pyramid structure of waste management was proposed, that is, the priority order from high to low is source reduction → reuse → recycling → other treatment → terminal disposal. This hierarchy has become the basic principle guiding sustainable waste management in the EU. 


Both the waste management hierarchy and the circular economy take into account the whole life cycle of a product, including the manufacturing, use and disposal. They also share a common philosophy that aims to manage waste by re-thinking, re-designing and re-using products to improve resource efficiency and reduce waste generation and its adverse effects.


However, from the perspective of the waste management structure, a part of waste still flows into the last disposal process, mainly including landfilling and incineration (with no energy recovery). The circular economy framework aims to bring circulation and flow of all substances into a closed loop. Through different treatment standards and methods, the "waste" in the previous link may be the "resource" available in the next link. Therefore, EU's waste management goal in the face of its carbon neutrality goal of 2050 is no longer to minimize the amount of terminal treatment, but to propose the recycling of raw materials and substances when economic development model changes fundamentally, which means that the waste in the traditional sense of terminal disposal no longer exists.


In March 2020, the EU released a new version of the EU Circular Economy Action Plan, which set the goal of achieving a significant total waste reduction and halving municipal non-recyclable waste by 2030. Specifically, "Waste and Recycling" is included in the action plan. [2] The EU's latest plan aims to apply circular economy concepts throughout the whole life cycle of product design, production, consumption, maintenance, recycling and reuse. The new action plan has provided an important policy tool for solid waste management and identified specific action plans for the next year or two in waste management.


Steady Action Plan advancement to cover more economic activities

After publishing a new version of the Action Plan in 2020, the European Commission has already started to push through specific policies. Although the COVID-19 pandemic has disrupted the implementation of specific policies in the EU Action Plan to some extent, the new policies planned for 2021-2022 are still largely within the timetable. [3]


The adoption of a new directive on industrial emissions, originally scheduled for the fourth quarter of 2021, has been delayed. This directive aims to promote cleaner production for businesses, supporting zero pollution targets and better use of recycled materials and resources, which is consistent with the principle of avoiding source waste in solid waste management.


In October 2021, the European Commission adopted a policy proposal to update the rules on sustainable organic pollutants in waste, bringing regulations for chemicals with serious public health implications to a new level.

In November 2021, the European Commission adopted a policy proposal on new rules for the cross-border transport of waste, which had huge implications for waste management in the EU and will be discussed briefly below.


In the first quarter of 2022, the European Commission will issue a proposal for a new packaging waste management directive, which aims to modify the design of packaging to improve recycling and reuse, increase the proportion of recyclable ingredients in packaging material, reduce the generation of packaging waste, and solve the problem of excessive packaging.


In the first quarter of 2022, the European commission also plans to adopt a sustainable product directive proposal that is designed to modify the ecological design directives of the EU, make our products more durable, and greatly improve features such as reuse, repair, recycling and energy efficiency. These product categories include not only the electronic and communication products, textiles, furniture and other consumer products, but also bulk industrial products such as steel, cement and chemicals. This directive proposal will help the EU to implement the principle of waste reduction at the front-end of solid waste management.


The EU's initiatives to implement the Action Plan are moving its solid waste management in a more environmentally, socially and climate-friendly direction.

The cross-border transport of solid waste proposal will enhance the EU's capacity for sustainable solid waste management

The transport of large quantities of solid waste (commonly known as waste export) has always been a headache for waste management in the EU. Exporting waste to low-income countries will not help the EU achieve its policy goal of sustainable waste management. Both legal and illegal exports of waste often cause serious environmental pollution for importing countries, a classic cross-border environmental justice challenge.


In December 2020, the EU announced that it would ban the export of unsorted plastic waste to non-OECD countries starting in 2021. But before that, much of the EU's plastic waste had gone to China, which in turn made its way to other Asian countries after China banned imports in 2018. According to statistics, the EU exported 1.5 million tons of plastic waste to Turkey, Malaysia, Indonesia and other countries in 2019. [4]

As part of the EU's "Green New Deal", the EU adopted a policy proposal on banning deforestation and innovating sustainable waste management in November 2021, to implement the EU's climate and biodiversity commitments. At the same time, the EU has updated its regulatory policies on waste transport. In order to curb the export of waste to third parties that do not meet EU environmental standards, the European Commission published a draft amendment to the EU Waste Transport Regulation on 17 November 2021 for consultation. New requirements include restrictions on waste exports to OECD countries and, if necessary, ensuring that the importing country has the capacity to sustainably dispose of the imported waste. In the case of waste exports from the EU to OECD countries, the EU requires that waste be monitored and that exports be suspended in the event of a serious environmental pollution incident in the importing country. Waste exporters in the EU are subject to independent audits to prove that their waste management is environmentally friendly. In addition, the revised regulation will promote the recycling and reuse of waste within the EU and support its transition to a circular economy. [5]


By setting stricter waste export policies, the EU aims to fulfil its long-term strategic ambitions of a circular economy and zero pollution. This will strengthen the EU's monitoring of waste management within its economic zone, reduce cross-border flows of waste, and also increase the EU's capacity for sustainable waste management.

Conclusion: The effectiveness of the Action Plan remains to be seen

Sustainable development of solid waste management must be complemented by systematic policy measures covering industrial production and emissions, product design and packaging, solid waste transport and trade, and consumer responsibility and sustainable investment. Various regulatory measures introduced under the Action Plan have provided an indispensable policy tool for the EU to pursue a zero-pollution society and sustainable management of solid waste. However, it remains unclear how well these policies will be implemented. The experience of the EU's policy implementation is certainly worth studying, especially for policy makers in China, who are still in the phase of extensive solid waste management and facing challenges like climate change, environmental improvement and economic development.


[1] 欧盟的绿色新政旨在推动欧盟经济和社会的可持续发展,彻底扭转目前过度消耗自然资源、破坏生态系统的经济模式,并围绕到“2050年成为全球第一个实现碳中和目标的大陆”落实一系列政策措施。

[1] The Green New Deal aims to promote the sustainable economic and social development of the EU, completely reverse the current economic model of excessive consumption of natural resources and destruction of the ecosystem, and implement a series of policy measures around "the goal of being the first continent to achieve carbon neutrality by 2050".

[2] circular economy action plan, link:

[3] homepage of circular economy action plan,link:'s%20new%20circular%20action,cleaner%20and%20more%20competitive%20Europe.&text=It%20targets%20how%20products%20are,for%20as%20long%20as%20possible.

[4] Plastic waste shipments: new EU rules on importing and exporting plastic waste, European Commission, link:

[5] Questions and Answers on new EU rules on waste shipments, European Commission, link:

Author:Zhao Ang

Translation: Chen Shikai

Proofread: Pan Yiren

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* This is the translation of an article in Chinese. Should there be any inconsistency between Chinese and English version, the Chinese version shall prevail.