UIPI Views on the Upcoming EU Circular Economy Act

UIPI responds to the EU Electrification Action Plan

In summer 2025, the European Commission launched the call for evidence on a proposed legislative Act on the Circular Economy . Scheduled for adoption in the fourth quarter of 2026, it aims to strengthen the circular economy in the internal market.

UIPI welcomes the upcoming Circular Economy Act and highlights the need to make circularity affordable and practical for Europe’s property owners. 

In its reply, UIPI supports the circular transition of the built environment, but warns that new obligations must not increase housing and renovation costs or create overlapping rules, highlighting several priorities: 

  • Preservation first: The most circular and cost-efficient approach is to preserve and adapt existing buildings rather than demolish and rebuild. 
  • Fix VAT barriers: Reused construction products should not face double VAT; neutral VAT treatment is essential to make circular materials competitive. 
  • Avoid binding quotas: Recycled-content quotas risk adding complexity and costs; circularity should be market-driven, supported by incentives and green procurement. 
  • Fair cost allocation: Environmental and waste costs must be assigned to those placing products on the market, not transferred to property owners or tenants. 
  • Proportionate compliance: New End-of-Waste and audit requirements must remain risk-based and affordable for small owners and SMEs. 

UIPI calls for a balanced Circular Economy Act that promotes sustainability without undermining affordability, thus ensuring that Europe’s property owners can remain key allies in the transition to a more circular built environment. 

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