AUTHOR: Antoine Oger

Building on IEEP’s proposal for an EU resources law, this brief recommends that the Circular Economy Act include a binding, time-bound target for absolute reduction of the EU material footprint, complemented by sectoral milestones, monitoring through existing Eurostat material flow accounts, and measures to address the EU’s externalised environmental impacts.

The European Union consumes natural resources well above the world average and at a rate roughly twice the level considered globally sustainable. In 2024, the EU’s material footprint stood at 13.7 tons of raw material consumption (RMC) per capita, equivalent to around 6.2 billion tons of total resources extracted worldwide to satisfy EU consumption and investment. This level of resource use is a key driver of the triple planetary crisis — climate change, biodiversity loss and pollution — both within the EU and, disproportionately, in the countries that supply its raw materials.

The forthcoming EU Circular Economy Act (CEA), expected to be proposed in the second half of 2026, is the most significant opportunity this decade to anchor an absolute reduction target for the EU’s material footprint in binding legislation. While the Act is currently framed primarily around a circular material use rate target (doubling from around 12% to 24% by 2030) and the development of a single market for secondary raw materials, this brief argues that circularity targets alone are insufficient. Without a parallel target to reduce overall material consumption, gains in circularity risk being outpaced by growth in absolute material throughput.

To ensure the Circular Economy Act delivers a coherent and effective response to the EU’s resource use challenge, we recommend that the legislative proposal include the following elements:

1. A binding material footprint reduction target. Set an absolute, time-bound target to reduce the EU’s material footprint (RMC) — for example, a defined percentage reduction per capita by 2040, with an indicative trajectory toward the sustainable consumption levels identified by the IRP — building on the ambition already articulated in the 8th Environment Action Programme.
2. Retain and strengthen the circular material use rate target. The 24% by 2030 circularity target should be maintained and treated as one of several complementary indicators, not a substitute for an absolute consumption target.
3. Use existing monitoring infrastructure. Base monitoring on Eurostat’s established material flow accounts, avoiding the need for new data infrastructure and enabling immediate tracking of progress.
4. Sectoral milestones for the largest footprint contributors. Given that non-metallic minerals (construction) and biomass together account for around three quarters of the EU’s footprint, set sector-specific demand-reduction milestones for the built environment, mobility and food systems.
5. Address externalised impacts. Incorporate measures — e.g. on secondary material exports, third-country partnerships and supply chain due diligence — recognising the EU’s responsibility for the environmental and social impacts of its material footprint beyond its borders.
6. Coherence with adjacent legislation. Ensure explicit alignment between the CE Acts material footprint provisions and the ESPR, the Critical Raw Materials Act, the EU Climate Law and other relevant legislations, so that dematerialisation and decarbonisation objectives reinforce one another rather than operating in silos.
7. Review and ratchet mechanism. Following the model of the EU Climate Law, include a periodic review mechanism allowing targets and measures to be strengthened in light of progress, new evidence, and updated assessments.