EPEA GmbH — Part of Drees & Sommer, a pioneer of the circular economy for decades, welcomes the draft National Circular Economy Strategy (NKWS). The guidelines, approaches and concrete measures described therein, when implemented consistently and quickly, provide the basis for a circular economy made in Germany. In addition to the associated security and sovereignty of raw materials supply, it offers companies the opportunity to take on a global pioneering role with circular key technologies and to become significant supporters in climate and resource protection. In doing so, the NKWS makes it clear what decisive role the public sector plays as legislator and turnmaker and at the same time as an exemplary consumer. Public sector as a role model

• Digitalization, public procurement law and the funding landscape are tackled as the first and most important fields of action. Current activities such as the development of a digital product passport (4.2), ideally compatible, for example, with the planned building resource pass, or current obstacles that the procurement transformation package is intended to remove, are prioritized.
• However, preferential procurement of used and remanufactured products should represent a short-term, rather bridging measure (4.11.4). Instead, with the volumes available to it, the public sector can focus on the procurement of innovative circular products in order to offer manufacturers the necessary incentives to gear their products to a circular economy and offer new business models such as product as a service. This focus would therefore also promote the development of market-leading technologies for climate protection and resource conservation.
• From the point of view of EPEA GmbH — Part of Drees & Sommer, the introduction of a CO2 shadow price as a sustainability criterion would be more effective than life cycle costs, which only reflect economic efficiency according to current criteria, but not overall societal climate change costs and future risks (4.11.4). This requires a realistic price, as set by the Federal Environment Agency at > 800 €/to CO2_e, in order to bring about the transformation as a tangible financial lever. Since 2023, Baden-Württemberg has introduced a CO2 shadow price of currently around 237 €/to CO2_e.

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Product design is crucial for a functioning and genuine circular economy based on the Cradle to Cradle Principle

As part of the development of the Ecodesign Regulation and in particular the revision of the EU Construction Products Regulation, we welcome the will to diligently and the high quality standards of input materials; this essentially ensures a high secondary raw material quality in the future (4.3.3). We are convinced that, in connection with an adjustment of product and manufacturer responsibility, this will have a positive effect on German companies and their innovative potential.

In this context, a further significant step towards the circular economy is the promotion of take-back systems and recycling technologies in conjunction with the use of secondary raw materials obtained in the company's own products (4.3.4) .Since the built environment, as an anthropogenic raw material depot, has a special position in a future circular economy, we would like to address a few points in more detail in the construction and building sector (4.8).

The built environment as a future raw material depot

• The NKWS has identified a number of measures to close the material cycles of mineral building materials as completely and promptly as possible. Practice has already shown that large portions of non-polluted mineral construction waste are recycled at least once (4.8.3, 4.8.4). If new buildings, i.e. new structures, are avoided in the future or if mineral building materials are replaced by renewable raw materials, the demand and availability of mineral recyclates will be significantly reduced. It is already the declared goal of builders today to develop buildings with a high degree of flexibility of use for maximum durability.
• On the other hand, there are short-term changes in user and use, which usually entail modifications and thus expansion waste. This is usually more complex mixed construction waste, which is currently being recycled to a large extent. The absence of harmful substances, the ability to separate and dismantle construction products can help provide companies with high-quality secondary raw materials in the future. This and the provision of knowledge about the raw materials that have already been bound in the building sector are essential for efficient material flow management. We therefore support the Federal Government's plans presented under 4.8.2 to develop a holistic and future-oriented urban mining strategy with the German Resource Efficiency Program.
• The rapid introduction of a component inspection requirement with inventory of reusable/recyclable building materials and components will already make a valuable contribution to “saving” resources (4.8.4). In this context, we explicitly welcome the reevaluation of waste wood for high-quality reuse/recycling along a long-term cascade of use.
• On the other hand, we do not consider the preparation of dismantling concepts for new buildings and modernizations to be effective (4.8.4). The need for digital documentation of material quality and recyclability (separability/dismantlement) in building resource passes is undisputed. However, dismantling concepts developed today rely on state-of-the-art dismantling technologies - for dismantling as distant as possible in the future. This generates documents that do not represent any added value in terms of content for future participants in construction.
• At this point, we would like to draw attention to the crucial role of digitizing material identities, over their entire life cycle in buildings and beyond. Without this, resource security and sovereignty in Germany and the EU is inconceivable in the future.

As part of the planned platform for circular economy, we will actively support the introduction of a true circular economy in Germany with our many years of expertise in the cradle to cradle design principle.