Promoting the circular economy is crucial for the German economy, offering ecological and economic benefits while addressing regulatory challenges.

Shaping fair competition by developing efficient and easy-to-implement requirements alongside businesses.

The European Packaging Regulation aims to harmonise requirements and ensure uniform implementation across Europe. National differences, particularly regarding the level of ambition in implementation, should be minimised or reduced to the bare minimum in existing cases. In further implementation, producer responsibility and registration obligations – if necessary at all – should be carried out once and universally across Europe. Labelling requirements and rules on packaging design should also apply uniformly across Europe. Many companies in the recycling industry support a standardised recycling label and requirements for the use of recycled materials (minimal-content). To ease the burden on small quantities, de minimis thresholds should be introduced.

Surveys by the German Chamber of Commerce and Industry (IHK) reveal that access to raw materials is not always assured. Consequently, the European Commission's adoption of a law for critical raw materials ("Critical Raw Materials Act") is fundamentally the right approach to improve the security of raw material supplies. From the perspective of the business community, a unified European strategy on raw materials is advisable to safeguard corporate raw material supplies.

The Chambers of Industry and Commerce emphasise that increased governmental monitoring of raw materials is only effective if it does not lead to additional bureaucratic burdens for companies. Businesses are concerned about potential bureaucracy, particularly the obligation to report to public authorities regarding raw materials. 

Strengthening efforts to access domestic resources benefits environmental and climate protection. Collaborative initiatives between politics and industry are necessary for promoting domestic raw material extraction.

To further advance the circular economy, a reform of waste legislation is necessary, particularly regulations regarding the end-of-waste status. However, the end-of-waste status is hindered by increasingly strict material law thresholds, requiring urgent simplification. Nationwide and Europe-wide uniform guidelines for the use of, for example, recycled building materials, are essential.

The development of European lead markets for secondary raw materials and sustainable products can provide a basis for the uptake of sustainable products. Currently, the market suffers due to recycled materials not being available in the required quantity and quality. In any case, it must be ensured that the quality standards of recycled materials match those of primary raw materials. Standardisation and norm-setting should guarantee this.