The Digital Health in a Circular Economy consortium (DICE Grant agreement ID: 101060184 & DOI 10.3030/101060184) welcomes the opportunity to provide input to the public consultation on the future Circular Economy Act (CE Act) and wants to highlight four points that support the circular transitioning of healthcare.
Broadening the CE Act Beyond Recycling: Embedding a Hierarchy of Circular Strategies
The Clean Industrial Deal recognizes that products must stay in circulation for as long as possible but its proposed measures place most emphasis on recycling. To achieve its objectives, the CE Act should extend its scope to other circular strategies. Hoveling et al. (2024a) mapped best circular practices and identified gaps for medical devices. Additionally, Hoveling et al (2024b) demonstrated that the waste hierarchy (in the Waste Framework Directive) may not yield the maximal environmental impact reduction and that a holistic revision of different strategies must be considered while delivering economic value (Rønn et al., 2023).
Guidance on circular priorities must be informed by life cycle assessments to target the most impactful areas. Without this, the CE Act risks locking in end-of-pipe solutions instead of improving upstream efficiency. Using an evidence-based approach would help the EU strengthen harmonisation and set a global benchmark for comprehensive circularity policy.
Harmonised Terminology
The CE Act should establish clear and harmonised terms & definitions to ensure consistent use. DiCE highlighted the value and need of a unified glossary to be able to communicate along the value chain. Hoveling et al (2024a) revealed that key actors were unclear of how circularity applies to them, and which strategies may be used. Therefore, DiCE’s consolidated Terms & Definitions can serve as the basis and be adopted by the CE Act for promoting a common understanding among value chain actors and regulatory bodies, reduce fragmentation, and support coherent application of the legislation.
Expanding CE Metrics Beyond Circular Material Use Rate (CMUR)
Relying only on the CMUR is too narrow to capture the full circularity. While useful, CMUR misses aspects like product design, repairability, durability, recyclability at end-of-life. To ensure comprehensive monitoring, the Act should add indicators such as recycled content, recyclability metrics (e.g. recycling rates, Jager et al., 2024) and repairability index, among others. This broader framework would track progress across product lifecycles more effectively, helping policymakers to target interventions where it matters and positioning the EU as a global leader in circularity monitoring.
Advancing Circularity and Social Sustainability through Awareness and Cooperation
The CE Act should focus on awareness-raising and fostering collaboration among actors and change agents as these are key enablers of circularity and social sustainability. Engaging all stakeholders including the public can boost medical device collection rates and speed up acceptance and adoption of circular practices2. Engagement can lower the (perceived) health & safety risks when circularising medical devices, and support social benefits such as skills development and the creation of new jobs, particularly within Europe (Valdivia et al., 2025).
Finally, citizen engagement is an essential component to enable closed loops. Integration of behavioural science through e.g. co-creation and motivational strategies is critical (Vermeylen et al. (2024)) to ensure that products designed for closed-loop systems are returned and can be recirculated.
