In summer 2025, the European Commission launched the call for evidence on a proposed legislative Act on the Circular Economy (deadline 6 November 2025). 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.
UIPI highlights that the most circular and cost-efficient approach is to preserve and adapt existing buildings rather than demolish and rebuild. Regarding materials, UIPI reminds construction products should not face double VAT as neutral VAT treatment is essential to make circular materials competitive, and also warns that tecycled-content quotas risk adding complexity and costs; circularity should be market-driven, supported by incentives and green procurement.
UIPI also points out that environmental and waste costs must be assigned to those placing products on the market, not transferred to property owners or tenants and that the 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.
