The BDE views the Federal Cabinet's consideration of the Circular Economy Action Programme as an important step towards implementing the National Circular Economy Strategy (NKWS). However, it is now crucial that concrete legislative measures emerge from the programme to boost the circular economy in practice, enable investments, and create reliable markets for recycled raw materials.
Dr Andreas Bruckschen, Chief Executive of the BDE, highlights that companies in the private waste management, water, and circular economy sectors rely on reliable markets for recycled raw materials. Only through faster permits, practical standards, and public procurement that actively demands recycled raw materials can investments in sorting, processing, and digitalisation be stimulated.
The BDE Federal Association of the German Waste Management, Water and Circular Economy sector welcomes the recognition of the circular economy as an integral part of resource security and industrial value creation, but sees the need for concrete legal regulations.
The action programme contains important starting points: the planned implementation platform, investment and innovation promotion, digitalisation, measures for raw material supply through a circular economy, the further development of circular economy law, the use of recyclates in plastics, and the round table on reducing the risk of fire from lithium batteries. The crucial step now is to swiftly translate these points into practicable legal regulations.
Criticism of public procurement
The BDE is particularly critical of the current regulations on public procurement. The association sees this as a missed opportunity to better leverage the potential of public procurement for the National Circular Economy Strategy. Although companies with majority state ownership are to report on the use of circular products and recycled raw materials in the future, there is a lack of steering effect to create a genuine market. The BDE is therefore calling for public procurement to be mandatorily geared towards strengthening the circular economy.
The necessity of specific legislation
The BDE already highlighted in the summer of 2025, through a legal opinion, that greater consideration of recycled raw materials in public procurement is legally permissible. However, this requires transparent, product-specific, and proportionate requirements. The association sees the action programme as a starting point for a further debate on the National Circular Economy Strategy and calls on the federal government to swiftly develop concrete legislative measures.
Source: BDE Federal Association of the German Waste Management, Water and Recycling Industry
