Does the National Circular Economy Programme now want to use more raw materials?

There are many good things in the recently published National Circular Economy Programme (NPCE). For example, the advisory routes for priority product groups provide valuable starting points (Ch. 3), supporting measures for these and other product groups are essential (Ch. 4), and good governance for circular economy policy is a priority (Ch. 5). Pricing environmental damage caused by products, and repairability and design requirements are also excellent measures. Perhaps we should go into more detail on all the good things in the NPCE. However, we would like to draw attention here to why this new circular policy plan still causes concern for Recycling Netwerk Benelux (RNB). Compared to the earlier government-wide policy programme "A Circular Economy in the Netherlands by 2050" from 2016, the ambition of the NPCE for circular economy policy has changed. De facto, the new ambition is a (significant) step backwards. This naturally requires introduction and explanation. NPCE wants to reduce waste and environmental pressure through resource use In the foreword by State Secretary Vivianne Heijnen, there is a telling sentence, namely "The Netherlands wants to be fully circular by 2050, with as little waste as possible and without needless waste of resources". Why "without needless waste of resources"? In "A Circular Economy in the Netherlands by 2050", it was still about substantially less use of primary metals, minerals and fossil resources, namely halving it before 2030 and full circularity before 2050. The State Secretary mentions waste before resources. This of course does not have to mean anything, but it gives the impression that less waste is more important than fewer resources. Moreover, there is no explanation of what is meant by "without needless waste of resources". If you take it literally, it is actually also about waste. After all, waste is about extracted but no (longer) used resources. Waste that must therefore be prevented. It has little to do with reducing the use of resources as such. The State Secretary's ambiguous language here at least raises questions about what exactly she is referring to. The summary of the NPCE then reports that the transition to the circular economy is about "... contributing to the climate challenge, the biodiversity challenge, the creation of a clean environment and a safe and clean living environment, and contributing to the security of supply of resources through resource use. In a circular economy, almost only reusable primary, secondary and sustainable bio-based resources are in circulation. Products are produced, distributed and consumed within closed loops. In this way, the value of resources, materials and products is preserved for as long as possible, meaning there is almost no waste left.". This quote states that tweaking our resource use is important to reduce its environmental pressure, and to safeguard the security of supply of resources. It also communicates that closing product loops is an effective way of doing this, also to prevent waste. As if the infinite circulation of (an unlimited amount of) secondary materials is what the circular economy is really about. As a result, it once again completely ignores the need to drastically reduce the use of resources. Fewer resources no longer a goal, but more resources the starting point in NPCE Page 18 in the NPCE explains why the previous reduction targets for Dutch resource use have been abandoned. It boils down to the fact that "Ultimately, [the goal is] to contribute to the climate challenge, the biodiversity challenge, the creation of a clean environment and a safe and clean living environment, and to contribute to the security of supply of resources through resource use." To be absolutely clear: RNB has been working for years to do something about the growing list of urgent environmental problems (partly) through our resource use. That is not only about climate and biodiversity, and indeed waste, but also, among other things, about nitrogen, litter, and the plastic soup. That is why RNB is heavily committed to, for example, less unnecessary packaging (such as for fruit & vegetables), stimulating reusable packaging (such as in the e-commerce sector; through the Mission Reuse alliance), and the broad introduction of deposit-return systems as a prerequisite to get recycling, but ultimately reuse, off the ground. RNB therefore fully supports the NPCE's ambition to tackle environmental problems through resource use. That security of supply also plays a role is logical. What worries RNB, however, is that reducing resource use as such is no longer a goal in the NPCE, nor is it part of the problem analysis. This was still the case in "A Circular Economy in the Netherlands by 2050". Increasing resource use is still a "[Furthermore, this] development [... which can ...] lead

There are many good things in the recently published National Circular Economy Programme (NPCE). For example, the advisory routes for priority product groups provide valuable starting points (Ch. 3), supporting measures for these and other product groups are essential (Ch. 4), and good governance for circular economy policy is a priority (Ch. 5). Pricing environmental damage caused by products, and repairability and design requirements are also excellent measures.

Perhaps we should go into more detail on all the good things in the NPCE. However, we would like to draw attention here to why this new circular policy plan still causes concern for Recycling Netwerk Benelux (RNB). Compared to the earlier government-wide policy programme A Circular Economy in the Netherlands by 2050 from 2016, the ambition of the NPCE for circular economy policy has changed. De facto, the new ambition is a (significant) step backwards. This naturally requires introduction and explanation.

NPCE wants to reduce waste and environmental pressure through resource use

In the foreword by State Secretary Vivianne Heijnen, there is a telling sentence, namely "The Netherlands wants to be fully circular by 2050, with as little waste as possible and without needless waste of resources". Why "without needless waste of resources"? In A Circular Economy in the Netherlands by 2050, it was still about substantially less use of primary metals, minerals and fossil resources, namely halving it before 2030 and full circularity before 2050.

The State Secretary mentions waste before resources. This of course does not have to mean anything, but it gives the impression that less waste is more important than fewer resources. Moreover, there is no explanation of what is meant by "without needless waste of resources". If you take it literally, it is actually also about waste. After all, waste is about extracted but no (longer) used resources. Waste that must therefore be prevented. It has little to do with reducing the use of resources as such. The State Secretary's ambiguous language here at least raises questions about what exactly she is referring to.

The summary of the NPCE then reports that the transition to the circular economy is about "... contributing to the climate challenge, the biodiversity challenge, the creation of a clean environment and a safe and clean living environment, and contributing to the security of supply of resources through resource use. In a circular economy, almost only reusable primary, secondary and sustainable bio-based resources are in circulation. Products are produced, distributed and consumed within closed loops. In this way, the value of resources, materials and products is preserved for as long as possible, meaning there is almost no waste left.".

This quote states that tweaking our resource use is important to reduce its environmental pressure, and to safeguard the security of supply of resources. It also communicates that closing product loops is an effective way of doing this, also to prevent waste. As if the infinite circulation of (an unlimited amount of) secondary materials is what the circular economy is really about. As a result, it once again completely ignores the need to drastically reduce the use of resources.

Fewer resources no longer a goal, but more resources the starting point in NPCE

Page 18 in the NPCE explains why the previous reduction targets for Dutch resource use have been abandoned. It boils down to the fact that "Ultimately, [it is about] contributing to the climate challenge, the biodiversity challenge, the creation of a clean environment and a safe and clean living environment, and contributing to the security of supply of resources through resource use."

To be absolutely clear: RNB has been working for years to do something about the growing list of urgent environmental problems (partly) through our resource use. That is not only about climate and biodiversity, and indeed waste, but also, among other things, about nitrogen, litter, and the plastic soup. That is why RNB is heavily committed to, for example, less unnecessary packaging (such as for fruit & vegetables), stimulating reusable packaging (such as in the e-commerce sector; through the Mission Reuse alliance), and the broad introduction of deposit-return systems as a prerequisite to get recycling, but ultimately reuse, off the ground.

RNB therefore fully supports the ambition of the NPCE to tackle environmental problems through resource use. That security of supply also plays a role is logical.

What worries RNB, however, is that reducing resource use as such is no longer a goal in the NPCE, nor is it part of the problem analysis. This was still the case in A Circular Economy in the Netherlands by 2050. Increasing resource use is still a "[Furthermore, this] development [... which can ...] lead to increasing inequality in access to resources, from which the poorest populations suffer the most. This affects the (non-)achievement of the Sustainable Development Goals (SDGs).".

The NPCE specifically says that "[In short,] our economy of the future requires more and different resources than our economy has so far. For certain resources, including critical resources, circular strategies cannot keep up with the increasing demand in the short term and more will have to enter circulation.".

A Circular Economy in the Netherlands by 2050 wants to halve our use of primary metals, minerals and fossil resources before 2030 and be fully circular before 2050. The NPCE assumes an increase in our future resource use. The summary of the NPCE explains "fully circular" in 2050 as "The environmental impacts of resource use in a circular economy, and therefore of all Dutch production and consumption, will then fall within 'planetary boundaries'.". A circular economy with more resources, but within planetary boundaries, does not seem compatible to us.

Just last month, in a discussion with the left-wing and coalition parties in the House of Representatives, Professor Jason Hickel of the Degrowth movement criticized the realism of growing production within planetary boundaries. That was after the release of the NPCE. The older recommendations of the United Nations International Resource Panel point in the same direction.

More resource use conflicts with fair wealth distribution

In its Global Resources Outlook 2019, the United Nations International Resource Panel addresses the development of global resource use. It shows that global resource extraction has more than tripled since 1970, and that high-income countries in particular are reaping the benefits of this at the expense of low-income countries. According to the panel, resource use in high-income countries must and can be reduced to such an extent that low-income countries can share proportionally in a still-growing prosperity, but within planetary boundaries.

Unlike the NPCE, but in line with A Circular Economy in the Netherlands by 2050, the International Resource Panel therefore advocates for less resource use in rich countries like the Netherlands. The PBL also talks in its Dutch Integral Circular Economy Report 2023 (ICER-2023) about "radically reducing and using resources more efficiently". The Social and Economic Council (SER) also speaks in its recent advisory report about reducing resource use. RNB therefore does not understand why the NPCE now assumes that growth in Dutch resource use is necessary and desirable. RNB also does not understand why the NPCE, despite more resource use, believes it can still get within planetary boundaries.

Bio-based resources are also not available in unlimited quantities

The reduction targets for 2030 and 2050 in A Circular Economy in the Netherlands by 2050 concern less primary use of metals, minerals and fossil resources, in short referred to as abiotic resources. This concerns both the resources themselves and new (primary) materials manufactured from them.

A Circular Economy in the Netherlands by 2050 wants to achieve less abiotic resource use through three strategic goals. Two of these concern using resources more efficiently in existing (1st goal) and new (3rd goal) product chains. The other (2nd) goal wants to replace fossil, critical and non-sustainably produced resources with sustainably produced, renewable and widely available resources.

In that 2nd strategic goal, the substitution goal, replacement by resources of biological origin (ergo, biotic resources, bio-based resources or biomass) is often referred to as a implementation. However, the Biomass and Food transition agenda from 2018 points out that biomass is also not available in unlimited quantities (certainly not in the way it is currently produced). Due to the growing world population and rising levels of prosperity, the demand for food is increasing, and a significant demand is already being made on biomass from the energy transition. The availability of land for food and biomass production is also limited, as space is also needed for recreation and biodiversity conservation & restoration. The ecological carrying capacity of the Earth is already being exceeded by the nature and scale of current agriculture. The Biomass and Food transition agenda is clear about this.

In short, there is still some debate about the starting point of more resource use, and the ambition to stay within planetary boundaries with it. The NPCE seems to be engaging in wishful thinking.

"More resources" does not rhyme with a smaller resource footprint

A Circular Economy in the Netherlands by 2050 still has resource reduction as its main objective. The NPCE replaces this with a framework for four new main objectives yet to be worked out in detail. These four main objectives, referred to as effect goals, concern 1) Combating climate change, 2) Restoring biodiversity, 3) Cleaner environment and cleaner living environment, and 4) Greater security of supply of resources.

For 2050, the NPCE wants "in any case, resource use for Dutch production and consumption to be reduced to such an extent that it falls within the planetary boundaries and the resulting 'safe operating space' for the Netherlands (...).". This seems in line with what the International Resource Panel says about this in its Global Resources Outlook 2019 (see above). That safe operating space for the Netherlands must then allow for an equal, global distribution of wealth. The NPCE says nothing further about this.

The NPCE wants to investigate how resource use and its environmental impact are related. This should provide insight into the link between the effect goals and the safe operating space. Based on this, the NPCE still wants to set a new ambitious goal for reducing our resource use for 2030, with a view to 2050. The NPCE does not address how that ambitious reduction goal relates to the starting point in the NPCE, already cited above, of more and different resources in our economy of the future. It therefore remains unclear to what extent the proposed ambitious resource reduction goal is at loggerheads with this.

That proposed ambitious reduction goal will apply to the total Dutch resource use in the entire international chain. This so-called resource footprint represents the total use of primary resources in the Netherlands and elsewhere for the Dutch economy.

The NPCE wants to have the research for the concrete implementation of the four effect goals carried out in 2023 with the aim of being able to take a decision on this in 2024. "Until that moment, the guiding halving target of primary abiotic resources in 2030 remains in force.", according to the NPCE.

A bit further on in the NPCE, regarding those reduction targets to be set, there is the somewhat unclear phrase that "We are looking at the extent to which we can align with the proposed reduction percentages for the resource footprint within the EU taxonomy of 50 per cent in 2030 and 75 per cent in 2050.". This non-binding formulation suggests, but does not yet reaffirm, a maintenance of the halving target for 2030 and concretisation of the completely circular in 2050 target in A Circular Economy in the Netherlands by 2050. In addition, it remains unclear how this rhymes with the starting point in the NPCE of more and different resources in our economy of the future.

Less resource use and four buttons to turn

Less resource use is one of the four buttons to turn in the NPCE to achieve the four effect goals of the NPCE. According to the NPCE, which bases this on a PBL policy brief from 2021, the four buttons represent a "simplification" of the R-ladder:

Reduction of resource use: using fewer (primary) resources by doing without products, sharing them or making them more efficient (narrow the loop);

Substitution of resources: replacing primary resources with secondary resources or sustainable bio-based resources that are applied as high-quality as possible, or with other more widely available resources with less environmental pressure;

Life extension: using products and parts longer and more intensively through reuse and repair. This slows down the demand for new resources (slow the loop);

High-quality processing: closing the loop by recycling materials and resources, so that less waste is incinerated or landfilled and there is a more high-quality supply of secondary resources (close the loop).

Substitution of resources, which corresponds to the 2nd strategic goal in A Circular Economy in the Netherlands by 2050, is however not part of the circularity ladder. The circularity ladder wants to reduce resource use in existing and new product chains.

As an elaboration of the 1st and 3rd strategic goals in A Circular Economy in the Netherlands by 2050, the draft system for monitoring progress towards the circular economy has assigned an important role to the circularity ladder. In doing so, the warning of the Biomass and Food transition agenda was taken to heart. The draft monitoring system, the basis for the ICERs of 2021 and 2023, assumes that the use of all resources must go down, including biomass (or primary biotic resources).

This means that substitution is still a circularity strategy, but one for other and not for less resource use. The substitution goal is therefore not of a lesser but of a different order than the goal of the circularity ladder to use fewer resources. In fact, the NPCE says so itself in a footnote to figure 4 ("Replacement is not part of the R-ladder").

A recent study by Potting et al. (2022) shows that "slowing & closing the loop" can also yield significant reductions in resource use. These third and fourth buttons in the NPCE aim for that just as much as the first button of "narrowing the loop". This makes the description of the first button "clunky". It would be better to describe "narrow the loop" as simply "using fewer products by doing without them, sharing them or making them more efficient" (then the first part "Reduction of resource use: using fewer (primary) resources" is omitted).