The European debate on the circular transition: the joint letter and the white paper

27 May 2026

Circular Economy, Institution, Innovation, Ecosystems

Intesa Sanpaolo, with the involvement and support of the Institutional Affairs Department, together with Intesa Sanpaolo Innovation Center, actively contributed to the drafting of a white paper and to the definition and signing of a joint business letter on the Circular Economy Act (CEA), the legislative proposal through which the European Commission aims to accelerate the transition toward a true European single market for the circular economy (CE).

In doing so, the Group reaffirms its commitment to promoting the circular economy as a strategic driver of industrial competitiveness, resource security, innovation and economic resilience.

The contribution of the business community to the European debate on the future CEA — expected by 2026 and designed to introduce a more harmonised framework supporting circular production and industrial models across the European Union — continues to grow stronger.

Within this context, two key reference documents have emerged: the joint business letter promoted within the ecosystem of the Ellen MacArthur Foundation, a leading international advocate of the systemic transition toward the circular economy, together with the white paper outlining the main strategic levers needed to position the CEA at the core of Europe’s industrial strategy.

Joint letter on the Circular Economy Act: the voice of European business

Addressed to European Commission President Ursula von der Leyen and key European Commissioners, the joint business letter represents a shared position by companies and organisations calling on the European Union to establish a regulatory framework capable of making the circular economy a genuine driver of industrial competitiveness, supply chain resilience and innovation.

The document highlights the need for harmonised rules, coherent economic instruments and market conditions that make it easier and more economically viable to scale circular solutions across all Member States.

As part of this initiative, Intesa Sanpaolo, with the involvement and support of the Institutional Affairs Department and Intesa Sanpaolo Innovation Center, contributed to both the drafting and signing of the joint letter, further strengthening the Group’s positioning in discussions with European institutions, regulators and stakeholders. The document was signed by Jacques Moscianese, Executive Director Institutional Affairs of the Group.

This contribution forms part of a long-term strategy that views the circular economy as a transformative paradigm for the economic and industrial system, capable of directing investment toward the systemic transformation of value chains and business models, while reducing financial risks and generating greater economic, social and environmental value.

This strategic vision is further supported by recent research promoted by Intesa Sanpaolo Innovation Center and Bocconi University, which highlights how circular business models can help reduce corporate financial risk and improve the risk-return profile of investments.

As confirmed by the recent renewal of the partnership between Intesa Sanpaolo and the Ellen MacArthur Foundation, the Group intends to continue supporting the circular transition through the development of dedicated financial instruments and the provision of credit facilities for circular transformation. These initiatives are complemented by advocacy, training and dissemination activities, advisory services, and open innovation programmes based on collaboration among institutions, companies, startups, universities and research centres.

Key points of the joint letter

The group of signatory companies supports the future CEA as a fundamental tool for strengthening Europe’s competitiveness, industrial decarbonisation and economic resilience.

Many companies are already adopting circular solutions to reduce dependence on virgin raw materials, mitigate exposure to commodity price volatility and supply chain disruptions — including those linked to geopolitical tensions — improve operational resilience, diversify sourcing strategies, and at the same time align with environmental sustainability goals.

However, the transition continues to be hindered by regulatory fragmentation, lack of harmonisation and economic mechanisms that often disadvantage circular models compared to linear ones.

According to the signatories, the CEA should contribute to the creation of a true European single market for circular solutions by fully integrating circularity into industrial strategy and enabling the scalability of activities and production and consumption models such as reuse, repair, refurbishment, remanufacturing, product-as-a-service, recycling and the use of secondary raw materials.

The document identifies three main priorities:

Building a single market for circular solutions
A simpler and more harmonised regulatory framework is needed, including clear European definitions for waste and circular activities; shared end-of-waste criteria; streamlined procedures for the cross-border movement of used products, components and secondary materials; and greater convergence among Extended Producer Responsibility (EPR) systems.
Creating fairer economic and demand conditions
The CEA should help address the upfront cost disadvantages and double-taxation risks that currently penalise circular business models. Requested measures include VAT reforms, harmonised circular criteria in public procurement, and other coordinated economic incentives at both European and national level capable of steering demand toward circular products, services and business models.
Unlocking private finance and strengthening value chains
Scaling circular solutions requires financial instruments capable of mobilising the private capital needed to support the growth of circular innovation and infrastructure, while improving both the economic sustainability and risk profile of circular business models.
At the same time, mechanisms are needed to provide greater market certainty — for example through the creation of a European platform for secondary materials that could help aggregate demand, increase transparency and improve price visibility.

In conclusion, the CEA represents a crucial opportunity to enable the creation of a European circular market with significant benefits in terms of economic security and long-term competitive advantage for businesses.

White paper: strategic guidance for the European regulatory framework

Alongside the letter, the white paper “The EU Circular Economy Act: Key policy levers for Europe’s industrial strategy”, published by the Ellen MacArthur Foundation, provides a strategic overview of the priorities that could shape the future CEA.

The document highlights how the transition toward the circular economy has become a crucial step in strengthening the European Union’s industrial competitiveness and economic resilience.

The white paper places particular emphasis on the need to create regulatory, economic and industrial conditions capable of fostering a more integrated European market for circular products, materials and solutions. This means promoting harmonised rules and common standards, developing dedicated fiscal and financial tools, and helping create demand geared toward circularity — all driven by stronger collaboration across value chains.

Il White Paper in brief

The white paper argues that the future CEA represents a decisive opportunity to fully integrate the circular economy into Europe’s industrial strategy, identifying several key priorities.

1. Enabling a true European single market for circular solutions

One of the paper’s central messages is that regulatory fragmentation and the lack of standardisation across Member States currently hinder the spread of circular business models and the circulation of secondary raw materials within the European market.

The document therefore stresses the need to harmonise definitions and criteria related to the circular economy, simplify EPR obligations, develop shared end-of-waste criteria, and build a common data infrastructure through tools such as Digital Product Passports.

2. Using fiscal levers and market demand to make circularity competitive

The white paper notes that many circular solutions are still disadvantaged by an economic system that does not properly reflect the environmental costs of linear models.

Among the issues highlighted are distorted incentives and cases of double taxation affecting used or refurbished goods, making models such as reuse, repair and second-hand markets less competitive than linear alternatives.

For this reason, the paper calls on the EU and Member States to make more coordinated and targeted use of fiscal levers, public procurement and demand-side instruments to make circular products and materials more accessible, affordable and scalable across Europe.

3. Treating the circular economy as industrial policy

The document presents circularity not merely as an environmental agenda, but as a genuine European industrial policy agenda.

The goal is to strengthen value chains and sourcing systems, reduce dependence on virgin raw materials and enhance Europe’s economic security.

From this perspective, the CEA should support industrial partnerships, investment in circular value chains, and mechanisms that help retain value, materials and expertise within the European economic system.

4. Mobilising private finance and de-risking tools

Another central message concerns the need to make circular investments more bankable.

Many circular business models are still perceived as high-risk and require significant upfront investment, particularly those based on reverse logistics, product-as-a-service, leasing, pay-per-use or asset management across multiple life cycles.

The white paper therefore underlines the role that both public and private instruments can play in reducing perceived risk and mobilising capital, including through guarantees, first-loss facilities, blended finance, European funds and instruments linked to the EIB, EIF or InvestEU, as well as within the future EU Multiannual Financial Framework.

5. Linking environmental policy, industrial policy and international alignment

The paper also highlights the need to move beyond an approach in which environmental and industrial policies operate separately.

Instead, the Ellen MacArthur Foundation proposes a framework capable of aligning environmental goals, the single market and competitiveness in order to accelerate the transition without creating further regulatory complexity.

In essence, circularity is described as a tool for combining economic growth, strategic autonomy and climate objectives. Finally, the paper stresses that, to be truly effective, European action must also be compatible beyond EU borders. Global investors and companies need interoperable rules, harmonised metrics and comparable market conditions.

For this reason, the EU should also use the CEA as a lever for international leadership by promoting regulatory convergence and common standards in external partnerships and trade relations.

Why these documents matter for the future of the circular economy

The joint letter and the white paper come at a crucial moment for the definition of European circular economy policies.

Both documents highlight a growing convergence among businesses, financial institutions, public bodies, international organisations and innovation actors around the need to accelerate the transition through a clearer, more harmonised and investment-friendly regulatory framework.

The underlying message is that the circular economy can no longer be regarded solely as a component of environmental policy, but must become an integral part of Europe’s industrial strategy.

For both the EU and its Member States, the future CEA represents a decisive opportunity to make circular economy models an economically advantageous choice capable of strengthening business and industrial competitiveness, reducing dependence on virgin resources, supporting the development of innovative industrial value chains, and contributing to the resilience and security of the European economy.