The Flanders-China Chamber of Commerce (FCCC) organized a webinar focused on “Grants and Opportunities in EU Circular Economy" on 21 October 2025. Ms. Gwenn Sonck, Executive Director of the Flanders-China Chamber of Commerce, introduced the topic of the webinar and the speakers. Navigating the European Union's rapidly evolving circular economy regulations is no longer just about meeting requirements, but is a strategic necessity for any business that imports or is doing business in the region. To avoid risks and find new market opportunities, it is critical to understand and adapt to this new framework. Expert speakers from Deloitte Legal and Deloitte's Grants and Incentives team will guide us through this evolving landscape, explain the key legal instruments shaping the EU circular economy framework, share practical case studies, and outline EU and Belgian funding opportunities that support sustainable and low-carbon investments.
Mr. Charles D’Haene, Junior Associate Public Law & ESG at Deloitte Legal Lawyers, replacing Mrs. Els Van Poucke, explained that the circular economy is one of the major political commitments under the European Green Deal, which is the EU's overarching roadmap for achieving a sustainable economy. The Green Deal itself was presented in 2019, and set out the EU's ambition to become climate neutral by 2050, which is also a target that is enshrined in the European climate law. Essentially, it explains how exactly the EU will achieve its climate and environmental objectives by combining an ambitious package of measures, including emission restrictions, innovation and preservation of Europe's natural environment, to drive a sustainable transition into this climate neutral 2050. Within the Green Deal, there are three main focus areas. First, we have decarbonization, which focuses on the use of raw materials, renewable fuels and energy efficiency standards. It is primarily delivered through the “Fit for 55” package, which contains several legislative initiatives, targeting emissions reduction specifically by at least 55% by 2030, compared to 1990 levels. A second key focus area in the Green Deal is sustainability reporting. You might already be familiar with directives such as the Non-Financial Reporting Directive (NFRD), and its successor, the Corporate Sustainability Reporting Directive (CSRD). These directives require large companies to report on their activities, and on the impact that they have on the environment and the impact that the environment might have on them. There are already quite a lot of companies reporting under the CSRD.
The third focus area is circularity and value chains. The EU aims to move away from the traditional take-make-dispose model and move towards a more regenerative system where products, materials and resources are kept in use for as long as possible. In the traditional model, a product is made, is produced, is sold, and then disposed of, and then the lifecycle ends. The EU is trying to move towards a loop where a product is produced, used, and not disposed, but maybe reused, recycled, and then actually the cycle just keeps on going, so there is no unnecessary waste being produced. Within this circularity focus area, there are several key regulatory initiatives that have already been introduced, some have already entered into force, and some that are about to enter into force or become applicable. At the heart of this policy area of circularity and value chains, we have the Circular Economy Action Plan. The first was adopted in 2015, and then the second followed in 2020, and builds upon lessons learned from the first action plan. The key objectives are to make products in the EU more sustainable and durable, to empower consumers and public buyers, to ensure that there is a reduction of waste generation – more specifically with a focus on those industries that use most resources, for example, batteries, textiles, furniture and electronics – to ensure that circularity benefits people in the economy and not only the environment. Finally, to lead global efforts from the EU side on the circular economy in respect to other economies in the world. The Circular Economy Action Plan lists 35 actions in the annex. There is also legislation on green public procurement to ensure that it is more green, more sustainable and more circular. By 2025, the EU had the aim to double the EU circular material use rates and reduce waste generation by 15%. By 2030, the aim is to increase the amount of waste that is recycled to 65%, reduce the carbon footprint of products by 30% and save 600 million tons of CO2 equivalent emissions. Finally, by 2050, the EU's aim is to ensure that 100% of resources are reused or recycled and that the EU has not contributed to climate change beyond its natural capacity. These are ambitious and very long term goals, but they give you a sense of where EU policy is heading today.
A recent initiative, the Competitive Compass, aims to strengthen the EU's position in the global market and closely linked to that, the Clean Industrial Deal, which includes six proposals, including the Circular Economy Act, which is expected to be proposed by the Commission in Q4 of 2026. Today there is no text yet, so we don't know exactly what will be in the Circular Economy Act, but it will be designed to facilitate the free movement of circular products, revise existing rules on e-waste, expand and digitalize extended producer responsibility, harmonize end of waste criteria, and strengthen sustainability criteria for public procurement.
Mrs. Dominique Vanherck, Director Climate & Energy, talked about specific regulatory initiatives that are already shaping company obligations today. The targets of the Commission to achieve this circular economy, in order for them to be enforceable, need to be translated into legislation. We have already seen a surge in ESG regulations over the past couple of years. For example, we have the Waste Framework Directive, which is really the cornerstone of the waste policy and legislation in the EU. It has been around for quite a while, but is amended regularly. It also contains the definition of waste in the EU, which has seen a lot of case law from the European Court of Justice in the past years. The Commission has a tendency to adopt more regulations instead of directives, which are directly applicable in the member states and do not need to be transposed. It is really an attempt from the Commission to regulate more at a European level and to avoid different applications of European provisions throughout the member states to achieve a more level playing field at the EU level.
An important piece of new legislation is the Eco-Design for Sustainable Product Regulation, which entered into force in 2024 with the ambition of the Commission to transition to a sustainable product policy throughout the EU. The Batteries and Waste Batteries Regulation is also an important piece of legislation because batteries are becoming more and more important. The Packaging and Packaging Waste Regulation (PPWR) also sets a framework for more sustainable packaging throughout the entire life cycle. It includes waste reduction targets for member states, and introduces a requirement to make packaging recyclable by 2030. It also enforces mandatory reuse and refilling systems in certain sectors, and requires minimum recycled content in plastic. The Rights to Repair Directive grants certain rights to consumers. It requires manufacturers to repair certain common household products, like for example, washing machines and vacuum cleaners, even after the legal guarantee has expired. Finally, we have the Green Claims Directive and Empowering Consumers for Green Transition Directive (EMPCO), which introduces mandatory criteria for the substantiation of voluntary environmental claims. If you want to say that a product is green, you really need to be able to substantiate that claim.
Design and labelling requirements have been introduced in the Sustainable Products Regulation, which was adopted in July 2024. The aim is to move to a sustainable product policy in the EU to extend the lifespan of products to make the products more durable, repairable, and recyclable. To achieve this, the ESPR provides a general framework with eco-design requirements. However, the precise scope of application still needs to be determined in specific Commission Delegated Acts, which we expect shortly. They may contain labelling and information requirements. Another novelty being introduced by the ESPR is the requirement to have a digital product passport (DPP). The Commission wants that every product which is placed on the European market has its digital identity. The digital product passport is really an electronic record providing comprehensive information about a product's origin, materials, sustainability impacts, and end-of-life possibility. It must be accessible to a wide range of stakeholders, from manufacturers to consumers, but also in certain circumstances to the relevant authority, really ensuring traceability throughout the supply chain, enhancing repair, and ensuring regulatory compliance. Products for which a delegated act will be adopted, will only be able to be placed on the market or put into service if a DPP is available for that product, which must be registered in the digital EU registry.
Another concept is the extended producer responsibility (EPR), whereby the producer is not only responsible for making a product, but also for what happens to it after it is used. In the EU, the principle already applies to certain product categories, such as packaging, electronics and batteries, but under the EU's Circular Economy Framework, these schemes are being expanded and strengthened. More product groups will fall under EPR, for example, textiles. EPR fees will become eco-modulated, meaning that producers who design products that are easy to recycle or reuse will pay less, while those producers who generate more waste will pay more. For companies exporting to the EU, this might have important consequences. If you place a product on the EU market, you will need to register in national EPR schemes. You will have to report volumes and materials, and you will have to finance the recycling of the waste management. If you are a foreign producer importing into the EU, you can designate a representative to fulfill these obligations in the EU on your behalf.
Mr. Charles D’Haene, explained that these instruments are really reshaping how our products are designed, produced, used and recycled in the EU. It is important for companies to understand the potential roadblocks to enter the EU market. But there are also opportunities to create competitive or operational advantages. The aim in navigating this landscape is not just complying, but to anticipate and to strategically respond to emerging rules. What could be a useful starting point is to take a close look at the company. So for example, its activities, the products it produces, the services it provides, the market it operates in, and to identify the relevant EU circular economy legislation that is applicable to those products, activities, and markets. Deloitte Legal Lawyers can provide a deep dive analysis on the opportunities and roadblocks. The outcome is kind of a really detailed and structured understanding of exactly what your company should do with this specific regulation in mind. Next, Mr. D'Haene gave an example of an opportunity identified for a fictitious phone manufacturing company. This may include who must be able to repair the product and the provision of spare parts and instruction manuals on how to replace them. It is also important to predict what can happen with a regulation in the next few years. The circular economy legislation can provide a significant benefit to companies.
Mr. Xu Lin, Manager, Deloitte’s Grants & Incentives Team, talked about grants and incentives. Grants are the financial instruments of these policies to stimulate companies and different organizations to achieve the circularity goals. The grants incentives team of Deloitte based in Brussels consists of over 40 different professionals with mostly scientific and engineering backgrounds, and a profound knowledge in fundings and tax incentives, trying to help clients to navigate the complex landscape of cash grants and tax incentives. There are many activities in your company which can be covered by grants incentives. For example, adopting circular business models, optimizing your supply chain or carbon pricing strategies, are all triggers of grants incentives. On the EU level, you have Horizon Europe, EU's largest R&D program, primarily supporting basic research up until development and demonstration. LIFE is a program which supports circular economy and climate action plans for demonstration actions. Innovation Fund and H2 Bank are finance projects which contribute to further industrial deployment. In Belgium, you have different fundings to support your sustainability and circularity activities from research up to production.
The Innovation Fund is the EU's largest decarbonization fund, amounting to €40 billion from 2020 to 2030, to reduce greenhouse gas emissions. Usually a more than 50% reduction is expected. You have to demonstrate that your technology is innovative beyond the state of the art in Europe. The Innovation Fund supports capex investment for large scale decarbonization projects within the EU. Funded projects range from battery recycling, biomass valorization, hydrogen production, to industrial products reuse. The LIFE program also supports sustainability and circularity activities with a total grant amount of around €5.4 billion between 2021 and 2027. Besides different schemes of EU fundings, in Belgium you also have different grants and incentives to support circularity and sustainability actions. In Belgium it's a bit complicated. For the tax incentives, it is mostly organized on a national level, but on the funding side, it is mostly organized by the regional level. The investment deduction applies to your CapEx investment that is capitalized under the Belgian book and it will be deducted from the income in the periods in which the intangible or tangible fixed assets are acquired or created. The depreciation period of the fixed asset has to be at least three accounting periods. The new investment deduction law entered into force in January 2025. There are three pillars: basic deduction, thematic deduction, and technology deduction. In Flanders, there is also different funding support for sustainability efforts. Mr. Lin showed a few examples of projects that acquired funding from the Flemish government, for example, the recycling of different materials, such as rubber, metals, glass, and zinc.
A Q&A session concluded the webinar.
