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VAT and circular economy

Full official titleProposal for a Council Directive amending Directive 2006/112/EC as regards the support of the circular economy

open on 5 Oct 2026 Open for answers from 9 Sep 2026 to 4 Nov 2026 (open). Answer on the Commission's site. Topics: Taxation.

What the Commission proposes

The European Commission has launched a call for evidence for an evaluation and impact assessment running in parallel regarding VAT rules and the circular economy. The initiative aims to modernise selected value added tax rules that currently hinder circular business models, sustainable consumption choices, and the single market for secondary raw materials. It focuses on three specific pillars: second-hand goods, the donation versus destruction of viable goods, and VAT deduction rules for passenger cars. A legislative proposal is indicatively planned for the second quarter of 2027.

Affected, as named in the text: businesses; SMEs; tax administrations; consumers; economic operators.

What is asked: The Commission asks respondents to provide feedback and evidence on the evaluation of current VAT rules and the impact assessment of potential policy options regarding second-hand goods, the donation or destruction of viable goods, and VAT deduction rules for passenger cars.

Summary written from 16 passages of the Commission document by gemini-3.5-flash-lite on 3 Oct 2026; cached and shared by every organisation.

Dossier summary from the portal

This initiative supports the transition towards a circular economy by modernising selected VAT rules that may currently hinder circular business models and sustainable consumption choices. It will focus on the VAT treatment of second-hand goods and circular production chains, the destruction of viable goods, and VAT deduction rules for passenger cars. The initiative will ensure that any solutions remain proportionate, fraud-proof and compatible with the principles and structure of the common VAT system.

Commission documents: Proposal for a Council Directive amending Directive 2006/112/EC as regards... (EN, 5 pages).

Who has already answered

22 submissions in the snapshot (13 from organisations), portal total 22. Feedback list on the portal.

By stakeholder type (as declared on the portal)
Submissions by stakeholder typeEU citizen9Company8Business association2Academic or research institution1Environmental organisation1NGO1
By country, top 10
Submissions by countryDEU4ITA3BEL3FRA2ESP2IRL1NLD1NOR1SVK1CHE1

13 of 13 organisation submissions analysed; the model reads them as: supports 1 wants changes 12

  • Aliapur Business association, FRA model reads as: wants changes source
    • Extend the right to deduct VAT and the simplification and harmonisation of the margin scheme to all second-hand tyres in all segments.
      we fully support the extension of the right to deduct VAT and the simplification/harmonisation of the margin scheme to all second-hand tyres in all segments (light and heavy vehicles).
      machine translation by the Commission, original in FR
    • Include heavy goods vehicle tyre retreading within the scope of remanufactured goods eligible for the new VAT regime.
      we fully support the inclusion of PL retreading within the scope of “remanufactured goods” eligible for the new VAT regime.
      machine translation by the Commission, original in FR
    • Exclude light vehicle tyre retreading from the favourable VAT regime until a reliable technical benchmark for retreadability exists.
      we do not support, at this stage, the inclusion of VL retreading in this same favourable regime.
      machine translation by the Commission, original in FR
  • Micro company, DEU Company, DEU model reads as: wants changes source
    • Upcycling should be explicitly recognized as a distinct circular economic activity rather than being treated like simple second-hand resale.
      UPCYCLING should be recognised as a distinct circular economic activity.
    • The VAT system should be adjusted so it does not disadvantage businesses that use existing materials.
      The VAT system should not disadvantage businesses that use existing materials.
    • The administrative burden of the VAT framework must be simplified to accommodate micro-businesses and artists.
      The administrative system should recognise this reality. A circular VAT framework should be simple enough for a one-person business or small creative studio to use correctly without requiring disproportionate accounting resources.
  • Universidad Complutense de Madrid Academic or research institution, ESP model reads as: wants changes source
    • Establish tax neutrality to remove bureaucratic barriers between refurbished and new goods.
      there is an urgent need to establish true tax neutrality that removes bureaucratic barriers on refurbished versus new goods.
      machine translation by the Commission, original in ES
    • Abolish the right of deduction for the destruction of viable goods and facilitate donation through harmonised exemptions.
      It is also imperative to abolish the right of deduction for the destruction of viable goods, facilitating donation instead through harmonised exemptions.
      machine translation by the Commission, original in ES
    • Make deductions for passenger cars exclusively conditional on zero-emission vehicles to decarbonise corporate mobility.
      Finally, to decarbonise corporate mobility, the new framework should make deductions for passenger cars exclusively conditional on zero-emission vehicles.
      machine translation by the Commission, original in ES
  • Atea Company, NOR model reads as: wants changes source
    • Increase the ambition of the initiative to better accommodate circular business models.
      The direction is right. The ambition, however, should be higher.
    • Address fragmented rules and administrative obstacles that hinder the cross-border flow of used and refurbished equipment.
      Yet the path to a second life is often obstructed by fragmented rules, documentation requirements, product-status uncertainty and transaction-specific VAT treatment.
    • Ensure the VAT framework supports the entire supply chain rather than focusing only on the final invoice.
      The VAT framework must therefore work for the chain, not merely for its final invoice.
  • Micro company, BEL Company, BEL model reads as: wants changes source
    • Apply reduced VAT on Bike-as-a-Service offers that include maintenance and repair.
      Reduced VAT on Bike-as-a-Service offers that include maintenance and repair.
    • Implement usage-based premiums linked to actual kilometres cycled or trips made rather than the purchase of a new bike.
      Usage-based premiums, linked to actual kilometres cycled or trips made, rather than to the purchase of a new bike.
    • Introduce a 120 percent corporate tax deduction for companies' Bike-as-a-Service expenses.
      A 120% corporate tax deduction for companies' Bike-as-a-Service expenses, so that shared, maintained and long-lasting fleets become at least as attractive as buying or leasing new bikes.
  • ESWET - European Suppliers of Waste-to-Energy Technology Business association, BEL; register: Trade and business associations model reads as: wants changes source
    • Apply reduced VAT rates to products that contain certified recycled content.
      ESWET supports reduced VAT rates for products containing certified recycled content, accompanied by taxation of virgin raw materials and plastics.
    • Establish recycled-content targets in specific sectors to ensure predictable demand for secondary raw materials.
      such incentives will only deliver their full potential if they are complemented by recycled-content targets in sectors such as metals and construction materials, thereby ensuring predictable demand for secondary raw materials.
    • Make advanced technologies recovering metals and minerals from incinerator bottom ash and fly ash explicitly eligible for EU funding instruments.
      ESWET calls for advanced technologies recovering metals and minerals from incinerator bottom ash and fly ash to be explicitly eligible for EU funding instruments.
  • Micro company, BEL Company, BEL model reads as: wants changes source
    • Apply reduced VAT rates to integrated circular services rather than products alone.
      I therefore advocate a reduced rate applicable to all integrated circular services: provision, collection, washing and maintenance necessary for re-use.
      machine translation by the Commission, original in FR
    • Develop the EU framework for circular services and encourage Member States to apply reduced rates.
      Action is needed at two levels: develop the European framework to better recognise circular services and encourage Member States to make effective use of the possibilities for reduced rates.
      machine translation by the Commission, original in FR
  • Micro company, DEU Company, DEU model reads as: wants changes source
    • Exempt donations in kind from VAT throughout the entire EU.
      Donations in kind should be exempt from VAT throughout the EU.
      machine translation by the Commission, original in DE
    • Waive VAT specifically for emergency assistance during disasters.
      VAT should be waived in particular for emergency assistance in the event of a disaster.
      machine translation by the Commission, original in DE
    • Ensure that the obligation to prove the benefit to recipients does not create excessive bureaucracy.
      The obligation to prove that the goods benefit beneficiaries should not lead to excessive bureaucracy and should only be aimed at preventing abuse.
      machine translation by the Commission, original in DE
  • Micro company, ITA Environmental organisation, ITA model reads as: wants changes source
    • Ensure the tax treatment for used and refurbished goods makes a clear distinction between different circular activities.
      For CNSBII, the first point requires a clear distinction between reuse, repair, refurbishment, remanufacturing and recycling.
      machine translation by the Commission, original in IT
    • Prevent the tax system from making the destruction of functional assets more convenient than their donation.
      On the issue of donation, we consider it particularly important to avoid that the tax system makes it more convenient to destroy assets that are still usable.
      machine translation by the Commission, original in IT
    • Ensure that compliance requirements and traceability for SMEs and re-use operators remain proportionate.
      Traceability of operations is necessary but must be proportionate.
      machine translation by the Commission, original in IT
  • Liberty Recycling NGO, IRL model reads as: wants changes source
    • Apply zero-rated VAT to upcycled products and inventions made from unwanted materials when resold.
      Products and inventions made from unwanted materials, particularly textiles, should also be zero-rated when resold to suppliers or the general public for reuse.
    • Provide direct State support including capital grants for premises and machinery.
      Beyond VAT reform, we believe the Irish Government must take a more proactive role in financial supporting established sorter/graders through capital grants for premises and machinery needed as well as increased public awareness and media support for the sector.
  • The North Face / VF Corperation Company, CHE model reads as: supports source
    • Remove VAT on resale goods to prevent double taxation.
      Removal of VAT means units are not double charged (for initial sale, then again upon resale)
    • Encourage more circular business practices by retail companies.
      but also would encourage more circular business practices by retail companies that are otherwise priced out of engaging within the second hand/resale market.
  • Micro company, NLD Company, NLD model reads as: wants changes source
    • Extend the Florence Agreement to exempt educational, scientific, and cultural materials from the new customs measure.
      is there any possibility of extending the 1950 Florence Agreement (which exempts educational, scientific, and cultural materials from import duties) to cover this new customs measure?
  • CAPNOR Company, FRA model reads as: wants changes source
    • Implement a unified VAT and circular economy scheme to enable clarity and ease transborder business.
      it would be helpfull to have a a unified VAT and circular economy scheme that unable clarity, easy transborder business within the Schengen area and the EU countries.
    • Implement a reduced VAT rate for circular economy products.
      I would encourage you to implement a reduced VAT rate and exclude them from the Ecotaxes.
    • Exclude circular economy products from ecotaxes considering they have already been taxed.
      To encourage the circular economy to grow and considering that these products have already been taxed, I would encourage you to implement a reduced VAT rate and exclude them from the Ecotaxes.

Who met the cabinets on the subject

60 meetings by subject similarity, approximate

subject match, approximate The top 60 cabinet meetings by similarity (the list stops at 60) whose recorded subject is close to this consultation's title and summary (embedding similarity at 0.45 or more, cached from the nightly map). Generic subjects such as "exchange of views on EU regulation" also pass, so read this as a lead, not a finding. Source: Commission meetings file, portal.

These 60 meetings by register category of the interest representatives (a meeting with participants from two categories counts in both)
Meetings by register category of the participantsTrade and business associations29Companies & groups22Non-governmental organisations, platf.10Other organisations, public or mixed.3Professional consultancies3Think tanks and research institutions3Trade unions and professional associa.1Self-employed individuals1
DateCabinetInterest representativeSubject as recorded
28 Nov 2025 Commissioner Jessika Roswall Norsk Hydro (Companies & groups) Circular Economy Act - End-of-Life Vehicles Regulation
21 Mar 2025 Commissioner Jessika Roswall Fédération Internationale des Véhicules Anciens (Non-governmental organisations, platforms and networks and similar) Upcoming End-of-Life Vehicle Regulation, Circular Economy Act and REACH
23 Apr 2026 Commissioner Dan Jørgensen Europex - Association of European Energy Exchanges (Trade and business associations) Protection of EU wholesale energy and environmental markets against VAT fraud
23 Apr 2025 Commissioner Jessika Roswall Verband Österreichischer Entsorgungsbetriebe (Trade and business associations) Exchange with VOEB Board on the circularity priorities for the mandate
12 Mar 2026 Commissioner Jessika Roswall Global Enabling Sustainability Initiative (Trade and business associations) Discussion on the upcoming Circular Economy Act
3 Jul 2025 Executive Vice-President Stéphane Séjourné Landbell Aktiengesellschaft für Rückhol-Systeme (Companies & groups) Discussion on the Circular Economy Act
4 Mar 2025 Commissioner Jessika Roswall Novelis Europe (Companies & groups) Circular Economy Act and End-of Life Vehicles
10 Jun 2025 Executive Vice-President Stéphane Séjourné Paprec Group (Companies & groups) Circular Economy Act, ETS for municipal waste incineration
23 Jun 2025 Commissioner Jessika Roswall Plastics Recyclers Europe (Trade and business associations) The upcoming Circular Economy Act, enforcement of environmental legislation; simplification (together with Cab Ribera)
2 Jul 2026 Commissioner Jessika Roswall Notre Europe - Institut Jacques Delors / Notre Europe - Jacques Delors Institute (Think tanks and research institutions) circular economy act
26 May 2026 Commissioner Jessika Roswall H/Advisors (Professional consultancies); Veolia Environnement (Companies & groups) circular economy act
4 Feb 2025 Executive Vice-President Henna Virkkunen Car Rental Coalition (Trade and business associations) Car Rental Coalition’s view on Commission initiatives
1 Jul 2026 Executive Vice-President Raffaele Fitto Seda International Packaging Group (Companies & groups) General discussion on EU circular economy policies
18 Mar 2026 Commissioner Jessika Roswall Verband Österreichischer Entsorgungsbetriebe (Trade and business associations) Circular Economy Act; Recycling; Waste Shipment Directive
21 Apr 2026 Commissioner Jessika Roswall eBay EU liaison office (Companies & groups) Discussions on specific provisions of the Environmental Omnibus and the forthcoming Circular Economy Act
2 Dec 2025 Commissioner Jessika Roswall American Chamber of Commerce to the European Union (Trade and business associations) EUDR and Circular Economy Act
3 Feb 2025 Commissioner Jessika Roswall Norsk Hydro (Companies & groups) Carbon Adjustment Mechanism and Circular Economy Act
22 Apr 2026 Commissioner Jessika Roswall Ernst & Young Core Business Services BV (Companies & groups) Environmental policies, circular economy
24 Oct 2025 Commissioner Jessika Roswall Wirtschaftsvereinigung Stahl (Trade and business associations) Circular Economy Act, Environmental Omnibus
22 Oct 2025 Commissioner Jessika Roswall Deutsche Industrie- und Handelskammer (Other organisations, public or mixed entities) Circular Economy Act, Environmental Omnibus
24 Jun 2025 Commissioner Jessika Roswall VELUX A/S (VELUX Group) (Companies & groups) Exchange on VELUX decarbonisation and circular activities as well as benefits of supportive policies.
3 Mar 2025 Commissioner Jessika Roswall Association des Constructeurs Européens d'Automobiles (Trade and business associations); Mercedes-Benz Group AG (Companies & groups) Exchange of views on circular economy and sustainability in the automotive sector
30 Jun 2026 Commissioner Jessika Roswall Westenergy Oy (Companies & groups) Circular Economy Act, ETS
28 May 2026 Commissioner Jessika Roswall BUSINESSEUROPE (Trade and business associations) Panel discussion, Circular Economy Act.
2 Mar 2026 Commissioner Jessika Roswall BRITA SE (Companies & groups); Acumen Public Affairs (Professional consultancies) How environmental protection and the transition to a more resource-efficient, circular economy can go hand-in-hand with clear, predictable rules and effective implementation of EU legislation.
18 May 2026 Commissioner Jessika Roswall T2T Alliance (Trade and business associations) Ecodesign for Sustainable Products Regulation Circular Economy Act
1 Dec 2025 Commissioner Jessika Roswall AIM - European Brands Association (Trade and business associations) Circular Economy Act, Environmental Omnibus, Packaging and Packaging Waste Regulation and Ecodesign for Sustainable Products Regulation.
6 May 2025 Commissioner Jessika Roswall H & M Hennes & Mauritz AB (Companies & groups) Exchange with H&M on the priorities for the mandate in the area of circular Economy.
16 Jul 2026 Commissioner Jessika Roswall Allianz Verpackung und Umwelt e.V. (Trade and business associations); Confrontations Europe (Think tanks and research institutions); Fost Plus (Other organisations, public or mixed entities); Reuse and Recycling European Union Social Enterprises (Non-governmental organisations, platforms and networks and similar); Zero Waste Europe (Non-governmental organisations, platforms and networks and similar); Association of Cities and Regions for sustainable Resource management (Non-governmental organisations, platforms and networks and similar); UNESDA (Trade and business associations); Mars Incorporated (Companies & groups); EXPRA EUROPE ASBL (Trade and business associations); Environmental Coalition on Standards (Non-governmental organisations, platforms and networks and similar); Citeo (Companies & groups); PepsiCo (Companies & groups); Bruegel (Think tanks and research institutions); Recycling Europe (Trade and business associations) Circular Economy Act
13 Jul 2026 Commissioner Jessika Roswall eBay EU liaison office (Companies & groups); Allegro sp. z o.o. (Companies & groups); Environmental Coalition on Standards (Non-governmental organisations, platforms and networks and similar); EUROPEAN APPAREL AND TEXTILE CONFEDERATION (Trade and business associations); EuroCommerce (Trade and business associations); Ecommerce Europe (Trade and business associations); European Tech Alliance (Trade and business associations); WRAP EU (Non-governmental organisations, platforms and networks and similar); OLX Global BV (Companies & groups); Bureau Européen des Unions de Consommateurs (Non-governmental organisations, platforms and networks and similar); Patagonia Europe Coöperatief (Companies & groups); Center for European Policy Analysis (Think tanks and research institutions); Vinted (Companies & groups); Stichting Fair Trade Advocacy Office (Non-governmental organisations, platforms and networks and similar) Circular Economy Act

Showing 30 of 60.