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Zero Waste Europe ZWE

NGO, Brussels, Belgium. EU Transparency Register entry

1 open consultation fits ZWE.

Check each match yourself. In a blind test about half of the suggestions were a real fit (15 of 30). How it was measured

Open a consultation below to see what it is about, who has already answered and the key passages. Data from 5 Oct 2026.

Open consultations for ZWE

VAT and circular economy until 4 Nov 2026 good fit Tax rules addressing the circular economy and halting the destruction of unsold goods align directly with the organisation's core mission.

Same initiative, also open: 25912

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.

  • Evaluates and reviews current EU VAT rules to ensure they align with the circular economy and complement the Ecodesign for Sustainable Products Regulation and the Circular Economy Act.
  • Examines the VAT treatment of second-hand, refurbished, and remanufactured goods to address lack of deduction rights and complex margin schemes.
  • Addresses economic distortions where destroying viable goods is more advantageous under current VAT rules than donating them.
  • Considers aligning VAT deduction rules for passenger cars with sustainability objectives and zero-emission mobility goals.
  • Assesses policy options including mandatory or discretionary measures on vehicle deductions, harmonised margin schemes, and VAT relief on donations.

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 by AI from the Commission's document.

Key passages on your topics

  1. The Ecodesign for Sustainable Products Regulation (ESPR), which entered into force in 2024 and is being progressively implemented, is a key instrument for making environmentally sustainable and circular products the norm. By establishing requirements relating to durability, repairability and reusability, which thereby support the repair- and second-hand markets, it prolongs product life and encourages customers to make more sustainable choices. In addition, the ESPR also addresses the destruction of unsold but viable consumer products by requiring economic operators to take all necessary measures to prevent them having 1 Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax (OJ L 347, 11.12.2006, p. 1, ELI: http://data.europa.eu/eli/dir/2006/112/oj) Ref. Ares(2026)8589104 - 09/09/2026
    Proposal for a Council Directive amending Directive 2006/112/EC as..., page 1 (EN)
  2. The initiative also supports broader EU efforts to accelerate the transition to zero-emission mobility, including the Commission’s 2025 Communication on decarbonising corporate fleets. It also aligns with the upcoming Recommendation on fiscal and non-fiscal demand-side incentives announced in the industrial action plan for the European automotive sector and the objectives of the revision of the CO2 standards and corporate vehicles proposal to decarbonise corporate fleets with binding national targets for zero- and low-emission vehicles. Value added tax (VAT) is a major source of revenue for Member States, accounting for 7.1% of EU GDP and representing 15.5% of total government tax revenue in 2024.
    Proposal for a Council Directive amending Directive 2006/112/EC as..., page 2 (EN)
  3. Reducing resource dependencies and keeping materials in productive use for longer are important not only for achieving the EU’s environmental objectives, but also for improving its industrial competitiveness and economic security. This is reflected in the Clean Industrial Deal, in which the Commission identified circularity as one of the key enablers of a competitive and decarbonised European economy and announced a future ‘green VAT initiative’ (also referred to as ‘Circular VAT’). The importance of the circular economy for achieving the EU’s ambition to boost competitiveness and economic security will also be reflected in the forthcoming Circular Economy Act (CEA), which is intended to strengthen the single market for secondary raw materials and is scheduled for adoption in late 2026.
    Proposal for a Council Directive amending Directive 2006/112/EC as..., page 1 (EN)

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

10 more analysed submissions on the consultation page.

Who met the Commission about it

60 meetings, 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

Showing 12 of 60.