As global environmental challenges such as resource depletion and climate change become more pressing, the defence sector is increasingly adopting circular economy principles to reduce its environmental impact and improve its resilience. Embracing circular economy strategies can offer substantial operational benefits for the armed forces, including enhanced resource security, reduced logistical burdens, and increased durability and adaptability of military assets. This paradigm shift is supported by a range of policies and initiatives at the EU level.
Circular Economy Action Plan
The Circular Economy Action Plan (CEAP), adopted by the European Commission, is a comprehensive strategy aimed at fostering a sustainable and resilient economy by transitioning from a linear to a circular model. The plan focuses on enhancing resource efficiency, reducing waste, and promoting the reuse, repair, and recycling of materials across various sectors. Key components of the CEAP include a sustainable product policy framework, initiatives to improve the circularity of key product value chains such as electronics, batteries, packaging, and textiles, and measures to boost recycling and reduce waste. The CEAP also emphasizes innovation and investment in circular technologies, the development of a market for secondary raw materials, and the alignment of policies to support the overall transition. By implementing these measures, the CEAP aims to reduce environmental impacts, enhance economic competitiveness, and achieve long-term sustainability goals.
While the CEAP itself does not specifically target the defence sector, its principles and goals can still influence and guide practices within defence organisations. Many of the technologies, materials, and processes used in defence operations intersect with those targeted by the CEAP, such as electronics, batteries, and materials management. Therefore, defence organisations may voluntarily adopt aspects of the CEAP to enhance sustainability, improve operational efficiency, and align with broader EU environmental goals.
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Critical Raw Materials Act
The Critical Raw Materials Act is a legislative initiative by the European Union aimed at ensuring a secure, sustainable, and resilient supply of critical raw materials (CRMs). The Act seeks to address the supply risks associated with these materials, many of which are sourced from outside the EU, by promoting domestic production, recycling, and diversification of supply sources.
Key provisions:
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Art. 5.1: “The Commission and Member States shall strengthen the different stages of the value chain of strategic raw materials (…) in order to: (…) ensure that, by 2030 (…) Union recycling capacity, including for all intermediate recycling steps, is able to produce at least 25% of the Union's annual consumption of strategic raw materials.”
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Foreseen: Commission, in cooperation with national authorities to perform a “stress test”, at least every 3 years (review trade flows between UE and third countries, as well as evolution of demand and supply).
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Creation of a “Critical Raw Materials Club” to foster international cooperation.
Defence-specific provisions:
- Member States shall not be required to submit information regarding certain strategic stocks when such information could compromise its defence and national security. In this case, it shall present a justified notice.” (Article 22)
- Specific exemptions.
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Ecodesign for Sustainable Products Regulation
The proposal establishes a framework to set ecodesign requirements for specific product groups to significantly improve their circularity, energy performance and other environmental sustainability aspects such as product durability, reusability, upgradability and reparability, recycled content or environmental impacts.
It also includes information requirements that could be met by the introduction of “Digital Product Passports”
Defence-specific provisions:
It is foreseen that:
- Products whose sole purpose is to serve defence or national security shall be excluded from the product group” (Article 5).
- for other military or sensitive equipment ecodesign requirements take into account the security needs and the characteristics of the defence market, as defined in Directive 009/81/EC of the European Parliament and of the Council”
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EU Strategy for Sustainable and Circular Textiles
The EU Strategy for Sustainable and Circular Textiles, launched in March 2022, aims to make the textile industry more sustainable by promoting durable, reusable, and recyclable materials while reducing waste and pollution. In the defence sector, this strategy can be applied by designing and procuring sustainable uniforms and gear, implementing waste reduction and recycling programs, and minimising the use of hazardous chemicals.
Additionally, adopting circular procurement policies and investing in innovative textile technologies can enhance the sustainability of military textiles. These measures help the defence sector align with broader EU sustainability goals and reduce its environmental footprint.
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Joint Communication on the Climate-Security Nexus
The Joint Communication on the Climate Security Nexus released in 2023 by the European Commission and the High Representative of the Union for Foreign Affairs and Security Policy addresses the critical impacts of climate change on global security. Recognising climate change as a threat multiplier, the document emphasises the need for integrating climate risk assessments into security and defence planning, promoting sustainable resource management, and climate-proofing infrastructure. It calls for enhanced international cooperation, including partnerships with organisations like NATO and the UN, to collectively tackle climate-related security challenges.
Key measures include developing early warning systems, adapting military operations to climate impacts, and investing in research and innovation to create resilient and sustainable defence strategies.
By aligning climate security policies with broader EU strategies and international frameworks such as the Paris Agreement, the EU aims to build resilience, operational readiness, and sustainability within the defence sector.
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The European Green Deal is the European Commission’s main instrument to align the EU’s climate, energy, transport, and taxation policies with reducing net greenhouse gas emission by at least 55% by 2030.
The EU now has legally binding climate targets covering all key sectors of the economy. The overall package includes
emissions reduction targets across a broad range of sectors
a target to boost natural carbon sinks
an updated emissions trading system to cap emissions, put a price on pollution and generate investments in the green transition
and social support for citizens and small businesses.
Member States will now spend 100% of their emissions trading revenues on climate and energy-related projects and the social dimension of the transition.
While the European Green Deal does not explicitly target the defence sector, its broad objectives and policies impact all sectors, including defence. For instance, policies on energy efficiency, emissions reduction, and sustainable practices apply across the board, potentially affecting defence operations, procurement, and logistics.
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Regulation on Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH)
REACH stands as the primary EU legislation safeguarding human health and the environment against potential chemical risks. This is achieved through improved and earlier identification of the inherent properties of chemical substances and through actions such as the gradual elimination or restriction of substances of significant concern.
REACH, as a European Regulation, is directly applicable in Member States and hence applies to the defence sector as well. However, REACH in its Article 2, paragraph 3, states that “Member States may allow for exemptions from this Regulation in specific cases for certain substances, on their own, in a mixture or in an article, where necessary in the interests of defence”. Granting such defence exemptions is first and foremost a national responsibility.
However, REACH is clearly an area where a harmonised approach towards granting or denying of national defence exemptions would contribute to a level playing field for European defence industries, reducing their administrative burden and related costs and hence support the creation of an open and transparent European Defence Equipment Market and the maintenance and development of a capable and capability-driven European Defence Technological and Industrial Base (EDTIB), providing Armed Forces with the right defence equipment to meet their operational requirements.
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Regulation (EU) 2023/1542 on Batteries & Waste Batteries
The EU's New Battery Regulation has three main goals: enhancing the EU internal market's efficiency, promoting circular economy principles, and minimiszing environmental and social impacts across all battery lifecycle stages. It mandates specific requirements for all batteries entering the EU market by introducing a digital product passport from 28 February 2027, excluding those for military, space, and nuclear purposes.
These requirements encompass sustainability, safety, labeling, due diligence, waste management, and more. The regulation assigns responsibilities to manufacturers, importers, and distributors, establishing conformity assessment procedures and market surveillance criteria. While this regulation does not apply directly to defence applications at this stage, it may have an effect on the entire supply chain of batteries including those for defence products.
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Safe and Sustainable by Design Framework
The EU's Safe and Sustainable by Design (SSbD) framework is a strategic approach aimed at ensuring that products and processes are environmentally friendly, safe for human health, and sustainable throughout their lifecycle. This framework emphasizes the integration of safety, sustainability, and circularity principles right from the initial design phase. It involves rigorous assessment criteria to minimize the environmental impact, reduce hazardous substances, and promote the use of renewable resources.
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Waste Framework Directive
The EU's Waste Framework Directive (WFD) is a central piece of legislation in European environmental law, aimed at ensuring sustainable waste management across the EU. Originally adopted in 1975 and subsequently revised, the most recent significant update was Directive 2008/98/EC. The Waste Framework Directive sets the basic concepts and definition related to waste management, including definitions of waste, recycling and recovery. The Waste Framework Directive lays down some basic waste management principles.
It explains when waste ceases to be waste and becomes a secondary raw material, and how to distinguish between waste and by-products. The Directive also introduces the "polluter pays principle" and the "extended producer responsibility".
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