Written by Marc Lütz
Dear reader,
From protecting fragile Arctic ecosystems to building markets for recycled materials, Europe’s sustainability agenda continues to raise a familiar question: how do ambitions translate into practical change?
This month’s Spotlight explores the EU’s new Arctic Strategy, examining how climate research, environmental protection and economic development can work together, and where tensions may arise for ecosystems and local communities.
We also look at the latest delay to the Circular Economy Act, negotiations on simplifying extended producer responsibility, and the EU’s priorities for international climate and biodiversity talks. With gaps remaining in implementation at home, the focus is increasingly on delivering results.
Rounding out this edition are the Commission’s new Climate Resilience Framework and preparations for revising EU food contact materials legislation. Read on for the latest developments and what they could mean for your organisation.
The spotlight
The EU’s Arctic Strategy: balancing sustainability and strategic interests
On 20 October, Commission President Ursula von der Leyen, Commissioner for International Partnerships Jozef Síkela, and the High Representative Kaja Kallas, presented a new Arctic Strategy, bringing security, climate action and economic development closer together. The Arctic is warming nearly four times faster than the global average, with significant consequences for ecosystems and local communities. At the same time, melting ice is making shipping routes and natural resources more accessible, increasing the region’s strategic importance. The strategy therefore raises an important question: how will the EU balance its growing economic and security interests with its sustainability ambitions?
Climate research and monitoring remain important parts of the EU’s approach. Through OceanEye, the EU will work with partners including Canada and Norway to share ocean data, improve climate predictions and support adaptation. Destination Earth, the EU’s digital twin of the planet, will help anticipate extreme weather and disasters such as coastal flooding. A new EU Polar Research Hub will also strengthen cooperation between researchers, policymakers and stakeholders, including Indigenous Peoples. These initiatives reflect the wider importance of Arctic climate change, with rising sea levels and changing weather patterns also affecting Europe.
Alongside these measures, the strategy places greater emphasis on Europe’s ability to operate in the Arctic. The EU also aims to support renewable energy and critical raw materials development, linking the region more closely to its efforts to secure supply chains. At the same time, it maintains its position that Arctic oil, coal and gas should remain in the ground. This shows that environmental commitments remain part of the strategy, even as security and economic interests receive greater attention.
The key question is how these priorities will work together in practice. Better monitoring can support both environmental protection and maritime security, but new infrastructure and resource projects may also put pressure on ecosystems and local communities. As projects move forward, their development will provide a clearer picture of how the EU intends to balance its strategic interests with the environmental and social objectives set out in the strategy.
Policy updates
Circular Economy Act faces further delay as Parliament weighs competitiveness and costs
The European Commission’s Circular Economy Act (CEA) is now likely to arrive in December 2026, following another delay from its previously expected publication on 18 November. No revised date has been confirmed. Initially scheduled for September, the initiative was postponed after a negative opinion from the Regulatory Scrutiny Board. According to Environment Commissioner Jessika Roswall, the Board highlighted insufficient attention to demand-side measures, a key consideration for creating commercially viable markets for circular products and secondary materials.
The delay comes as political discussions sharpen around the initiative’s economic objectives. During a European Parliament plenary debate on 21 October, the Council and Commission framed the CEA as an economic-security and competitiveness measure intended to reduce dependence on imported raw materials, strengthen the single market for secondary materials and make circular products and services more affordable.
The Council called for predictable rules, improved waste traceability, more effective extended producer responsibility (EPR) systems and stronger investment conditions for recycling technologies. Commissioner Wopke Hoekstra also emphasised the role of reuse, remanufacturing and recycling in retaining valuable materials within Europe, supported by harmonised and digitalised requirements.
MEPs from the EPP, Renew and S&D broadly supported this framing, although their policy priorities differed. Members of PfE, ECR and the non-attached group raised concerns that mandatory targets, reporting obligations and high eco-contributions could increase costs for consumers and smaller businesses. For businesses, the central question remains how the proposal will translate circularity ambitions into stronger demand, simpler compliance and fewer barriers across the single market.
EU sets priorities for biodiversity and climate summits as domestic implementation lags
On 12 October, European Environment Ministers adopted a common position for the COP17 on biodiversity and the COP31 climate summit. For COP17, which took place from 19 to 30 October, the EU sought to mainstream biodiversity within and across all levels of government and society, policies, and sectors. With these conclusions, Member States recognise the fundamental importance of healthy ecosystems and biodiversity for health, food security, jobs, and long-term economic and social stability. It also highlights their role in protecting against natural hazards and strengthening resilience. The conclusions also underline the urgent need to phase out subsidies and incentives that harm biodiversity.
For COP31, taking place from 9 to 20 November, the EU has agreed to stress the urgency of achieving the Paris Agreement goals, while recognising that the warming of 1.5ºC is likely to be exceeded in the coming decades. As its overall objective, the Council stresses that COP31 must deliver tangible progress on implementing the Paris Agreement and set the direction for the second global stocktake. The Council calls for the effective implementation of nationally determined contributions (NDCs) and urges Parties that have not yet done so to submit their NDCs ahead of COP31. The deadline for Member States to submit draft National Restoration Plans under the Nature Restoration Regulation was 1 September 2026. As of late October, only 10 Member States have submitted theirs.
European Commission presents new Climate Resilience Framework
On 27 October, the European Commission presented its EU Climate Resilience Framework, following its announcement by President Ursula von der Leyen in her September State of the Union address (SOTEU). The initiative follows a summer marked by extreme heatwaves, droughts and wildfires across Europe, highlighting the growing need to strengthen Europe’s preparedness for climate-related risks.
At the heart of the Framework is the proposed European Climate Resilience Law, which would require Member States to conduct national climate risk assessments by June 2029 and adopt strategic resilience plans by December 2030. These plans would identify priority risks, adaptation measures and responsible authorities. The proposal also introduces a common warming trajectory to guide long-term planning and stronger cross-border cooperation to address shared climate risks, such as droughts affecting waterways and disruptions to interconnected energy and transport networks.
The Commission also announced forthcoming initiatives, including a European Heatwave Plan and a European Water initiative addressing drought and flood resilience. To support climate risk assessments, it has launched the European Climate Viewer, an interactive map showing projected climate hazards across Europe.
EPR simplification: scope and timing remain contested
On 19 October, a European Parliament plenary debate brought the Extended Producer Responsibility (EPR) reform dilemma to centre stage. EU institutions agree on the urgent need to simplify cross-border compliance by waiving the requirement for sellers to appoint an “authorised representative” in each EU Member State. However, key differences persist regarding the scope and timeline of the reform In terms of scope, the European Parliament originally favoured a blanket exemption for small enterprises across multiple waste streams. On 21 October, the Council proposed a narrower, volume-based exemption for producers placing less than 1 metric ton of packaging annually on a given national market. This 1-ton packaging threshold is rapidly gaining traction, as Socialists and Greens have backed it as far easier for national authorities to enforce than verifying company size.
To deliver immediate relief before Christmas, Environment Commissioner Jessika Roswall is urging co-legislators to uncouple EPR from the broader four-part Environmental Omnibus package. Lawmakers are also pressing lead negotiator Ingeborg ter Laak to conclude the agreement via written procedure, so businesses benefit before the year ends. However, a procedural bottleneck remains: the Council, under the Irish Presidency, prefers negotiating all omnibus files together to conclude the package by the end of 2026.
European Commission to host a Reality Check on Food Contact Materials
On 25 November, the European Commission will hold an online Reality Check on the revision of EU food contact materials (FCM) legislation. This session is intended to take stock of the Commission’s work to date and gather practical evidence from stakeholders on how the current framework operates in practice.
FCM rules apply to all materials and articles intended to come in contact with food, including packaging, containers, tableware and processing equipment. The existing framework is designed to ensure that materials do not transfer substances into food at levels that could endanger health or alter the food’s composition, taste or smell. However, the regulatory landscape remains uneven. Alongside the overarching EU framework, some materials continue to be governed primarily at national level. This can create legal uncertainty, duplicate compliance work and barriers to placing products on the internal market. The Commission has been considering a more coherent, risk-based framework that could improve EU harmonisation. Against this background, the 25 November Reality Check is an important preparatory step that will allow the Commission to test how the existing rules work in practice and identify areas for improvement ahead of a possible revision.
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