Berlin, 03.06.2026: The German Environmental Association (DNR) and its member organisations BUND, Deutsche Umwelthilfe, Germanwatch, NABU, natureplus, NaturFreunde Deutschlands and WWF as well as the Forum Umwelt und Entwicklung, the INKOTA network and Powershift e.V. welcome the new action programme adopted today by the Federal Government for the implementation of the National Circular Economy Strategy (NKWS), but see significant weaknesses. With the Action Programme, the Federal Government defines the priorities for the implementation of the strategy adopted by the previous government. However, from the point of view of the organisations, the paper does not mark a real departure towards resource-saving economies.
According to the associations, there is a lack of measures that significantly reduce raw material consumption and waste generation in Germany, for example by increasing the promotion of reuse and repair. “The programme falls short of its own objectives”, the associations emphasise. “NKWS wants to significantly reduce the consumption of primary raw materials – this requires more genuinely up-and-coming measures. Many good approaches from NPPs remain unused.”
The associations criticise the fact that the measures for circular public procurement were significantly weakened in the course of the departmental vote. Instead of circulating public procurement and creating binding targets for procuring entities, it is still largely voluntary. Now, at least the majority of federally owned companies have to procure more circular products annually, increase the proportion of recycling and report on this. It remains open what the federal government wants to measure in 2028, whether the companies have sufficiently met these requirements. Overall, this is not enough to finally exploit the potential of public procurement. Because with its immense purchasing power, the public sector could specifically boost the market for products and services of the circular economy.
On the other hand, the organisations are positive about the planned introduction of waste prevention targets, the use of a dialogue platform to accompany the implementation and further development of the strategy and the creation of a 305 million euro support programme for pilot projects and SMEs, as well as the continuation of the "Future Circular Economy" funding programme in the Climate and Transformation Fund. According to the associations, the political announcements must now be followed by a real system change in practical implementation. “These measures point in the right direction, but only mark the beginning. Now we expect the Federal Government to work out a further package of measures together with the Dialogue Platform in this legislative period," the associations said.
Ulrike Kallee, Head of Fabrics and Technology, BUND: “Solutions for resource transition and independence from raw material imports are on the table: Binding reduction targets as well as reusable and high-quality mechanical recycling. What is lacking in the action programme is the political will to implement it, inter alia, with a strong packaging law and an effective plastic tax.”
Barbara Metz, Federal Managing Director, German Environmental Aid: "The promotion of reusable systems is a key to waste prevention and a true circular economy and should therefore be a prominent objective in the Action Programme, but has not yet been mentioned. Instead of binding requirements, the Federal Government now plans only voluntary minimum contributions from the disposable industry to waste prevention under the Packaging Act. That's not enough. While France's single-use industry has to invest tens of millions of euros in the expansion of reusable systems every year, there is a political brake in Germany. We therefore call on the Bundestag to enforce a clear, binding and ambitious financing mechanism for the promotion of reusable funds.”
Christoph Bals, Chief Political Officer, Germanwatch: "Unfortunately, with the Action Programme, the Federal Government is missing the opportunity to set the course for a circular, resource- and climate-friendly and resilient industry. It should make much more determined use of this legislature to advance the circular economy, for example through industrial policies that create lead markets for circular economy products and services and promote circular innovation. However, we welcome the fact that companies with a majority shareholding in the federal government are expected to boost circular procurement on an annual basis, such as Deutsche Bahn. After all, this is a start. Now it depends on how the federal government implements the project and on what it wants to measure progress. We will monitor this closely.”
Daniel Rieger, Head of Transformation and Alliances, NABU: “The Federal Government can already show how serious it is about improving and extending product responsibility in the action programme when it comes to designing extended producer responsibility for textiles: The future levies of textile manufacturers must be differentiated in such a way that durable and recyclable textiles are promoted and short-lived disposable products become noticeably more expensive.”
Rebecca Tauer, Team Leader Circular Economy, WWF Germany: "The Action Programme is an important first step because it underpins the implementation of the circular economy with concrete support measures and an implementation platform. At the same time, it falls short of the aspirations of the National Circular Economy Strategy. Circular economy is much more than a matter of supplying raw materials or recycling. It is a central building block for climate protection, biodiversity, security of supply and long-term prosperity. In order to exploit this potential, Germany needs binding resource targets, economic framework conditions for circular business models and a consistent prioritisation of prevention, reuse and repair.”
Contacts for questions:
BUND: Moritz Böttcher, Policy Officer for Raw Materials and Resource Policy, e-mail: moritz.boettcher@bund.net Tel. 030 27586-334
German environmental aid: Elena Schägg, Deputy Head of Circular Economy, e-mail: schaegg@duh.de
Forum Environment and Development: Josephine Koch, Policy Officer for Raw Materials and Resource Policy, e-mail: koch@forumue.de
Germanwatch: Franziska Koop, Policy Officer for Resource Policy and Circular Economy, E-mail: franziska.koop@germanwatch.org, Tel. +49 (0)30 577132-848
NABU: Indra Enterlein, Team Leader Circular Economy, E-mail: Indra.Enterlein@NABU.de
Inkota: Anne Neumann, Policy officer on raw materials, business and human rights, e-mail:
Neumann@inkota.de, Tel. +49 304208202-59
NatureFriends of Germany: Maritta Strasser, Federal Managing Director, e-mail: strasser@naturfreunde.de
Natureplus: Rolf Buschmann, CEO, E-Mail: buschmann@natureplus.org, Tel. 0179-2191360
PowerShift: Maja Wilke, Policy Officer for Raw Materials Policy, e-mail: maja.wilke@power-shift.de
WWF: Rebecca Tauer, Team Leader Circular Economy, E-mail: Rebecca.Tauer@wwf.de
