Kevin Bradley MA Ph.D
September 15 2025
Ireland has embarked on a transformative journey toward a circular economy, aiming to reshape its economic and environmental landscape. This article looks at Ireland´s progress to date at both the policy and implementation level. It consolidates insights from various national and third-party policy documents and assessments to provide an overview of Ireland’s current efforts, achievements and challenges. Comparisons in terms of circular economy performance are made with several similar sized EU member states across a number of metrics. Some thoughts on where Ireland needs to double-down or adjust its approach to the circular economy are offered.
The foundation of Ireland’s circular economy approach is encapsulated in the Whole of Government Circular Economy Strategy 2022-2023 (1). This strategy aims to demystify the concept of the circular economy, highlighting that many circular practices are already commonplace in Irish society. From rental services to community-based reuse initiatives, citizens are actively engaging in behaviours that support circularity.
Ireland´s Whole of Government strategy aligns with the broader EU Circular Economy Action Plan (2020) which emphasises the need to realign Europe’s economy toward sustainability and resource efficiency. Key objectives at EU level include:
The EU plan also aims to reduce resource pressure, minimize waste and pollution, and support the transition to a climate-neutral economy while strengthening value chains in key sectors like electronics, packaging, and textiles. Since its adoption, plan implementation has focused on Electronics and ICT, Batteries and Vehicles, Packaging, Plastics, Textiles, Construction and Buildings, Food, Water, and Nutrients. A range of EU regulatory measures have been adopted to address resource and circularity within the sectors mentioned with further measures in the pipeline.
With the advent of the Ukraine war in 2022, an additional focus of EU Circular Economy policy has been placed on recovering and recycling critical raw materials post end of life has been highlighted. The adoption of the EU Critical Raw Materials Act in 2024 set specific targets for recycling of critical raw materials (25% by 2030) in the EU to both diversify supply and reduce dependency on third country supplies. These objectives will be formally reflected in the upcoming EU Circular Economy Act scheduled for publication in late 2025.
The EU is thus deepening its Circular Economy activities and aligning them to broader political, economic, climate and raw materials security goals. Ireland, as an EU Member State, is part of these developments and needs to keep a close eye on developments, adjusting and aligning its own national Circular Economy effort with the EU efforts. An update of the Whole of Government Circular Economy Strategy (2) would be a useful platform for reflecting recent and nascent changes in focus and policy around the Circular Economy at EU level.
Reflecting its desire to embed circular economy thinking and practice with public policy, the Circular Economy Miscellaneous Act was adopted in 2022. This Act provides enabling provisions for a range of measures to legally support Ireland´s transition to a more Circular Economy. A wide-ranging definition of what the Circular Economy entails is set out in Part 2, para. 6 sections (a-e). Importantly, an enabling provision related to the development of a statutory Circular Economy Strategy (3) is set out in Paragraph 7. It states:
The Minister shall, prepare and submit to the Government for their approval, with such modifications (if any) as they consider appropriate, a strategy (in this Part referred to as a “circular economy strategy”) setting out the policy, objectives and priorities for the time being of the Government in relation to the circular economy.
The first circular economy strategy shall be prepared and submitted under subsection (1) not later than 6 months after the date on which this section comes into operation and thereafter a circular economy strategy shall be prepared and submitted under that subsection not less than once in every period of 3 years after the date on which the most recent circular economy strategy was published in accordance with subsection.
In developing the Circular Economy Strategy, the 2022 Act sets out a number of specific steps. Including bringing together various existing, Circular Economy related, plans such as the Waste Action Plan for a Circular Economy, the Climate Action Plan, the National Policy Statement on the Bioeconomy amongst at least 11 national and sectoral plans.
Additionally, the strategy should refer to the UN SDG goals and any related EU laws (here one could already add the EU Critical Raw Materials Act (2024) and the shortly, the EU Circular Economy Act to be adopted by the Commission at the end of 2025).
An important dimension of the strategy will be the development and setting of targets, in respect of each of the following sectors of the economy:
Other targets for other sectors of the economy may also be set where the Minister responsible considers it necessary. In the area of public procurement, circular economy criteria will be promoted within the strategy.
Where targets are being set for each of the sectors identified, they shall be with reference to a number of specific criteria:
Development of any targets will be subject to a consultation process both at government level and with the sectors concerned prior to adoption and inclusion in the strategy. It’s not clear from the Act whether on not the targets will have a binding nature though the Act does require the strategy to outline how the various targets set will be met. Monitoring of progress with respect to meeting the targets set will be through an annual reporting process. A dedicated website related to Ireland´s circular economy strategy is to be established to enable communication and dialogue with the public.
The intent, scope and purpose of the Circular Economy Strategy are clear and having a robust strategy would put Ireland in a strong position to better manage its resource inputs and flows as well as putting the economy on a clear circularity path. The Act was passed in 2022, so what has happened? Where is the Circular Economy Strategy?
The Irish Environmental Protection Agency (EPA) has developed and published a Circular Economy Programme 2021 – 2027 (4). It is intended to be “the driving force for Ireland’s move to a circular economy, where businesses, citizens and the public sector reduce resource use, prevent waste and achieve sustainable economic growth”. In describing the Programme, the EPA notes:
“The Circular Economy Programme will be a statutory programme when the Circular Economy Bill is enacted and shall incorporate the existing statutory National Waste Prevention Programme. The Circular Economy Programme sits under the whole of government Circular Economy Strategy and supports this national strategy”.
This suggests that the current programme is the precursor for an eventual Circular Economy Strategy, as prescribed by the Circular Economy Act 2022 and described above. However, as currently drafted, it does not reflect the scope and focus set out in the Circular Economy Act. It is rather rooted in a more traditional waste management framework with a focus for the period 2021-2027 on priority areas set out in national waste policy documents as well as the EU Green Deal. These priority areas include Packaging, Plastics, Textiles, Food, water & nutrients, Construction & buildings, Electronics & ICT, Batteries & vehicles.
The EPA states that it will develop targets for its programmes to track progress and provide direction. Developing these targets will be undertaken to such a way as to ensure they integrate with monitoring frameworks being developed to capture and report circularity including those within the Whole of Government Circular Economy Strategy, the EU Circular Economy Action Plan and relevant legislative reporting requirements.
The targets were to be developed from 2022 onwards but to date have not appeared. Perusal of recent EPA Circular Economy Programme updates from 2022 or 2023 (published in 2024), make no mention of targets or progress towards their development.
This said, another document, the Irish National Waste Management Plan for a Circular Economy 2024 – 2027 does include eight (non-statutory) targets (in relation to 2024). The majority of these are, as expected, waste related. The target achievement date is 2030. There is also a national food waste reduction target of 50% by 2030.
Establishing circular economy metrics, targets and a robust monitoring framework are important for measuring progress and informing political decision making. A 2024 EEA Circular Economy Profile Report for Ireland notes that the European Commission has set up a monitoring framework to keep track of progress towards a circular economy.
The Commission framework consists of 5 thematic sections with a total of 11 statistical indicators, some of which have additional sub-indicators. In some cases, policy targets exist which should be achieved in the future, and the indicators monitor progress towards these targets. This monitoring framework is in effect the template for developing Irish circular economy datasets, indicators, targets and establishing a national monitoring framework.
In short, without clear targets the current EPA programme, is lacking a robust basis for measuring progress towards achieving its goals and those set out in the Whole of Government Circular Economy Strategy. The EPA is not unaware of the current situation in particular the challenges to developing appropriate metrics and has been conducting research on appropriate metrics and data needs to inform the development of robust indicators suitable for policy making.
According to the EEA (5), Ireland's circular materials use (CMU) rate is notably low at 1.8%, compared to the EU average of 11.8%. Eurostat figures on EU CMU confirm this, placing Ireland 2nd from the bottom in terms of CMU performance. Only Romania has a lower score. Looking at similar sized EU countries across key EU Circular Economy indicators, Ireland performs better (Table 1). Austria has a CMU higher than the EU average, with Denmark and Ireland lower. Othe indicators reflect each countries demographics and relative maturity with respect to waste management. Eco-innovation is a qualitive or indirect metric which suggests Ireland has low eco-innovation rates. This may not be reflective of the actual situation.
Table 1 – Circular Economy Scorecard – Austria, Denmark, Ireland
Indicator Austria Denmark Ireland
Circular Material Use Rate (%) 12 8 1.8
Municipal Waste per Capita (kg/person) 588 754 555
Recycling Rate of Municipal Waste (%) 58 46 40.4
Packaging Recycling (%) 65 65 62.5
Eco-Innovation Score (proxy: patents/jobs/etc.) Moderate-High Moderate Low
Regarding the broader macro indicator, CMU, The Irish Whole of Government Circular Economy Strategy 2022-2023 aims to elevate Ireland's CMU rate above the EU average by 2030. Given where Ireland is at present, this seems unattainable. It may be better to focus on other metrics or to develop a broad suite of metrics based on the European Commission framework than to focus too much on CMU.
In 2024, the Circle Economy Foundation published Ireland’s Circularity Gap Report (6). It looked at Ireland’s technical cycling rate (TCR) - the technical term for the secondary material input rate and the Circularity Metric. The TCR for Ireland is calculated at 2.7%, meaning that over 97% of the materials flowing through the Irish economy come from virgin sources. This is considerably lower than the technical cycling rate for the global economy, measured at 7.2% in 2023.
According to the EEA (op.cit) the lower rate can, in part, be attributed to Ireland’s very high material footprint: its economy consumes 111 million tonnes of virgin materials - metal ores, non-metallic minerals, biomass and fossil fuels - each year, equivalent to 22 tonnes per capita— well above the EU average of 17 tonnes per capita.
The current lack of a comprehensive monitoring framework for the circular economy in Ireland limits the EPA's ability to track and report progress effectively. Many indicators related to circularity at present are linked to existing EU waste management objectives and targets. There is a need therefore to double down on developing a comprehensive set of circular economy metrics in line with the European Commission monitoring framework for the Circular Economy. This is currently challenging. The European Environmental Agency (op.cit) notes many EU level indicators lack corresponding Irish data, complicating a detailed analysis of circular economy activities. It also noted the absence of data on reuse, repair, and remanufacturing activities indicates a need for improved data collection practices. Ireland's reliance on export markets for recycling poses challenges, especially concerning future EU recycling targets.
Ireland's journey toward a circular economy has commenced. While the country has made significant strides at the policy level through strategic frameworks, enacted legislation and dedicated programmes as well as community engagement, there is a need for a more rigorous approach. The OECD observed this in their 2022 report (7) on the Circular Economy in Ireland noting the need for “a shift from a narrow focus on waste to a wider lens of resource management, utilizing the circular economy as a driver of economic growth and job creation”.
The current situation, therefore, is sub-optimal. A profusion of circular economy related strategies, plans, documents and programmes. Equally one might ask who is in charge? The Department of Environment and Climate Change (DECC)? the EPA? both? Clarity around leadership and governance would help.
To enhance its journey toward a circular economy on an operational level, Ireland must focus on the following:
Developing cohesive national circular economy strategy in accordance with Part 2 of the Circular Economy is a prerequisite step to provide a clear roadmap for government, businesses, and civil society. This strategy should set ambitious targets and prioritize actions that drive circular practices, secure critical raw materials, build technical capacity and develop and deepen Ireland´s own resource recycling infrastructure.
The Department of the Environment and Climate Change in particular, needs to initiate the statutory process for the development of a more coherent Circular economy Strategy in accordance with the provisions set out in the Circular Economy Act 2022. The process associated with the development of the strategy will address key data and materials, data collection and monitoring frameworks and the setting of KPIs to enable transparent reporting of progress.
Establishing robust circular economy metrics, monitoring frameworks and measurable policy targets based on the nascent EU Circular Economy monitoring framework, will enable Ireland to gather, analyse and report data effectively, facilitating informed policymaking and policy adjustments to achieve set goals and targets.
Supporting innovative business models that prioritise sustainability and resource husbandry is crucial to embed circular economy thinking and practice. This includes promoting and supporting the “Right to Repair” and encouraging the development of sustainable products with low environmental, resource and GHG footprints. Ireland also needs to build out its end of life, recycling and materials processing infrastructure to build local capacity and resource security for its industrial value chains.
Ireland is an island geographically, but it is part of the EU. From a circular economy perspective, it is important for Ireland to see circularity not just in terms of narrow national or geographical terms. The upcoming EU Circular Economy Act will clarify the purpose and scope of the EU´s Circular Economy policy. An all-EU approach to product, materials and resources management is expected to be a key goal. The Circular Economy will be vital for the EU´s geo-political security. Ireland can play its part in contributing to this collective goal.
Footnotes & References:
[2] The original strategy indicated that it would be updated periodically – every 18 months to two years which suggests an update in 2025.
[3] At the time of writing, no Circular Economy Strategy in the meaning of Part 2, para. 7 of the Act has been promulgated.
[6] https://circularity-gap.world/ireland?mc_cid=721f7dde31&mc_eid=6f25251e8c
[7] https://www.oecd.org/en/publications/the-circular-economy-in-ireland_7d25e0bb-en.html
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