Policy Support to the European Commission on EU Circular Economy Legislation and Developing Countries

The EU SWITCH to Green Facility is an initiative of the European Commission managed by the Directorate-General for International Partnerships (DG INTPA, unit F2), serving as a platform for enhancing the coherence, coordination, and effectiveness of EU international partnerships supporting the transition to greener and more circular economies in partner countries. Working with the Facility, Tulip provided targeted technical advice and policy support to inform the European Commission’s approach to circular economy and environmental legislation, bringing specialised expertise on how these evolving regulatory frameworks affect least developed countries (LDCs) and developing economies, particularly micro, small, and medium-sized enterprises (MSMEs).

The EU’s climate and circular economy agenda has advanced rapidly in recent years, with a wave of legislative and regulatory initiatives reshaping product markets, supply chains, and industrial processes. While these measures are designed to drive sustainability within the European single market, they inevitably carry significant implications for the EU’s trading partners, particularly for smaller enterprises in developing countries that supply European markets but often lack the resources, information, and technical capacity to adapt to rapidly changing requirements. Understanding and addressing these extraterritorial effects was at the heart of Tulip’s advisory work under this project.

A central contribution of the engagement was providing the Commission with expert technical input on public consultation processes for major EU legislative initiatives. Tulip advised the SWITCH to Green Facility on how these processes could be made more responsive to the concerns of third-country stakeholders, and on how the insights gathered could be more effectively integrated into the EU’s regulatory design. Tulip also delivered detailed technical analysis of specific EU legislative instruments, examining how they could better take into account the situation of MSMEs in developing countries. This included in-depth advisory work on Extended Producer Responsibility (EPR) schemes — being progressively introduced across EU product categories and imposing new obligations on producers and importers regarding end-of-life product management — as well as the EU Ecodesign for Sustainable Products Regulation (ESPR) and upcoming product-specific standards.

By combining legal expertise on EU regulatory measures with a strong understanding of the development dimension, Tulip identified concrete ways in which the European Commission could ensure that the design and implementation of EU climate and circular economy legislation can support, rather than undermine, the economic prospects of partner countries and the MSMEs at the heart of their economies.