Policy Briefs (Final)

This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement N° 101036838. D7.13 – Policy Briefs (final) February 2025 Authors: Serra-Castells, Carlos; Gallego-Valadés, Alfonso; Garcés-Ferrer, Jorge. Ref. Ares(2025)1627076 - 28/02/2025 A2C – Deliverable D7.13 v1.0 Page 2 І61 Technical references Project Acronym Agro2Circular Project Title TERRITORIAL CIRCULAR SYSTEMIC SOLUTION FOR THE UPCYCLING OF RESIDUES FROM THE AGRIFOOD SECTOR Project Coordinator Fuensanta Monzó CETEC [email protected] Project Duration October 2021 – March 2024 (36 months) Deliverable No. D7.13 D60 Dissemination level* PU Work Package WP7A2C systemic solution adoption, replication and scalability Task Task 7.7 - Validation of the A2C multidimensional model through cross-fertilization with other clusters Lead beneficiary 22 - UVEG Contributing beneficiary/ies Due date of deliverable 28th February 2025 Actual submission date 28th February 2025 * PU = Public PP = Restricted to other programme participants (including the Commission Services) RE = Restricted to a group specified by the consortium (including the Commission Services) CO = Confidential, only for members of the consortium (including the Commission Services) A2C – Deliverable D7.13 v1.0 Page 3 І61 Document history V Date Comments v0.1 6/02/2025 First draft of document v0.2 24/02/2025 Revised version based on the comments of José Carpintero (EURADA) v1.0 28/02/2025 First final version, approved by the WP leader and the project coordinator, (will be) submitted to EC. v1.1 First draft based upon first final version v2.0 Second final version, approved by the WP leader and the project coordinator, (will be) submitted to EC. Document Distribution Log Version Date Distributed to v0.1 06/02/2025 Facundo Pérez Rubio (CARM), José Carpintero Molina (EURADA) v0.2 28/02/2025 Fuensanta Monzó (CETEC) Verification and approval Name Date Verification Final Draft by WP leader Alba Matamoros (KVELOCE) 28/02/2025 Approval Final Deliverable by coordinator Fuensanta Monzó (CETEC) 28/02/2025 A2C – Deliverable D7.13 v1.0 Page 4 І61 Disclaimer and acknowledgement This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No 101036838 Disclaimer This document reflects only the views of the author(s) the European Research Executive Agency (REA) is not responsible for any use that may be made of the information it contains. Whilst efforts have been made to ensure the accuracy and completeness of this document, the A2C consortium shall not be liable for any errors or omissions, however caused. A2C – Deliverable D7.13 v1.0 Page 5 І61 Table of contents List of abbreviations 7 Glossary ............................................................................................ 8 1 Executive summary ................................................................... 10 2 Introduction ................................................................................ 11 2.1 To whom is this report addressed? ...................................................................... 11 2.2 Policy brief’s structure .......................................................................................... 12 3 Methodology .............................................................................. 14 4 The Agro2Circular Model ........................................................... 16 4.1 Purpose and application of the A2C Model ......................................................... 16 4.2 Dimensions ............................................................................................................. 17 5 Policy briefs ............................................................................... 23 5.1 Promoting end-consumer acceptance of upcycled products ............................ 23 5.2 Reduced VAT .......................................................................................................... 27 5.3 Engage end-consumers in upcycling schemes ................................................... 29 5.4 Governance: Circular Public Procurement .......................................................... 33 Current State of Green Public Procurement in the Agri-Food Sector ......................... 35 5.5 Traceability for industrial symbiosis .................................................................... 42 Traceability in the Agri-Food Sector: A Review of Current Evidence .......................... 42 Workshop Report: Traceability in Circular Economy and Agricultural Films ............... 44 5.6 Regulation of by-products and End of Waste status .......................................... 47 The Evolving Regulatory Landscape for Agri-Food By-Products and End-of-Waste Criteria ........................................................................................................................ 47 End-of-Waste Criteria and Their Impact on Agri-Food By-Products ........................... 49 Stakeholder Views on End-of-Waste, By-Products, and Secondary Markets in Spain ................................................................................................................................... 51 A2C – Deliverable D7.13 v1.0 Page 6 І61 Policy Recommendations for Enhancing End-of-Waste, By-Product Recognition, and Secondary Markets ..................................................................................................... 52 6 Conclusions ............................................................................... 54 7 Bibliography ............................................................................... 55 List of Figures Figure 1 - Agro2Circular Model depiction ........................................................................... 16 Figure 2 - Upcycled Certified™ mark ................................................................................. 23 Figure 3 - Food Waste by sector of activities, 2022 ........................................................... 30 A2C – Deliverable D7.13 v1.0 Page 7 І61 List of abbreviations • A2C – Agro2Circular • CE – Circular Economy • CEAP – Circular Economy Action Plan • DPPs – Digital Product Passports • EC – European Commission • EoW – End-of-Waste • EU – European Union • GPP – Green Public Procurement • GPFP – Green Public Food Procurement • IED – Industrial Emissions Directive • IoT – Internet of Things • LCC – Life-Cycle Costing • MSWI – Municipal Solid Waste Incinerator • NFC – Near Field Communication • PP – Restricted to other programme participants (including the Commission Services) • PU – Public • RE – Restricted to a group specified by the consortium (including the Commission Services) • RFID – Radio Frequency Identification • R&D – Research and Development • SROI – Social Return on Investment • SMEs – Small and Medium-sized Enterprises • ToC – Theory of Change • UFA – Upcycled Foods Association • VAT – Value-Added Tax • VASP – Value-Added Surplus Products • WP – Work Package A2C – Deliverable D7.13 v1.0 Page 8 І61 Glossary • By-Product: A material generated during production that is not the primary product but can be reused without requiring additional treatment to prevent it from becoming waste. • Certification of Upcycled Products: Certification systems that ensure products are made from recycled or recovered materials, providing trust to consumers and businesses. • Circular Economy (CE): A production and consumption model that aims to minimise waste and maximise the reuse, recycling, and regeneration of materials within a closed system to reduce environmental impact. • Circular Public Procurement (CPP): A specific approach within Green Public Procurement (GPP) that includes circularity criteria in public procurement, promoting the purchase of recycled, reusable, or upcycled products. • Consumer Acceptance of Upcycled Products: The degree to which consumers are willing to buy products made from recycled or upcycled materials, influenced by factors such as quality perception, trust in certification, and marketing strategies. • Eco-labels: Environmental labels that certify compliance with ecological standards in products or services, helping consumers make informed choices. • End-of-Waste (EoW): A regulatory concept that allows certain waste materials to be reclassified as products when they meet specific criteria for reuse, safety, and market demand. • Food Waste Prevention: Strategies and policies aimed at reducing food waste generation across the entire supply chain, from production to consumption. • Green Public Procurement (GPP): A public procurement strategy that integrates environmental criteria into the acquisition of goods and services, encouraging sustainable products and processes. • Industrial Symbiosis: A model of collaboration between industries where the waste or by-products of one company are used as inputs by another, promoting resource efficiency and waste reduction. A2C – Deliverable D7.13 v1.0 Page 9 І61 • Multi-Level Governance for Circular Economy: A governance approach that involves multiple administrative levels (local, regional, national, and European) in implementing circular economy strategies. • Reduced VAT for Circular Products: A policy proposal to lower VAT on certified upcycled products to encourage their consumption and support the adoption of circular economy models. • Traceability in Circular Economy: Tools and mechanisms that allow tracking the origin, transformation, and final destination of materials and products within circular systems to ensure sustainability and safety. • Upcycling: The process of enhancing the value of waste or by-products by transforming them into higher-value products, preventing them from becoming waste. A2C – Deliverable D7.13 v1.0 Page 16 І61 4 The Agro2Circular Model Given that these policy briefs are intended to promote the adoption and replication of the A2C model, it is essential to provide a comprehensive description of its structure, purpose, and key dimensions. 4.1 Purpose and application of the A2C Model The A2C multidimensional model (see Figure 1) provides a structured framework to guide regions and cities in adopting circular economy (CE) practices, particularly within the agrifood sector. Designed to assess and strengthen readiness for CE, the model organizes essential factors into eight core dimensions: environmental, socioeconomic, governance, policy and regulatory, funding and finance, technology and R&D, standardisation, and capacity building. The model’s practical application lies in its self-assessment tool, which allows public authorities and stakeholders to evaluate existing capacities, identify areas for improvement, and formulate actionable Circular Economy Action Plans (CEAPs). Beyond its immediate focus on local and regional entities, the model also serves as a reference for researchers, clusters, and organizations interested in advancing sustainable practices through circular principles. The A2C model was developed through a multistep process that combined theoretical foundations with stakeholder inputs. Beginning with a Theory of Change (ToC) review, the team identified the project’s goals and mapped the key outputs needed to drive circularity within the agrifood sector. An initial diagnosis of CE challenges specific to the Region of Murcia helped to define relevant factors for each Figure 1 - Agro2Circular Model depiction A2C – Deliverable D7.13 v1.0 Page 17 І61 dimension, which were then validated through stakeholder consultations, surveys, and workshops. Subsequent workshops with A2C project partners and broader European panels enabled cross-regional validation and further refinement. Inputs from existing assessment tools and other European CE initiatives contributed to the model’s robustness, ensuring its relevance across diverse territorial contexts. 4.2 Dimensions Environmental dimension. The Environmental Dimension focuses on evaluating how a region or city manages resources and environmental impacts in transitioning to a circular economy (CE). Key factors in this dimension include: 1. Efficient Waste and Water Management: Assessing the presence of infrastructure and policies that enhance the sustainable use of resources, minimizing waste generation and optimizing water management. 2. Waste Valorisation Channels: Evaluating established systems that allow for the transformation of waste materials into useful products or raw materials, closing loops within the local value chain. 3. Territorial Exploitation Level: Ensuring that territorial resources are used in a way that does not exceed environmental limits, with managed resource extraction, material transport, and waste circulation. 4. Land and Biodiversity Degradation: Considering how well the region mitigates impacts of the linear economy on ecosystems and biodiversity by reducing resource consumption and pollution that degrade habitats. 5. Climate Change Mitigation and Adaptation: Measuring efforts to assess and reduce greenhouse gas (GHG) emissions across value chains, addressing both mitigation and adaptation needs to achieve sustainability goals. Socioeconomic dimension. The Socioeconomic Dimension evaluates the intersection of economic resilience, social inclusivity, and quality of life in supporting a transition to a circular economy. The factors in this dimension are: A2C – Deliverable D7.13 v1.0 Page 18 І61 1. Business Reinvention Capacity: The ability of local businesses to adapt and innovate sustainably, fostering economic, social, and environmental benefits aligned with CE principles. 2. Strength of the Production Ecosystem: The robustness and resilience of the region's economic structure, driven by diverse industries that sustain stability, foster innovation, and adapt to changes. 3. Professional and Technical Skills: The readiness of the regional workforce to support the shift from a linear to a circular economy, with an emphasis on relevant skills and expertise. 4. Trust in the Production System: The degree of confidence that stakeholders— including economic actors, communities, and institutions—have in the efficiency, fairness, and sustainability of the local economy. 5. Regional/Local Cultural Aspects: The influence of local beliefs, values, and behaviours on sustainable consumption, production, and waste practices, reflecting community attitudes toward CE. 6. CE Citizenship Participation: The active involvement of citizens in CE initiatives and campaigns, reinforcing the transition through widespread public engagement. Governance Dimension. The Governance Dimension examines the effectiveness of governance structures and stakeholder collaboration in enabling a circular economy transition. This dimension includes the following factors: 1. Promotion of CE Culture and Trust: Initiatives by local governments to foster a cultural shift toward sustainable practices, building confidence among stakeholders in the transition to CE. 2. Dialogue Promotion in Decision-Making: Encouraging collaboration across sectors (quintuple helix model) and including private actors in the policy-making process to create more inclusive CE strategies. A2C – Deliverable D7.13 v1.0 Page 19 І61 3. Effective Multi-Level Governance: Ensuring coordination and synergy across various levels of government to avoid working in silos, facilitating cohesive policy actions for CE. 4. Adoption of a Functional Approach: Promoting interconnectivity between urban and rural areas, fostering community-based initiatives, and identifying opportunities for industrial and urban symbiosis to enhance resource efficiency. 5. Holistic Regional Systemic Approach: Implementing long-term strategies that integrate circular models within government, aligned with CE objectives through clear goals and sustained political commitment. Policy & Regulatory Dimension. The Policy & Regulatory Dimension addresses the legislative and regulatory framework needed to promote a circular economy by ensuring that policies facilitate sustainable practices and efficient resource use. Key factors in this dimension are: 1. Circular Economy Action Plan (CEAP): The existence of a CEAP that provides a strategic roadmap, with defined targets and actions, guiding the region or city toward circularity. 2. Adapted Regulatory Instruments: Policies, laws, and regulations at the regional or local level that are tailored to support and accelerate the shift toward circular economic practices. 3. Secondary Raw Materials Market: The establishment of a regulated market that certifies recycled materials, ensuring quality, safety, and compliance with EU standards, promoting the use of secondary materials. 4. Effective Legislation Implementation: The ability of regional or local authorities to not only implement but enforce legislation effectively, avoiding excessive bureaucracy and ensuring the intended environmental and economic outcomes. Funding & Financial Dimension. The Funding & Financial Dimension evaluates the availability and effectiveness of financial resources and incentives that support circular economy (CE) initiatives at the regional and local levels. This dimension includes the following factors: A2C – Deliverable D7.13 v1.0 Page 20 І61 1. Dedicated Financial Lines for CE Projects: The presence of specific funding channels or instruments established by governments, financial institutions, or other entities to support projects advancing CE principles. 2. Economic Instruments for Behavioural Change: Financial mechanisms—such as tax incentives, environmental taxes, or differentiated tariffs—that encourage sustainable behaviours and discourage unsustainable practices within the community. 3. Transparent Disclosure and Coordination of Funding Opportunities: Clear and accessible information on available financial resources, along with strategic alignment of funding opportunities, ensuring that stakeholders can effectively access and leverage funding for CE initiatives. This dimension underscores the necessity of financial backing and incentives to advance CE projects. By establishing dedicated funds, promoting behaviour-aligned incentives, and ensuring transparency, regions and cities can drive resource-efficient practices that support the overall transition to a circular economy. Technology, Research & Innovation Dimension. The Technology, Research & Innovation Dimension assesses the scientific and technological capabilities required to support circular economy practices, focusing on innovation, infrastructure, and collaboration. The key factors are: 1. Availability of Valorisation Technologies: The presence of technologies and infrastructure for the valorisation of waste and byproducts, such as reuse and upcycling processes that enable efficient resource recovery. 2. Public Investment in R&D: The existence of public funding mechanisms dedicated to research and development in CE, fostering innovation at the regional or local level. 3. Research-Industry Connection: Strong linkages between research institutions and industry, which drive practical applications of CE innovations and enhance regional competitiveness. A2C – Deliverable D7.13 v1.0 Page 21 І61 4. Participation of SMEs in R&D: Engagement of small and medium-sized enterprises in research and development activities related to CE, promoting diverse and innovative solutions. 5. Product and Process Traceability: Implementation of tools that improve the traceability of products and processes, ensuring transparency and accountability within the circular economy. 6. Local R&D Funding Availability: Access to regional or local resources for R&D that are mobilized specifically to support CE initiatives. Standardisation Dimension. The Standardisation Dimension evaluates the extent to which a region or city adopts and implements standardized practices and certifications aligned with European Union standards to advance a circular economy. This dimension includes the following factors: 1. Creation of EU-Aligned Standards and Norms: Active support for developing and adopting EU-wide standards for products made from secondary materials, ensuring quality, safety, and environmental compliance within the CE. 2. Digital Tools for Product Traceability: Adoption and promotion of standardized digital tools that improve the traceability of products and processes, making it easier to track materials and assess their sustainability. This dimension highlights the importance of harmonized standards and traceability in supporting CE initiatives. By aligning with EU standards, regions foster consistency, reduce risks like greenwashing, and build public trust, while digital traceability tools ensure accountability and streamline CE operations across the value chain. Capacity Building Dimension. The Capacity Building Dimension assesses a region’s or city’s ability to develop the necessary skills, knowledge, and workforce alignment to support circular economy initiatives. This dimension includes the following factors: 1. Education System’s Capacity for CE: The extent to which the regional or local education system equips individuals with skills, knowledge, and technical expertise essential for addressing CE challenges. A2C – Deliverable D7.13 v1.0 Page 22 І61 2. Alignment of Labour Supply and Demand in CE Sectors: Ensuring that the local workforce supply meets the specific needs of CE industries, promoting a balanced match that supports sustainable economic growth. A2C – Deliverable D7.13 v1.0 Page 23 І61 5 Policy briefs 5.1 Promoting end-consumer acceptance of upcycled products To date, the only known standard for the standardisation of upcycled food products is that of the Upcycled Foods Association (2022), which defines upcycled food as products using ingredients that otherwise would not have gone to human consumption, are procured and produced using verifiable supply chains, and have a positive impact on the environment. The standard applies to operators involved in the cultivation, production, manufacturing, processing, preparation, and marketing of non-durable consumer goods, including food, beverages, dietary supplements, pet food, cosmetics, personal care items, household cleaning products, and the inputs used to produce them. The Standard outlines three distinct designations: (1) Upcycled Ingredient(s) (UI), (2) Product Containing Upcycled Ingredient(s) (PUI), and (3) Minimal Content PUI(s). UIs are inputs originally intended for human consumption but otherwise wasted, requiring a composition of at least 95% upcycled inputs and up to 5% additives. PUIs must include at least 10% upcycled inputs or meet diverted tonnage thresholds. Minimal Content PUIs meet all standard requirements but fall below minimum thresholds for upcycled content by weight or tonnage. Certified products may display the Upcycled Certified™ mark (Figure 2) on packaging, with PUIs required to list upcycled ingredients, while Minimal Content PUIs may display the relevant mark on the back of the packaging. Upcycled food products therefore contain ingredients from waste, damaged food products or by-products from different stages of the supply chain, which partially reduces the allocative inefficiency caused by the gap between production and actual human consumption. It is an emerging category of environmentally friendly products, whose main purpose lies in the reduction of total food waste. However, a sustainable product also needs to be accepted by the end consumer. As stated by Moshtaghian et al. (2021), the current definitions describe upcycled foods from the perspectives of researchers (…) and other stakeholders (…), (…) but the general public may have difficulty understanding these definitions. Figure 2 - Upcycled Certified™ mark A2C – Deliverable D7.13 v1.0 Page 24 І61 Upcycled foods are a novel product category and need to find a stable niche market. Bhatt et al. (2018) suggest that there is a strong potential for such foods to command a position as a new category of foods that is distinct from both conventional as well as organic foods. This highlight is drawn from a set of three studies based on online surveys that directly ask participants about their perceptions of different food categories, including upcycled products. The first study found that participants perceived upcycled food as more beneficial to the environment than conventional food, but less beneficial compared to organic food. Also, upcycled foods were perceived to be significantly less frequent in respondents' consumption than conventional foods, but similar to organic foods. Finally, upcycled foods were perceived to be significantly more organic than conventional foods, with no differences compared to organic foods. The second study highlights that "Upcycled" was the most preferred label for food value-added surplus products (VASP), out of a total of 9 different labels. In the third study participants perceived the category of food labelled "upcycled" as significantly higher in terms of social benefits than conventional food. However, they did not perceive the social benefits to be different from those of organic food. In terms of self-benefits, upcycled foods were perceived to provide significantly higher selfbenefits than conventional foods, but not organic foods. In general, the three studies taken together reflect that there is a potential consumer-perceived differentiation between upcycled products and other food product categories. Despite their potential, there still seems to be a widespread lack of knowledge among consumers about what upcycled products are. Grasso & Asioli (2020) found from online survey data that most UK consumers surveyed (85%) had not heard the term "upcycled" in relation to a food ingredient prior to this study. These results contrast with those provided by Coderoni & Perito (2020) when surveying a sample of Italian consumers about their knowledge of foods made from waste or by-products, finding that 61% of respondents reported having heard about Waste-To-Value food and knowing what it means. Other studies from different countries report highly variable findings (McCarthy et al., 2020, Goodman-Smith et al., 2021, Yilmaz & Kahveci, 2022). It is difficult to know whether these differences are due to true cross-sectional variability between countries or to a lack of standardisation in study designs. According to Yilmaz & Kahveci (2022), none of the sociodemographic variables were found to significantly affect participants’ familiarity with upcycling. Lifestyle variables, on the other hand, had an impact on the sample's awareness A2C – Deliverable D7.13 v1.0 Page 25 І61 of the concept, including frequency of cooking at home, having a special diet, and frequency of recycling at home. Is acceptance stable across different personal and contextual consumer characteristics? Based on survey results, Zhang et al. (2021) find that Gen Z, Gen Y, and Baby Boomers have higher intentions to purchase upcycled foods while Gen X shows lower intentions to purchase because of quality concerns. Specifically, Baby Boomers indicated the highest intentions to purchase upcycled foods and Gen X showed the lowest. These results are in partial contrast to those obtained by Aschemann-Witzel et al. (2022), who find that younger respondents (in the age bracket 18–34) show a more favourable attitude towards upcycled food compared to older respondents, although these differences may be partly due to the way in which different studies define generational boundaries. How can industry improve customer willingness to consume upcycled food products? In a set of two studies, Bhatt et al. (2021) used a three-item scale administered to over 200 participants to assess the willingness to purchase and perceived quality of two different upcycled food products. The results suggest that the presence of an appropriate logo on product labelling can not only improve the perceived quality of the product for the consumer, but subsequently the willingness to purchase it. In the food industry, logos are used as indicators that a product meets certain characteristics and have a varying degree of reliability depending on the organisation issuing them (see Morrone & Schena, 2018). Overall, logos have consistently been shown to improve consumer acceptance through different mediators (Rihn et al., 2019). The study by Bhatt et al. (2021) illustrates another additional reason for standardisation in the development and production of upcycled food products, as the presence of a logo on the labelling is a driver of consumer decision-making. Evidence suggests that standardisation and labelling have the potential to positively influence consumer willingness to purchase upcycled products. However, it is crucial to acknowledge certain limitations in the existing body of knowledge. Many studies exploring this behaviour have been conducted in controlled environments, where participants were not subject to the habitual and automatic decision-making dynamics of everyday life. Moreover, participants were often provided with detailed descriptions of product categories, an advantage that real-world consumers may not consistently seek when making purchasing decisions. Given these limitations, it is essential to complement standardisation efforts with awareness-raising campaigns to enhance consumer familiarity with and A2C – Deliverable D7.13 v1.0 Page 32 І61 not explicitly address. Furthermore, both studies are based on a choice experiment design with no real-world implications. Unfortunately, we have not been able to identify other similar studies or real-world intervention experiments, whether randomised or quasi-experimental. While it is plausible that the results can be translated to real-world scenarios in the short term, the mediumand long-term implications for sustaining participation are unknown, although different hypotheses can be put forward on the basis of evidence on comparable cases. The collection of discarded fruit and vegetables from the Alhama de Murcia market, conducted as part of the project, yielded insufficient quantities for industrial-scale production of recycled products. This fact suggests that isolated actions are inadequate, and that collection networks would need to be established to achieve industrial-scale operations. Policies should not only facilitate the reclassification of waste as by-products or the declaration of end-of-waste status but also enable collection and exchange networks to extend beyond the primary and manufacturing sectors, achieving greater cross-sectoral reach. • Incentivise consumer participation. Develop programmes through local retailers where consumers can exchange discarded food for rewards like discount vouchers or loyalty points. Focus on low-effort activities, such as occasional drop-offs or home collection, to maximise engagement. • Establish local collection and exchange systems involving retailers, industry, municipal services and waste management operators to ensure sufficient volumes of discarded food for recycling on an industrial scale. • Raise awareness and leverage social norms. Run campaigns highlighting the environmental and social benefits of participation, emphasising community-driven behaviours, especially in urban areas where food waste is seen as a major issue. • Offer convenient participation models. Design simple and flexible options, like home collection or infrequent delivery schedules, to lower barriers to entry and encourage ongoing consumer involvement. • Engage retailers as key partners by providing them with tax benefits for participating in the programme. A2C – Deliverable D7.13 v1.0 Page 33 І61 • Support regulatory alignment. Simplify regulations to enable the classification of discarded food as by-products or non-waste materials and promote cross-sector collaboration to expand circular practices. 5.4 Governance: Circular Public Procurement Public procurement plays a crucial role in shaping sustainable economic models, particularly in the transition towards a circular economy (CE). Given that public authorities within the European Union allocate approximately 14% of the EU's GDP to procurement, their purchasing decisions can drive significant change towards more sustainable production and consumption patterns (Sapir et al., 2022). Circular public procurement (CPP) is an advanced approach to procurement that incorporates circular economy principles throughout the entire lifecycle of goods, services, and infrastructure projects. Unlike conventional procurement methods, which primarily focus on cost-efficiency and immediate value, CPP prioritises durability, reparability, reusability, and resource efficiency in the selection and management of public contracts (Nilsson Lewis et al., 2023). By doing so, it helps to minimise waste generation, reduce environmental impact, and extend the lifespan of products and materials. This strategic approach to public procurement goes beyond simply choosing "green" products—it involves rethinking procurement criteria to ensure that purchased goods and services support circularity. This means considering design, production processes, maintenance, and end-of-life disposal, ensuring that all aspects align with circular economy goals. Additionally, CPP can drive innovation in product design and supply chains, encouraging the market to develop more circular solutions in response to public sector demand. At the EU level, public procurement is regulated by Directive 2014/24/EU, which sets out harmonised rules for tenders exceeding specific financial thresholds (European Commission, 2014). While this directive must be transposed into national laws, it provides a common framework that promotes transparency, competition, and environmental considerations in procurement processes. However, its application remains limited to tenders that surpass these thresholds, meaning that for lower-value contracts, national regulations prevail, albeit within the general principles established by EU law (European Commission, 2023). A2C – Deliverable D7.13 v1.0 Page 34 І61 Despite the growing emphasis on green public procurement, its application to agrifood products remains relatively underdeveloped (Nilsson Lewis et al., 2023). Public institutions—including schools, hospitals, universities, and military bases—are major purchasers of food products, presenting a significant opportunity to promote sustainable food systems. Integrating circular principles into food procurement can reduce food waste, enhance the valorisation of biowaste, and support the development of bio-based products, such as compost and biogas. Ensuring that public spending is aligned with sustainability goals will not only help meet climate objectives but also enhance social and economic resilience within local food systems. Circular Public Procurement in the agrifood sector – what’s the evidence? The available evidence suggests that Green Public Food Procurement (GPFP) can be an effective mechanism for promoting sustainable agrifood systems. However, its success largely depends on how procurement models are designed and implemented. While GPFP is often assumed to contribute to environmental goals, studies indicate that its environmental impact is not always as significant as expected. A key element influencing the effectiveness of GPFP is the presence of short food supply chains and territorially embedded institutions, which have been found to improve the economic sustainability of public food procurement while also ensuring better health outcomes. The case studies from Spain analysed by Gómez-Ramos and Rico Gonzalez (2023) show that GPFP schemes that prioritise local production and distribution tend to enhance economic viability and food sovereignty. However, the environmental dimension often remains underdeveloped, as the integration of renewable energy sources and other circular economy principles is not always a priority at the local level. The study suggests that strong social capital and territorial cohesion are crucial for ensuring that GPFP principles of social and labour justice are effectively upheld. From a business model perspective, Lioutas et al. (2023) highlight that while GPFP schemes can generate economic and social value, their capacity to create environmental value is more limited. Their study, which focuses on France, finds that despite the intention to implement environmentally responsible procurement practices, the environmental efficiency of agrifood production remains a major constraint. The environmental benefits of GPFP tend to be compromised by inefficiencies at the production stage, as well as logistical challenges such as transportation-related emissions and food waste management. This aligns with A2C – Deliverable D7.13 v1.0 Page 35 І61 previous research indicating that while GPFP can promote responsible consumption patterns, its actual contribution to emissions reduction and resource efficiency varies depending on the procurement model used. The effectiveness of GPFP schemes depends on several factors, including policy frameworks, procurement design, and stakeholder involvement. The Spanish cases show that procurement specifications that explicitly include environmental and social criteria can lead to positive outcomes. However, there is a risk that without proper monitoring mechanisms, sustainability claims may not translate into tangible impacts. Similarly, the study from France underscores that governance mechanisms in GPFP schemes tend to be well-defined and transparent, but may not always be flexible enough to accommodate the specific needs of different stakeholders. The context in which GPFP is implemented also plays a significant role in determining its success. In regions where there is already strong institutional support for sustainable food policies, such as the Basque Country and Catalonia, GPFP initiatives are more likely to be effective. However, in cases where green procurement is merely an administrative requirement rather than an actively managed strategy, its potential benefits can be diluted. Moreover, while GPFP can promote the inclusion of small-scale farmers and local producers, there is also the risk of excluding non-certified farmers who may not meet the specific sustainability criteria required by public contracts. Overall, the evidence suggests that while GPFP holds promise as a tool for promoting sustainable agrifood systems, its actual impact depends on the extent to which it is integrated into broader food policy strategies. Ensuring that procurement processes are not only environmentally sound but also economically viable and socially inclusive requires a holistic approach that goes beyond simply applying green criteria to public contracts. The integration of circular economy principles into public procurement remains a key challenge, particularly in terms of improving production efficiency, reducing supply chain emissions, and promoting systemic changes in food governance. Current State of Green Public Procurement in the Agri-Food Sector Public authorities in Europe have access to several tools and frameworks to integrate sustainability criteria into public food procurement and catering services. Among the most relevant resources is the Green Public Procurement (GPP) Toolkit, developed by the A2C – Deliverable D7.13 v1.0 Page 36 І61 European Commission to provide guidance on how to incorporate environmental considerations into procurement processes. The toolkit consists of various modules, including a specific section on food, catering services, and vending machines, which outlines criteria for sustainable food procurement. The EU GPP criteria focus on key environmental impacts throughout the food lifecycle, such as energy and water consumption in production, land use changes, biodiversity loss, pesticide and fertilizer use, and waste generation. The criteria are structured into core criteria, which allow for relatively easy application, and comprehensive criteria, which set more ambitious environmental performance requirements. For food procurement, specific guidelines are provided on organic products, sustainable fish and aquaculture sourcing, animal welfare, and responsible use of vegetable fats. The procurement of food services also falls under these criteria, ensuring that catering services apply sustainability principles in menu planning, waste management, transportation, and energy use. Provisions include a preference for organic and sustainable food, measures to reduce food waste, and requirements for the use of eco-labelled cleaning products and recyclable packaging. Additionally, criteria for life-cycle costing (LCC) help contracting authorities assess the long-term value of sustainable procurement, considering factors such as operational costs, energy efficiency, and waste disposal. Despite the availability of these frameworks, there is no specific reference to upcycled products within the current EU GPP guidelines. While sustainability criteria address organic food, fair trade products, and reduced food waste, upcycled food, nutraceuticals, and cosmetics remain largely absent from official procurement standards. This gap suggests that public authorities interested in promoting the use of upcycled products must either adapt existing procurement criteria or develop new ones. The Upcycled Foods Association (UFA) has developed a certification standard for upcycled food products, providing definitions and labelling requirements to increase consumer acceptance. The certification distinguishes between different levels of upcycled content and allows certified products to display the Upcycled Certified™ mark. However, this standard is currently not integrated into EU procurement frameworks, meaning public buyers lack clear guidance on how to prioritise upcycled products in tenders. Several challenges related to circular supplier certification were identified in dedicated stakeholder workshops, including the need for clear certification protocols, an impartial A2C – Deliverable D7.13 v1.0 Page 37 І61 certifying body, and better accessibility for SMEs. Certification costs and administrative barriers often discourage small businesses from seeking accreditation, limiting their ability to participate in public procurement. Additionally, dynamic purchasing systems and requirements for suppliers to hold environmental management certifications have been discussed as potential ways to promote sustainability in public food procurement. Public institutions such as schools and hospitals could play a leading role in integrating upcycled products into their food procurement strategies. However, bureaucratic complexity and budget constraints have been identified as key obstacles. Effective monitoring and impact assessment systems are needed to track the outcomes of green public procurement policies and provide evidence of their economic and environmental benefits. Participants in stakeholder discussions also pointed to successful local initiatives, such as the INFO certification scheme in Murcia, which could serve as a model for regional or national adoption. While current procurement frameworks provide a strong foundation for sustainable purchasing, they do not yet fully account for the potential of upcycled products. Addressing this gap will require engaging public administrators and technical staff to streamline processes, developing policies to support SMEs in accessing certification schemes, and establishing monitoring systems to showcase the benefits of integrating upcycled products into public procurement. Additionally, examining international best practices could provide valuable insights into how upcycled products can be effectively incorporated into sustainable procurement strategies. Policy Recommendations for Integrating Upcycled Products in Public Procurement 1. Incorporating Upcycled Product Criteria into Green Public Procurement (GPP) o Develop technical specifications to include upcycled products in food, nutraceuticals, and cosmetics procurement. o Require suppliers to demonstrate the use of upcycled ingredients through certification or third-party verification. o Adapt existing EU GPP criteria to integrate upcycled materials as a preferred category alongside organic and fair-trade products. 2. Streamlining Certification for Circular Suppliers o Establish a Circular Supplier Certification scheme to recognise businesses incorporating upcycled materials. A2C – Deliverable D7.13 v1.0 Page 38 І61 o Reduce administrative barriers and costs to certification, particularly for SMEs, through regional grants or simplified compliance pathways. o Allow certification as a scoring advantage in procurement tenders under award criteria. 3. Leveraging Public Institutions as Market Drivers o Require public sector canteens, hospitals, and schools to prioritise upcycled products in food procurement contracts. o Use dynamic purchasing systems (DPS) to facilitate continuous supplier engagement with sustainable product options. o Ensure large-scale food contracts incorporate specific quotas for upcycled ingredients or packaging. 4. Introducing Financial Incentives for Upcycled Procurement o Implement a reduced VAT rate for upcycled-certified products in food, cosmetics, and nutraceuticals. o Provide tax benefits for businesses adopting upcycled materials in production. o Offer subsidies for upcycling technologies and industrial processes to encourage supplier participation. 5. Strengthening Monitoring and Impact Assessment o Establish a public monitoring platform to track green procurement implementation and spending. o Develop standardised KPIs to measure environmental and social impacts, such as waste reduction, emissions savings, and economic benefits. o Use collected data to support policy adjustments and incentivise continuous improvement in procurement strategies. 6. Facilitating Supply Chain Coordination for Upcycled Inputs o Support collaborative networks between food processors, suppliers, and waste valorisation industries to ensure a stable supply of upcycled materials. o Encourage local sourcing agreements to integrate surplus food into public catering services. o Promote cross-sector partnerships to scale the use of upcycled inputs beyond food, extending to nutraceuticals and cosmetics. A2C – Deliverable D7.13 v1.0 Page 39 І61 7. Scaling Regional and International Best Practices o Expand successful pilot projects, such as Murcia’s INFO certification, to national or EU-wide levels. o Align upcycling criteria with international circular economy standards to ensure consistency and facilitate market access. o Engage regional and national authorities to harmonise procurement standards, preventing fragmentation in adoption. 8. Enhancing Public Awareness and Consumer Acceptance o Integrate consumer education campaigns into GPP strategies to boost confidence in upcycled products. o Work with retailers to increase visibility of upcycled-certified goods in procurement supply chains. o Promote positive narratives around upcycling, avoiding terminology that could reinforce negative perceptions (e.g., "waste-derived"). 1. Establishing Selection Criteria for Upcycled Product Suppliers Public procurement processes should prioritise suppliers with demonstrated expertise and experience in upcycled food production, nutraceuticals, and cosmetics. To qualify, suppliers must: • Provide organic and sustainability certifications for upcycled ingredients. • Demonstrate adherence to circular economy principles through evidence of waste valorisation in their production processes. • Maintain records of training activities for staff on sustainable sourcing and processing of upcycled materials. • Show compliance with local and EU regulations related to food safety and environmental sustainability. Example: A public catering contract could require that at least 30% of the menu ingredients come from upcycled food sources, with suppliers demonstrating compliance through third-party certification. 2. Defining Technical Specifications for Upcycled Products Contracting authorities should define clear requirements for upcycled products in food, nutraceutical, and cosmetic procurement. The specifications should include: A2C – Deliverable D7.13 v1.0 Page 40 І61 • Minimum percentages of upcycled ingredients in purchased food and consumer goods. • Accepted certification standards (e.g., Upcycled Foods Association, EU organic certification). • Product traceability documentation to verify sustainable sourcing. • Requirements for suppliers to provide environmental impact assessments related to their products. Example: A municipality procuring catering services for schools may require that at least 20% of fresh produce be sourced from surplus or by-product valorisation, aligning with EU GPP criteria. 3. Awarding Additional Points for Circular and Sustainable Practices Procurement tenders should reward suppliers that exceed sustainability requirements, offering additional points for: • Higher percentages of upcycled ingredients in food and personal care products. • Innovative food waste reduction strategies, such as participation in redistribution programmes. • Carbon footprint reduction commitments, including sustainable packaging and transport. • Participation in Circular Supplier Certification schemes that validate compliance with upcycling standards. Example: A public hospital tender could offer bonus points to suppliers that provide at least 40% upcycled content in food and beverage procurement, helping drive market demand for circular products. 4. Introducing Contract Performance Clauses to Ensure Compliance To ensure long-term sustainability, contracts should include enforceable clauses requiring: • Monitoring and reporting of upcycled product usage, including data on name and quantity of upcycled inputs. • Waste prevention plans detailing measures taken to reduce food and material waste in production and supply. • Mandatory training for food service staff on sustainable sourcing, storage, and preparation. A2C – Deliverable D7.13 v1.0 Page 41 І61 • Carbon-reduction strategies in supply chain logistics, such as low-emission delivery vehicles and route optimisation. Example: A university cafeteria contract could mandate quarterly sustainability reports from its suppliers, tracking the percentage of upcycled ingredients used and the impact on food waste reduction. 5. Encouraging Financial Incentives for Sustainable Suppliers To encourage participation from circular suppliers, policymakers should consider: • Reduced VAT rates for upcycled-certified food, cosmetics, and nutraceuticals. • Subsidies for SMEs transitioning to circular production models. • Tax breaks for retailers and distributors prioritising upcycled products in procurement. Example: A regional government could introduce a 5% VAT reduction for all public contracts involving at least 30% upcycled product purchases, incentivising businesses to incorporate circular practices. 6. Scaling Upcycled Procurement Through Regional and International Collaboration Public authorities should facilitate: • The replication of successful regional certification schemes, such as Murcia’s INFO, at national and EU levels. • Cross-border partnerships to harmonise upcycled product procurement criteria. • Engagement with international sustainability initiatives to align standards and increase product acceptance. Example: A procurement framework developed in Spain for school catering services using upcycled food could serve as a model for other EU municipalities, enhancing policy consistency. 7. Strengthening Consumer Awareness and Market Development To ensure long-term success, governments should: • Launch education campaigns to increase consumer trust in upcycled products. • Work with retailers and public institutions to increase visibility and accessibility. • Promote positive framing, avoiding terms like “waste” while highlighting sustainability and quality benefits. A2C – Deliverable D7.13 v1.0 Page 48 І61 At the European level, the Waste Framework Directive (WFD) (Directive 2008/98/EC, as amended by Directive 2018/851) provides the foundational legal framework for distinguishing by-products from waste. According to this directive, a substance or object resulting from a production process may be classified as a by-product rather than waste if it meets four key criteria: it must be certain to be further used, usable directly without additional processing beyond standard industrial practices, produced as an integral part of a production process, and its further use must be lawful. These criteria aim to facilitate the reintegration of by-products into economic cycles while mitigating environmental risks associated with misclassification. Despite this legal foundation, practical implementation varies widely across EU Member States, leading to regulatory uncertainty for businesses seeking to valorise agri-food by-products. The classification of by-products in the agri-food sector is particularly sensitive due to food safety concerns, which intersect with environmental and waste regulations. The General Food Law (Regulation (EC) No 178/2002) establishes key principles ensuring that materials derived from food production remain safe for human consumption, directly influencing the regulatory pathways for by-products. Additionally, sector-specific regulations, such as the Animal By-Products Regulation (EC) No 1069/2009) and the regulatory framework for feed production, introduce further complexity. These legal instruments impose stringent conditions on the handling, processing, and transport of agri-food by-products, requiring careful alignment between environmental and food safety policies. A persistent challenge within this regulatory framework is the lack of harmonisation in the interpretation of by-product status at the national level. While some Member States have established clear guidelines or sectoral lists defining acceptable by-products and their uses, others apply case-by-case assessments, creating administrative burdens and legal uncertainty for businesses. In response, the European Commission has provided guidance documents and promoted best practices to enhance regulatory consistency. Nevertheless, stakeholders continue to call for more streamlined procedures, particularly in cross-border trade, where discrepancies in national classifications hinder the development of secondary raw material markets. The EU’s recent policy initiatives, including the European Green Deal and the Circular Economy Action Plan, have emphasised the importance of regulatory clarity in enabling byproduct valorisation. The revision of the Industrial Emissions Directive (IED) and the A2C – Deliverable D7.13 v1.0 Page 49 І61 expansion of End-of-Waste (EoW) criteria for specific materials further signal the EU's commitment to reducing regulatory barriers. In the agri-food sector, these initiatives align with broader efforts to increase the circular use of organic materials, including biowaste, agricultural residues, and food processing side streams. However, achieving a fully integrated regulatory approach will require enhanced coordination between waste legislation, product safety regulations, and industrial policies. End-of-Waste Criteria and Their Impact on Agri-Food By-Products The EoW framework is a critical regulatory mechanism designed to facilitate the transition of materials from waste status to that of a product, thereby reducing reliance on virgin resources and improving resource efficiency. This transition is governed by Article 6 of the WFD, which establishes cumulative conditions under which a material ceases to be classified as waste. Despite its potential to stimulate secondary raw material markets, the application of EoW criteria has faced challenges related to legal harmonisation, administrative burdens, and market fragmentation, limiting its full implementation across Member States. The legal foundation for EoW criteria was initially introduced under Directive 2008/98/EC, which aimed to provide legal clarity and facilitate the circulation of recovered materials. This framework was later refined through Directive 2018/851, which introduced a case-by-case approach where explicit criteria are absent, granting greater flexibility to economic operators. However, the application of EoW remains inconsistent across Member States, leading to regulatory fragmentation and creating barriers to intra-EU trade. While the EU has established harmonised EoW criteria for select materials, such as metal scrap, glass cullet, and specific fertilisers, many waste streams—including plastics, textiles, and organic residues—lack clear guidance, thereby limiting the expansion of secondary raw material markets. A major obstacle in implementing EoW criteria lies in the stringent conditions set by Article 6(1) of the WFD. These require proof that a material is intended for a specific purpose, has a clear market demand, meets technical and regulatory standards, and does not pose environmental or health risks. While these requirements are intended to prevent potential environmental harm, they have also introduced significant administrative burdens, restricting the scope of materials that can achieve EoW status. Furthermore, disparities in national A2C – Deliverable D7.13 v1.0 Page 50 І61 regulations, such as variations in contaminant thresholds for materials like wood waste in Austria and France, undermine market confidence and create unequal competitive conditions among EU operators. In response to these challenges, the concept of tacit EoW status has gained traction as a practical solution, particularly for compost, digestate, and construction materials such as municipal solid waste incinerator (MSWI) bottom ash. Under this approach, materials attain product status without requiring explicit administrative approval, provided that they comply with established regulatory frameworks. The EU Fertiliser Regulation (2019/1009) already recognises this principle for compost and digestate, facilitating their circulation within the single market. Expanding tacit EoW mechanisms to additional industrial by-products and agri-food residues could reduce administrative burdens while ensuring environmental compliance, provided that robust monitoring and verification mechanisms are in place. For the agri-food sector, the development of targeted EoW criteria could yield significant benefits by improving the valorisation of biowaste-derived fertilisers, treated organic residues, and compost. These materials align with the sector’s sustainability goals, offering a viable alternative to synthetic inputs while enhancing soil health and carbon sequestration. However, the absence of harmonised EU-wide criteria for these materials limits their commercial potential and discourages investment in circular bioeconomy initiatives. Addressing this gap through sector-specific regulatory frameworks could drive innovation, improve waste valorisation, and facilitate cross-border trade in secondary raw materials. In this context, prioritising the harmonisation of EoW criteria across Member States is essential to reducing regulatory disparities, promoting fair competition, and fostering market confidence in secondary material markets. The establishment of sector-specific EoW criteria, particularly for agri-food residues and biodegradable materials, would enhance resource efficiency while ensuring compliance with environmental standards. Expanding the tacit EoW approach for certified industrial processes could further streamline administrative procedures, allowing for a more efficient integration of secondary materials into the economy. As the EU continues refining its circular economy policies, strengthening the EoW framework within the agri-food sector will be critical to improving resource recovery, increasing market efficiency, and supporting the transition towards a more sustainable and resilient economic model. A2C – Deliverable D7.13 v1.0 Page 51 І61 Stakeholder Views on End-of-Waste, By-Products, and Secondary Markets in Spain The perspectives of Spanish stakeholders on the regulation of End-of-Waste (EoW) status, by-products, and secondary markets reveal a strong demand for simplification, harmonisation, and enhanced economic viability in circular economy practices. Spain's Law 7/2022 on Waste and Contaminated Soils for a Circular Economy provides a regulatory foundation for reclassifying materials from waste to valuable resources after undergoing recovery or recycling operations. However, stakeholders highlighted that while recent advancements have been made in defining EoW regulations for plastics, similar frameworks for organic and food waste remain underdeveloped, creating significant regulatory obstacles. A key concern among industry representatives is the rigidity of current classifications, which often label organic materials as waste even when they meet food safety and quality standards. This results in unnecessary regulatory burdens, impeding the efficient valorisation of by-products. In particular, businesses operating in the food and agriculture sectors expressed frustration over costly and time-consuming administrative processes required to obtain by-product status, which limits the potential reuse of materials in innovative applications such as nutraceuticals, cosmetics, and bioplastics. Economic constraints were also emphasised as a major barrier. Lengthy approval procedures—sometimes taking up to 18 months—discourage businesses from seeking EoW certification, while regulatory uncertainty forces companies to bear disposal costs for materials that could otherwise be reused. Stakeholders in the plastics sector pointed out that secondary markets remain constrained by a lack of flexibility, as recovered materials continue to be classified as waste until the final moment of sale. In contrast, some European countries, such as France, have introduced incentives such as recycling fee reductions for plastics containing recycled content, although these measures have had limited impact due to the persistent price gap between virgin and recycled materials. The issue of traceability was another major point of discussion, particularly in relation to regulatory acceptance and consumer confidence. While robust traceability mechanisms are seen as essential for market development, their absence in some sectors—especially in food waste valorisation—prevents by-products from re-entering the economy. Stakeholders noted that digital solutions, including blockchain and AI-powered certification systems, could A2C – Deliverable D7.13 v1.0 Page 52 І61 significantly improve transparency, reduce administrative burdens, and streamline crosssector material exchange. Despite these challenges, participants acknowledged Spain's proactive role in shaping plastic EoW regulations and suggested that similar approaches should be extended to other material streams. International comparisons highlighted that countries such as the UK and the Netherlands have successfully implemented secondary market mechanisms, particularly in construction materials and industrial by-products, demonstrating the potential benefits of a more dynamic and transparent regulatory framework. Stakeholders in Spain agreed that further regulatory reforms are necessary to unlock the full potential of circular economy models, with a focus on fostering industrial symbiosis, reducing bureaucratic barriers, and strengthening economic incentives to enhance secondary material markets. Policy Recommendations for Enhancing End-of-Waste, By-Product Recognition, and Secondary Markets 1. Streamlining the End-of-Waste Process • Establish accelerated approval procedures with fixed timelines and automatic recognition for low-risk materials. • Develop pre-approved material lists, allowing certain recovered materials to achieve EoW status without requiring case-by-case assessment. • Implement a centralised online registry for tracking and facilitating EoW applications, reducing administrative delays and increasing transparency. 2. Enhancing By-Product Recognition • Develop sector-specific guidelines to clarify by-product recognition criteria, particularly in the food, agriculture, and packaging industries. • Shift the regulatory focus from classification towards quality and safety standards, allowing materials to be sold as co-products rather than being classified as waste. • Promote collaborative industry platforms to standardise by-product valorisation criteria, fostering regulatory consistency across Member States. 3. Strengthening Economic Incentives and Market Viability • Introduce tax incentives and financial mechanisms to offset the higher costs of using post-consumer recycled content. A2C – Deliverable D7.13 v1.0 Page 53 І61 • Develop regional secondary material marketplaces to facilitate certified byproduct exchanges between industries, reducing waste disposal costs. • Implement public procurement policies that prioritise the use of EoW-certified and secondary materials to create stable demand and increase market confidence. 4. Improving Traceability and Digital Solutions • Create digital traceability platforms to document material origins, transformation processes, and compliance with safety and quality standards. • Encourage the adoption of blockchain and AI-powered certification systems to enhance transparency and trust in secondary markets. • Develop harmonised labelling schemes for products containing recycled or upcycled content to increase consumer awareness and market uptake. 5. Supporting SMEs in Circular Transition • Provide technical support and regulatory guidance to help SMEs navigate EoW and by-product frameworks. • Establish regional advisory hubs to assist small businesses in optimising waste valorisation opportunities. • Integrate circular economy requirements into public procurement frameworks, ensuring SMEs benefit from demand for secondary materials. A2C – Deliverable D7.13 v1.0 Page 54 І61 6 Conclusions The policy briefs in this deliverable present a cohesive framework for advancing circular economy practices in the agri-food sector, particularly in waste reduction, resource recovery, and packaging sustainability. While each brief targets a specific policy area, their interdependence is crucial for achieving systemic change. For instance, consumer acceptance of upcycled food products is essential for market viability, yet it cannot be effectively promoted without complementary fiscal measures. Reducing VAT on upcycled agri-food products not only makes them more competitive but also aligns with behavioural insights on price sensitivity. Similarly, consumer participation in food upcycling schemes— such as surplus food redistribution or valorisation initiatives—relies on well-designed incentives and public awareness. Governance mechanisms further reinforce these efforts. Circular public procurement in the agri-food sector can act as a demand-side driver by prioritising upcycled ingredients and sustainable packaging in institutional purchasing. However, this requires reliable traceability systems for food by-products and secondary materials, ensuring compliance with food safety regulations and enabling industrial symbiosis among agri-food actors. Additionally, the regulation of by-products and EoW status in the agri-food sector is fundamental for unlocking circular business models. 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