Excess Materials Exchange

Dutch and EU barriers for a circular carpet industry: policy suggestions to overcome them

July 2, 2020



Early this year, the law firm Stibbe and the Utrecht Centre for Water, Oceans and Sustainability Law wrote a position paper on behalf of Excess Materials Exchange. This position paper offers concrete recommendations to remove the existing European and Dutch barriers which impede the acceleration of the transition towards a Circular Economy using the case study of the Dutch carpet industry. More particularly, the paper underlines the necessary policy tools for such transition to happen. These include the introduction of a mandatory Extended Producer Responsibility scheme for carpet, the mandatory use of Resources Passport, the introduction of a sustainability label as well as green and circular public procurement criteria for carpets. 

Product and market barriers in the Dutch carpet industry 

The Dutch carpet industry counts 15 producers including large manufacturers such as Interface Desso (part of Tarkett), and DSM Niaga. Despite the growth of the carpet market industry in Europe, only 1 to 3% of carpets are today reused (60% landfilled, 37-39% incinerated). Reasons for such a low reuse percentage include the following barriers: 

  • Design barriers: carpets are complex products made of interwoven components which might even contain harmful substances for human health and the environment. 
  • Installation barriers: carpets are frequently installed with glue which impedes easy disassembly for reuse. 
  • Market barriers: carpets are collected in a mixed stream at their first end-of-life which leads to potential contamination.  
  • Lack of transparency in material composition: the exact composition of carpets is unknown and impedes high-quality recycling and reuse.
  • Perceptions of consumers: most consumers perceive used carpets as waste. Consequently, reusable carpets suffer from a bad image. 

Policy tools for a Circular Economy transition in the carpet industry 

To remove such barriers, the law firm Stibbe and the Utrecht Centre for Water, Oceans and Sustainability Law and Excess Materials Exchange identified several policy tools.

Mandatory Extended Producer Responsibility (EPR) Scheme 

An EPR scheme for the carpet industry would shift the responsibility for the end-of-life treatment costs from consumers (via municipality treatment costs) to the producers, leading to a fairer distribution of costs. Such responsibility shift incentivises producers to minimise treatment costs by changing the design of their carpets and scaling up reuse facilities to reach economies of scale. To create a level playing field between producers at the EU level and to avoid free-riding, the law firm Stibbe, along with the Utrecht Centre for Water, Oceans and Sustainability Law and Excess Materials Exchange advocate for a mandatory EPR scheme. Successful examples such as the introduction of an EPR scheme for carpets by the State of California in 2010 encourages such choice. Lastly, in light of the established criteria for EPR scheme of the Organisation for Economic Co-operation and Development (OECD), the carpet industry would be a suitable material flow for an EPR scheme. It constitutes a significant waste stream flow in tonnage, within a relatively concentrated market and the nature of the flow makes it difficult to dispose of, using existing waste collection infrastructure such as containers and garbage bags. 

Mandatory use of Resources Passports

Resource passports are a tool which documents the identity of a product by centralising all data about a product under a clear, easy and standardised format, bringing administrative coherence and consistency. Such passports contain comprehensive data about components, subcomponents and materials which facilitate high-quality recycling and reuse. Such resource passports can also include additional obligatory information such as safety data sheets and declarations of performance and can come as a support for other initiatives such as green public procurement and sustainability labels. Stibbe, along with the Utrecht Centre for Water, Oceans and Sustainability Law and Excess Materials Exchange advocate for a mandatory use of Resource Passports which could be included under different legal bases such as the Article 8 of the EU Waste Framework Directive, the EcoDesign Directive (if extended to non-energy related products) or within the Environmental Product Declarations. 


Sustainability Labels 

The existing energy label applies to 15 product groups within the EU but does not cover carpets. Because such a policy tool has been driving environmentally conscious purchasing behaviors as well as innovation in energy efficiency, Stibbe, the Utrecht Centre for Water, Oceans and Sustainability Law and Excess Materials Exchange advocate for the creation of an additional Sustainability Label Regulation for carpets based on various sustainability indicators. This label should, for example, encourage producers to phase out toxic substances that are frequently present in carpets. It should rely on existing successful tools such as on the clear design of the energy label, the GUT international label and the European Commission’s requirements for carpets from 2009. To be successful, it should also be accompanied by a large awareness raising campaign in the EU. 

Circular Green Public Procurement 

Public procurement is an essential polity tool to stimulate a market as it accounts for 14% of the EU gross national product. By introducing circularity criteria within the existing green public procurement criteria, public authorities would purchase works, goods or services that seek to contribute to closed energy and material loops within supply chains, whilst minimizing or  avoiding, negative environmental impacts and waste creation across their whole life-cycle. Stibbe, along with the Utrecht Centre for Water, Oceans and Sustainability Law and Excess Materials Exchange advocate for green and circular procurement criteria for carpets to be drawn up at European level. The criteria could include requirements that encourage the recyclability of carpets but also a reference to the possible Ecolabel or sustainability label introduced above. To limit competition at the EU level and internal market distortion, criteria should be made at European Union level rather than national level.

In summary, this position paper argues that numerous policy tools could be implemented at the EU level to remove some of barriers for a circular carpet industry to emerge in the Netherlands.

Interested in more details? Read the full paper here.



Excess Materials Exchange (EME) is a young and innovative technology company. On our digital matching platform, we find new high-value reuse options for materials or (waste) products for companies. We believe that far too many valuable resources and materials are wasted or ill-designed in the current paradigm, for which the planet must pay a heavy price. Isn’t that a waste? EME is determined to accelerate the global transition to a circular economy – and play a part in creating a more viable planet. By showing the financial and ecological value of materials. By challenging companies to design and produce their goods in a more efficient and circular manner. And by making matches. A whole lot of matches.