The European Union’s Circular Economy Action Plan, first unveiled in March 2020, has quickly become a cornerstone of industrial sustainability policy across the bloc. For manufacturers, particularly those operating within energy-intensive and material-heavy sectors, the Action Plan has introduced not just high-level goals but increasingly detailed expectations for supply chain transparency. One of the most significant shifts concerns the mapping of closed-loop material flows and the need to produce verifiable data on how post-consumer materials are re-entering production cycles. While some firms have long championed circular principles, the emerging regulatory landscape makes this type of reporting no longer optional. It’s now expected. And this expectation is accompanied by a growing library of open data tools and guidance—chief among them, Eurostat’s material flow accounts—that manufacturers can and should integrate into their compliance strategies.
Manufacturers might feel understandably overwhelmed at first glance. The material flow accounts, after all, are dense and complex, capturing data that span extraction, imports, processing, consumption, and waste recovery across dozens of material categories. But the starting point need not be perfect. The value lies in beginning to connect these macro-level data with specific supply chain nodes—identifying, for example, where critical post-consumer materials such as recycled aluminum, PET, or steel are being sourced and how they tie back to individual Tier 1 and Tier 2 suppliers. Doing this effectively requires both strategic thinking and technical agility. It’s about constructing a bridge between broad statistical aggregates and the firm’s own procurement records.
The first step in that process involves isolating the material categories most relevant to a given firm’s operations. For a producer of consumer electronics, this might mean focusing on critical metals and plastics. For a food and beverage packager, attention will naturally fall on paperboard, PET, and aluminum. Eurostat’s material flow accounts provide data at a level granular enough to trace these material streams across national boundaries, including data on imports of secondary materials. By cross-referencing these accounts with internal supplier master data, firms can start building a picture of how much of their input material is likely to be of post-consumer origin, and where that material is coming from geographically.
What complicates matters—and what makes the exercise so valuable—is the need to identify not just material flows, but the specific suppliers through which these materials enter the production chain. Here, the linkage between Eurostat’s open data and supplier records becomes critical. Companies will need to enhance their supplier questionnaires and certification processes to include clear attestations regarding the proportion of post-consumer or secondary material incorporated into supplied goods. Many firms are now requesting supporting documentation, such as chain-of-custody certificates or declarations referencing recognized recycling standards. While it may take time to build a fully robust data set, even initial estimates can help guide sourcing decisions and identify areas where circularity performance is weak.
Once the basic material flows are mapped, manufacturers face the challenge of presenting their findings in a way that meets both regulatory expectations and stakeholder interest. Increasingly, this is where annual circularity performance dashboards come into play. These dashboards, posted publicly on corporate websites, offer a means of demonstrating alignment with the Circular Economy Action Plan while showcasing progress against internal sustainability targets. The content of such dashboards will vary by sector, but core elements should include a breakdown of material inputs by origin (virgin versus secondary), an accounting of waste generated and recovered, and highlights of closed-loop initiatives—for example, take-back programs or supplier partnerships aimed at increasing recycled content.
Designing these dashboards poses its own challenges. Firms must strike a balance between transparency and simplicity. Overly technical presentations may meet compliance requirements but risk alienating non-expert audiences. On the other hand, dashboards that are too high-level can feel superficial, raising questions about the depth of the company’s engagement with circularity principles. A good practice is to layer information: providing summary metrics up front, with links or downloads available for more detailed data sets and methodological notes. This approach allows interested stakeholders—whether regulators, investors, or civil society groups—to dig deeper as needed.
It is worth noting that the creation of circularity dashboards should not be a one-off exercise. The pace of regulatory development in this space suggests that reporting requirements will only grow more detailed over time. Companies that treat the dashboard as a living document, updated regularly and refined as data quality improves, will be better positioned to respond to these evolving demands. This also creates internal benefits, fostering a culture of continuous improvement around material efficiency and waste reduction.
Manufacturers should also expect increasing scrutiny of the accuracy and integrity of their circularity data. As the EU moves toward more standardized reporting frameworks, external verification is likely to become the norm rather than the exception. Proactively engaging with third-party auditors or certification bodies can help firms stay ahead of the curve, ensuring that their material flow claims are both credible and defensible. Some companies have already begun piloting such initiatives, finding that independent verification not only builds stakeholder trust but also uncovers opportunities for process improvement that might otherwise have gone unnoticed.
The EU Circular Economy Action Plan is reshaping the way manufacturers think about their supply chains. Material flow transparency is no longer a niche concern for sustainability teams; it is becoming a core element of operational strategy. And while the path to full compliance is complex, the tools needed to navigate that path—chief among them, Eurostat’s material flow accounts—are available. The challenge now lies in integrating these tools into day-to-day business practices, turning data into insight, and insight into action.