Ireland’s Circular Economy Strategy 2026-2028

Published in February this year, Ireland’s Second Whole of Government Circular Economy Strategy 2026-2028 “Accelerating Action”, sets out how the State plans to move from ambition to action over the next few years. Following on from the 2021 strategy, while it impacts many sectors, the new strategy emphasises planned, programmed change with sectoral actions and timelines. Ireland will align with EU measures through a phased implementation approach, with further guidance to follow.

The Strategy has 7 core objectives to:

• Raise Ireland’s circular material use rate (CMUR): by two percentage points each year, with the aim of reaching 12% by 2030.
• Support economic expansion while improving resource productivity and reducing dependency on virgin raw materials.
• Enhance competitiveness and innovation: Strengthen Ireland’s position as a centre for sustainable design, advanced manufacturing and innovative circular business models, enhancing competitiveness in domestic and export markets.
• Enhance social equity: Ensure the benefits of the circular transition are widely shared by communities and workers.
• Empower people to make sustainable, cost-effective lifestyle choices.
• Actively support local authorities in developing coordinated, community-level circular initiatives.
• Establish digitalisation as an enabler of the circular economy by businesses adopting digital tools such as digital product passports, traceability and resource optimisation systems.

Key EU instruments considered in the Strategy include:

• Packaging and Packaging Waste Regulation (EU) 2025/40
• Ecodesign for Sustainable Products Regulation (EU) 2024/1781
• Right to Repair Directive (EU) 2024/1799
• Revised Waste Framework Directive (Directive (EU) 2025/1892)
• EU Batteries Regulation (EU) 2023/1542
• Construction Products Regulation (EU) 2024/3110
• Recast Energy Performance of Buildings Directive (EU) 2024/1275
• Corporate Sustainability Reporting Directive (EU) 2022/2464 as amended
• Critical Raw Materials Act (EU) 2024/1252

The European Commission is expected to propose a Circular Economy Act in 2026 to address structural barriers and create a Single Market for waste and secondary raw materials. This will provide further detail on how businesses can navigate the circular transition in the coming years.

For organisations - whether in retail, food and beverage, property, infrastructure or manufacturing - it is important to start considering these measures now.

Below, we highlight the key commercial impacts, important dates, and areas of opportunity.

Energy Performance of Buildings Directive

The recast Energy Performance of Buildings Directive (EPBD) introduces an important new focus on whole‑life carbon in construction projects.

From 1 June 2026, any project receiving more than €5 million in public funding for non‑residential buildings, or €30 million for residential buildings, will be required to carry out a Whole Life‑Cycle Greenhouse Gas Emissions assessment. While projects below these thresholds are not captured by the formal requirement, the Strategy actively encourages their use as good practice.

From January 2028, all new buildings larger than 1,000m² must apply this methodology, with all other new buildings following from January 2030. From these same dates, embodied carbon declarations will also become mandatory within Building Energy Rating (BER) certificates.

For developers and those operating in the construction sector, these changes mark a shift toward assessing carbon impacts much earlier in the project lifecycle. Engaging with these requirements at an early stage will support smoother project delivery as the new regime is introduced.

All‑Island Circular Economy Opportunities

The Strategy places strong emphasis on cross‑border collaboration, building on the government’s Shared Island Initiative, which has already allocated over €550 million to projects.

A key development is the creation of an All‑Island Circular Economy Forum, led by InterTrade Ireland. The forum will explore practical opportunities for cooperation, including greater alignment of waste regulation, shared approaches to green public procurement, and the development of resource‑matching services. Alongside this, a feasibility study on industrial symbiosis will be carried out, with the aim of establishing an all‑island digital platform to support the exchange of materials and by‑products across key sectors.

The government intends to use Shared Island funding to develop a network of circular economy hubs in Dublin and Belfast, alongside measures to better coordinate existing supports along the Dublin-Belfast corridor.

Sectoral impacts

Development and Construction

Presently, only 11% of construction and demolition waste is recycled, with the majority being backfilled. The Strategy introduces strengthened Green Public Procurement requirements e.g. from 2028, at least 10% by weight of construction materials used in publicly procured infrastructure projects and public non‑residential buildings must comprise recycled materials.

Retail

Retailers will be particularly affected by a suite of EU‑driven measures. The Packaging and Packaging Waste Regulation introduces binding targets on waste reduction, recyclability, reuse, packaging minimisation and recycled content in plastics.

In parallel, the Right to Repair Directive, due to be transposed by July 2026, will make it easier for consumers to choose repair over replacement. The Ecodesign for Sustainable Products Regulation (ESPR) will further reshape product design requirements, introducing mandatory standards for durability, repairability, reusability and recyclability, supported by Digital Product Passports (DPP). An ESPR action plan is due in 2026.

DPPs will require in‑scope products to be accompanied by standardised, machine‑readable digital information covering areas such as material composition, durability, reparability, recycled content and end‑of‑life options. While requirements will be phased in through product‑specific delegated acts, DPPs will have significant implications for supply‑chain transparency, data governance and IT systems, particularly for manufacturers, importers, retailers and online marketplaces.

Renewable Energy and Supply-Chain

The EU Critical Raw Materials Act is aimed at reducing dependence on single‑country suppliers and strengthening supply chain resilience, particularly for materials critical to the green transition. Ireland will introduce a national circularity programme under the Act, focusing on the recovery of critical raw materials and circular product design. For businesses involved in batteries, electronics and renewable energy infrastructure, this creates both new compliance considerations and opportunities to participate in more resilient, circular supply chains.

Food and Beverage

Ireland has committed to halving food waste by 2030. The revised Waste Framework Directive introduces legally binding targets, including:

• a 10% reduction in food waste from processing and manufacturing, and
• a 30% reduction across retail, food services and households by 2030.

The Strategy reinforces a prevention‑first approach, prioritising better measurement, redistribution and reuse.

Textiles and Fashion

With one of the highest textile consumption rates in the EU, at 53kg per person per year, the Strategy confirms that Extended Producer Responsibility (EPR) for textiles will be introduced by April 2028.

At EU level, the ESPR has also introduced a ban on the destruction of unsold apparel and footwear, signalling a clear shift toward reuse, resale and longer product lifespans.

Key Dates and Timelines

Below is an overview of key milestones. Guidance, roadmaps and support will continue to emerge over the next two years, and most measures build gradually toward 2030 rather than landing all at once.

Supporting the Transition 

The shift toward a more circular economy touches all sectors which creates opportunities and challenges. Monitoring new laws and evolving guidance will be key to ensure readiness and practical implementation of these measures.