Innspill til EUs forslag til revisjon av GBER

Need for coherence between GBER and EUs ambition to scale the circular economy

We hereby submit Sirk Norway's input to the EU Commission’s ongoing revision of the GBER, with a strong call to ensure that the state aid rules build on the EU’s ambitions to scale the circular economy.

The transition from linear to circular business models is complex. The transition to a circular economy requires extensive changes and adaptations in business models, both for individual companies and for services spanning interconnected value chains. Restructuring businesses to achieve circular services that are as competitive and profitable as today’s linear alternatives is very complex and time-consuming. This constitutes a systemic barrier that is reinforced in high-cost countries with high consumption, such as Norway and the other Nordic countries. This type of transition requires both financial muscle and expertise, which is often lacking in small and medium-sized enterprises (SMEs).

Current GBER criteria hinder necessary innovation. Our experience is that current GBER limits the circular transition in practice. In Norway, in recent years, we have seen that applications for state aid for R&D activities (GBER Article 25) as well as process and organizational innovation (GBER Article 29) have been rejected with reference to overly strict compatibility criteria in the regulations. When the regulations are too strict to support actual transition processes, they act as a bottleneck for the EU's green goals.

Need for strong interaction between GBER and Circular Economy Act (CEA). For the EU to succeed in its ambitions to scale the circular economy, there must be coherence between the regulatory requirements and the financial framework conditions. Sirk Norge therefore urges the EU Commission to reform the GBER so that the regulations facilitate – rather than restrict – efforts to transform businesses and value chains from linear to profitable circular solutions.

We firmly believe that the ongoing revision of the GBER must be seen in direct connection with the design of the upcoming Circular Economy Act (CEA). The challenges associated with scaling circular solutions, especially the need for support for circular business modeling, should be given special attention by the Commission in its work on the CEA. If the GBER does not provide sufficient flexibility to support tomorrow's circular business models, the goals of the CEA will be very difficult to realize.

Concrete experiences to build on in order to design the most accurate possible exemption regulations, we recommend that the Commission look at ongoing pilot projects. For example, Innovation Norway has established pilot programs that attempt to support circular business modeling and circular value chains. The experience from such schemes provides valuable insight into the barriers that companies encounter in the transition, and how state aid regulations can best be designed to alleviate the economic risk associated with restructuring business models.

Sirk Norway welcomes a revised GBER that actively aligns with the EU's broader circular economy policy and the upcoming Circular Economy Act.