From fragmented regulation to a more enabling European framework
The INSET project has finalised its State-of-the-Art Report on European Union policies for Industrial Symbiosis, developed under Work Package 5, Activity 5.2. Compiled and enriched by IRIUS at the Université de Strasbourg, the report provides a comprehensive overview of the European policy, legal, financial and standardisation instruments that shape the development of Industrial Symbiosis.
Industrial Symbiosis enables companies and organisations to exchange resources such as materials, by-products, energy, water, equipment, logistics capacity and expertise. By turning one organisation’s unused resource into another organisation’s input, it can reduce waste, limit the use of primary raw materials and create new forms of economic and environmental value.
The report shows that Industrial Symbiosis is increasingly recognised within European circular economy, climate and industrial policies. However, it also finds that significant legal, financial and implementation barriers continue to prevent its deployment at scale.
A changing European policy landscape
The report traces the evolution of European policy from the 2011 Roadmap to a Resource Efficient Europe to the European Green Deal, the Circular Economy Action Plans and the 2025 Clean Industrial Deal.
Over this period, Industrial Symbiosis has progressively moved beyond its original positioning as a waste-management or resource-efficiency practice. It is now increasingly connected to broader European priorities, including industrial competitiveness, decarbonisation, strategic autonomy, access to critical raw materials and the resilience of European value chains.
This shift is particularly visible in recent instruments such as the revised Industrial Emissions Directive, the Critical Raw Materials Act and the Net-Zero Industry Act. Together, these instruments create new opportunities to integrate Industrial Symbiosis into industrial transformation plans, permitting processes, clean-technology clusters and raw-material recovery strategies.
The report nevertheless underlines an important distinction: ambitious strategic objectives do not automatically create the legal and operational conditions required for resource exchanges between companies.
Three major barriers to scaling Industrial Symbiosis
The analysis identifies three structural deficits that continue to limit the development of Industrial Symbiosis across Europe.
The first is the fragmentation of end-of-waste and by-product procedures. The Waste Framework Directive provides the legal foundations for materials to be recognised as by-products or to cease being classified as waste. In practice, however, harmonised European criteria currently cover only a limited number of material categories. Many resources relevant to Industrial Symbiosis remain subject to different national or regional procedures, creating uncertainty, delays and additional costs.
The second barrier is the absence of a common European certification system for Industrial Symbiosis. The 2020 Circular Economy Action Plan announced the development of an industry-led reporting and certification framework, but this system has not yet been formally implemented. Without common standards and recognised certification, companies, public authorities and investors may find it difficult to assess the quality, reliability and environmental performance of Industrial Symbiosis exchanges.
The third barrier concerns access to finance, particularly for small and medium-sized enterprises. Although several European instruments can support circular economy and industrial transformation projects, they are not always adapted to the size, capacities and investment needs of SMEs. Complex procedures, high qualification costs and financing thresholds can discourage smaller companies from developing Industrial Symbiosis projects.
Why Industrial Symbiosis matters for the Clean Industrial Deal
The report places particular emphasis on the European Union’s objective of increasing the circular material use rate to 24% by 2030.
Achieving this target will require a major acceleration compared with the historical rate of progress. Industrial Symbiosis can make an important contribution because it enables industrial resources to be recovered and reused directly within production systems, often at a higher value than conventional post-consumer recycling.
The report therefore argues that Industrial Symbiosis should be treated not only as an environmental practice, but also as a strategic instrument for European industrial policy.
Digitalisation and standardisation as enabling tools
Digital solutions can also help reduce the transaction costs associated with identifying and managing potential exchanges. The development of Digital Product Passports, interoperable data systems and artificial-intelligence-supported matching tools could improve access to information on material composition, availability and quality.
However, the report notes that Industrial Symbiosis is not yet sufficiently integrated into emerging European digital-product frameworks. Future legislation should ensure interoperability between Industrial Symbiosis platforms and European data infrastructures.
Standardisation is another important condition for building trust. The report examines the contribution of CWA 17354, which provides a broad definition of Industrial Symbiosis, as well as the certification roadmap developed by the European RISERS project. This roadmap proposes certification at three levels: individual exchanges, Industrial Symbiosis networks and professional facilitators.
For INSET, this last dimension is especially important. The professionalisation of Industrial Symbiosis facilitators is central to the project’s training methodology and to the long-term development of effective regional and industrial ecosystems.
From analysis to policy recommendations
The State-of-the-Art Report will directly support the preparation of the INSET Policy Brief. Its findings point towards five main priorities for European action:
+ integrate Industrial Symbiosis more explicitly into the forthcoming Circular Economy Act;
+ accelerate the harmonisation of end-of-waste criteria;
+ establish a proportionate and accessible European certification framework;
+ develop financing instruments better adapted to SMEs;
+ connect Industrial Symbiosis platforms with Digital Product Passport infrastructure.
The report also provides a common policy baseline for the INSET partner countries—France, Italy, Spain and Slovenia—while highlighting the different national procedures and implementation challenges they face.
By bringing together legal analysis, academic research and evidence from European projects, the report transforms a complex policy environment into a clear framework for action. It strengthens INSET’s contribution to the European debate and supports a central message: Industrial Symbiosis can play a decisive role in Europe’s circular and industrial transition, but its full potential will only be realised through coherent regulation, accessible finance, common standards and skilled facilitators.
