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Circularity Declaration for Product Design

Most manufacturers now understand that recycled content is a compliance metric. But the European Union's vision for product sustainability extends far beyond the percentage of recycled plastic in your packaging. The EU Circular Economy Action Plan (CEAP) and the Ecodesign for Sustainable Products Regulation (ESPR) are pushing companies toward a comprehensive approach known as circularity — and they are creating a new documentation requirement to prove it: the Circularity Declaration.

A Circularity Declaration is a structured document that demonstrates your product has been designed and manufactured for the circular economy. It covers material selection, design-for-disassembly, repairability, spare parts availability, material recovery rates, and end-of-life processing instructions. This is not a marketing claim. Under ESPR, specific circularity metrics will become mandatory for product categories covered by Digital Product Passports.

What Is Circularity?

Circularity is the principle of keeping products, components, and materials in use at their highest value for as long as possible. It stands in direct opposition to the traditional linear economy model of "take, make, use, dispose."

A circular product is characterized by:

Principle What It Means in Practice
Design for durability The product is engineered for a long service life with materials that resist wear, corrosion, and fatigue.
Design for repair Components most likely to fail are accessible, replaceable, and supported by long-term spare parts availability.
Design for disassembly The product can be easily taken apart using standard tools, enabling component recovery and material separation.
Design for remanufacturing Worn components can be restored to as-new condition and reintegrated into the product.
Design for recyclability Materials are selected and combined in ways that allow efficient separation and high-quality recycling at end-of-life.
Material transparency Complete documentation of material composition, including additives and coatings that may affect recycling.

Why a Circularity Declaration Matters

Regulatory Drivers

The EU ESPR (Regulation [EU] 2024/1781) explicitly mandates circularity requirements for covered products. As delegated acts are published for each product category, specific circularity metrics will become legal requirements:

  • Repairability scores: Already mandatory for smartphones and tablets in France (Indice de Réparabilité), with EU-wide requirements under development.
  • Spare parts availability: The ESPR requires manufacturers to make essential spare parts available for a defined period (typically 7 to 10 years) after the last unit is placed on the market.
  • Disassembly information: Manufacturers must provide clear disassembly instructions enabling authorized repairers and recyclers to efficiently dismantle products.
  • Recycled content targets: Binding minimum percentages for specific materials, starting with plastics and expanding to other material categories.

Commercial Drivers

Major retailers and B2B buyers are building circularity into their procurement criteria. Government tenders in the EU increasingly award points for circular design. A documented Circularity Declaration differentiates your product in competitive bids and demonstrates alignment with the EU's long-term regulatory trajectory.

What a Circularity Declaration Must Cover

A robust Circularity Declaration, aligned with the Sustalium Circularity Declaration framework, addresses each stage of the product lifecycle:

1. Material Selection and Sourcing

  • Bill of Materials (BOM): Complete breakdown by material type and weight percentage.
  • Recycled content: For each material, the percentage of pre-consumer and post-consumer recycled content, verified against standards like EN 15343.
  • Renewable materials: Percentage of bio-based or renewable materials, with certification (FSC, GOTS, etc.).
  • Hazardous substance status: Confirmation that materials comply with REACH SVHC restrictions and RoHS limits, as hazardous substances disrupt recycling streams.
  • Material compatibility for recycling: Assessment of whether material combinations (e.g., multi-layer packaging, bonded textiles) inhibit recyclability.

2. Design for Disassembly

  • Disassembly sequence: A documented, illustrated step-by-step guide showing the correct order of disassembly for component recovery.
  • Disassembly time: Estimated time required for a trained technician to fully disassemble the product.
  • Tools required: A list of standard tools needed — products requiring proprietary or specialized tools score poorly on circularity.
  • Fastener types: Preference for reusable or easily removable fasteners (screws, clips) over permanent joints (adhesives, welds) in assemblies that house valuable or hazardous components.
  • Material marking: Components should be permanently marked with material identification codes (e.g., ISO 11469 for plastics) to facilitate automated sorting at recycling facilities.

3. Repairability and Maintenance

  • Repairability score: A standardized score (e.g., the French Indice de Réparabilité methodology) based on documentation availability, disassembly ease, spare parts availability, spare parts pricing, and product-specific criteria.
  • Spare parts list and availability period: A catalog of replaceable components with guaranteed availability windows (minimum 7 years recommended for most product categories).
  • Repair manual access: Publicly accessible repair documentation, including troubleshooting guides, part numbers, and step-by-step replacement procedures.
  • Software and firmware updates: For products with digital elements, a published policy on the duration and scope of software support and security updates.

4. End-of-Life Processing

  • Material recovery rate: The percentage of the product's total mass that can be recovered through established recycling processes.
  • Recycling instructions by material stream: Specific guidance for recyclers on how to separate and process each material type (metals, plastics, glass, electronics, textiles).
  • Collection and take-back scheme participation: Details of any producer responsibility organization (PRO) membership or proprietary take-back program.
  • Hazardous component identification: Clear marking of components requiring special handling (batteries, capacitors, mercury-containing lamps, refrigerants).
  • Landfill diversion: The percentage of product mass designed to be diverted from landfill through a combination of reuse, remanufacturing, and recycling.

How to Build Your Circularity Declaration

Step 1: Audit Your Product Against Circularity Criteria

Using the framework above, conduct a gap analysis of your current product design. Identify which circularity features are already in place and which need development. Prioritize improvements based on regulatory timelines for your product category under ESPR.

Step 2: Engage Your Supply Chain

Circularity cannot be achieved unilaterally. Request material composition data from your suppliers, including recycled content percentages, hazardous substance declarations, and material marking compliance. Your suppliers' willingness and ability to provide this data is a key indicator of their own circularity readiness.

Step 3: Document the Evidence

Compile your evidence into a structured technical file: disassembly photographs, material test reports, recycling compatibility assessments, spare parts catalogs, and repair manuals. This dossier forms the backbone of your Circularity Declaration and must be maintained for the product's lifetime plus the mandatory record-keeping period.

Step 4: Publish Your Circularity Declaration

Generate a formal Circularity Declaration document and a public-facing transparency page. Under the Green Claims Directive, public circularity claims must be substantiated by this documentation and accessible at the point of sale.

How Sustalium Simplifies Circularity Documentation

Building and maintaining circularity documentation manually across a product catalog is exceptionally complex. Sustalium's Circularity Declaration platform provides a structured, scalable solution.

  • Circularity Assessment Framework: Sustalium's guided template walks you through each circularity criterion — material selection, disassembly, repairability, end-of-life — prompting you for the specific data, evidence, and documentation required for ESPR compliance.
  • Integrated BOM and Material Mapping: Link your Bill of Materials directly to your circularity data. The platform automatically calculates recycled content percentages, material recovery rates, and compatibility assessments.
  • Public Transparency Page: Generate a consumer and buyer-facing Circularity Declaration page, accessible via QR code. This page displays your product's circularity metrics, repair information, and end-of-life guidance in a clear, structured format.
  • Continuous Improvement Tracking: As your product design evolves and circularity metrics improve, Sustalium versions your Circularity Declaration, maintaining a complete audit trail of your progress toward circular economy goals.

Build Your Circularity Declaration Today

Circularity is the next frontier of product compliance. Document your design-for-disassembly, repairability, and material recovery strategies before ESPR mandates make them mandatory.

With Sustalium, you can generate a comprehensive Circularity Declaration and public transparency page for just €10 per document.

Create Your Circularity Declaration Now →

Frequently Asked Questions

Is a Circularity Declaration mandatory yet?

The ESPR has entered into force and circularity requirements are being defined through delegated acts for specific product categories. While a standalone Circularity Declaration is not yet a universal legal requirement, the underlying data it contains (material composition, repairability, recyclability) is already mandatory under the ESPR's Digital Product Passport requirements. Building your Circularity Declaration now positions you ahead of the regulatory curve.

How is circularity different from just using recycled content?

Recycled content is one component of circularity — it addresses the input side. A truly circular product also addresses durability (how long it lasts), repairability (whether it can be fixed instead of replaced), disassembly (whether materials can be recovered at end-of-life), and material health (whether hazardous substances are avoided). Circularity is the complete system; recycled content is a single metric.

Can I make circularity claims without third-party verification?

Under the EU Green Claims Directive, explicit environmental claims — including circularity — must be substantiated. While third-party verification of your entire circularity assessment is not always required, every specific claim (e.g., "85% recyclable") must be supported by documented evidence aligned with recognized standards (e.g., EN 45555 for recyclability assessment).

Last updated: June 19, 2026