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      Circularity has moved from a sustainability topic to a strategic imperative. For CSOs as well as leaders in operations, procurement and reporting across resource-intensive sectors, regulatory and commercial pressures are converging rapidly: 

      ESRS E5, the EU Ecodesign for Sustainable Products Regulation and the Digital Product Passport, the Packaging and Packaging Waste Regulation (PPWR) from August 2026, the EU Critical Raw Materials Act (CRMA), the revised Swiss Environmental Protection Act effective from January 2025, the UK Packaging EPR live since January 2025 with the Circular Economy Strategy for England expected in 2026 and the upcoming EU Circular Economy Act anticipated in late 2026. 

      Alongside regulatory developments, resource volatility, supply chain disruption, rising EPR fees (Extended Producer Responsibility) and investor demand for verified circular performance are reshaping competitive dynamics.

      KPMG helps you turn these pressures into opportunities. As co-author of the WBCSD Circular Transition Indicators (CTI) and a technical contributor to the Global Circularity Protocol (GCP) we support you in moving from ambition to measurable circular performance.

      Julian Meitanis
      Julian Meitanis

      Director, Corporate Sustainability Services

      KPMG Switzerland

      Manfredi Fiorillo
      Manfredi Fiorillo

      Senior Manager, Sustainability & Climate Advisory

      KPMG Switzerland

      Why KPMG services?

      • Value, not just compliance

        As ESPR, PPWR and CRMA requirements tighten, circularity becomes a question of margins and resilience, not a cost line. We help clients turn transition requirements into competitive advantage, before they become a liability.

      • One accountable partner, strategy to assurance

        A KPMG team spans strategy, technology, legal, tax and audit-grade assurance, ensuring that circularity claims withstand scrutiny from boards, investors and regulators, not just marketing reviews.

      • Proven at scale

        From multinational material product passport programs to enterprise-wide decarbonization initiatives, we have delivered circular transformation at scale across some of the world's largest energy and life sciences organizations, not as theory, but as a proven track record.

      Understand your challenges & addressing key pain points

      We have no baseline for measuring circularity.

      Most companies have fragmented material data spread across procurement, operations, reporting and ESG systems. At the same time, regulations and standards, such as ESRS E5, the GCP, and DPP (Digital Product Passport) requirements all demand verified material flows.

      We deploy standard-aligned measurement approaches and the KPMG Circularity Tracker to establish a single, reliable data foundation, ready for assurance.

      How does circularity actually translate into financial value?

      Circular initiatives rarely fail due to a lack of ambition, they fail due to a lack of a business case. Material savings, EPR fee modulation, revenue from circular models, and avoided regulatory risk all impact the P&L, yet few organizations can quantify where.

      We build this business case and integrate it into strategic planning, product strategy and capital allocation, turning ambition into investable decisions.

      Which regulation actually applies to us, and when?

      The regulation, spanning from the EU’s ESRS E5 and ESPR to the PPWR, the Critical Raw Materials Act and the revised Swiss EPA, overlap across product, packaging and material flows.

      We help you identify your exposure across markets and design a single compliance pathway aligned with the most stringent applicable requirements, protecting market access without duplicating effort.

      Tailored solutions for your industry

      Circularity plays out differently across industries, depending on which regulations take effect first, which materials are most critical, and where the value pools are created.

      We support clients across all sectors, with a particular focus on those where our Swiss and international organizations face the highest exposure:

      • Industrial Manufacturing

        ESPR sector requirements (beginning with iron and steel in 2026), CRMA (Critical Raw Materials Act) recycling benchmarks, and the EU Circular Economy Act will reshape industrial value chains.

        We help redesign products for circularity, secure access to critical materials, and build the data infrastructure required for Digital Product Passport compliance.

      • Consumer & Retail

        The PPWR, effective from August 2026, is reshaping packaging design and EPR economics. ESPR (Ecodesign for Sustainable Products Regulation) ecodesign requirements will affect textiles, apparel and footwear from 2026 onwards.

        We support clients in reconfiguring packaging portfolios, scaling Product-as-a-Service and resale models, and preparing for the ban on destroying unsold textiles.

      • Life Sciences & Pharma

        Single-use packaging, sterile devices, and complex supply chains create sector‑specific circularity challenges.

        We help balance PPWR requirements with patient safety, design circular cold-chain solutions and embed circularity into ESG and reporting frameworks.

      • Healthcare & Medtech

        Medical devices face increasing circularity requirements, including ESPR scope expansion to take-back and refurbishment requirements.

        We help design for repair and remanufacture, the development of closed-loop systems with hospitals, and alignment with both MDR (EU Medical Device Regulation) and circular economy requirements.

      • Real Estate & Construction

        Buildings account for over 50% of material extraction and 35% of waste in the EU. The revised Swiss EPA mandates resource-efficient construction; the EU Construction Products Regulation is increasingly aligned with circularity principles.

        We help embed circular design, material passports and reuse strategies across real estate portfolios.

      • Commodities & Natural Resources

        Demand for traceability and recycled content, driven by the Critical Raw Materials Act, is reshaping critical minerals and metals markets. In combination with the EU Circular Economy Act, this is expected to unlock a secondary raw materials market with new opportunities and revenue streams.

        We help quantify circular flows and build transparency across supply chains.

      • Asset Management

        Investors face increasing pressure to assess circular performance in portfolio companies.

        We support due diligence by integrating circular risks and opportunities, build investment frameworks aligned with the GCP, and help managers embed circular data into ESG and stewardship processes.

      • Technology, Media & Telecom

        The revision of the Waste Electrical and Electronic Equipment Directive (WEEE), ESPR requirements for electronics, and DPP obligations are driving new approaches to e-waste management, repairability and component recovery.

        We support circular hardware strategies, refurbishment and take-back models, and the digital infrastructure needed to enable traceability across global supply chains.

      Navigating success: our proven approach

      Our approach mirrors the structure of the Global Circularity Protocol: adapted to the realities of your business, sector and regulatory exposure.

      • Frame – diagnose your starting point

        We assess your circular maturity, map regulatory exposure across EU, Swiss and Middle Eastern markets, and benchmark you against your peers. The outcome is a clear view of your current position and which regulatory requirements are likely to impact you first.

      • Prepare – build the strategy and business case

        We define your circular ambition, set targets aligned with the GCP and CTI, and quantify the business case across material savings, EPR economics, new revenue streams, and avoided regulatory risk. The result is a board-ready roadmap.

      • Measure – install the data foundation

        Using the KPMG Circularity Tracker and CTI/GCP methodologies, we implement a measurement framework that tracks material flows, circular performance, and ESRS E5 disclosures from a single, trusted data source, ready for assurance.

      • Manage – integrate and implement

        We embed circularity into your operating model, product and packaging design, procurement, and reverse logistics. Through change management, training and operating model redesign, we translate strategy into operational reality across functions and geographies.

      • Communicate – report, assure, and scale

        We support disclosure under ESRS E5, IFRS S1/S2, and the GCP, prepare you for assurance, and design stakeholder communications that build credibility with regulators, investors, customers and rating agencies, turning circular performance into a competitiveness narrative.

      KPMG Circularity Tracker:
      Make your circular performance visible

      The KPMG Circularity Tracker is a future-ready tool, co-developed with Microsoft and based on the “Cloud for Sustainability” solution, designed to organize and enhance circularity across your organization. 

      It helps automate data collection from diverse sources and performs model-based data calculations using recognized circularity measurement frameworks, such as the Circular Transition Indicators (CTI).

      Download PDF

      Make your circular performance visible

      Download PDF

      Partnering for success:
      submit your interests & open questions

      The companies acting now (building data foundations, redesigning for circularity and translating regulatory pressure into competitive advantage) will define the next decade of industrial leadership in Europe and beyond.

      Those that hesitate may find that catching up is significantly more costly than leading from the start.

      Contact our experts

      Tell us where you stand on your circular journey, whether it’s a regulatory exposure scan, a strategy session, a measurement diagnostic or a full transformation roadmap.

      You will gain insights drawn from sector best practices, KPMG's global circular economy network, and our hands-on experience implementing circular strategies worldwide.

      Meet our experts

      Julian Meitanis
      Julian Meitanis

      Director, Corporate Sustainability Services

      KPMG Switzerland

      Manfredi Fiorillo
      Manfredi Fiorillo

      Senior Manager, Sustainability & Climate Advisory

      KPMG Switzerland