The eight pilots conducted in the Nordic Circularity Piloting Program (NCPP), covering HVAC, elevators, access systems, sanitary equipment and electrical systems, prove that circularity is technically feasible and financially viable: the products work, the demand exists, and the climate case is clear. But procurement rules, building codes, price signals, regulatory frameworks, and the infrastructure for take-back and quality assurance is still largely optimised for a linear economy. These are barriers that cannot be fully resolved by the industry itself, policy action is needed to achieve the necessary system change.
The NCPP identified seven policy suggestions that we direct to the Nordic Council of Ministers, the coordinating body of the Nordic governments:
1. Enable a Nordic circular market for technical building solutions
Technical building solutions have properties that make them particularly suited for a shared Nordic market: standardised design, high value per unit of volume, and components that are economically viable to transport between countries for refurbishment or redeployment. Individual national markets may not provide enough volume for circular businesses in this category to scale. A joint Nordic initiative that would investigate barriers, opportunities and the infrastructure needed would give companies a market large enough to invest in, while helping Nordic EU member states meet binding obligations under the Critical Raw Materials Act, the Waste Framework Directive, and the forthcoming Circular Economy Act.
2. Make circular requirements mandatory in public procurement
A Cradlenet survey shows that only 14% of Swedish municipalities often include circular requirements in procurement, and statistics from the Swedish National Agency for Public Procurement show that only 0,8% of Swedish procurements in 2025 had any circular criteria. Without a demand-side requirement, reused products compete on price against new ones in a market where the true cost of virgin materials is not reflected. Mandatory circular requirements in public procurement would create the volume of demand needed for companies to develop scalable circular offerings. They also have a mainstreaming effect: when circularity is required at procurement, redesigning business models becomes a natural response across the whole market, not just for public contracts.
3. Set binding circularity targets for technical solutions in building codes
Mandatory circularity targets in building codes would make circular solutions the default rather than the exception in technical installation projects, and give circular business models a predictable framework to scale within. A complementary measure would be requiring systematic material audits of existing building portfolios to proactively map reuse potential before renovation or demolition is planned. The FutureBuilt Circular criteria for circular buildings could serve as a guiding framework for developing harmonised Nordic criteria, methods and timelines.
4. Use economic incentives to make circular technical building solutions competitive
Circular practices are more labour-intensive than linear ones. In the Nordics, labour is heavily taxed while natural resource prices rarely reflect environmental externalities. The result is a structural cost disadvantage for circular business models. Targeted instruments such as subsidies, favourable loan criteria, or a shift in the tax burden from labour to resource use could correct this imbalance. A joint Nordic study of the most effective fiscal and financial instruments, followed by coordinated recommendations to member governments, would align with the Nordic Roadmap for Circular Financing 2026–2030 and support competitiveness for Nordic companies providing circular solutions.
5. Set climate-aligned lifecycle GWP thresholds for technical building installations
Well-intended rules for improving building energy performance have had an unintended consequence: older installations are often replaced with new ones even when the full lifecycle emissions of a new product are significantly higher than continued use of the existing one. The recast Energy Performance of Buildings Directive (EPBD) introduces lifecycle global warming potential (GWP) thresholds for new buildings, including technical installations, and member states were obliged to transpose it into national law by May 2026. Nordic countries should ensure that national thresholds are set in line with EU climate targets and the 1.5°C Paris Agreement target, setting a new standard that promotes circular technical installations over premature replacement with new.
6. Remove CE marking barriers for refurbished and remanufactured products
In the NCPP pilots, CE marking emerged as one of the most concrete regulatory blockers for scaling refurbishment. Current conformity assessment requirements make refurbishment economically unviable for many technical installation categories, and legal ambiguity about whether the original manufacturer or the remanufacturer holds CE responsibility discourages investment. A joint Nordic position toward the EU calling for simplified and clarified conformity assessment procedures for refurbished and remanufactured products, combined with interim national guidance to reduce legal uncertainty, would remove a structural barrier that currently stops viable circular business models from scaling.
7. Develop Chromium VI field testing standards to unlock reuse of ventilation ducts
Ventilation ducts manufactured before 2006 may contain Chromium VI, a carcinogenic substance that can be released during cleaning and cutting. As a precaution, pre-2006 ducts are typically destroyed rather than reused when taken out of service even where the substance may not actually be present. Standardised rapid field-testing protocols, integrated into pre-demolition audit requirements, would enable reliable on-site assessment and release significant volumes of ventilation components into circular reuse streams. A joint Nordic project to develop and evaluate these methods would address a practical barrier with an outsized effect on the circular potential of HVAC systems.
These policy inputs have been co-developed with representatives from the companies that piloted circular solutions in the program. They reflect the hands-on insights and practical expertise of individuals directly involved in the pilots, and do not necessarily represent the official position of their organisations.