A new comprehensive framework for waste management and circular transition

1. Introduction: from sectoral planning to a comprehensive strategy

The Agreement of 23 December 2025 of the Governing Council approving the Circular Economy Strategy of the Region of Madrid 2025-2032 marks a turning point in regional environmental policy. For the first time, the Region of Madrid articulates in a single strategic instrument not only waste management plans, but also a cross-cutting circular economy model, aligned with the most recent European and state regulations and with a clear vocation for stability, legal certainty and attracting investment.

The Strategy responds to the express mandate of article 8 of Law 1/2024, of 17 April, on the Circular Economy of the Community of Madrid, and replaces the previous Sustainable Waste Management Strategy 2017-2024, significantly broadening its material scope, ambition and degree of integration.

It is not, therefore, a mere programmatic document on waste, but an instrument for economic, environmental and administrative planning, with direct implications for public administrations, companies, collective systems of extended producer responsibility (SCRAP), waste managers, local authorities and investors.

2. Regulatory framework and legal framework of the Strategy

2.1. Alignment with EU Law

The Strategy fits coherently into the framework of European law on waste and the circular economy, taking as its main reference:

• Directive 2008/98/EC, Waste Framework Directive, as amended by Directive (EU) 2018/851.
• The favourable conditions set out in Regulation (EU) 2021/1060, essential for access to ERDF and Cohesion Fund financing.
• The Community objectives of prevention, reuse, recycling and reduction of landfill.

This is not merely declaratory: the content of the regional management plans is expressly designed to meet the requirements of European regulations, guaranteeing the eligibility of future investments in treatment and recovery infrastructures.

2.2. Development of state and regional regulations

At the domestic level, the Strategy develops systematically:

• Law 7/2022, of 8 April, on waste and contaminated soils for a circular economy, in particular its articles 12, 14 and 15.
• The State Waste Management Framework Plan (PEMAR) 2024-2035.
• Law 1/2024, on the Circular Economy of the Community of Madrid, which introduces its own approach, aimed at competitiveness, innovation and administrative simplification.

Of particular relevance is that the Strategy integrates in a single document:

• The circular economy action plan.
• The circular waste prevention programme.
• All the waste management plans required by basic legislation.

This integration represents a substantial novelty compared to previous planning and reinforces the coherence of the system.

3. Territorial, temporal and material scope

3.1. Territorial scope and involvement of local authorities

The Strategy is applicable to the 179 municipalities of the Region of Madrid, which must align their actions in the area of municipal waste with the objectives and strategic lines set at regional level.

While respecting local competences, the document introduces a framework of mandatory coherence, especially relevant for:

• Separate collection systems.
• Treatment infrastructures.
• Municipal waste management financing models.

3.2. Time horizon and review

The 2025-2032 horizon complies with the legal requirement of medium-term planning, with a mandatory review after six years, which gives the system flexibility in the face of regulatory, technological or market changes.

4. A "smart" and competitive circular economy model

One of the distinctive features of the Strategy is its deliberately non-dogmatic approach, oriented towards the economic and productive reality of the Madrid Region. As opposed to models based exclusively on restrictions or regulatory burdens, the Strategy opts for a smart circular economy scheme, conceived as a vector of competitiveness, innovation and attraction of investment.

In this sense, the Madrid model is characterised by being:

• incentivising and facilitating economic activity,
• open to public-private collaboration,
• sensitive to the diversity of productive sectors and their different capacities for adaptation,
• and oriented towards administrative simplification and rationalisation.

The circular economy is thus seen not only as an environmental obligation derived from regulatory compliance, but also as an opportunity to modernise production processes, optimise the use of resources and generate new economic activities, especially in areas such as waste recovery, technological innovation and industrial symbiosis.

5. Action plan and strategic objectives

The action plan constitutes the operational core of the Strategy and articulates its objectives around a combination of environmental, economic and organisational goals, aligned with European and national commitments on waste and the circular economy.

Among the most relevant strategic objectives, the following stand out:

• Prevention and reduction of waste generation.
• Increasing separate collection, especially at source.
• Improving the digital traceability of waste.
• Promotion of mechanical and chemical recycling facilities.
• Recovery of non-recyclable fractions in line with the waste hierarchy.
• Mitigation of greenhouse gas emissions.

This integrated approach connects waste policy with other key public policies - climate, energy, industry or innovation - and reinforces the coherence of the whole model.

6. A comprehensive system of waste management plans

The Strategy includes specific plans for virtually all relevant waste streams, among others:

• Municipal waste.
• Packaging and packaging waste.
• Industrial and bio-sanitary waste.
• Used industrial oils.
• Construction and demolition waste (CDW).
• WEEE, batteries and accumulators.
• End-of-life vehicles and tyres.
• Sewage sludge.
• Agricultural waste.
• Contaminated soils.

This completeness enhances legal certainty and facilitates long-term investment planning.

7. Governance, monitoring and financing

7.1. Governance model

The Strategy incorporates a governance model based on inter-administrative coordination, transparency and continuous monitoring of results. To this end, the use of clear and homogeneous indicators is foreseen, as well as the carrying out of periodic evaluations that allow the measures adopted to be adjusted according to their real effectiveness.

This system of governance is particularly relevant in a context of plurality of actors - public administrations, economic operators, extended producer responsibility systems and local authorities - and makes it possible to reinforce the coherence of the model throughout the duration of the Strategy.

7.2. Budget and financial tools

From the financial point of view, the Strategy is based on a framework compatible with the mobilisation of European funds, regional budgetary resources and formulas for collaboration with the private sector. Compliance with the favourable conditions established by European regulations is an essential element in guaranteeing the economic viability of the planned investments, especially in waste treatment and recovery infrastructures.

8. Cross-cutting perspective: equality, training and innovation

In line with current legislation, the Strategy incorporates:

• The gender perspective in public procurement, subsidies and training actions.
• Education, awareness-raising and training measures.
• Promotion of technological innovation, digitalisation and industrial symbiosis.

9.TheDeposit, Return and Refund System (DRS): a legally enabled option, but not anticipated by the Strategy.

A particularly relevant aspect in the current debate on packaging management is the possible role of the deposit, return and refund system (DRS) as an instrument to improve the levels of separate collection and recycling. The Circular Economy Strategy of the Madrid Region 2025-2032 adopts, on this point, a deliberately cautious position that is legally consistent with the existing regulatory framework.

Indeed, the Strategy does not contain a really significant mention (it barely mentions it succinctly and in passing) or a direct commitment to the implementation of a DRS in the Madrid Region, nor does it incorporate it as an autonomous strategic line within the action plan or the Packaging and Packaging Waste Management Plan. This absence should not be interpreted, however, as an exclusion from the system, but rather as a conscious choice not to anticipate structural decisions without a prior and objective evaluation of the functioning of the current model.

From a legal point of view, the Strategy is based on the framework established by Law 7/2022 of 8 April on waste and contaminated soils for a circular economy, which expressly recognises the DRS as a possible and conditional instrument, the implementation of which is linked to compliance or non-compliance with the legal targets for separate collection of certain packaging streams. In this logic, the DRS is not configured as an ideological or automatic solution, but as an additional correction mechanism that can be activated when existing systems do not achieve the results required by the regulations.

For its part, Law 1/2024 of 17 April on the Circular Economy of the Community of Madrid does not impose a specific organisational model either, but rather reinforces the principles of technological neutrality, waste hierarchy and improved efficiency of separate collection, leaving open the use of different economic and organisational instruments depending on their real effectiveness.

In line with this framework, the Madrid Strategy opts for an approach based on:

• reinforcing separate collection,
• improving the traceability and efficiency of the system,
• periodic evaluation of results,
• and the review of the model in the medium term.

On the other hand, we know that, to date, four organisations have applied to the Community of Madrid for the establishment of a deposit, return and refund system with national authorisation.

10. Conclusion: an ambitious, flexible and results-oriented roadmap

The Circular Economy Strategy of the Madrid Region 2025-2032 is a substantial step forward in regional environmental planning, as it articulates an integrated strategic framework, consistent with European and national regulations, and aimed at guaranteeing the real efficiency of waste management and separate collection systems.

One of the main successes of the Strategy is its results-oriented approach, which avoids predetermining specific instruments, but designs a planning, monitoring and evaluation system that makes it possible to clearly identify when the existing mechanisms are insufficient to achieve the legal objectives.