Role of regulations and governance in the circular economy for construction: a comparative analysis

Abstract

The construction sector is among the largest global consumers of raw materials and generators of waste, making regulatory governance a decisive factor in the circular economy (CE) transition. This paper presents findings of a comprehensive document analysis examining CE-relevant regulatory frameworks across six Asian jurisdictions, China, Japan, South Korea, Hong Kong, Singapore, India and Sri Lanka’s (SL’s) national regulatory landscape, comprising eleven instruments. Applying a structured analytical framework consistently across all documents, the study interrogates legislative intent, compliance mechanisms, enforcement architecture and identified limitations. The Asian analysis reveals stratification across three governance tiers, i) advanced statutory architectures with mandatory waste separation, ii) quantified recovery targets and multi-instrument enforcement, and iii) framework legislation with variable subnational implementation and early-stage disposal-oriented regulation. SL’s framework is characterised by a pre-CE legislative inheritance, institutional fragmentation and a systematic implementation deficit. The Construction Industry Development Authority (CIDA) Regulations 2018 represent the only operative mandatory CE-adjacent obligation in the national framework, yet threshold, monitoring and penalty provisions limit their effectiveness. The paper concludes by identifying governance pathways informed by Asian regulatory experience and germane to SL’s institutional context.