European Union seeking input on proposed Circular Economy Act

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Dive Brief:

• The European Commission has announced a public “call for evidence,” seeking input on the Circular Economy Act (CEA), according to an August 1 press release. The Commission plans to finalize the proposal in Q4 of 2026, after which it will move through the European Union’s legislative process.
• Part of the EU’s Clean Industrial Deal announced in February 2025, the CEA is meant to create a single European market for circular products — designed to optimize the resources used and minimize waste across its lifecycle — as well as secondary materials and waste. The Commission’s proposal also hopes to foster a larger supply of high quality recycled materials and reduce feedstock costs.
• The CEA is motivated by the current regulatory fragmentation of the European market for recycled materials and waste, according to the call for evidence. It also seeks to make 24% of the region’s materials circular by 2030 and address the higher cost of recycled materials, which hurts their competitiveness with virgin materials.

Dive Insight:

One of CEA’s priorities will be ensuring collection, recycling and demand for electronic waste, of which less than 40% is recycled in the EU, according to the call for evidence.

The CEA could also make changes to extended producer responsibility schemes, criteria that allow waste to be reclassified as secondary raw materials and public procurement criteria in order to “foster the single market for waste, secondary raw materials and their use in products.” Such laws are gaining steam in the U.S., and at least seven states have EPR laws for packaging on the books with compliance deadlines over the next few years. 

The Act is also meant to support other circularity initiatives in the Clean Industrial Deal, such as the Waste Framework Directive, Ecodesign for Sustainable Products Regulation and Packaging and Packaging Waste Regulation, the Commission said. 

“These initiatives cannot unfold their potential unless the barriers to circularity in the single market are removed and there is sufficient and cost-effective supply of high-quality, verifiable secondary raw materials,” the Commission said in the evidence call.

It is too early for the Commission to speculate on the CEA’s potential impacts on third countries, a spokesperson said in an email to ESG Dive. But the text of the Clean Industrial Deal notes that the CEA could include “measures to make recycling of critical raw materials waste within the Union more attractive than their export” to support the Critical Raw Materials Act. Additionally, the European Parliament asked that the Clean Industrial Deal’s circular economy provisions include “export monitoring” of “those secondary raw materials that are strategic” and to “tackle any imbalance in their supply and demand, including by exploring export restrictions,” in a June statement addressed to the Commission.  

European recycling industry groups have also called on the EU for increased protections for the European market. Plastics Recyclers Europe released a May report noting that their industry saw slowed growth in 2023, down to 6%, compared to 17% in 2021 and 10% in 2022. In a subsequent position paper, the group demanded that “the persistent threat of low-cost, unverified imports of both virgin and recycled plastics be addressed urgently, as they distort the market, erode competitiveness and pose a risk to the EU’s circular economy,” according to a press release. 

An April 2025 position paper on the CEA by the European Recycling Industries’ Confederation echoed that sentiment: “The EU market is being flooded with both imported virgin and recycled plastics … from third countries with lower environmental and labour standards.”

Stakeholders, including NGOs, businesses, trade organizations and third country trading partners, are invited to weigh in on the Circular Economy Act until Nov. 6, according to the call for evidence. Results of the consultation will be published eight weeks later, along with the Commission’s own impact assessment, which will pay special attention to potential impacts on small and medium-sized enterprises, the EU’s competitiveness and international trade, the release said.

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