European Commission consults on the Circular Economy Act

On 1 August 2025, the European Commission launched a public consultation and a call for evidence to gather views on the upcoming Circular Economy Act. The consultations are open until 6 November 2025. 

The Commission indicated in the call for evidence that progress towards a circular economy in the EU has been too slow, with the circularity rate in the EU economy remaining essentially stagnant over the last 15 years (from 10.7 per cent in 2010 to 11.8 per cent in 2023). The supply of, and demand for, secondary raw materials is insufficient or imbalanced, both in terms of quantity and quality. The Commission believes that the problem cannot be adequately addressed by individual Member States and requires EU-level intervention.

In the Single Market Strategy published by the Commission on 21 May 2025, fragmented rules on packaging, labelling and waste were identified as one of the ten most harmful barriers to the free movement of goods and services in the EU. In the Circular Economy Act, the Commission plans to address the fragmentation created by different national extended producer responsibility (EPR) schemes, including through a digital one stop shop for information, registration and reporting. It also plans to reform end-of-waste and by-product criteria, provide a more harmonised framework for reaching end-of-waste and by-product status and facilitate cross-border shipments of waste feedstocks for recycling. For more details on the circular economy aspects of the Single Market Strategy, see our blog post.

According to the call for evidence, the Circular Economy Act aims to help create sufficient supply of and demand for secondary raw materials (including critical ones) and a true single market for waste and secondary raw materials. 

The Act will be structured around two main pillars:

• It will address e-waste (electronic and electrical equipment), to ensure its effective collection and recycling and to generate market demand for the secondary critical raw materials they contain. 
• A mix of interventions to foster the single market for waste, secondary raw materials and their use in products could include the reform of end-of-waste criteria; the simplification, digitalisation and extension of (EPR) schemes; and setting mandatory criteria for public procurement of circular goods, services and works.

The Circular Economy Act is planned for adoption in Q4 2026.