Circular Economy Act: Public Consultation Expected

The European Commission is expected to imminently launch the public consultation on the forthcoming Circular Economy Act. The consultation will serve as the first formal step in shaping a legislative proposal that is widely seen as a centrepiece of Commission President Von der Leyen’s second mandate.

First announced in the Commission’s 2025 Work Programme and framed as a flagship initiative for the next policy cycle, the Circular Economy Act aims to accelerate the internal market for secondary raw materials, waste-derived products and circular goods. It will seek to harmonise national policies, reduce barriers to cross-border material flows, and address long-standing challenges in waste classification, end-of-waste criteria, and by-product definitions.

The Act is expected to be structured around three legislative pillars: • the reform of national EPR schemes through harmonisation, simplification and digitalisation • an amendment to the Landfill Directive, and • a recast of the Waste Electrical and Electronic Equipment (WEEE) Directive These revisions will aim to improve supply and demand dynamics for high-quality recyclates, simplify permitting for secondary material use, and expand extended producer responsibility (EPR) systems with the help of digital tools and harmonised reporting requirements.

We will actively monitor all developments related to the Circular Economy Act and participate in the public consultation process. The Commission is expected to table the final legislative proposal in the first half of 2026.