Circular Economy Act – Will it Close the Gap?

The European Commission’s consultation on the planned Circular Economy Act (CEA) formally closed on 6 November. The initiative provided an opportunity for stakeholders to respond to the Commission’s ideas.

In our Group’s submission, we welcomed the overarching ambition, but emphasised that the success of the Act will depend on the practical design of its instruments and called for EPR to be placed at the heart of the circular framework, underpinned by:

• more harmonised KPIs
• enforcement
• robust and comparable data, and
• a level playing field for producers across the EU

One key request is to update outdated monitoring mechanisms in existing legislation, such as the WEEE Directive. Current collection targets are calculated using a three-year average of products placed on the market (POM), a method that no longer reflects real market dynamics.

The Commission has said that the CEA – expected in the third quarter of 2026 – will align with existing EU waste and circularity legislation such as:

• the WEEE Directive
• the Eco-design for Sustainable Products Regulation
• the Packaging and Packaging Waste Regulation, and
• the Critical Raw Materials Act

If designed well, it could become the key overarching framework needed to deliver on Europe’s circularity and competitiveness goals.