Circular Economy Act: consultation open, Commission prepares ambitious package

On 1 August, the European Commission launched its public consultation on the forthcoming Circular Economy Act (CEA), which will run until 6 November 2025.

The consultation consists of a call for evidence, a detailed questionnaire and the option to upload position papers.

The consultation is open to all stakeholders, and its aim is to gather evidence and views on how to strengthen circularity in the Single Market, with a particular focus on removing barriers, harmonising rules and scaling up sustainable business models.

How it might be structured

According to the latest information obtained by Landbell Group, the CEA might be structured in three parts:

1. A non-binding Communication to set the framework and outline the EU’s vision for circularity
2. Targeted legislative amendments to key waste and product laws, including the Waste Framework Directive, the Packaging and Packaging Waste Regulation, and a revision of the WEEE Directive, and
3. Flanking measures, covering broader tools to stimulate demand and investment, such as greening VAT (lowering VAT for greener products and services) and strengthening green public procurement

While the Commission’s official Work Programme foresees publication in Q4 2026, officials have indicated that an earlier proposal in 2026 is under consideration following the priority Von der Leyen has given the CEA in her State of the Union address (see article above).

Preparatory work on the file is already underway, reflecting the political importance attached to the initiative.

Flagship framework

The Circular Economy Act is intended to serve as the EU’s flagship framework for scaling up circularity.

It will consolidate and update existing legislation, address persistent gaps and introduce market-based incentives to drive demand for secondary raw materials.

For producers, recyclers and compliance organisations, the Act will likely bring significant changes to EPR obligations, product design rules, and market access conditions – aiming for more circularity and less bureaucracy through simplification.

Stakeholders are encouraged to participate in the consultation before 6 November. The Commission will use the feedback to inform its drafting, with first proposals expected in 2026.

Landbell Group will contribute to the consultation.

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