Focus on 2026

2026 Policy Outlook: From legislative design to implementation

In 2026, EU circular economy policy will enter a decisive phase: the Commission is preparing the new Circular Economy Act, and we will also gain clarity on the planned amendments to the WEEE Directive.

Furthermore, while other major framework regulations have already been adopted, the coming year will also be defined by secondary legislation, national transposition and the first practical impacts on producers, recyclers and compliance schemes across Europe.

Circular Economy Act

A central development is the European Commission’s work on the upcoming Circular Economy Act, expected to be proposed in Q3 2026.

The initiative aims to:

• improve the functioning of the Single Market for secondary raw materials
• strengthen recycling value chains, and
• reduce administrative barriers, such as simplifying, harmonising and digitalising EPR obligations

Throughout 2026, the Commission is expected to conduct impact assessments, further stakeholder consultations and technical studies, with a strong focus on competitiveness, resilience and SME participation.

At the same time, broader policy discussions will continue to influence the regulatory environment.

Here is a sample:

WEEE

Work related to the revision of the WEEE Directive is ongoing, following earlier evaluations of its effectiveness.

A key topic will be a new calculation methodology for WEEE collection targets (see related article for more details).

Moreover, the negotiations on the EU’s Multiannual Financial Framework refer to WEEE.

In this context, the European Commission is also exploring new own-resource options at EU level, including a proposal linked to non-collected WEEE.

PPWR

This year will also be key for the operationalisation of recently adopted legislation.

Provisions of the Packaging and Packaging Waste Regulation (PPWR) will enter into application in August 2026, following an 18-month transition period.

In parallel, the Commission is expected to adopt a series of implementing and delegated acts, including rules on the calculation and verification of recycled content, as well as harmonised labelling requirements, and digital marking technologies.

These measures will be central to providing required clarity to producers and ensuring consistent implementation across Member States.

Critical Raw Materials

Following the Commission’s ‘RESourceEU’ proposal, legislative discussions on amendments to the Critical Raw Materials Act (CRMA) are also expected, including new circularity-related requirements for permanent magnets (see also related article).

In parallel, the Commission is planning the first operational steps to strengthen recycling, improve traceability and limit exports of certain CRM-rich waste streams.

Batteries

Under the Batteries Regulation, further progress is expected in translating the regulatory framework into operational requirements.

Work on implementing and delegated acts will continue, particularly in relation to the targets for recycling efficiency and recovery of materials, and the labelling of batteries (see also related article).

For producers, this will result in more standardised compliance obligations across the EU.

Textiles

Textiles will gain increasing regulatory relevance under the amended Waste Framework Directive.

Following the introduction of mandatory extended producer responsibility (EPR) for textiles at EU level, attention in 2026 will increasingly shift towards national implementation.

Member States are expected to work on setting up or adapting EPR systems, including producer registration, reporting obligations and governance structures, while discussions on remaining secondary legislation at EU level continue.

Two implementing acts will establish the harmonised format for registration in the register of producers, as well as defining eco-design criteria for textiles under the Ecodesign for Sustainable Products Regulation (ESPR).

Ecodesign

Generally, the ESPR will move further into its implementation phase.

In 2026, the Commission is expected to advance preparatory work, technical studies and discussions on delegated acts that will lay the groundwork for future product-specific requirements.

This will support the gradual integration of durability, reparability and circularity criteria into EU product policy.

Conclusion

Overall, 2026 will mark a clear transition from legislative design to implementation.

For companies subject to environmental compliance obligations, the focus will move from anticipating new rules to implementing existing legislation across multiple waste streams in an increasingly interconnected regulatory landscape.