Focus on… the 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 its submission, Landbell Group company, European Recycling Platform (ERP) welcomed the overarching ambition, but emphasised that the success of the Act will depend on the practical design of its instruments.

ERP calls for extended producer responsibility (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

ERP also calls for a genuine internal market for waste and secondary raw materials being essential for scale and efficiency.

One key request is to update outdated monitoring mechanisms in existing legislation, such as the WEEE Directive.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.

These concerns were also echoed by Germany’s Environment Agency, which recommended changes to the Commission’s impact assessment, including a more differentiated approach to data quality and cost allocation within EPR systems.

Eurostat figures

Recent Eurostat figures underline the challenge ahead.

In 2024, the EU’s circular material use rate rose only marginally to 12.2% – far from the 2030 target of 23.2%.

Meanwhile, collection and recycling rates show mixed progress: while overall packaging waste recycling reached 67.5% in 2023, only two Member States met the 50% plastic packaging recycling target.

WEEE collection continues to lag, with only a few countries achieving the EU’s 65% benchmark based on the current POM methodology.

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.