Focus on… the circular economy

The circular economy is a vital priority for the EU Commission:

State of the Union 2025: circular economy central to Europe’s competitiveness
Circular Economy Act: consultation open, Commission prepares ambitious package

State of the Union 2025: circular economy central to Europe’s competitiveness

Each September, the President of the European Commission delivers the State of the Union address to the European Parliament.

This annual speech sets out the Commission’s priorities for the year ahead, taking stock of progress and announcing major new initiatives.

In her 2025 address, Ursula von der Leyen placed strong emphasis on reducing Europe’s strategic dependencies through clean technologies and circular production models.

She highlighted that circularity is not only an environmental imperative but also a vital competitiveness strategy for the EU.

Von der Leyen stressed that Europe’s ability to thrive in turbulent times depends on securing critical materials and keeping industrial leadership within the Union.

To this end, she announced the Commission will:

• Accelerate the work on the Circular Economy Act, moving quickly in sectors that are ready
• Launch an Industrial Accelerator Act to scale up strategic sectors and technologies
• Create lead markets for circular and clean products through instruments such as green public procurement and ‘made in Europe’ criteria, and
• Boost investment in recycling and reuse as part of the broader Clean Industrial Deal

The President made clear that circularity limits Europe’s exposure to volatile global supply chains while opening opportunities for export-oriented frontrunner industries.

By combining circular production with clean energy, the EU can strengthen its independence, attract investment and support jobs around the continent.

The Circular Economy Act remains a flagship file for this mandate and is expected to advance in 2026.

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.