Environmental compliance

Circular Economy Act

New reports outline options for EPR and WEEE

The European Commission’s Directorate-General for Research and Innovation (DG RTD) has published five independent expert reports analysing lessons from EU-funded projects that could inform the forthcoming Circular Economy Act (CEA).

The reports cover circular public procurement, Extended Producer Responsibility (EPR), recycled and bio-based content, WEEE and critical raw materials, and regional circular economy initiatives.

EPR

For EPR, recommendations include an EU-wide one-stop shop for producer registration and reporting, more interoperable digital systems and further harmonisation across Member States.

Other proposals concern eco-modulation, PRO governance and the role of reuse operators.

WEEE

The WEEE report highlights measures including binding CENELEC treatment standards, improved recovery of critical raw materials and stronger recycling infrastructure.

Several of these themes are also addressed in ERP’s new policy paper on the future WEEE framework. The paper calls for clearer and more harmonised producer obligations, realistic collection targets, stronger control and treatment of WEEE flows, and better conditions for returning recovered materials to production.

The CEA proposal itself, originally planned for September, is now expected to be published on 11 November 2026, after the Regulatory Scrutiny Board rejected the Commission’s impact assessment.

Authorised representatives

Debate over proposed EPR changes intensifies

The debate over the proposed suspension of authorised representative (AR) requirements under the Environmental Omnibus has gained further momentum. Recent discussions have focused particularly on concerns from micro and small businesses in the packaging sector.

In Parliament, negotiations are moving towards a compromise.

EPP, Renew, ECR and PfE negotiators reportedly support suspending the AR obligation for micro and small EU-based enterprises while maintaining existing requirements for third-country producers.

S&D and the Greens also appear open to a suspension for packaging and textiles. They remain more cautious about WEEE and other waste streams.

The issue is also gaining traction in the Council.

While Member states have not yet endorsed a specific amendment, they recently agreed that a targeted solution should be explored to address the potential burden on small packaging producers.

Germany has already proposed a packaging-specific exemption for low-volume producers. Poland has called for reconsidering mandatory AR appointments where de minimis exemptions apply.

With negotiations between political groups still ongoing, the parliamentary timetable has shifted, with the AR file currently scheduled for a first-reading plenary vote on 19 October 2026.

MFF 2028–2034 (non-collected e-waste levy)

Negotiations continue on budget size and new own resources

Negotiations on the EU’s 2028–2034 Multiannual Financial Framework (MFF) are continuing. The Irish Council Presidency is still aiming for a political agreement between Member States by the end of 2026. However, differences remain over both the overall size of the budget and its financing.

In August, Denmark, Germany, the Netherlands, Austria, Finland and Sweden called for the Commission’s proposal to be reduced by several hundred billion euros, while maintaining the objective of concluding negotiations this year.

The European Parliament, by contrast, supports a larger budget, as well as additional own resources to finance EU priorities.

Non-collected e-waste levy

The Commission’s proposed revenue package includes a new own resource based on non-collected e-waste, alongside the existing contribution based on non-recycled plastic packaging waste.

ERP has joined a broad industry coalition opposing the e-waste levy, citing concerns over data reliability, national fragmentation, additional costs and overlap with the forthcoming WEEE reform.

The Irish Presidency plans to present its interim position in October. This will form the basis for further discussions at the European Council on 15-16 October.

Waste Shipment Regulation

Commission proposes simpler rules for treated e-waste

The European Commission has published a draft delegated regulation to clarify how non-hazardous e-waste can be shipped between Member States from 1 January 2027.

The proposal would replace the current GC010 and GC020 entries with a new EU-specific classification, BEU09, covering properly treated and depolluted WEEE, non-hazardous components and non-hazardous fractions resulting from WEEE processing.

These streams could continue to move under the general information requirements of Article 18, without prior notification and consent.

By contrast, non-hazardous WEEE that has not undergone proper treatment would fall under a new entry (EU49) and remain subject to the prior informed consent procedure.

The proposal broadly reflects recommendations set out in a joint industry paper co-signed by ERP in July, which called for non-hazardous intra-EU e-waste shipments to retain access to the green-list procedure beyond 1 January 2027.

The paper argued that this would reduce unnecessary administrative barriers while preserving traceability and environmental safeguards.

The stakeholder consultation on the draft delegated regulation closed on 15 September 2026. The Commission will now finalise the act ahead of 1 January 2027, when the current GC010 and GC020 entries cease to apply.