Delivering on the Circular Economy Act: Step 1
The European Commission has officially launched preparations for the new Circular Economy Act (CEA), beginning with a Clean Industrial Dialogue on Circularity held on 2 July. A public consultation is now expected to open in the coming weeks (date TBC) to support the Act's development. Set for publication in Q4 2026, the Circular Economy Act aims to boost investment in Europe’s recycling capacity and curb the landfilling and incineration of valuable raw materials.
From EUROPEN’s perspective, the upcoming Circular Economy Act presents a unique opportunity to tackle the structural shortcomings that continue to hinder effective packaging waste management across Europe. In 2024, the European Commission’s Early Warning Report revealed that 10 out of 27 EU Member States are at risk of missing the 65% packaging waste recycling target set for 2025. The report also pointed to widespread Member States’ challenges in meeting material-specific packaging recycling targets. That same year, in July 2024, the Commission launched infringement procedures against all 27 Member States, urging them to comply with EU waste collection and recycling obligations.
The Circular Economy Act represents a last, critical opportunity to address the persistent structural flaws undermining the efficiency of packaging waste management systems across Europe. It offers a chance to build a resilient EU market for secondary raw materials and create the necessary conditions to meet the sustainability requirements set forth at EU level, such as those outlined in the Packaging and Packaging Waste Regulation.
It is essential that the CEA establishes a strong foundation for greater transparency and oversight in packaging waste management while driving increased investment in collection, sorting, and recycling infrastructure, supporting the EU’s decarbonisation and competitiveness objectives. The potential of Extended Producer Responsibility (EPR) schemes for packaging needs to be fully leveraged to support these goals and the new CEA should ensure:
The effective enforcement of Article 8a of the Waste Framework Directive, which outlines EU-wide general minimum requirements for EPR, established to foster the harmonisation of EPR governing principles, increase their transparency and cost-efficiency.
The banning of State-run EPR schemes and removal of all references to State-run systems from EU legislation. A basic principle of EPR is that the payment of a fee is linked to the delivery of a service, shifting responsibility for waste management away from the public sector towards the producers. Contrary to this, State-run models might entail that the fees collected from different producers will be used to finance the general State budget, rather than being reinvested in waste management operations for different waste streams.
The incorporation of the earmarking principle into EU law to ensure that EPR fees are effectively reinvested in the sorting, collection and recycling of packaging that are designed to be recycled in line with upcoming Design for Recycling criteria. (according to the net cost principle)
That’s right, our expectations for the new Circular Economy Act are high. As discussions to shape the future Act continue, we invite you to watch our video to learn how EPR schemes can drive sustainable packaging design, enhance recycling infrastructure, and foster true circularity. You will also discover why disparate national approaches and State-run systems risk slowing down progress.
For a deeper dive, explore our interactive map showcasing the EPR schemes for packaging currently in place across all 27 EU Member States. The map provides insights into how these systems function, who the key stakeholders are, and the degree of transparency they provide.
WHAT DID YOU MISS?
02 July 2025: Clean Industrial Dialogue on Circularity
WHAT’S NEXT?
From July 2025 (TBC): Public consultation on the new Circular Economy Act