One Europe, One Market: One Circular Economy?
The conclusions of EU Heads of State at the European Council meeting in March 2026 were clear: the EU Single Market is Europe’s greatest asset. A ‘One Market’ approach, with harmonised EU-wide rules replacing 27 sets of national rules, is critical. Only by leveraging this asset will Europe be able to boost competitiveness and drive growth and resilience. The creation of a Single Market for secondary raw materials is therefore essential, and packaging has a key role to play in delivering this objective.
But where do we stand? Today’s waste management landscape across the EU remains highly fragmented, marked by uneven performance and divergent national regulatory frameworks. Nearly half of EU countries still landfill more than 30% of their municipal waste, with 4 reaching levels between 60% and 80%. When it comes to recycling, only 9 out of 27 Member States are expected to meet the 2025 recycling target. Expectations for the upcoming Circular Economy Act (CEA) are therefore high. The Act must be grounded in an internal market legal basis to deliver results. Without it, diverging national approaches risk deepening fragmentation. A harmonised framework will be key to unlocking scale, improving efficiency, and ensuring a level playing field across the EU.
This CEA’s anticipated focus on Extended Producer Responsibility (EPR) is also pivotal. Strengthening harmonisation in EPR, addressing national gold-plating, improving transparency and cost efficiency, and facilitating the free movement of waste can significantly enhance system performance, ultimately enabling the creation of a Single Market for secondary raw materials.
Making EPR an enabler, not a barrier
The European Commission’s recent Single Market Strategy highlighted that certain features of EPR schemes are among the most frequently reported barriers for companies operating cross-border in the EU. Fragmentation across schemes is also a drain on resources. In this context, the proposed suspension, via the Commission’s Environment Omnibus, of the authorised representative (AR) requirement for EPR under the PPWR until 2035 (for producers based in the EU) is a positive step forward. In a recent joint statement, EUROPEN and key stakeholders across the EPR landscape have underlined the importance of supporting the Commission’s proposal.
The mandatory appointment of national ARs creates fragmentation and limits scalability. It runs counter to the EU’s objective of removing unjustified barriers and enabling businesses to operate seamlessly across borders. The costs associated with national representation can be significant and vary widely across Member States and product categories. Strengthening EU-level mechanisms, such as data exchange, reporting, and risk-based compliance checks, can improve enforcement and fee collection without requiring national representatives. With the PPWR already providing for national producer registers (Article 44) to track compliance, these tools should be sufficient to ensure effective enforcement without imposing additional administrative burdens on EU-based producers.
Circular Plastics Alliance relaunched
The road to circularity is also advancing through renewed collaboration. The European Commission has relaunched the Circular Plastics Alliance (CPA), following its announcement in the Communication on “Accelerating Europe’s transition to a circular economy: boosting the circularity of plastics.” The revived Alliance aims to address the challenges facing the plastics sector and accelerate the uptake of recycled plastics. Its structure, comprising a General Assembly, Steering Committee, and Working Groups, will support targeted action across the value chain. Current members will remain on board, with no need to renew their commitment. The first Steering Committee and high-level meeting took place in March and April 2026, marking the official restart of the initiative, with next steps to follow.
WHAT DID YOU MISS?
- 10 December 2025: Publication of the Environmental Omnibus, “Simplification of administrative burdens in environmental legislation”
- February 2026: Joint industry statement, “An Internal Market Legal Basis to drive waste management step-change in the New Circular Economy Act”
- March 2026: Joint industry statement, “Industry Coalition Supports Temporary Suspension of National Authorised Representative Requirement Under EPR”
- March 2026: Relaunch of the Circular Plastics Alliance
WHAT'S NEXT?
- Q3 2026 (TBC): Publication of the EU Commission’s Circular Economy Act