On 1 August 2025, the European Commission (EC) launched a consultation and call for evidence[1] on its forthcoming proposal for a Circular Economy Act (CEA), a flagship legislative initiative designed to accelerate the EU’s transition to a more circular, sustainable and resilient economy. The CEA aims to address persistent barriers to circularity, foster more sustainable production and business models and support the EU’s decarbonisation objectives.
Objectives and Scope of the Circular Economy Act
The CEA is intended to establish a single market for secondary raw materials, increase the supply of high-quality recycled materials and stimulate demand for these materials across the EU. As a a central component of the EU’s broader policy framework, it will support the ambitions set out in the Competitiveness Compass and the Clean Industrial Deal to make the EU a global leader in the circular economy by 2030 and to double the EU’s circularity rate, which has remained largely stagnant for the past 15 years.
Key Policy Areas
The CEA will complement and align with other recent circularity initiatives including the Ecodesign for Sustainable Products Regulation (ESPR), the Packaging and Packaging Waste Regulation (PPWR) and the Critical Raw Materials Act. Its focus will include:
- Establishing a Single Market for Secondary Raw Materials: Harmonising rules to reduce regulatory fragmentation, facilitate cross-border movement of secondary raw materials and waste and lower costs for businesses.
- Boosting Supply and Demand: Considering legislative and non-legislative measures to ensure a sufficient and cost-effective supply of high-quality, verifiable secondary raw materials, including critical raw materials.
- E-waste: Improving collection, recycling, and recovery of valuable resources from the rapidly growing stream of electronic and electrical waste.
- Simplification and Digitalisation: Streamlining extended producer responsibility (EPR) schemes, introducing digital solutions, and setting clear end-of-waste criteria.
- Public Procurement: Exploring the introduction of mandatory circularity criteria in public procurement of goods, services, and works to drive market demand.
Next Steps
The consultation and call for evidence are open for feedback until 6 November 2025. The EC will then conduct an impact assessment of the proposed policy options, with the proposal for the CEA currently scheduled for adoption by the end of 2026.
For further information please contact the authors or your usual CMS contact.
[1] https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14812-Circular-Economy-Act_en.
