Brussels: The European Commission now plans to present its Circular Economy Act on 11 November 2026, according to its provisional timetable, after pulling the proposal from the third quarter. The Circular Economy Act was due earlier this autumn, but the Commission’s Regulatory Scrutiny Board raised concerns about the impact assessment and sent the file back for more work.
Environment Commissioner Jessika Roswall has said the board’s main criticism was that the draft did not do enough on demand. In plain terms, the Commission had to show how recycled materials will find buyers, not only how waste will be collected and sorted. Roswall also stressed that the new rules must ease the burden on small and medium-sized enterprises rather than add paperwork.
The delay matters because the Circular Economy Act sits at the heart of the 2026 Commission work programme, listed in Parliament’s legislative train tracker as an announced legislative proposal. The work programme itself carries the reference COM(2025) 870. Industry groups, recyclers and waste managers have waited months to see the text.
Early reporting points to a broad package. Officials are expected to propose harmonised extended producer responsibility schemes, common waste classifications and definitions, and simpler procedures for cross-border waste shipments. The aim is a genuine single market for waste, so that secondary raw materials compete with virgin materials on cost and quality instead of losing out to cheaper imports.
The package may also open the Waste Electrical and Electronic Equipment Directive. A revision could reset collection targets, widen the directive’s scope and push recovery of critical raw materials from old devices. The European waste management association FEAD has already set out its position on that revision. The Commission has not yet confirmed which waste streams could receive new end-of-waste criteria.
The timing also collides with a busy autumn in Brussels. Member states hold the European Council on 15 and 16 October, where leaders will debate competitiveness, and the Council’s own forward look for 12 to 25 October shows ministers juggling climate and biodiversity files as well. Supporters of the Circular Economy Act argue that cheaper, locally recovered materials strengthen Europe’s industrial base and cut dependence on imports.
Several questions remain open. Businesses want to know how far the Commission will harmonise producer responsibility fees, and national authorities want to know who pays for enforcement. Environmental groups want binding targets, while manufacturers want predictable rules before they redesign products.
For now, the 11 November date gives all sides a deadline. Once the Commission tables the Circular Economy Act, Parliament and the Council will start negotiating, and the final shape of Europe’s single market for waste will depend on those talks through 2027.
