Rotterdam: The Circular Economy Act is still a draft idea rather than law, and the Commission was expected to propose it later in 2026, according to an industry report published on 30 June. I could not confirm from the sources reviewed whether the proposal has been tabled since then, so businesses should check the Commission’s own page for the current status.
The report from ERP Ireland, a producer compliance scheme, says the Commission recently held a final stakeholder workshop to present emerging findings from its impact assessment studies. The discussion covered three themes. They were reducing dependency on imported critical raw materials, simplifying the regulatory framework for secondary raw materials, and strengthening access to circular feedstocks across the Single Market.
The emerging approach reportedly includes five elements. These are a wider scope for the rules on waste electrical and electronic equipment, mandatory material recovery targets, EU-wide recognition of end-of-waste status, digital registration systems for extended producer responsibility, and recycled content thresholds. The report gives no percentages, tonnages or deadlines, so the real ambition of the Circular Economy Act cannot yet be judged.
The legal basis matters. The report says the Commission relies on an internal market legal basis for the producer responsibility, end-of-waste and electronics provisions, which the author reads as a push for harmonisation over national discretion. That reading is the author’s interpretation, not Commission text. An internal market basis would make the Circular Economy Act bind all member states in the same way, ending the patchwork that producers complain about.
Politics around the Circular Economy Act is already visible. The Socialists and Democrats call for mandatory eco-modulation of producer fees, transparency in producer responsibility schemes and incentives for repair. BusinessEurope wants harmonised producer responsibility systems, stronger support for secondary raw materials and stricter market surveillance of online trade. Neither position is attributed to a named spokesperson in the report.
Why does it matter? Recyclers say they cannot invest without predictable demand for recycled material, and recycled content thresholds would create that demand. End-of-waste rules decide when a sorted material can be sold as a product instead of treated as waste, and today they differ from country to country. A single set of rules could therefore cut cross-border trade barriers for recyclers. The link to critical raw materials also ties the Circular Economy Act to the Union’s economic security agenda.
Readers should treat the details with caution. The source is a single secondary summary of unpublished thinking, and its publisher has a commercial interest in how producer responsibility rules turn out. Phrases such as emerging approach describe discussions, not decisions, and the report does not mention eco-design at all.
Three signals will clarify the picture. The first is the formal proposal and its date, the second is the numerical level of recovery and recycled content targets, and the third is the choice between a regulation and a directive. Until they appear, the Circular Economy Act remains a promise of simpler rules for secondary materials, and companies across the supply chain are right to prepare for tougher recovery duties.
