For a law meant to redefine how the bloc handles its waste, the Circular Economy Act is drawing an awkward amount of criticism from the very people it was supposed to champion. When the European Commission wrapped up its final stakeholder workshop on the proposal in May, the Right to Repair coalition emerged warning that repair and reuse, the practices that keep products in use rather than shredding them into raw material, are largely missing from the emerging text.
The complaint cuts to a tension that has shadowed the Act since Environment Commissioner Jessika Roswall began shaping it. Officials frame the legislation, due to be tabled in the third quarter of this year, primarily as an industrial-policy instrument. Its headline ambition is a genuine single market for secondary raw materials: harmonised end-of-waste criteria, a steadier supply of recycled feedstock, and demand levers strong enough to double the EU’s circular material use rate to roughly 24 percent by 2030. Reducing dependence on imported resources gives the project an economic-security logic that resonates in the current geopolitical climate.
That framing is precisely what worries repair advocates. A circular economy built around recycling rewards throughput, because the more material flows into recovery streams, the better the numbers look. Repair, refurbishment and remanufacturing do the opposite. They slow the flow, extend product lifespans, and shrink the very waste volumes that recyclers depend on. Treating recycled content as the central metric risks privileging the least circular form of circularity while the higher-value options that keep a phone or washing machine alive go unrewarded.
There is a parallel track that complicates the picture. The Repair Directive, agreed separately, becomes applicable on 31 July, obliging manufacturers to offer repair within and beyond legal guarantee periods and giving consumers clearer access to spare parts. The Commission can therefore argue that repair is already covered and need not be duplicated in the new Act. Critics counter that a directive on consumer rights is no substitute for embedding repair incentives into the structural rules governing producers, procurement and extended producer responsibility, the areas the Act will actually reshape throughout this year.
The design choices ahead are unusually consequential. Work has been signalled on extended producer responsibility harmonisation, public procurement rules, reform of electronic-waste handling and broader resource-use considerations before the proposal lands. Each of these is a lever that could be tuned toward longevity or toward volume. Public procurement alone, given the scale of state purchasing across the bloc, could create durable demand for refurbished equipment if the rules permit it.
For businesses, the stakes are immediate. Packaging producers anticipate pressure toward reusable formats and simplified materials; electronics makers face the prospect of design obligations that assume a second and third life for their products. The lobbying over the next quarter will determine whether the Act becomes a recycling statute with circular branding or a genuine attempt to move Europe up the waste hierarchy. The coalition’s warning is essentially a plea not to settle the question by omission. Whether Roswall’s team listens before the autumn proposal will say a great deal about what circularity means in practice.




