Antwerp: The Circular Economy Act will reach the European Commission’s table on 11 November 2026 at the earliest, after the proposal slipped from its original September slot. The date is provisional, according to trade reports from EUWID and ERP Ireland, and it follows concerns raised by the Regulatory Scrutiny Board about the impact assessment behind the file. ERP says the Board rejected the assessment, while EUWID says it raised concerns, so the exact wording of the Board’s verdict remains unclear.
Environment Commissioner Jessika Roswall said the Board’s main criticism was that the proposal did not address the demand side of the market enough. She stressed that the Commission wants to ease the burden on small and medium-sized businesses and to make secondary raw materials more competitive with virgin materials. She gave no detail on which waste streams might receive new end-of-waste criteria, which leaves recyclers guessing about the scope of the Circular Economy Act.
Trade press expects the package to centre on harmonised extended producer responsibility systems, common waste classifications and definitions, and simpler cross-border waste shipment procedures. A revision of the Waste Electrical and Electronic Equipment Directive is also expected inside the Circular Economy Act, covering collection targets, producer responsibility, scope and the recovery of critical raw materials. The legal basis is Article 114 of the Treaty on the Functioning of the European Union, which points to a single market for waste and secondary raw materials.
A January 2026 briefing from the European Parliament’s research service names the likely legal vehicles as amendments to the Waste Framework Directive, the Landfill Directive and the WEEE Directive. The briefing links the Circular Economy Act to the Critical Raw Materials Act target of covering 25 percent of strategic raw material demand from recycling. Lithium and rare earths recovered from electric vehicle magnets and electronic waste are the examples most often cited by officials.
Independent evidence is arriving ahead of the proposal. On 27 October ERP reported that the Commission’s research directorate had published five expert reports on public procurement, producer responsibility, recycled and bio-based content, WEEE and critical raw materials, and regional initiatives. The producer responsibility report recommends an EU-wide one-stop shop for producer registration and reporting, while the WEEE report recommends binding CENELEC treatment standards.
Industry positions are already set. BusinessEurope wants harmonised producer responsibility rules and tighter online market surveillance, while the Socialists and Democrats group wants mandatory eco-modulation of fees and incentives for repair. Ecodesign requirements appear in calls from consumer and environmental groups, but no source seen by this newsroom confirms them as part of the Circular Economy Act.
The consultation that fed the file ran from 1 August to 6 November 2025, and the Commission told stakeholders on 31 August 2026 that adoption would come before the end of the year. A further slip past 11 November would still meet that promise, although it would push parliamentary work into 2027. Packaging companies are watching closely, since earlier trade expectations pointed to stronger recycled-content and traceability duties.
For businesses, the practical task is to map their exposure to producer responsibility and waste shipment rules before the text appears. The Circular Economy Act will not take effect for years, because Parliament and the Council must agree on it first. Even so, the draft will set the terms of the debate on secondary raw materials in 2027, and the 11 November date is now the one to watch.
