The European Commission has opened a public consultation on its proposed Circular Economy Act, inviting feedback from stakeholders across the manufacturing and chemicals sectors. Running from 1 August to 6 November 2025, the initiative is a critical step towards enhancing economic security, reducing import dependencies, and accelerating the EU’s green transition.
The regulation, due for adoption in Q4 2026, seeks to transform how waste and secondary raw materials are traded and used across the single market. Professionals in chemicals, electronics, construction, and transport supply chains should take note: the legislation could reshape supply dynamics and compliance requirements across Europe.
Driving Market Access for Secondary Raw Materials
The Circular Economy Act is designed to dismantle existing market barriers that hinder the free flow of waste and secondary raw materials. By improving access to high-quality recycled inputs, the Act aims to level the playing field for EU manufacturers competing against virgin material imports.
Fragmentation in current national interpretations of EU waste legislation has hampered cross-border recycling and reuse. According to the Commission, the EU’s circularity rate has stagnated at just 11.8% in 2023, a modest increase from 10.7% in 2010. The Act will address both regulatory inconsistencies and economic disincentives that prevent wider uptake of recycled materials.
Key Provisions: E-Waste and Procurement Reform
Two policy pillars underpin the proposed legislation. First, it targets electronic waste, the EU’s fastest-growing waste stream, with goals to increase collection, simplify rules, and incentivise recovery of critical raw materials like rare earth elements.
Second, the Act proposes reforms to public procurement, making it mandatory for authorities to prioritise circular products and services. Extended producer responsibility schemes are also set for digitalisation and expansion to encourage accountability throughout the product lifecycle.
These changes are expected to support the EU Green Deal, reduce lifecycle emissions, and strengthen the industrial base—especially among SMEs engaged in circular business models.
Impact Across the Chemicals Value Chain
Chemicals professionals must assess both risks and opportunities. Regulatory clarity may ease market entry for recycled inputs, but it also imposes new obligations for compliance, traceability, and performance verification. Stakeholders in packaging, coatings, industrial polymers, and related areas will need to realign sourcing strategies and reporting protocols.
The Act also intersects with existing frameworks like the Waste Framework Directive and Ecodesign for Sustainable Products Regulation, ensuring coherence but increasing the complexity of compliance landscapes.
