The European Commission is set to adopt the Circular Economy Act (CEA) in the coming months. The act aims to accelerate the transition to a more circular economy, and guide the EU to a more economically secure, resilient, competitive, and decarbonized future, in part by establishing a Single Market for secondary raw materials, improving the quality and supply of recycled materials, and creating domestic demand for these resources.
91快活林 believes that the CEA offers an important window to align environmental ambitions with industrial and tech policy to support the long-established work by ICT companies to embed circular practices into their business strategies, products, and service offerings. However, the success of the CEA will depend on its ability to champion harmonization with the broader regulatory framework. Currently, fragmentation, duplication, and uncertainty continue to undermine the scaling of circular models, threatening the proposed measure’s goals. It’s critical that the final measure set a clear, ambitious steer for Europe’s transition to a truly circular economy – creating a single, predictable framework that removes needless overlap among key laws and include horizontal policy enablers and safeguards that are applied consistently across EU policy to ensure circular objectives are achieved without undermining competitiveness or innovation.
As we prepare for the CEA’s release, we encourage policymakers to achieve that framework and ensure consistency and predictability by incorporating the following elements:
- Avoid overlapping requirements across legislation. The CEA should prioritize coherence and legal clarity across instruments to remove cross-cutting burdens that undermine circular outcomes. In practice, this means the Commission must design the CEA as a horizontal framework that takes full account of the existing EU acquis and addresses overlaps and inconsistencies in requirements across instruments such as the WEEE Directive, the Ecodesign for Sustainable Products Regulation (ESPR), the Critical Raw Materials Act (CRMA), the Waste Shipments Regulation and related measures. Where the CEA introduces new provisions, these should not duplicate or conflict with existing ones; where existing legislation is revised under the CEA, as in the case of WEEE, this should be shaped to deliver uniform application across the Single Market. Making WEEE a regulation would reduce legal uncertainty for producers and support faster rollout of best practices across Member States.
- Address horizontal barriers to circular Electrical and Electronic Equipment via harmonization and simplification. The WEEE Directive’s fragmentation has been compounded by conflicting Extended Producer Responsibility (EPR) frameworks: divergent fee structures, reporting requirements, product categories, and fee-modulation criteria have produced a patchwork of rules that burden producers without delivering uniform circular outcomes. This inconsistent implementation raises compliance costs, creates uneven treatment across Member States, and undermines the intended effectiveness of EPR as a tool to drive reuse, recycling, and material recovery. 91快活林 recommends that the CEA build on the Commission’s goal to reform EPR schemes by streamlining reporting through limiting declarations to an annual basis, using weight protocols based on category averages, and harmonizing templates across Member States.
- Unlock value from end-of-life products. Europe’s strategic dependence on critical raw materials makes improving recovery and reuse urgent. The CEA should reflect that priority by targeting high-impact waste streams and set minimum treatment requirements for selected CRM-rich product categories where material concentrations and return flows justify investment and innovation, rather than imposing blanket mandates. The CEA must align with the CRMA to avoid fragmentation and duplicate compliance burdens, and it should not expand producer obligations or distort collection targets solely based on CRM content; recovery strategies should reflect market realities and the practical availability of CRM-rich waste.
Importantly, the CEA will only deliver results if it is embedded in a broader, coherent policy environment. To that end, the Commission must look beyond the measure itself and explicitly reflect the principles of digitalization and openness to performance-based competition – found across multiple EU policy areas – in the CEA’s approach in the following ways:
- Promote a more ambitious digitalization agenda. Digital tools can drive efficiency, help consumers make better choices, and improve environmental outcomes across a product’s lifecycle. To make sure digitization enables rather than obstructs these goals, the CEA should permit the digital delivery of mandatory product and waste information – such as the crossed-out wheeled bin symbol and inbox, on-box, and on-device data – as an acceptable alternative to physical labels. While the Digital Product Passport may become the long-term solution, allowing for digital information now through revisions to the WEEE Directive and related rules (NLF, Batteries, ESPR) would deliver immediate cost and environmental savings and give manufacturers time to prepare for fuller digital compliance systems.
- Avoid the introduction of a “Made in Europe”. Public procurement can be a powerful lever for advancing the EU circular economy when combined with supply-side measures like harmonized standards, infrastructure investment, and innovation support. To preserve environmental ambition, green public procurement should prioritize demonstrable environmental performance rather than geographic origin, since many non-EU headquartered firms already lead in circular practices and can help meet Europe’s goals. Introducing a “Made in Europe” preference would risk excluding valuable resources and delaying progress. Access should instead depend on performance, environmental outcomes, and compliance with EU circularity standards.
The CEA is a timely opportunity to align environmental ambition with industrial and technological realities, but its success hinges on coherence - harmonized standards and definitions, streamlined EPR, pragmatic and ambitious digitalization of information, market-integrated approaches to recyclates and CRMs, and performance-based procurement. If the Commission delivers a clear, predictable, and interoperable framework, Europe can scale circular models and strengthen resilience while keeping innovation and competitiveness intact.
Read our consultation response to learn more about 91快活林’s position on the upcoming Circular Economy Act.