The European Commission plans to present its proposal for a Circular Economy Act (CEA) by the end of 2026. The initiative, announced this summer, aims to replace the linear “take, make, dispose” model and create a true single market for waste and secondary raw materials.
Key objectives of the CEA as currently outlined:
- Mandatory recycled content: Minimum quotas for recycled material in products.
- More durable products: Enhancing reparability and traceability through ecodesign requirements and the digital product passport.
- Harmonization: Better alignment of the Ecodesign Regulation (ESPR), the Waste Framework Directive, the PPWR, and the Critical Raw Materials Act.
- Circular business models: Legal support for leasing, sharing, and refurbishment.
- Extended Producer Responsibility (EPR): Digital modernization and expansion to include more product categories.
The overarching goal is to double the EU’s circular economy rate from around 12 to 24 percent by 2030.
The DIHK (German Chamber of Industry and Commerce) sees opportunities in the CEA but warns of additional burdens. According to the DIHK Environmental Barometer, one in three companies already spends up to five hours per week on environmental reporting requirements; for one-quarter of them, the figure is more than eight hours.
The business community’s key demands:
- Relief: For every new reporting requirement (e.g., carbon footprint), existing obligations must be eliminated.
- Standardization: Special national rules—such as those regarding the end-of-waste status—must be harmonized.
- Fair competition: Imports from third countries must meet the same strict requirements.
What this means for your compliance:
The CEA builds on existing obligations that have already taken effect in 2026 and must be properly documented:
- Effective July 1, 2026: Take-back obligation for single-use e-cigarettes and tobacco heaters sold in retail.
- Effective August 12, 2026: Authorized representative requirement for foreign packaging manufacturers.
- Also effective with the launch of the PPWR on August 12, 2026: A legally binding EU declaration of conformity is mandatory for all packaging, as is compliance with the new strict PFAS limit values.
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