Building on challenges and best practices identified among frontrunner cities and regions, ICLEI Europe and its members have provided nine policy recommendations to address the limitations of the current scope of the CEA:

1. Leverage circular economy to cut consumption-based emissions
2. Reduce material consumption to enhance the EU’s economic security
3. Ensure the transition to a circular economy is just and inclusive, leaving no one behind
4. Ensure a multilevel governance approach in policy development and implementation
5. Shift funding from piloting towards scaling-up
6. Build capacity in cities to support circular economy implementation
7. Build the case to reform the linear tax system
8. Leverage public procurement to provide a launch market for circular businesses
9. Send clear signals to de-risk private investment

GCE welcomes the Circular Economy Act initiative as a very important step forward in enhancing the circular economy in the EU. It highlights the need to rethink the current economic system in order to secure intergenerational and resource justice, uphold planetary boundaries and ultimately ensure the resilience and security of the EU.

However, incentivising the market for secondary materials will not suffice, and additional actions are needed:

• recycling is not enough: reusing and remanufacturing must be prioritised;
• steps must be taken to address overconsumption and overproduction;
• harmonised end-of-waste criteria, a systemic shift in business model, appropriate waste collection and the promotion of reuse and repair are particularly necessary in the textiles and electronics sectors.

In this position paper, FEAD offers its input for the Circular Economy Act consultation. 

It supports a CEA that turns circularity into a core competitiveness strategy for Europe by: 

• creating a predictable, integrated single market for recycled materials;
• activating strong, durable demand for recycled materials;
• aligning fiscal and financial tools with circular outcomes;
• strengthening governance, enforcement and administrative capacity so rules deliver in practice.

It proposes a binding target of 25% by 2030 for the Circular Material Use Rate. It argues that recycling and recovery must become industrial-scale resource streams, and that robust recovery and final treatment systems for residual waste are key for safeguarding system resilience and environmental protection.

ECOS believes that by adopting clear targets and definitions and reflecting prevention and reuse priorities in key legislative files, the CEA can deliver environmental and economic benefits.

It feels that the approach outlined in the Call for Evidence risks narrowing the CEA to the functioning of the internal market for waste and secondary raw materials, instead of addressing the structural causes of Europe’s linear economy or respecting the waste hierarchy. The CEA is an opportunity achieve the ambition of the Clean Industrial Deal, committing the EU to become a circular economy world leader by 2030. To succeed, the Act must rest on a dual legal basis, embed the waste hierarchy and lifecycle thinking and provide clear, harmonised definitions that guide implementation across Member States.

The Circular Economy Act is a pivotal opportunity to translate Europe’s ambitions into functioning markets by removing obstacles to the free movement of recycled materials and creating strong demand for circular products.

Recycling is a strategic enabler of circularity and plays a critical role in securing Europe’s economic resilience and decarbonisation agenda. Accordingly, Recycling Europe's policy recommendations aim to unlock demand, establish a level playing field for recycled materials and support the development of a globally competitive recycling industry aligned with the EU’s environmental and strategic objectives.