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.

While welcoming the EU’s recognition of the circular economy’s transformative potential for the EU economy, RREUSE expressed concern about the current narrow focus on recycling and the lack of ambition to promote waste prevention and reuse.

Its recommendations are as follows:

Establish a right to reuse:

• Set binding separate targets for (preparing for) reuse;
• Set EPR fees in line with the waste hierarchy;
• Ensure full cost coverage of (preparing for) reuse activities;
• Prioritise reuse in future criteria for circular public procurement.

Unlock the full potential of social circular enterprises:

• Guarantee social enterprises’ access to waste streams and collection points, as well as ownership of collected materials;
• Allocate earmarked EPR funding for social enterprises;
• Apply zero VAT rates

Greening metals and minerals production, including CRMs, comes with higher capital and operating costs – a 'green premium'. This reflects investment in decarbonising production processes, ensuring robust environmental and social safeguards and advancing circularity.

Manufacturers appear hesitant to absorb such premia and a credible green-premium market for CRMs is unlikely to emerge without regulatory intervention.

This analysis has laid out a phased, two-tier pathway towards a premium market. The first tier would focus on setting minimum market-access requirements, in order to level the playing field and exclude the worst performers from EU market access. A second tier of instruments is therefore needed to reward those who exceed baseline standards through targeted, conditional incentives.

Academics for Circular Economy welcomes the creation of a Circular Economy Act that aims to address issues such as resource dependence, competitiveness, and environmental pressures. To leverage the full economic, social and environmental potential of the circular economy, the Circular Economy Act must address a number of critical points:

• Competitiveness through upstream innovation
• European resource independence by design
• Resilience of the single market
• Environmental protection via a regenerative bioeconomy
• Innovation driven by research and development