Circular Economy Act

The Circular Economy Act is a key opportunity to strengthen EU's circularity via targeted legislation that supports material-efficient and genuinely circular systems. Together with the Critical Raw Materials Act, the Net-Zero Industry Act and the Clean Industrial Deal, the Circular Economy Act should become a central pillar of the EUs regulatory framework, helping to secure secondary raw materials within Europe…

APQuímica, the Portuguese reference association for the Chemical, Petrochemical and Refining sector appreciates the opportunity to express its views and submit its contributions on this public consultation regarding the upcoming EU Circular Economy Act (CEA) Proposal.

Comprehensive Legal Position of the Market Neutrality Research Forum (MNRF) to the European Commission concerning the Draft Circular Economy Act (CEA) Introduction On behalf of the Market Neutrality Research Forum (MNRF) a research centre analysing and safeguarding the principles of competition, market neutrality and regulatory efficiency in the EU we submit this legal position on the Draft Circular Economy Act…

The European Construction Industry Federation (FIEC) welcomes the initiative of a Circular Economy Act aimed at supporting the creation of a functioning and effective EU single market for waste and secondary materials. Circularity is a key driver of the sustainable transition and decarbonisation in construction, and it must be both strengthened and accelerated.

IFOAM Organics Europe welcomes the European Commissions initiative to accelerate circularity in the European Union (EU) through the Circular Economy Act. We support a systemic transition towards a resilient and fair circular economy, one that operates within planetary boundaries and strengthens rural communities.

European Plastic Films (EuPF) is the dedicated sector group of EuPC (European Plastics Converters), representing and uniting Europes plastic film producers. The sector provides a wide range of applications and is already investing heavily in recycling technologies and circular design to accelerate Europes transition toward a resource-efficient plastics economy.

The Réduire + network represents 60 French authorities involved in reducing waste and preserving soil. Among our different actions, we support at national level the extension of the EPR scheme for wipes by Europe to the whole range of single-use sanitary textiles, i.e.

Filed in French · English published by the European Commission

Łukasiewicz Research Network Institute of Non-Ferrous Metals (IMN), a leading European R&D Institution, specializing in the processing and recycling of non-ferrous metals, welcomes the European Commissions proposal for a Circular Economy Act.

The global economy is at a critical juncture, as interlinked environmental, social, and political pressures intensify. States are increasingly pursuing aggressive strategies to secure materials and resources for economic gain. In this context, the Circular Economy Act gives the EU the chance to lead strategically by embedding circularity at the core of its approach to prosperity, resilience, and strategic autonomy.

We welcome the initiative of the European Commission to prepare a comprehensive Circular Economy Act (CEA) aimed at accelerating the transition towards a more circular economy in the European Union. The forthcoming Circular Economy Act offers an important opportunity to reposition circularity from being seen purely as an environmental concept to a strategic industrial policy instrument that strengthens the EUs…

Proposal for Legislative Promotion of Circular Material Use including Closed-Loop Systems by the Alliance to Zero The Alliance to Zero advocates for the integration of a new category, circular material use, into the waste hierarchy across all legislation related to the EU Circular Economy Act and future initiatives.

Although characterised by different tasks and responsibilities in their own national contexts, the regulatory authorities (NRAs) generally aim to ensuring fair tariffs and transparency for citizens, a level playing field for operators, and quality of public services. NRAs are called upon to ensure the recovery the efficient costs of services, while supporting the necessary investments.

The Brewers of Europe fully supports the European Union ambition to transition to a circular economy and appreciates the opportunity to actively participate in the preparations for the Circular Economy Act. Circular economy is one of the key pillars of sustainable growth, enhances resource efficiency, reduces the environmental impacts of production and consumption, and contributes to the long-term competitiveness of…

Circular Economy Act – Mecaware Proposal We welcome the opportunity to contribute to the consultation on the Circular Economy Act (CEA). Below, we outline the Mecaware’s perspective on the main issues raised in the Call of evidence and propose targeted solutions to foster a robust, harmonised, and competitive circular economy in the EU. 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Circularity is no longer a niche environmental ambition - it is fast becoming a defining pillar of Europes industrial strategy. Amid mounting geopolitical pressures, volatile supply chains, and climate emergencies, the ability to retain materials, reduce resource dependence, and lower emissions has moved to the core of EU policymaking.

On behalf of WEEE Ireland, Irelands not-for-profit compliance scheme for electrical and electronic equipment (EEE) and batteries, we welcome the opportunity to respond to the European Commissions consultation on the Circular Economy Act. WEEE Ireland has more than 1700 Producer Members of EEE and/or Batteries onto the Irish market.

EMO Input to the Consulta1on on the Circular Economy Act EMO’s Commitment to Circularity The European Mortar Industry Organisa5on (EMO) strongly supports the principles of circularity. Efficient use of resources – including the reduc5on of waste and the promo5on of reuse and recycling – is essen5al to the long-term economic success and sustainability of our industries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Scope of submission. This submissions scope is limited to the impact of the circular economy to the Irish seafood sector (primary producers of aquaculture and wild capture) and auxiliary service providers (such as fishing and aquaculture gear providers and to a less extent marine electronics).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response to the European Commission – Ref. Ares(2025)9576237 - 06/11/2025 Call for Evidence: Circular Economy Act (CEA) 1. Summary The Free ICT Europe Foundation (FIE) represents independent ICT service providers, refurbishers, repairers, maintainers, and secondary-market operators who ensure that ICT equipment and Software can be repaired, reused, upgraded, and kept in service long after the original manufacturer…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Confederation of Finnish Industries (EK) welcomes the opportunity to provide its statement regarding the Circular Economy Act initiative. The circular economy is a key enabler of sustainable economic growth, competitiveness, and resilience in the European Union.

This comment is intended to recommend that the proposed bioeconomy framework include considerations regarding the source of the carbon use, reused and recycled within the Circular Economy Act and require the carbon-14 testing to determine the biomass-derived portions of products seeking the recognition of the renewable share, and to calculate GHG emissions savings caused by the adoption of biomass-derived products.

PLEASE FIND OUR FULL CONTRIBUTION ATTACHED. ESWET represents companies that have built and supplied over 95% of the Waste-to-Energy (WtE) plants in operation in Europe. Its mission is to promote technologies that safely treat non-recyclable waste while recovering valuable energy and materials, contributing to Europes climate goals, resource efficiency, and energy resilience.

Eurogroup for Animals’ answer to the EU Public Consultation on a Circular Economy Act While it is urgent to transition to sustainable and circular food systems, insect farming cannot deliver on enhancing circularity in EU agriculture. Authorising waste streams to be channelled to insect farms could threaten the safety of the food chain without sustainability benefits.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

JOUGA – SAS LADY COOCTTE welcomed the arrival of the Circular Economy Act (CEA) to stimulate demand for secondary materials and to build a genuine single market for waste. However, limiting ambition to the simple management of waste and recycling of raw materials will not allow the European economy to be truly competitive or to assume global leadership in circularity.

Filed in French · English published by the European Commission

Disclaimer: The recommendations and views presented are those of the International Cotton Advisory Committee (ICAC) Secretariat and do not represent the positions of ICAC Member countries. The International Cotton Advisory Committee (ICAC), representing 20 Member Governments including the EU, welcomes the Circular Economy Act (CEA) as a vital step toward a harmonized, fair, and globally responsible circular economy.

The Association of Finnish Cities and Municipalities (AFCM) thanks the European Commission for the opportunity to give feedback in this call for evidence. The AFCM represents all the 308 Finnish municipalities. In Finland, municipalities are central actors in implementing the EUs climate and environmental policies.

ETIRA (www.etira.org) represents the interests of the inkjet and toner cartridge remanufacturers in the EU. Reuse of a printer cartridge as a cartridge is textbook circularity. A cartridge can be reused as a cartridge multiple cycles, thereafter its materials can be recycled and used as raw material.

Accelerating circularity in Europe’s packaging industry Mondi Group’s position on the upcoming EU Circular Economy Act November 2025 Mondi Group Position on the EU Circular Economy Act 1 Introduction This paper sets out Mondi’s response to the European Commission’s public consultation on the upcoming Circular Economy Act.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Accelerating Circularity welcomes and celebrates the European Commission initiative to boost circularity in general, and we emphasize the importance of ensuring that textile-sector circularity is strongly included in this effort. Accelerating Circularity is an action-oriented nonprofit focused on achieving textile-to-textile recycling at commercial scale through a collaborative, stakeholder-led approach.

The Insect Institute is a non-profit, non-governmental organization (NGO) dedicated to conducting research and providing policymakers, the public, investors, NGOs, and other stakeholders with evidence-based recommendations concerning the farming of insects as food and feed globally. Thank you for the opportunity to submit feedback on the Commission's plans to propose a Circular Economy Act.

Avfall Sverige (Swedish Waste Management) welcomes the opportunity to contribute to the European Commissions consultation on the forthcoming Circular Economy Act and the Clean Industrial Deal. In our submission - Turning Non-Recyclable Waste into European Resilience - Avfall Sverige presents a proposal on how high-efficiency Waste-to-Energy (WtE) facilities, integrated with Carbon Capture, Utilisation and Storage…

VTTI is developing an advanced recovery project for end-of-life tyres. We appreciate the Commissions efforts to establish a robust policy framework for circularity and would like to offer input on several key aspects based on our industrial experience and ongoing investments in circular technologies. Please find our contribution attached.

As a recycler and manufacturer of plastic compounds with production and development sites in Europe, MOCOM welcomes the objective of the Circular Economy Act to strengthen a competitive, climate-friendly and circular industry within the European Union. To achieve this goal in practice, we propose the points set out in the attached document.

Ecoembes appreciates the opportunity to participate in the public consultation process for the forthcoming Circular Economy Act. We are committed to supporting the European Commission in its efforts to advance the transition towards a more circular, resilient and competitive economy.

The NSPA stands ready to contribute to the development and implementation of the Circular Economy Act. We call on the European Commission to ensure that the voices of Europes northernmost regions are heard and that the CEA reflects the diversity of regional contexts across the Union. A truly inclusive and resilient circular economy should be built with and for all regions.

XXXXX welcomes the arrival of the Circular Economy Act (CEA) to stimulate demand for secondary materials and to build a genuine single market for waste. However, limiting ambition to the simple management of waste and recycling of raw materials will not allow the European economy to be truly competitive or to assume global leadership in circularity.

Filed in French · English published by the European Commission

VinylPlus has uploaded a document describing the following recommendations to deliver a Circular Economy in Europe, for Europe: - Revise Technical Guidance on waste classification to ensure waste classification follows an End of Life (EoL) product classification logic. - Make pre-demolition/renovation audits and the separate collection at source, and identification of recyclable waste streams, mandatory.

Founded in 2017, CirculR is a leading voice on the circular economy in France and internationally, recognized for its close collaboration with businesses, public institutions, and local authorities. We are dedicated to supporting both public and private organizations in their transition towards circular business models and operations.

adopted an Bureau welcomes the arrival of the Circular Economy Act (CEA) to stimulate demand for secondary materials and to build a genuine single market for waste. However, limiting ambition to the simple management of waste and recycling of raw materials will not allow the European economy to be truly competitive or to assume global leadership in circularity.

Filed in French · English published by the European Commission

Please find attached BEUC's contribution to the call for evidence on the Circular Economy Act. We are pleased to share our views so this proposal delivers for consumers in Europe, as circular economy policies need to keep consumer needs in mind.

Call for Evidence for the upcoming Circular Economy Act Our contribution to the problems identified in the call for evidence Reframing waste as a resource: Advocates treating end-of-life plastics as valuable feedstock, not waste, to unlock circularity and reduce reliance on virgin materials.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Swedish Aggregates Industry (SBMI) represents producers of aggregates that form the base of Europes infrastructure. Circular handling of excavated soil, rock and recycled aggregates is already central to reducing emissions, improving resource efficiency and strengthening supply security.

VNO-NCW (Confederation of Dutch Industry and Employers) and MKB-Nederland (Dutch Federation of Small and Medium-Sized Enterprises) are pleased to share their position paper presenting the Dutch business perspective on the EU Circular Economy Act (CEA).

Thank you for the opportunity to provide additional input to the Circular Economy Act. Ørsted supports the Commissions efforts to boost the circular economy as circularity can be a powerful tool towards decarbonization, environmental protection, competitiveness and supply chain resilience.

ICL Group, a manufacturer of innovative and sustainable fertilizing products and one of the leading EU players in recycled fertilizers, welcomes the opportunity to contribute to this consultation and share its views on advancing a circular economy for nutrients.

Unknown or toxic chemical content in recycled material is a main hurdle for increased use in products. While many companies have very high ambitions to increase this use, the material available is often not meeting their standards that are in place to ensure safety.

Secure and affordable access to raw materials is critical for the competitiveness of European businesses and for advancing the green and digital transitions. Yet, Europes continued dependence on external suppliers remains a strategic vulnerability.

Irish Manufacturing Research in its capacity as Secretariat of CIRCULÉIRE (Irelands National Circular Manufacturing & Innovation Network) and on behalf of our >50 cross-sectoral industry members welcome the ECs proposal to develop a Circular Economy Act (CEA) and support the objective to address fragmentation within Europes CE landscape.

The Saami Council, a voluntary Sámi organization representing Sámi interests and rights across Finland, Sweden, Norway, and Russia, welcomes the opportunity to contribute to the European Commissions consultation on the potential of a Circular Economy Act.

Climate change plus rare natural resources demand a shift toward sustainability and circularity in economy. This transition requires an inclusive, resilient, and competitive bioeconomy, underpinned by systems analysis and modelling.

Classification of the climate impacts of the circular economy Recommendations and background Authors: Prof. Dipl.-Ing. Frank Baur HTW of the Saarland Prof. Dr. Peter Hense HS Bochum Prof. Dr. Soraya Heuss-Aßbichler LMU Munich Prof. Dr rer. nat. techn. Marion Huber-Humer BOKU Vienna Prof. Dr Mario Mocker OTH Amberg-Weiden Prof. Dr. techn. Helmut Rechberger Vienna University of Technology Prof. Dr.-Ing.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Setting quotas in the circular economy Recommendations and background Authors: Prof. Dipl.-Ing. Frank Baur HTW of the Saarland Prof. Dr. Peter Hense HS Bochum Prof. Dr. Soraya Heuss-Aßbichler LMU Munich Prof. Dr. rer. nat. techn. Marion Huber-Humer BOKU Vienna Prof. Dr. Mario Mocker OTH Amberg-Weiden Prof. Dr. techn. Helmut Rechberger Vienna University of Technology Prof. Dr.-Ing. Gerhard Rettenberger HS Trier Prof.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Summary of Key Recommendations for the Future EU Circular Economy Regulation A. Definitions The regulation should expand and harmonize definitions across EU legislation (e.g., Waste Framework Directive, Eco-design for Sustainable Products Regulation, Batteries Regulation).

Circularity is essential to the sustainability of the built environment sector, due to its cross-cutting role with other main sustainability issues like decarbonisation and biodiversity conservation. Beyond the environmental benefits, we are convinced that the development of circular practices can generate significant financial savings and strengthen the competitiveness and robustness of our business models.

Schneider Electric welcomes the future publication of the EU Circular Economy Act, viewing the circular economy not merely as an environmental initiative, but as a strategic framework that can help meet the goals of both the European Green Deal and the Clean Industrial Deal. Schneider Electric outlines four key policy recommendations to make the Circular Economy Act effective and impactful: 1.

ReZorce Ltd Kinetic Business Centre Watford WD6 4PJ UK [email removed] ReZorce Limited welcomes the EU’s Circular Economy Act (CEA). The past 50 years or so have seen an explosion in consumerism combined with a demand for convenience: together, these factors have resulted in a significant increase in per capita waste generation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As the European value chain initiative to realise the circular economy for styrenic plastics, Styrenics Circular Solutions (SCS) welcomes that the Commission has again confirmed the EUs commitment to accelerate the transition towards circularity.

Circular Economy Act Commentaires et recommandations de Automotive Mobility Europe Novembre 2025 La Commission européenne a lancé une consultation publique sur le futur acte législatif relatif à l’économique circulaire, qu’Automotive Mobility Europe salue favorablement afin de soutenir le développement de ce domaine.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Department of Public A3airs and Communication Circular Economy Act Commentaires et recommandations de Mobilians Novembre 2025 La Commission européenne a lancé une consultation publique sur le futur acte législatif relatif à l’économique circulaire, que Mobilians salue favorablement afin de soutenir le développement de ce domaine.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Czech Association for Marked Products (ČSZV) recommends that the Circular Economy Act (CEA) place particular emphasis on: a. streamlining and aligning the minimum requirements and obligations for Extended Producer Responsibility (EPR) and b. initiatives aimed at increasing the availability of quality secondary raw materials, including ensuring access to feedstock. On the contrary, demand-side measures (e.g.

Filed in Czech · English published by the European Commission

Circular Economy Act Eastman contribution to the Public Consultation – November 6, 2025 Ambitions – contradictions – solutions 1) Ambitions of Eastman and European Commission: Eastman has a rich history of innovation for over 100 years and drives material solutions for a wide range of applications; industries packaging, building and construction, medical, consumer durables, automotive, agriculture and more, making…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eni S.p.A. welcomes the initiative of the European Commission to introduce a Circular Economy Act, which can play a pivotal role in supporting the development of a single market for waste and secondary raw materials while increasing the supply and demand for secondary raw materials and circular products.

The Council of European Municipalities and Regions (CEMR) is the representative organisation of local and regional governments in Europe, bringing together more than 100,000 municipalities, cities and regions from 40 countries. Local and regional governments are at the heart of the circular economy transition.

The International Council on Clean Transportation (ICCT) is pleased to provide feedback to the call for evidence of the Commissions Circular Economy Act. The ICCT is an independent nonprofit organization founded to provide first-rate, unbiased research and technical and scientific analysis to environmental regulators.

Comments from the Nordic Swan Ecolabel to the Circular Economy Act - Call for evidence for an impact assessment Nordic Ecolabelling supports the EU Commissions proposed Circular Economy Act. Especially the focus on increasing the use of recycled material and setting mandatory, targeted, impactful and implementable criteria for public procurement of circular goods is highly supported.

FEEDBACK Towards a Repairable Europe: Right to Repair Europe’s Input on the Circular Economy Act Brussels, November 2025 The Right to Repair Europe coalition represents over 180 organisations from 30 European countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Sonae welcomes the opportunity to contribute to the European Commission Call for Evidence on the Circular Economy Act. Our feedback, outlining key considerations and recommendations to strengthen the proposal and support its effective implementation, is provided in the attached document.

We welcome the Commission's ambition to strengthen the circular economy and reduce Europe's dependence on imported raw materials. However, we caution against including insect farming as a circular economy solution. Evidence indicates that incorporating food waste into insect production risks causing significant health liabilities while delivering marginal circularity benefits. 1.

Priorities include: establish a coherent policy framework in the EU for exports, imports and domestic demand (of waste and materials generated by their treatment), increase demand for recycled materials, create a strong single market for recycled materials, accelerate the clean and circular transition.

Filed in Italian · English published by the European Commission

IMA-Europe Position Circular Economy Act (CEA) - Open public consultation FINAL (6 November 2025) Industrial Minerals Association Europe (IMA-Europe) representing the interests of industrial minerals producers in Europe, welcomes the opportunity to provide stakeholder input on the Circular Economy Act (CEA) publication and highlight the specificities of the minerals sector and the implementation challenges with…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EDF welcomes the European Commission initiative to propose a Circular Economy Act to facilitate the free movement of circular products, secondary raw materials and waste. We share the belief that it will enhance the EUs economic security and competitiveness, while promoting more sustainable production, circular economy business models and decarbonisation.

Detailed ESRG-Response = attached Only Summary / ESRG Proposal: In support of this sector to establish: 1. Mechanisms to see the waste hierarchy is better used, justified and enforced. 2. Harmonized end-of-waste criteria at EU level, like existing solutions, based on a study led by the Joint Research Centre, with contributions from the ESRG supporting the three mentioned elements

Bekaert welcomes the objectives of the proposed Circular Economy Act (CEA) to strengthen EU competitiveness, economic security, and sustainability. We support a harmonized, science-based, and market-oriented approach that ensures consistent product standards, avoids overlap with existing legislation, and promotes fair competition between EU and non-EU producers.

Eurogypsum, the association representing European manufacturers of gypsum products such as plaster, plasterboard, and gypsum blocks, supports the European Commissions ambition to advance the circular economy and welcomes the forthcoming proposal for a Circular Economy Act. Today, buildings account for 40% of global raw material use, and construction generates millions of metric tons of waste annually.

Etex welcomes the European Commissions initiative to develop a Circular Economy Act (CEA) as part of the Clean Industrial Deal and the Competitiveness Agenda. As a leading European manufacturer of sustainable construction materials including plasterboard, fibre cement, insulation, fire protection solutions and offsite construction Etex fully supports the ambition to accelerate circularity and resource efficiency…

The Marine Care Association (MCA) is the trade association representing companies serving the collection and management of waste generated by the shipping industry. The association provides a unique platform for Port Reception Facility operators managing about 3 million tonnes per annum of ship generated wastes, enabling both upstream and downstream players to network, exchange good practices, and propose solutions…

GEREGRAS ASSOCIATION with VAT: G85148609 represents its partners at Spanish and European level vis-à-vis any public or private body. It provides the necessary support for the optimal development of its activity: Waste managers and edible fats and oils sub-products.

Filed in Spanish · English published by the European Commission

Global 2000 welcomes the creation of a Circular Economy Act. This opportunity must be used to implement a truly circular economy within planetary boundaries. This requires strengthening the first stages of the circular economy hierarchy rather than pushing for a purely market-based, recycling-focused circular economy that cannot fulfil the purpose of reducing material flows.

Filed in German · English published by the European Commission

FEAD, the European Waste Management Association, represents the entire waste and resource recovery sector in Europe, including collection, sorting, recycling, energy and material recovery, and the final disposal.

Paris, le jeudi 6 novembre 2025 Numéro de registre de transparence : 30032231266-82 Position de la Fédération nationale des Travaux Publics (FNTP) sur l’économie circulaire L’économie circulaire constitue un levier majeur de la transition écologique et, à cet égard, doit être renforcée et accélérée.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ERSAR is the Water and Waste Services Regulation Authority in Portugal, with a statute of independence regarding the economic and quality of service regulation of municipal waste services. Under that mandate, ERSAR has an intervention in the implementation of the policy and in the approval of tariff regulations and opinions on investments to be made by municipal waste management operators.

TITLE OF THE INITIATIVE LEAD DG (RESPONSIBLE UNIT) Circular Economy Act DG ENV B3 (‘From Waste to Resources’) and DG GROW I4 (‘Sustainable Products Comments from Ministry of the Environment in Finland Finland appreciates the EU’s aim to use circular economy to boost the EU’s economic security, resilience, competitiveness and decarbonisation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Contribution de France urbaine à la consultation publique de la Commission européenne relative à un futur acte législatif pour l’économie circulaire France urbaine réunit les grandes villes, agglomérations et métropoles de France, composées de 2 000 communes de toutes tailles rassemblant près de 30 millions de Françaises et de Français.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback to Call for Evidence on Circular Economy Act The Circular Economy Act will facilitate the free movement of ‘circular’ products, secondary raw materials and waste. It will also increase the supply of high-quality recycled materials and stimulate demand for these materials in the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The upcoming Circular Economy Act represents a crucial opportunity to align EU frameworks and deliver on the objectives of the Clean Industrial Deal and Competitiveness Compass. It can strengthen systemic, market-based incentives and policy-driven initiatives for biobased and recycled alternatives to fossil-based inputs, driving competitiveness and enabling a sustainable transition towards circularity.

The Renewables Grid Initiative (RGI) welcomes the opportunity to provide feedback to the call for evidence on the upcoming Circular Economy Act (CEA). In a world of scarcity and rising geopolitical tensions, circularity is not only an environmental imperative but a strategic necessity for Europes security, competitiveness, energy and economic resilience, and job creation.

On behalf of ATEDY, the Spanish Technical and Business Association of Gypsum representing manufacturers of Gypsum such products as plaster, drywall panels, and Gypsum boards, we are pleased to submit our formal contribution to the public consultation on the Circular Economy Act. ATEDY supports the European Commissions ambition to advance circular economy principles and welcomes the upcoming legislation.

Filed in Spanish · English published by the European Commission

Bioenergia ry the Bioenergy Association of Finland believes that the EUs bio- and circular economy plans should promote development of EUs productivity, where the Union faces significant challenges compared to competitor countries. Ideally, new bio- and circular products will increase the added value and employment of the European economy and reduce its environmental footprint.

MedTech Europe envisions a future where healthcare systems are environmentally and financially sustainable, equitable and resilient to future crises. Building such resilient and sustainable healthcare systems requires a robust, competitive, and innovation-driven medical technology industry.

Steels recyclability is a strategic advantage for Europes green transition. Smart policies that prioritize scrap quality, CRM recovery, and domestic processing will accelerate decarbonization, strengthen resource security, and maintain EU industrial competitiveness.

Dear Sir/Madam, Finnish Minerals Group supports a Circular Economy Act that promotes circularity through innovation, proportionate regulation, and industrial collaboration, while strengthening Europes raw material independence. Recycled content targets should be designed to support responsible and sustainable European primary production.

The CEA supports the future Circular Economy Act and in particular all measures aimed at creating a single market for secondary raw materials, increasing the supply of high quality recycled materials and stimulating demand for such materials in the EU.

Filed in French · English published by the European Commission

Founded in 1960 FESI, the Federation of the European Sporting Goods Industry, is the unique pre-competitive platform representing the interests of the sporting goods industry in Europe, advancing its members priorities and promoting initiatives that benefit the sector, EU citizens and the society as a whole.

From WEEE to European Self-Sufficiency: Empowering Public Waste Operators to Secure Critical Raw Materials 6 November 2025 CONTENTS EXECUTIVE SUMMARY…………………………………………………………………………………………………………………..… 2-4 EXPLANATORY …………..………………………………………………………………………………………………………………..….

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Solstice supports the European Unions ambition to accelerate the transition to circularity. Increasing refrigerant circularity is essential to meet the EUs decarbonisation goals. We encourage the European Commission to be ambitious by: 1) Explicitly including Hydrofluoroolefins (HFOs) within the scope of the WEEE Directive: As part of the WEEE revision, the Commission should establish a minimum quantity of…

ECSPA’s input to the Circular Economy Act 1 ECSPA’s Commitment to Resource Efficiency and Circularity The European Calcium Silicate Producers Association (ECSPA) fully endorses the principles of circular economy and sustainable resource management. Efficient use of raw materials and the reduction of waste are essential to the competitiveness and environmental responsibility of our industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EUREFAS (the European Refurbishment Association) welcomes the proposed Circular Economy Act as a way to stimulate demand for secondary materials and harmonize a single market for waste. However, it warns that the CEA overlooks a core pillar of circularity: product lifetime extension through reuse or repair of electrical and electronic equipment.

Priorities for the upcoming EU Circular Economy Act We call for Reduction first in respect of waste treatment hierarchy The reduction part of the 3 R is currently under developed, funded and we lack incentives and penalties Reduction should be the driver of the circular act : reduction of raw materials and ressources use, reduction of quantities of products and focus on quality and durability, reduction of all kind…

CLC welcomes the ambition of the EU Circular Economy Act (CEA) and recognizes circularity as a vital element of European resilience and environmental sustainability as well as competitiveness. Circularity and access to materials is critical for the EUs industry. The EU needs to secure access to such materials and reduce dependence on unreliable suppliers.

Green Deal, Circular Economy Package, Clean Industrial Deal... The European Union has one of the most encouraging legislative frameworks for sustainability. Across Europe, the adoption of circular models proved that it is possible to move from a throw-away economy and dependency on uncertain supply chains, to a more resource-efficient economy that creates local value.

Filed in French · English published by the European Commission

FINAL VERSION FOR ADOPTION – 4 NOVEMBER 2015 MWE RECOMMENDATIONS FOR THE CIRCULAR ECONOMY ACT NOVEMBER 2025 Municipal Waste Europe aisbl, Rue d’Arlon 63, B-1040, Brussels - Tel: [phone removed] – VAT: BE0816952509 Web: www.municipalwasteeurope.eu FINAL VERSION FOR ADOPTION – 4 NOVEMBER 2015 RECOMMENDATIONS FOR THE CIRCULAR ECONOMY ACT Our Priorities for the Circular Economy Act (CEA): 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Hydro, the largest producer of aluminium in Europe and one of its top three recyclers of aluminium, with operations in 18 EU countries, welcomes the opportunity to contribute to the public consultation on the upcoming Circular Economy Act (CEA).

EUCOPRO European association for co-processing brings together European best in class management companies dealing services of recovery and treatment of hazardous waste. We treat and transform hazardous waste into alternative fuels and raw materials. Our waste products substitute fossil fuel and raw material in industrial processes by co-processing.

Distribution supports a clear, enforceable and predictable law, consistent with the framework already adopted in the EU, that reduces waste in a verifiable manner and administrative complexity by eliminating duplication, without compromising consumer confidence.

Filed in Spanish · English published by the European Commission

The European Federation of Corrugated Board Manufacturers (FEFCO) welcomes the opportunity to contribute to the consultation on the Circular Economy Act. The Corrugated cardboard industry operates within a mature, closed-loop system. With a recycling rate of 86.6% paper and cardboard packaging remain the most recycled packaging materials in Europe.

November 2025 Position on the EU’s Circular Economy Act Key messages BASF welcomes the European Commission’s ambition to make Europe a global leader in the circular economy by 2030. To reach that ambition, BASF believes that the upcoming EU Circular Economy Act (CEA) should: • Provide a coherent and up-to-date legislative framework to support both cross-cutting and sector-specific measures, aligning upstream…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Material use and waste generation show no signs of significantly decreasing in the EU, and it is clear that ambitious measures are required to remedy this. The Rethink Plastic Alliance is therefore advocating for an EU Circular Economy Act that truly rises to the challenge and reflects the urgent need to reduce, reuse and recycle materials.

ESGRA – Associação para a Gestão de Resíduos is the Portuguese association of the waste management systems´ companies. Established in 2009, its purpose is to protect the interests of the national waste management system, with the aim of contributing to the development of management practices that promote good sanitation and environmental standards and to the country's sustainable development in a circular economy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Public consultation on “Circular economy act” Input from ferrous and non-ferrous metals industry A3M – l’Alliance des Minerais, Minéraux et Métaux - represents players with operations in France in the fields of mining, metallurgy and steelmaking.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Econic supports the overarching objective of the Circular Economy Act in fostering resource efficiency and promoting sustainable industrial practices. Circularity is essential to the transition toward a sustainable economy, and the reuse of carbon within material and chemical systems plays a critical role in achieving that goal.

GRDF is the leader Distribution System Operator (DSO) in France, managing more than 200.000 km of distribution grid, serving more than 11 million households, companies and industrial customers. Sustainability is at the heart of our companys strategy: by 2050, we plan on reducing the gas distributed by two and entirely substitute fossil gas by green gases.

Founded in 1973, the Fédération de la Haute Couture et de la Mode (« the FHCM » or « the Federation ») represents over a hundred of the most recognised French and international fashion Houses, covering creative designers and high-end segments of the fashion industry.

CRECEMOS Position Paper on the forthcoming European Circular Economy Act 1. General assessment As an association representing the renewable fuels value chain, the circular economy sector in Spain, and sustainable mobility, CRECEMOS welcomes the European Commission’s public consultation on the forthcoming European Circular Economy Act, framed within the Green Deal Industrial Plan and the Competitiveness Compass.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

APEP, the European Potash Producers Association, representing the potash mining sector and ‎fertilizer industry in the EU, welcomes the opportunity to comment on the European ‎Commissions call for evidence on a Circular Economy Act for Europe.

International Synergies Limited (ISL) has been active in the field of industrial symbiosis for over 20 years, delivering economic, environmental and social benefits through projects in more than 50 countries across six continents. ISL welcomes the European Commissions initiative for a Circular Economy Act (CEA).

We support the EU Commission ambition to accelerate the transition to a circular economy, while ensuring EU-wide harmonization and simplification. We encourage the EC that the Circular Economy Act (CEA) focuses on: (i) simplification and harmonization of EPR minimum requirements and reporting; (ii) measures to increase supply of high-quality secondary raw materials and (iii) development of the EPR one-stop shop (EPR…

Europes transition towards climate neutrality and a sustainable circular economy requires a rapid and ambitious scale-up of the biomass-derived sector, supported by robust and consistent policy starting with a strategic framework for a competitive and sustainable EU Bioeconomy. To be a global leader in circular bioeconomy, the EU must move beyond incremental measures.

Outokumpu comments the planned Circular Economy Act The circular economy is advancing, but more encouraging examples of its business models are needed. Achieving a true circular economy requires well-functioning markets. We support the general purpose of the planned Act, as it will facilitate the free movement of circular products, secondary raw materials and waste.

The construction and building sector have huge potential in terms of resource savings and waste reduction. Action must be taken urgently to apply circular economy principles in these sectors, and architecture has a crucial role to play here.

CAOBISCO, the Association representing the Chocolate, Biscuits and Confectionery Industries of Europe, welcomes the European Commissions initiative to propose a Circular Economy Act and appreciates the opportunity to contribute to this public consultation. Our detailed feedback is attached to this document.

Enrich Environmental Ltd is an Ireland-based circular economy company specialising in the treatment of bio-waste, production of high-quality soil improvers and compost, and recovery of recyclables from residual municipal waste. The company operates at the interface of biological resource management, recycling markets, and soil health restoration. Recommendations: 1.

As farmers face increasing pressuresfrom climate stress to market volatilitythey need access to a broad toolbox of innovative, sustainable solutions. The updated Circular Economy Act (CEA) must support greater market access for circular products, such as specific plant biostimulants, which play a crucial role in helping farmers remain competitive while enhancing resilience and sustainability.

Siemens Healthineers is a leading provider of medical technology, principally active in the areas of imaging, diagnostics, cancer care and minimally invasive therapies augmented by digital technology and artificial intelligence.

The Circular Economy Act provides a unique opportunity to enable the construction sector to transition from a linear to a circular economy, while at the same time achieving the EUs decarbonization, competitiveness, and sustainability goals.

Supporting Sustainable Materials, Repairability and Reconditioning The CEC believes that the CEA should adopt a broad approach that promotes not only secondary raw materials but also circular, sustainable and durable materials such as leather. Leather is inherently circular, produced from raw hides and skins that are by-products of the food industry.

European Association for Ductile Iron Pipe Systems (EADIPS®) / Fachgemeinschaft Guss-Rohrsysteme (FGR®) e. V.: Statement on the Circular Economy Act To: European Commission Subject Inclusion of underground infrastructure in the Circular Economy Act Date 6 November 2025 Dear Madams and Sirs EADIPS®/FGR® e. V.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The CEA represents a major opportunity to advance Europes transition to a circular economy. For our sector, the central issue lies in ensuring that the CEA creates a coherent, harmonised and practical framework that genuinely enables circularity across Europe, without imposing disproportionate or conflicting obligations on retailers and other actors in the electronics value chain.

The transition to a circular economy, which is central to this consultation, necessarily involves the entire agri-food chain closely. Like Filiera Italia, we reiterate our support for initiatives to simplify legislation and administrative burdens for businesses in the sector so that circular economy becomes a real opportunity for profitability, with the consequent real and concrete consequences of increasing…

Filed in Italian · English published by the European Commission

The European Commission announces a Circular Economy Act (CEA) in Q4 2026, a regulatory framework to promote the circular economy in the EU single market and strengthen the EU’s resilience. The proposed Regulation aims to help create sufficient supply and demand for secondary raw materials and a genuine internal market for waste and secondary raw materials.

Filed in German · English published by the European Commission

The transition to a circular economy, which is central to this consultation, necessarily involves farmers closely. Like Coldiretti, we reiterate our support for initiatives to simplify legislation and administrative burdens for farms so that circular economy becomes a real opportunity for the sector in terms of profitability, with the consequent real and concrete consequences of increasing environmental…

Filed in Italian · English published by the European Commission

The steel industry welcomes the European Commission's initiative to prepare a comprehensive Circular Economy Act (CEA) to accelerate the transition towards a more circular economy in the European Union. The forthcoming CEA offers an important opportunity to reposition circularity from a purely environmental concept to a strategic industrial policy instrument that strengthens the EUs competitiveness, resilience, and…

Effective enforcement is essential to ensure that the European Unions upcoming Circular Economy Act remains both achievable and capable of strengthening the competitiveness of European industry. APPLiA, representing the Home Appliance Industry, together with a coalition of other leading industry associations, is calling for concrete action to remove persistent barriers that continue to hinder circularity.

Organic-Based Fertilisers (OBFs) are prime examples of the circular economy in action in the EU. The OBF industry transforms what would otherwise be discarded materials from other agricultural and industrial processes into refined fertilising products for the benefit of farmers.

To improve Agri-plastics circularity, APE Europe recommends setting voluntary or compulsory National Collection and Recycling Systems throughout the EU. Since 2013, voluntary collection and recycling systems for agricultural plastics have made remarkable progress across Europe, expanding the range of products covered and steadily increasing both collection and recycling rates.

The Circular Economy Act represents an opportunity to move beyond the EUs current fragmented waste policy and embed circularity as a core pillar of Europes industrial and climate strategy, creating the harmonised, predictable conditions needed for circular business models.

We agree with the Circular Economy Acts objective of increasing circularity in the single market and helping to create sufficient supply and demand for secondary raw materials and the development of a true Single Market for waste and secondary raw materials. The initiatives stated goal of targeting several regulatory and market failures is commendable.

Key messages: - Strong business cases for circularity: The Circular Economy Act must correct market failures to create robust, profitable business cases on a large scale. Transitioning to a circular economy not only requires clear recycled content standards and phasing out high-impact materials, but also strong structural economic incentives to reward circularity and stimulate demand, including through public…

Feedback to consultation. Established in 2024, the Advanced Packaging Association (APA) brings together key industry stakeholders who recognize polyamide (PA) as a sustainable, high-performance material for packaging applications.

Underdog salue larrivée dun Circular Economy Act (CEA) pour stimuler la demande en matières secondaires et bâtir un véritable marché unique des déchets. Cependant, limiter lambition à la simple gestion des déchets et du recyclage des matières premières ne permettra pas à léconomie européenne dêtre réellement compétitive ni dassumer un leadership mondial en matière de circularité.

Bruxelles, le 6 novembre 2025 R E P O N S E A L A C O N S U L T A T I O N P U B L I Q U E C O M M I S S I O N E U R O P E E N N E D E L A Circular Economy Act Lien vers la consultation : https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14812-Circular-Economy-Act_en Contexte de la consultation publique Pilier essentiel du Clean Industrial Deal, la circularité constitue un levier essentiel…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Mandatory Recycled Content Requirement For man-made fibres the EU should introduce a binding traceable recycled content obligation at product level in the upcoming Circular Economy Act. This will create market certainty and drive innovation in recycling technologies whilst maintaining the EU industry competitive in markets where it would otherwise be at a cost disadvantage.Gradual and Predictable Roadmap Targets…

The German Textile Cleaning Association welcomes the Circular Economy Act. Our position paper addresses 5 key issues that should be tackled: 1. In our view, it is essential that the legislation does not focus exclusively on new circular economy models. Established and economically successful circular business models already exist today and make a valuable contribution to conserving resources.

Being a cross-sectoral association with member companies operating in different industries and across various stages in the supply chain, the Japan Business Council in Europe (JBCE) and the Japanese associations in Japan welcomes the opportunity to contribute to the Call for Evidence on the Circular Economy Act.

Montpellier Méditerranée Métropole is fully committed to the development of a circular economy aimed at transforming production and consumption models in order to preserve resources, limit waste and develop local employment.

Filed in French · English published by the European Commission

CECOP, the European Confederation of Industrial and Service Cooperatives, welcomes the opportunity to provide feedback to the European Commission on the Circular Economy Act (CEA). CECOP represents approximately 43,000 cooperatives across Europe, being mainly worker cooperatives, social cooperatives and cooperatives of autonomous workers1. In turn they employ over 1.3 million people.

Toy Industries of Europe (TIE) welcomes the opportunity to contribute to the Call for Evidence on a Circular Economy Act. To fully exploit the potential of circular economy, TIE calls on the European Commission to develop a comprehensive Act that respects sectoral needs, guarantees harmonised rules in all Member States, consolidates rights and duties of all actors involved and corrects distortions.

The CEA should ensure that SMEs are not marginal actors but central players, driving innovation, circular business models, and transparency through data and technology. To achieve this, the European DIGITAL SME Alliance puts forward a set of key recommendations to enable SMEs to thrive in the circular economy and strengthen Europes industrial sovereignty.

Meta welcomes the European Commissions proposal for a Circular Economy Act, supporting its aims to strengthen the EUs economic security, competitiveness, and sustainability. Meta values the Acts intended focus on promoting sustainable production, circular business models, and decarbonisation, as well as its efforts to reduce legal uncertainty and remove barriers within the single market.

31 Ottobre 2025 Consultazione CEN - Circular Economy Act Proposte del Sistema CONAI L'economia circolare è uno dei pilastri della strategia dell'Unione Europea per favorire una transizione sostenibile, contribuendo a una gestione più efficiente delle risorse e a una riduzione delle emissioni.

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The metals ecosystem is pivotal to Europe's industrial base and plays a critical role in enabling the twin green and digital transitions. Non-ferrous metals from the base ones (aluminium, copper, lead, nickel, tin, zinc) through technology metals (e.g. cobalt, lithium, germanium, vanadium, gallium, bismuth) to precious metals (e.g.

European Aluminium, the association representing the full aluminium value chain in Europe, welcomes the European Commissions consultation on the Circular Economy Act (CEA) and restates its commitment to continue boosting the growth of aluminium recycling in Europe and alongside secure Europes economic security, strategic autonomy, decarbonisation objectives and competitiveness.

In 2023, the EU generated over 58 million tonnes of food waste, valued at approximately 132 billion. Meanwhile, in 2024, 38.2 million people, corresponding to 8.5% of the EU population were unable to afford a meal with protein every second day.

The European Furniture sector follows closely and contributes to several initiatives under the European Green Deal, including the Ecodesign for Sustainable Products Regulation (ESPR) or the Waste Framework Directive, to name a few. In this context, we welcome the opportunity to provide comments to the Commissions public consultation on the Circular Economy Act.

PET EUROPE outlines key recommendations to ensure that the CEA reinforces Europes circular leadership and industrial resilience. The association calls for measures to foster market demand for high-quality, strengthen trade and market-defence tools to maintain a level playing field, and align EPR and recycled-content policies with Europes production and investment objectives.

We strongly welcome the European Commission’s initiative to create a Circular Economy Act (CEA). The transition to a truly circular economy is a key building block for resource conservation, sustainability and competitiveness in Europe. E-commerce plays a central role in the success of the circular economy.

Filed in German · English published by the European Commission

CLEPA Recommendation on the EU Circular Economy Act Executive Summary CLEPA welcomes the European Commission’s initiative to develop the Circular Economy Act (CEA), viewing it as a key instrument to ensure the sustainability, competitiveness and industrial autonomy of the European automotive sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Unilever supports the EUs ambition for a circular economy and is committed to sustainability, innovation, and circularity across its value chains. We are taking voluntary action to reduce virgin plastic use by increasing recycled content, light-weighting packaging, and exploring alternative materials and formats.

As a consortium, we generally welcome the EU Commission's initiative to accelerate the transition to a circular economy through the Circular Economy Act (CEA). Our joint position builds on the policy expertise and practical experience of several regional networks: Circular Berlin (CB), Circular Black Forest (CBF), and Steinbeis Consulting Center Circular Economy, and the realisation of more than 20 projects on the…

Summary of E3G's recommendations for the Circular Economy Act - for the full feedback, please see the attached document: 1) Set overarching EU targets on resource use, accompanied by a comprehensive monitoring framework to create long-term predictability.

Registre des représentants n° 841999438055-85 Octobre 2025 Contribution de la FFB sur le projet d’Acte pour une économie circulaire La Fédération Française du Bâtiment (FFB) est forte de 50 000 adhérents, dont 35 000 de taille artisanale. Ces entreprises réalisent les 2/3 des 208 milliards d’euros HT du chiffre d’affaires et emploient les 2/3 des 1 258 000 salariés du secteur 1.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Sok supports the Commission’s objectives with regard to the Circular Economy Act, which can bring significant benefits to both the economy and the environment. It is important that circular markets function as part of the development of the internal market and that the legislative act is able to create a favourable market environment for the circular economy, including waste and secondary raw materials.

Filed in Finnish · English published by the European Commission

Confapi, the Italian Confederation of Small and Medium Private Industry, represents and supports Italys industrial SMEs the backbone of the national productive system. Confapi welcomes the initiative for a Circolar Economy Act (CEA), recognizing circularity as essential for the EUs strategic autonomy and competitiveness.

As one of the largest global sporting goods manufacturers and retailers, Decathlon aims to reduce its environmental footprint as a way to further strengthen the European circular economy. Therefore, Decathlon welcomes the European Commissions ambition to adopt a Circular Economy Act that removes single market barriers, strengthens the economics of secondary raw materials (SRMs), and accelerates reuse, repair…

Building on its leadership in the circular economy, the EU has an opportunity to lessen reliance on external energy and raw materials, reinforcing its resilience and strategic autonomy. The upcoming Circular Economy Act should address current regulatory gaps and strengthen circular value chains, while confirming its environmental commitment.

The MEMN calls for the Circular Economy Act, beyond an environmental text, to be a real structuring lever for European sovereignty. In this context, it supports, in particular, the following proposals: 1. Implement the recycling deposit as a pragmatic and effective European lever to improve the collection and recycling of packaging, promoting the development of the least CO2-emitting containers (rPET, PET and…

Filed in French · English published by the European Commission

UBQ Materials strongly supports the goals of the Circular Economy Act, and we are pleased to have this opportunity to provide feedback on the subject. We offer several recommendations, which are discussed in more detail in the attached file: 1) Enhance the supply of quality secondary materials, to be broadly defined to include innovative materials produced from residual waste along with conventional recycled…

SmartBack welcomes the arrival of the Circular Economy Act (CEA) to boost demand for secondary materials and build a genuine single market for waste. However, limiting ambition to the simple management of waste and recycling of raw materials will not allow the European economy to be truly competitive or to assume global leadership in circularity.

Filed in French · English published by the European Commission

With a significant number of ships expected to reach the end of their service life in the coming years, ship recycling presents a strategic opportunity for Europe. Boosting ship recycling in the EU will: - secure a steady supply of secondary raw materials for the internal market and strengthen Europes industrial resilience and strategic autonomy by reducing dependence on virgin raw materials; - make a meaningful…

Independent Retail Europe highly welcomes the Call for Evidence regarding the Circular Economy Act that is due to be published in 2026. A harmonized overarching framework in the form of a Circular Economy Act can bring consistency in the circular strategy of the EU. Sustainability and circularity bring opportunities but also many challenges for the independent retail sector.

The Icelandic Recycling Fund (IRF) welcomes the proposed revision of the Circular Economy Act, to enhance the EUs economic security and competitiveness, while promoting more sustainable production, circular economy business models and decarbonization. IRF has operated as an Extended Producer Responsibility (EPR) scheme since 2003.

Plastics are integral to the European economy, serving a wide range of strategic industries such as automotive, packaging, construction, electronics, healthcare, renewable infrastructure and consumer goods. Although the European plastics value chain currently supports around 1.5 million jobs across more than 50,000 businesses2, the warning signs are clear: production lines are shutting down, plants are closing, and…

The Spanish Mineral Water Association (ANEABE) thanks the European Commission for launching the process of the future European Circular Economy Act. We fully share the objective of boosting the circular economy in the European Union by strengthening the single market for waste and secondary raw materials.

Filed in Spanish · English published by the European Commission

Royal Vopak welcomes the opportunity to provide input on the European Commission's Call for Evidence for a Circular Economy Act. We are committed to the energy transition, are involved in the development of a storage plant for pyrolysis oil from chemical recycling in the Netherlands. Our response to the consultation is attached.

The European Union (EU) has established itself as a global leader in promoting circular economy (CE) principles, setting benchmarks in resource efficiency and industrial sustainability. However, other global economic powers, such as the United States and China, are also advancing towards circularity, emphasizing the need for Europe to maintain and enhance its competitive edge.

The cannabis industry association (BvCW) represents more than 100 companies and traders from all sectors of the cannabis industry, working, among other things, to fully develop the sustainability potential of hemp materials. In the industrial hemp sector, the criticised stagnation of the circularity rate is more recently reflected in market conditions for hemp producers.

Filed in German · English published by the European Commission

The chemical industry is a cornerstone of Europes economy and an essential enabler of circularity across all value chains. Its products and technologies form the foundation of numerous downstream sectors such as automotive, construction, packaging, agriculture, textiles and electronics.

Brussels, 6 November 2025 SERRED’s contribution Circular Economy Act SERRED, the European association representing, defending and promoting the interests of industrial packaging reconditioners, welcomes the European Commission's initiative to develop a Circular Economy Act (CEA) to accelerate the EU's transition towards circularity.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European recycling industry is facing a profound crisis. In addition to increasing competition from cheaper primary raw materials and low-cost recycled materials from third countries pursuing aggressive trade policies, the sectors competitiveness is further undermined by the growing number of battery fires that destroy recycling facilities or make them extremely difficult to insure.

We welcome the EU’s initiatives and legislation on the circular economy so far. However, key indicators for the circular economy, such as the circularity rate and per capita consumption of primary raw materials, show that the EU still has a long way to go to largely closed loops and effective resource protection.

Filed in German · English published by the European Commission

The recycling of flat glass presents environmental and industrial advantages and should therefore be explicitly integrated into the Circular Economy Act. Incorporating recycled glass cullet into new flat glass production reduces energy consumption, as cullet melts at lower temperatures than virgin raw materials.

Murfy praised the arrival of the Circular Economy Act (CEA) to boost demand for secondary materials and build a genuine single market for waste. However, limiting ambition to the simple management of waste and recycling of raw materials will not allow the European economy to be truly competitive or to assume global leadership in circularity.

Filed in French · English published by the European Commission

FNADE welcomes the European Commissions decision to take up the crucial issue of circular economy through this ambitious initiative. Our members, industrial actors in waste management and resource recovery, see this proposal as a key step towards strengthening the EUs sovereignty, competitiveness and industrial resilience.

CME welcomes the opportunity to submit input to the preparation of the Circular Economy Act, which can be found in attachment. CME recommends that it is also considered to explore fiscal measures that support circular choices, notably reduced VAT on second-hand goods and on the shipping of second-hand goods.

'ELVALHALCOR S.A. welcomes the Commission's initiative for public consultation on the Circular Economy Act. We believe that the Circular Economy Act will emerge as the cornerstone for enhancing the EUs industrial competitiveness and strategic autonomy, improve supply chain resilience and accelerate the transition to a green and circular economy, thereby contributing to the EU economy as a whole.

Södra Rooted in the Forest, Growing the Future Founded in 1938 on the idea that we are stronger together, Södra is Swedens largest forest-owner association with over 50,000 members. Together, we operate a world-leading industrial business that transforms forest raw material into renewable products such as pulp, timber, building systems, liquid bioproducts, and energy.

The SIRRMIET, representing Frances refurbishers and second-hand electronic distributors, welcomes the European Commissions ambition to accelerate circularity through the upcoming Circular Economy Act (CEA). Refurbishment is identified as a strategic pillar for achieving the EUs climate neutrality, resource independence, and competitiveness objectives.

AIM, the European Brands Association, represents manufacturers of branded consumer goods in Europe in the food, beverage, personal care, home care, luxury, toy and apparel categories. Our members are all intent on delivering trusted and high-quality goods to consumers across Europe.

ADIVALOR is a long-term member of APE Europe. We are completely aligned with APE Europes contribution to this consultation as well as with the contribution of the COMITÉ DE LA PLASTICULTURE ET DE LAGROENVIRONEMENT (CPA) with which ADIVALOR operates the French scheme.

FEDIAF is the voice of the European pet food industry. We represent 15 national pet food industry associations and five pet food manufacturers operating in Europe, accounting for around 95% of the market. We work closely with EU institutions, national authorities, scientific bodies and NGOs to ensure the availability of safe, nutritious and high-quality pet food across Europe, while promoting best practices and…

The European Union Circular Economy (CE) Act offers a pivotal opportunity to expedite Europe's transition towards a clean, competitive, and resource-efficient economy. As the industry association representing 39 European mechanical ventilation manufacturers and six national associations across Europe, our organisation is firmly committed to the overarching objectives of this Act.

As the Netherlands leading short-sea port and an integral part of Europes industrial ecosystem, Port of Moerdijk welcomes the European Commissions initiative to develop a new Circular Economy Act (CEA). In the enclosed document we would like to offer our recommendations for the CEA reflecting Port of Moerdijks specific role in developing and managing our port and industrial area.

Introduction The Circular Economy Act presents a critical opportunity to reinforce circularity through targeted legislation that supports material-efficient and truly circular systems. By complementing the Critical Raw Materials Act, the Net-Zero Industry Act, and the Clean Industrial Deal, the Circular Economy Act stands as a cornerstone of the EUs regulatory framework, helping to secure secondary raw materials…

HWE feedback Circular Economy and Hazardous Waste 1/ Not all hazardous waste is recyclable, and the treatment is determined by the characteristics of the waste. HWE welcomes this consultation and emphasizes the need to take into account the specific nature of hazardous waste streams in terms of circularity.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The International Union of Property Owners (UIPI) welcomes the opportunity to contribute and share the vital perspective of property owners on the forthcoming Circular Economy Act (COM(2025) 85). As an association representing private property owners, be they owner-occupier households or individual as well as professional landlords, we recognise the crucial role of the built environment in achieving resource…

Primark welcomes the Circular Economy Act (CEA) as an important opportunity to strengthen Europes transition to a more circular and resource efficient economy. We believe the CEA can help create a coherent and harmonised EU legislative framework, which if, supported by investment and incentives, can help companies adapt supply chains, invest in circular innovation, and improve competitiveness.

November 2025 Position Paper accompanying CEFLEX’s submission to the Circular Economy Act public consultation Key Messages CEFLEX’s Model for Circularity • About half of primary food packaging units on the EU market are flexible formats, although they represent only 17% of food packaging by weight.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EuroWindoor supports the general objectives of improving resource efficiency, facilitating recycling and stimulating demand for circular products in the internal market. However, we would also like to point out that any recommendation or requirement must be chosen with care, taking into account the differing situation of each product group especially in the construction sector with very long-lasting products.

Essity is a leading global hygiene and health company touching the lives of 1 billion people every day. Europe is one of our primary markets for developing, producing, and distributing our products such as tissue paper products, absorbent hygiene products e.g. incontinence products, menstrual products, baby diapers as well as wound care products and other medical solutions.

Refashion, the recognised eco-body of the Producer Enlargement Sector (REP) for textiles, footwear and household linen (TLC) in France, calls for the construction of an integrated European ecosystem, guaranteeing genuine industrial sovereignty and effective circularity of TLC. The Circular Economy Act must become a major lever for industrial structuring in the service of this European sovereignty.

Filed in French · English published by the European Commission

The Union supports the EU Commission ambition to accelerate the transition to a circular economy, while ensuring EU-wide harmonization and simplification. The Circular Economy Act is great opportunity to streamline and clarify the EU legislation through targeted revisions of EU rules and the introduction of new measures.

COSMED fully supports the ambition of the Circular Economy Act to boost EU competitiveness while accelerating the shift to more sustainable production, circular models, and decarbonisation. However, we would like to stress that the transition towards a circular economy must be pursued without losing sight of the health and safety considerations specific to certain sectors.

The EU Circular Economy Act represents a vital opportunity to shift Europe's economy toward a model that prevents waste, reduces emissions, and enables a market for secondary raw material. The IKEA business is committed to advancing the circular economy and a well-crafted Circular Economy Act can accelerate the green transition, contribute to climate goals, and deliver environmental, social, and economic benefits…

UNIFE, the European Rail Supply Industry Association, welcomes the European Commissions call for evidence for an impact assessment on the Circular Economy Act. This upcoming regulation proposal will be vital for the rail supply industry, as circular-economy business models are central to it. Rolling stock can remain in service for over 40 years, transporting millions of passengers and tonnes of freight.

06.11.2025 (25) EU 23 FEFAC contribution to call for evidence Circular Economy Act FEFAC welcomes the opportunity to contribute to the call for evidence for the impact assessment anticipating the Circular Economy Act. We strongly support the objective of increasing circularity as a key driver for EU Competitiveness Compass objectives on competitiveness, decarbonisation, and reduced strategic dependencies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The INNOAQUA Project (https://innoaquaproject.eu/), funded under Horizon Europe, aims to advance circular aquaculture by integrating sustainable practices such as Recirculating Aquaculture Systems (RAS) and Integrated Multi-Trophic Aquaculture (IMTA). These systems convert fish farming effluents and by-products into high-value outputs (algae-based food ingredients, bio-based food contact materials).

The URBACT Action Planning Network LETS GO CIRCULAR! - Paving the way for a circular transition of cities funded by the URBACT IV programme strongly supports the EUs ambition establish a Single Market for secondary raw materials, increase the supply of high-quality recycled materials and stimulate demand for these materials in the EU.

Waste-to-Energy (WtE) is an essential public-service infrastructure that safely treats residual, non-recyclable waste, supports high recycling quality by removing contaminants, and recovers materials and energy that would otherwise be lost. Like this, the waste we generate is returned to the economy not only as secondary raw materials, but also as energy.

Emerson’s response to the call for evidence on the Circular Economy Act Introduction Emerson is a leading importer, manufacturer, and distributor of electrical and electronic equipment.1 Together with batteries and packaging, we make EEE available on the EU market.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The BMW Group supports the development of the EU's circular economy legislation by presenting a concrete and holistic concept. This paper is intended to present an underlying strategic concept and go beyond individual positions.

The TRUSTex consortium, Textile Extended Producer Responsibility (EPR) schemes oriented, contribution to the Circular Economy Act consultation reflects a systemic perspective on textile performance and quality, addressing regulatory foundations, technical systems, economic instruments, infrastructure development, social dimensions, market mechanisms, and governance structures as interconnected elements that together…

Europes excessive material and consumption footprint has severe social and environmental consequences worldwide. We cannot continue to extract from a finite planet, nor recycle our way out of the current ecological crisis. The EU urgently needs to move away from a linear economy and ensure that resource extraction, processing, and waste do not exceed what the Earth can sustain.

The City of Umeå welcomes the European Commissions initiative on the Circular Economy Act (CEA) and strongly supports its ambition to accelerate Europes transition towards circularity. Located in the Arctic-subarctic north, Umeå is an innovation-driven city recognised for leadership in climate neutrality and circular economy.

Corporate Leaders Group Europe (CLG Europe) welcomes the ambition of the Circular Economy Act and urges the Commission to ensure it delivers a coherent, impactful framework that accelerates Europes transition to a circular, resilient and competitive economy. Please find attached the evidence submitted on behalf of CLG Europe.

6 November 2025 Concrete Europe Making the Circular Economy Act work for the Construction Ecosystem Concrete Europe response to the Commission’s call for evidence for the upcoming Circular Economy Act. As the voice of the European concrete industry, Concrete Europe fully supports the transition to a more circular, resilient, and resource-efficient economy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir or Madam, In the name of Foodvalley and The Upcycling Community (https://foodvalley.nl/en/upcycling-community/), we strongly support the Circular Economy Act and specifically its pivotal role in enabling the growth of, among others, circular food - also known as upcycled food, by removing common hurdles on value chain partnerships and market uptake.

The Interreg Euro-MED Innovative Sustainable Economy (ISE) Mission welcomes the opportunity to contribute to the consultation on the EU Circular Economy Act (CEA), a crucial step toward a sustainable and resilient Europe.

The Baden-Württemberg Ministry of Environment, Climate and Energy supports the Commission’s efforts to create a circular economy act and to establish a functioning internal market for waste and secondary raw materials, including critical raw materials. We would like to thank you for the opportunity to comment on this. Please find our detailed comments in the annex.

Filed in German · English published by the European Commission

As a National Promotional Institution, we believe its important that the Circular Economy Act also addresses barriers to investments. KfW is part of the Joint Initiative on Circular Economy (JICE), a partnership between the EUs largest National Promotional Banks and Institutions and the European Investment Bank aiming to provide long-term financing for projects that accelerate the transition to a circular economy.

Province of Zuid-Holland - input on the EU Circular Economy Act The province of Zuid-Holland has set its target to become fully circular in 2050. We therefore welcome Europe’s mission to achieve circularity in 2050 and to become global leader in circular economy by 2030, as presented in the Clean Industrial Deal. Current developments however, show a different trend.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

GROW INTERNATIONAL welcomes the European Union's continued ambition to advance the circular economy. The principles of designing out waste, keeping materials in use, and regenerating natural systems are fundamental to a sustainable future. Wooden packaging is a valuable material stream to be optimised.

Sirk Norge represents Norway's waste and recycling industry and its stakeholders. Our 200 members (private and public companies) handle materials across all waste streams. We have over 30 years of industry-specific knowledge to promote and develop responsible waste management and circular economy policies.

Input to the public consultation on the Circular Economy Act Europe has shown that when public funding and private entrepreneurship are brought together around a clear mission, systemic change can accelerate. A leading example is EIT InnoEnergy, established by the European Institute of Innovation and Technology (EIT) to drive the energy transition.

Public Consultation on the upcoming Circular Economy Act NMWE’s Contribution Natural Mineral Water Europe (NMWE) welcomes the Commission’s objective to increase circularity in the single market by creating sufficient supply and demand for secondary raw materials as well as a true single market for waste and secondary raw materials in the upcoming Circular Economy Act (CEA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association for the Return and Recovery of Waste Electrical and Electronic Equipment (Vere) e.V. is the largest German association with some 4000 members. Since its creation in 2003, it has been working for manufacturers, distributors and importers of electrical and electronic equipment and other non-food products to reduce bureaucracy and strengthen the circular economy.

Filed in German · English published by the European Commission

November 2025 DHL Group Call for Evidence Contribution: Circular Economy Act DHL Group welcomes the opportunity to contribute to the European Commission’s call for evidence and public consultation on the upcoming Circular Economy Act. Introduction: DHL Group as Industry Leader DHL Group is the world’s leading logistics company.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Chemical Regions Network (ECRN) welcomes the European Commissions proposal for a Circular Economy Act (CEA) as a key step to strengthen the European Green Deal and accelerate the transition toward a competitive, resource-efficient, and climate-neutral economy by 2050. Circular economy is not only an environmental goal but a strategic industrial policy.

CirkelWaarde welcomes the European Commission's intention to adopt the Circular Economy Act in 2026. This initiative is necessary to enable and accelerate the transition to a circular economy. We hope the Commission adopts some bold systemic changes in this Act, as those are whats needed to realise a truly circular Europe.

Ireland welcomes this opportunity to inform the Commissions ambition to consolidate and strengthen EU legislation on the circular economy, increasing the EUs circular material use rate from circa 12% today to 24% by 2030. Ireland also supports efforts to strengthen the EUs economic security, boost competitiveness and supporting economy wide decarbonisation from circular solutions.

AEB Amsterdam supports the goals of the Circular Economy Act and highlights five priorities. First, the EU should ensure a functioning internal market for residual waste and Waste-to-Energy (WtE), without new taxes or restrictions on cross-border shipments. The Netherlands has high-efficiency WtE overcapacity that can help other Member States avoid landfill.

Seite Magistratsdirektion Bereichsleitung für Klimaangelegenheiten Europäische Kommission Rue de la Loi 200 1040 Bruxelles Magistrat der Stadt Wien MD-BLfK | Vordere Zollamtsstraße 11/9 1030 Wien [email removed] wien.gv.at/umwelt/klima MDBLK-817482-2025 Online Konsultation: Rechtsakt über die Kreislaufwirtschaft Wien, 06.11.2025 Sehr geehrte Damen und Herren, Wien bekennt sich ausdrücklich zu den globalen…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Beryllium Science and Technology Association (BeST) represents the manufacturers, suppliers and users of beryllium metal, beryllium containing alloys and beryllium oxide ceramics in the EU market. Please find attached BeSTs position statement on the Circular Economy Act.

We welcome the European Commissions initiative to develop a Circular Economy Act and wish to express our strong support for the key priorities outlined by APRA Europe. We believe the considerations listed in the attached LKQ document are essential for the Acts success and for achieving the EUs environmental and sustainability goals.

KLM welcomes the opportunity to participate in the call for evidence of the Circular Economy Act and would like to share its contribution from our experience to the better drafting of the text. The Circular Economy Act offers a critical opportunity to address long-standing regulatory barriers that hinder circularity in the aviation sector.

Position of the Association for Sustainable Business on the European Commission’s Public Consultation on the Circular Economy Act The Association of Sustainable Business – Asociace udržitelného podnikání z.s. (AUP) is a professional association bringing together companies that are actively engaged in sustainabilityrelated topics.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Confederation of Industry of the Czech Republic (SPČR) welcomes the European Commissions initiative to create the Circular Economy Act (CEA) as a tool to strengthen the EUs competitiveness, strategic autonomy, and climate neutrality. The document emphasizes the need for realistic legislative settings without excessive administrative and financial burdens, with a focus on harmonizing existing rules.

Europes ports play a crucial role in the transition towards greater circularity. ESPO therefore welcomes the intentions set out in the Clean Industrial Deal and views ports as key players in establishing the announced Trans-Regional Circularity Hubs. Ports can serve as important nodes in the circular economy by linking inland circular activities (such as urban mining or repair centres) with international markets.

The province of Noord-Brabant urges the European Commission in drafting the new Circular Economy Act to: Prioritize lifespan extension To become truly circular, we must above all, prioritize extending the lifespan of products and prevent waste from being generated in the first place. More focus on efficient use of feedstocks and materials is therefore needed as well as more focus on repair and refurbishment.

The Plastics masterbatch, compounding and converting Industry is a cornerstone pf the Eus strategic value chains and is committed to leading the transition to a circular economy. However, this transition and the Eus strategic autonomy are at risk. Ambitious regulations such as the Packaging & Packaging Waste Regulation or the End-of-Life Vehicles Regulations fix ambitious targets in this transformative journey.

Promoting the circular economy especially at the EU level is a high priority for the German economy. In addition to ecological benefits, such as contributing to climate protection, there is also economic potential.

Enel welcomes the Commission initiative to develop an EU Circular Economy Act as a key element for a sustainable energy transition, recognizing its central role in accelerating the transition to a more sustainable, resilient, and competitive European economic model.

MOBICCON-PRO Project Consortium Response Regarding the forthcoming European Circular Economy Act The partners involved in the MOBICCON-PRO initiative are pleased to see the Commissions efforts to push forward the Circular Economy Act and express their full support.

6 November 2025 ERA contribution for the EU Circular Economy Act The European Rental Association (ERA) represents the equipment rental industry in Europe and promotes rental as a cornerstone of the circular economy and sustainability in the industry. Rental is, by definition, a circular business model1. It is one of the proven examples of circularity in practice, especially in the B2B relations.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Semiconductor Industry Association (ESIA), representing the European leader-ship in semiconductor research, design, and manufacturing, would like to comment on the po-tential impact of the upcoming Circular Economy Act and the revision of the Waste Electrical and Electronic Equipment (WEEE) Directive on the sector. Semiconductors are the core of Europes clean and digital transitions.

On behalf of the Spanish Confederation of Mineral Raw Materials Industries (PRIMIGEA), we are pleased to submit this Position Paper on the forthcoming Circular Economy Act (CEA). PRIMIGEA represents the extractive and primary materials industries of Spain, encompassing the production and transformation of essential mineral resources that underpin Europes industrial, energy and construction value chains.

Jastrzębska Spółka Węglowa S.A. (JSW) is the largest producer of coking coal in the European Union, recognised as a critical raw material, and a key producer of coke used in the steel production process. The JSW commends the European Commission’s initiative to draw up a Circular Economy Act, which aims to accelerate the transformation of the European Union’s economy towards a circular model.

Filed in Polish · English published by the European Commission

The EU Circular Economy Act represents a vital opportunity to shift Europes economy toward a model that prevents waste, reduces emissions, and enables a market for secondary raw material. The IKEA business is committed to advancing the circular economy and a well-crafted Circular Economy Act can accelerate the green transition, contribute to climate goals, and deliver environmental, social, and economic benefits…

Deltalinqs, representing companies within the Rotterdam mainport, believes that to unlock the full potential of circular production, Europe must urgently address three interconnected challenges: 1. Stimulating market demand for sustainable products, 2. Ensuring the availability and usability of secondary feedstocks, and 3. Creating a level playing field through harmonized regulation.

The RCube Federation, a major player in reuse and repair, is submitting its proposals for the Circular Economy Act (CEA) of the European Union, aimed at establishing a robust legal framework for a strengthened circular economy. The aim is to position re-use, refurbishment and repair as strategic pillars, essential for European competitiveness and economic sovereignty.

Filed in French · English published by the European Commission

The European Compost Network (ECN), the European umbrella organisation representing the bio-waste recycling sector, welcomes the Commission's intention to amend several pieces of European waste legislation and is pleased that the Commission appears to recognise the need to further implement existing legislation on the collection and use of bio-waste.

As the EUs leading food innovation ecosystem, EIT Food supports the Commissions plan to propose a Circular Economy Act to enhance the EUs economic security and competitiveness, while promoting sustainability, circular economy business models, and decarbonization across the entire value chain.