Circular Economy Act

The objective of creating a sustainable and permanently established European circular economy is strongly welcomed by the Austrian municipal waste management. The comprehensive position can be found in the attached position paper [JEU_PP_Circular Economy_202510_DE_01.3].

Filed in German · English published by the European Commission

The EU wants circularity, but the chemical sector risks stagnation. Without targeted European intervention, the circular transition in chemistry risks stalling. The Circular Economy Act (CEA) and the Eco-design for Sustainable Products Regulation (ESPR) are essential to achieving a circular economy.

The Nordic Capital Regions welcome the European Commissions initiative to advance the circular economy with the Circular Economy Act. This joint response to the public consultation on the Act is submitted by regions and cities from three Nordic Capital regions: the Capital Region of Denmark, the City of Helsinki, Helsinki-Uusimaa Regional Council, and the Oslo Region European Office.

The National Wooden Pallet & Container Association (NWPCA) - representing over 800 company members coming from 40 countries, who manufacture, repair, and distribute pallets and wood packaging in unit-load solutions, or who supply products and services to the industry in the wood packaging sector - welcomes the opportunity to share its feedback on the upcoming Circular Economy Act.

CEPE Feedback on the Call for Evidence – Circular Economy Act 06-11-2025 The European Council of the Paint, Printing Ink, and Artists’ Colours Industry (CEPE) welcomes the European Commission’s initiative to accelerate the transition to a circular economy through the forthcoming Circular Economy Act (CEA). CEPE recognises the importance of resource efficiency, decarbonisation, and reducing environmental impacts.

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

The circular economy represents the next critical frontier of greenhouse gas (GHG) mitigation and is equally critical for biodiversity protection. Properly implemented, it can serve as a flagship winwin policy: advancing Europes climate goals, competitiveness, resource sovereignty, and strategic resilience.

The Policy Hub Circularity for Apparel & Footwear welcomes the European Commissions intention to advance circularity targets in the EU through the upcoming Circular Economy Act (CEA). We believe it is essential to continue identifying the remaining levers and gaps that must be addressed to achieve a truly circular EU Single Market and a market for secondary raw materials.

The objectives are: creating a sustainable and permanently established European circular economy is strongly welcomed by the Austrian Waste Management Associations’ ARGE. To this end, a functioning EU internal market for secondary raw materials should be established with better product qualities, market-effective incentives and harmonised and simple rules across the EU.

Filed in German · English published by the European Commission

The Port of Antwerp-Bruges and Port of Rotterdam fully support the EUs ambition to enhance Europes strategic autonomy, establish an internal market for circular products and accelerate the transition towards a circular economy.

The Port of Antwerp-Bruges and Port of Rotterdam fully support the EUs ambition to enhance Europes strategic autonomy, establish an internal market for circular products and accelerate the transition towards a circular economy.

The CE act should seek to clearly include and consider the action, regulations and acts around Critical Raw Materials. This must include the CRMA with the challenging 2030 deadlines and the NZIA with also 2030 deadlines. The proposed Green Industrial Deal (section 5) also proposes 'circular CRM' and needs to be considered.

Position paper Province of Utrecht, the Netherlands input on the EU Circular Economy Act The Dutch provinces have 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)

TOMRA is a technology leader in the field of resource management, with over 50 years of experience and a strong presence across the Single Market. Our technological solutions promote the circular economy by using advanced collection, sorting and grading systems enabling the reuse and recycling of resources.

Grodan welcomes the European Commissions initiative to gather stakeholder feedback on the forthcoming Circular Economy Act (CEA). The CEA offers a historic opportunity to realign Europes industrial and environmental strategies with sustainable principles. To successfully transition from a linear to a truly circular economy, driving competitiveness, resilience and decarbonisation.

A clear and structured EU regulatory framework is essential for the construction sectors circular transition. This approach will allow us to reap the benefits of a fully functional circular construction ecosystem. Construction Products Europe stands ready to share its expertise with EU policymakers to achieve our shared objectives.

ASD represents the interests of the European Aerospace, Security and Defence Industries. With 26 major European companies and 23 National Associations members, the overall representation adds up to more than 4,000 companies across 21 European countries. We are actively supporting the competitive development of the sector in Europe and worldwide.

Brother is a global imaging equipment manufacturer with remanufacturing facilities in the UK and Slovakia. It ranks No. 2 in the European laser printer market and leads in circular economy practices, remanufacturing millions cartridges annually and saving 3,300 tonnes of CO equivalent and 1,200 tonnes of raw materials. Remanufacturing is a high-value circular activity that preserves embedded carbon and materials.

We encourage the European Commission to take the following actions: 1. Growing secondary raw material markets through public procurement, standards and requirements. 2. Introducing recycled content and re-use obligations to construction material markets. 3. Revising and harmonising end-of-waste and by-product criteria on an EU level. 4.

UNEP welcomes the opportunity to contribute to the EC public consultation on the Circular Economy Act. The EU Circular Economy Act can act as a vehicle for continued ambitious EU leadership on circular economy globally, while leveraging peer to peer exchanges and supporting a science-based, systemic approach that embeds circularity within a broader strategic agenda of industrial competitiveness and societal and…

The Circular Economy Act (CEA) will be key to scaling Europes recycling industry across batteries, steel, aluminium and beyond, whilst also promoting greater materials recovery from other waste streams. Building up local recycling companies and getting recycling production going will be key to building a sustainable electric vehicle industry, whilst driving industrial opportunities in Europe and creating resilient…

Zero Waste Europe welcomes the European Commissions plan to adopt a Circular Economy Act (CEA) in 2026 (Q3) and its ongoing call for evidence and public consultation, but would like to highlight the following: On the framing, while we agree that boosting recycling and improving the market for secondary raw materials are essential to strengthen Europes competitiveness and resource resilience, the current framing…

To launch and support a circular carbon economy, the Circular Economy Act (CEA) needs to support the development of recycling cascades that are discussed in the literature. Such cascades should focus on the best fit of technology to plastic types, e.g. on feed contaminant, product performance and overall yields, and overall efficiency of the system in terms of recovery, cost and footprint.

Brief Opinion on the EU Circular Economy Act (CEA) Focus: Highly recyclable ferrous scrap as the main input in canal casting/deep construction Dear ladies and gentlemen, we are a medium-sized iron foundry in Germany. Our shaft covers and other canal casting components are mainly made from iron/steel scrap. In this way, we reduce the need for primary raw materials and ensure full recycling at the end of use.

Filed in German · English published by the European Commission

Driving Innovation, Value Retention, and Strategic Resilience. The Circular Economy Act (CE Act) must move beyond end-of-life recycling and focus on retaining material and product value throughout their lifecycle. True circularity relies on R-strategies (repair, refurbishment, remanufacturing, and repurposing) which must be prioritized alongside circular design, research and innovation (R&I), and skills development.

The SPICE consortium calls on the EU to reform the current regulations for transboundary waste shipments, which are based on principles ill-suited for specialized material streams. For materials like solar panels (PV panels), establishing high-tech recycling facilities in every Member State is neither technically nor economically viable.

Prior Informed Consent Obligation for (all) Non-hazardous WEEE + Abolition for the 20 kg Exemption Conflicts with the Goals of the Circular Economy Act. Introduction PostNL welcomes the opportunity to contribute to the consultation on the Circular Economy Act.

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

CCIA Europe welcomes the opportunity to contribute to the European Commissions call for evidence on the upcoming EU Circular Economy Act (CEA). While progress has been made, fragmentation across the EU and divergent national rules still hinder cross-border operations, circular business models, and ultimately the EUs Green Deal goals.

The Austrian Chamber of Agriculture emphasizes the urgent need to defossilize the European Unions economy, to reduce the dependencies on fossil-based and critical raw materials. In times of geopolitical insecurities and vulnerable supply changes, defossilization and the reduction of dependencies are essential to strengthen and expand resilience and economic viability in the EU-27.

SMEunited supports the aim to effectively address barriers to the EU Single Market for secondary raw materials and circular business models, such as regulatory fragmentation, lack of economic incentives and limited funding for small and medium enterprises (SMEs).

Recupel is the Belgian Extended Producer Responsibility (EPR) scheme. It was founded proactively in 2001 as a not-for-profit entity governed by producers and federations of producers. Its mission is to organise, on their behalf, the collection and treatment of end-of-life electrical and electronic equipment in Belgium.

Dear Sir/ Madam, Please find EUROPEN's contribution attached, which brings together two Joint Statements - one on the forthcoming Circular Economy Act and another one on One-stop-shops (OSS) for EPR - along with EUROPEN's feedback to the public consultation on the 28th Legal Regime. Kind regards, [name removed]

EUnited, representing European manufacturers of cleaning systems, municipal equipment, and vehicle wash systems, welcomes the European Commissions initiative for a Circular Economy Act (CEA). The Act provides an opportunity to strengthen the EU single market for waste and secondary materials while ensuring fair and proportionate requirements for industry.

BSEF the International Bromine Council, welcomes the opportunity to provide written comments on the ongoing work around the EU Circular Economy Act (CEA). BSEF has been actively involved in responding to and engaging with the EU Green Deal and in particular the Circular Economy Action Plan and Chemicals Strategy for Sustainability.

The construction sector presents a strategic opportunity to scale circularity across Europe, yet fragmentation among Member States and insufficient economic incentives threaten to exclude Construction and Demolition Waste (CDW) from a functional EU single market for waste.

Rückmeldung zur öffentlichen Konsultation der EU-Kommission zum Kreislaufwirtschaftsakt Wien, 05.11.2025 Über den Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Österreichs Unser Ziel ist es, dass Dienstleistungen der Daseinsvorsorge für alle Menschen in Österreich zugänglich, leistbar und von hoher Qualität bleiben – heute und in Zukunft.

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)

Once we talk about circular economy, it is essential to remember the European Waste Framework Directive published in 2008 that establishes the waste hierarchy and defines prevention and reuse as priority treatment modes in comparison with recycling and incinerating. In fact, prevention and reuse are much more Virtuous than recycling: they consume less natural resources, energy and produce less waste to treat.

Filed in French · English published by the European Commission

Westenergy Ltd is a circular economy company owned by seven municipal waste management companies operating in Western Finland. Westenergys waste-to-energy plant located in the Vaasa region takes care of the residual waste management of more than 700 000 people by refining non-recyclable, source separated municipal waste into district heating, electricity and recovered materials.

CPME suggestions for the Circular Economy Act: Making SMEs the drivers of European industrial circularity: 1. Valuing the contribution of SMEs in all circular value chains (production, repair, reuse, recycling, reverse logistics). 2.

Filed in French · English published by the European Commission

Advania's Response to the European Commissions Circular Economy Act Thanks for the opportunity to provide input. Advania welcomes the European Commissions Circular Economy Act as a vital step to strengthen the EUs economic resilience, competitiveness, and sustainability.

Our society and specifically, in our latitude, we are facing a water security crisis, meaning the availability of an acceptable quantity and quality of water for health, life, ecosystems and production, together with an acceptable level of water risks for people, the environment and the economy (Grey and Sadoff., 2007).

Filed in Spanish · English published by the European Commission

Eni S.p.A. response to the call for evidence for the ‘Circular Economy Act’ 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.

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

The European Unions ambition to advance a circular economy presents a critical opportunity to reshape production and consumption patterns in ways that protect both the environment and consumers. In response to the European Commissions Call for Evidence for the forthcoming Circular Economy Act, ANEC- the European consumer voice in standardisation - calls for a systemic shift toward a resource-saving and…

Gemeinsame Stellungnahme Circular Economy Act Hinweis: Die vorliegende Stellungnahme wurde in ihrer Grundfassung von NRW.Energy4Climate erarbeitet. Die im Dokument aufgeführten Logos kennzeichnen Akteure, die den Entwurf kommentiert und in Teilen mitgestaltet haben. 1. Kernaussagen Zirkularität soll messbar, marktfähig und rechtssicher werden.

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)

To launch and support a circular carbon economy, the Circular Economy Act (CEA) needs to support the development of plastics recycling cascades that are discussed in the scientific literature. Such cascades should be built in a technology-agnostic way, instead focusing on the best fit of plastic types to technologies (in terms of input tolerances, output qualities and overall yields) and overall efficiency of the…

DIN - the German national standards body representing about 37,000 experts within the European standardization system - welcomes the opportunity to give feedback on the Circular Economy Act (CEA). Standards are a key enabler of the CEA.

APRA Europe Statement on the EU Circular Economy Act Public Consultation As APRA Europe, we represent, through our members, approximately two-thirds of the workforce in the European automotive remanufacturing industry. We strongly welcome the European Commissions initiative to develop a Circular Economy Act, which we consider a vital step toward achieving the EUs environmental and sustainability goals.

Samfunnsbedriftene, the association for municipal enterprises in Norway, represents companies providing statutory waste management services to all Norwegian inhabitants. Municipal waste operators are central to the EUs transition to a circular economy, facilitating the collection, sorting, and transport of waste and linking consumers to the recycling industry.

The Dutch Municipal Waste Association (NVRD) welcomes the European Commissions intention to adopt the Circular Economy Act (CEA) in 2026. The initiative is essential: the transition toward circularity in the EU is progressing too slowly and requires decisive, binding policy.

A-Gas welcomes the European Commissions initiative on the Circular Economy Act and highlights the importance of refrigerant reclamation in advancing circularity within the Refrigeration, Air Conditioning, and Heat Pump (RACHP) sector. Reclamation the reprocessing of recovered refrigerant gases to virgin-equivalent quality delivers major climate and resource efficiency benefits.

Dear reader, Municipality of Leiden, as a municipality, is a frontrunner in the transition to a Circular Economy. As a medium-sized Dutch city, we want to deal with our raw materials in a structurally different way. The transition from a linear to a circular economy will make our city more future-proof, competitive and within planetary boundaries, to become climate neutral also as a city.

Filed in Dutch · English published by the European Commission

6th of November 2025 The Swedish Recycling Industries’ input to the Circular Economy Act The Swedish Recycling Industries is an industry association representing private recycling companies with a combined turnover of SEK 36 billion and over 10,000 employees at facilities across Sweden. Our members recycle both municipal and non-municipal waste.

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

Business & Science Poland (BSP) welcomes the European Commissions initiative on the Circular Economy Act and submits its position paper as a contribution to the ongoing consultation. The document presents BSPs key recommendations aimed at supporting the effective and competitive implementation of circular economy principles across the European Union

Novonesis welcomes the Circular Economy Act (CEA) which will be a driving force in accelerating Europes transition towards a more sustainable, resource-efficient, and competitive economy. We note the importance of ensuring that the CEA takes a holistic approach to circularity.

Joint Statement on the Circular Economy Act The CEE Wood, a platform of Central and Eastern Wood Industry Associations, welcomes the possibility to contribute to the Circular Economy Act. Wood, being renewable, reusable, repairable and recyclable, by having a good environmental impact is for sure one important materials for the envisaged Circular Economy.

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

The German Sustainable Business Association (BNW), representing forward-thinking companies across sectors and value chains, strongly supports the Circular Economy Act (CEA) as a cornerstone of the EUs Clean Industrial Deal and competitiveness agenda. Our members serve as leading examples for pioneering and creating circular and sustainable business cases.

ePURE the European Renewable Ethanol Association represents bioethanol producers from crops, wastes and residues committed to sustainable bio-based solutions. Our members operate 21 state-of-the-art biorefineries across the EU, transforming primary agricultural biomass into renewable ethanol, high-protein animal feed, food, and other valuable co-products.

EIT RawMaterials welcomes the Circular Economy Act (CEA) as the operational engine to meet the Critical Raw Materials Act (CRMA) benchmarks by 2030 - 10% extraction, 40% processing, and 25% recycling of the EUs annual critical raw materials (CRM) needs - while reducing strategic dependencies on any single third country below 65%.

Vianode welcomes the opportunity to contribute to the European Commissions consultation on the Circular Economy Act. We applaud the Commissions focus on addressing systemic obstacles to recycling and specifically on recovering critical raw materials, including graphite. Vianode is a producer of battery anode synthetic graphite based in Norway.

cylib, German battery recycler spun out of RWTH Aachen in 2022, recovers lithium, nickel, cobalt, manganese, graphite, aluminum, and more from EoL batteries, scrap, and black mass, achieving 90% recovery; and 80% lower CO2 footprint vs. primary extraction.

The Polish Association of Tire Recyclers (PSRO), representing 90% of Poland's tire recycling capacity, strongly supports the European Commission's Circular Economy Act (CEA). Only a unified EU regulation can address persistent challenges in waste management and unlock the potential of "hidden raw materials" by closing material cycles. Key Points: 1.

The Norwegian Confederation of Trade Unions (LO Norway) refers to the Commissions call for evidence on the Circular Economy Act. Sustainable resource management is intrinsic to a healthy climate and environment.

PM Datum: 6 November 2025 Diarienr: H25-08803 EU Coordination Unit Till: DG ENV DG GROW Swedish Chemicals Agency Comments on the Call for Evidence for a Circular Economy Act The Swedish Chemicals Agency welcomes the opportunity to comment on the Commission’s initiative for a Circular Economy Act (CEA), to be adopted by the end of 2026, that aims to address the slow transition to circularity in the EU.

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

Cities and regions recognise the ambitious policy reforms that have established the European Union as a global leader in the circular economy over the last decade. However, both material use and waste generation show no signs of a significant reduction in the EU: this indicates that the EU has not yet transitioned to a low material intensity and less wasteful circular economy.

Biond argues that the Circular Economy Act should combine environmental ambition with industrial realism, ensuring a harmonised, efficient framework that recognises the diversity of European industrial sectors. For Portugal, the success of this legislation will depend on the effective implementation of end-of-waste criteria, the valorisation of biomass and industrial by-products and the integration of the forest…

Filed in Portuguese · English published by the European Commission

The upcoming Circular Economy Act creates an opportunity to lay the foundations for greater transparency and oversight in waste management, as well as to strengthen Extended Producer Responsibility schemes, and drive investment in collection, sorting, and recycling infrastructure.

All the views expressed are those of the Federal Environment Agency (UBA) and may under no circumstances be regarded as an official opinion of the Federal Ministry for the Environment, Climate Protection, Nature Conservation and Nuclear Safety (BMUKN) or the Federal Government of the Federal Republic of Germany.

Filed in German · English published by the European Commission

Wood-based value chains offer great potential for the EU circular economy. When sourced sustainably, renewable raw materials, e.g. wood, can be supplied to loops according to principles of circular economy, in a regenerative way. Renewable carbon notably present in wood products - can support the transition from a fossil economy to a circular bio-based economy.

Airline catering providers and their airline partners are committed to supporting the EUs circular economy ambitions. However, existing EU animal by-product (ABP) rules specifically Regulation (EU) 1069/2009 significantly limit the sectors ability to implement sustainable waste prevention, reuse, and recycling practices.

Finnish Energy represents Finnish energy sector companies and employers that produce and distribute electricity, district heating and cooling and of otherwise connected to energy industry. Our members play a key role in enabling energy solutions for society and industry, and in promoting a sustainable, competitive, and low-emission energy system. We see the advancement of the circular economy as highly desirable.

The European Union has set ambitious goals for achieving climate neutrality (Net Zero) by 2050 and for transitioning to a Circular Economy. Although these policies are essentially synergistic, in specific cases the heavy industry actively operating also as waste recycling sector the objectives for carbon neutrality by 2050 come into direct collision with the circular economy and recycling targets and threaten the…

Arisa Advocating Rights in South Asia works to improve respect for human rights andlabourrights in global supply chains. Working with CSOs in (among others) India and Pakistan, we expose rights abuses in the production of garments, leather, naturalstoneand vegetable seeds, and we call on companies and governments to ensure that rights are respected.

IFF welcomes the objectives of the proposed Circular Economy Act to accelerate Europes transition towards a circular, resource-efficient, and resilient economy. IFF is an innovative market leader which creates products of value across industry sectors and that strives for innovative solutions to lower carbon emissions and environmental impact.

Plastic Change calls for a strong EU Circular Economy Act that prioritizes reuse, resource optimization, and elimination of harmful chemicals. The EUs resource consumption remains far too big, and urgent action is needed to ensure smarter and more responsible use of the planets resources.

Harris Tweed Hebrides supports the Commissions goal to expedite circularity and make a greener more sustainable fashion industry through the Circular Economy Act (CEA) A tradition of circularity: Harris Tweed® is more than just a fabric or piece of clothing it is a story and a living cultural heritage.

Repsol welcomes the European Commissions initiative to establish a Circular Economy Act as a key step to accelerate industrial decarbonisation, reduce strategic dependencies, and strengthen the EUs single market for secondary raw materials.

Reducing resource use The Circular Economy Act presents a vital opportunity to address the EUs excessive material consumption, with each citizen currently using around 14 tonnes of materials annuallyfar beyond sustainable limits. To bring resource use within planetary boundaries, we in VOICE Ireland advocate for binding EU-wide targets that reduce both material and consumption footprints.

Anzahl Seiten: 10 | Stand: 06.11.2025 Position - VCI CIRCULAR ECONOMY ACT Die chemisch-pharmazeutische und biotechnische Industrie spielt eine zentrale Rolle bei der Transformation hin zu einer Kreislaufwirtschaft.

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 Swedish Construction Federation is an industry and employer organization for construction, civil engineering and specialized companies that want to build Sweden on a foundation of fair principles. We represent approximately 4000 member companies of all sizes. We fully support the EUs climate and environmental ambitions and want to see an active, ambitious climate and environmental agenda at EU level.

EBCA welcomes the European Commissions initiative for a Circular Economy Act (CEA) to further stimulate circularity and address competitiveness gaps. The upcoming CEA is an unique opportunity to reinforce sector-specific textile policies with strong, horizontal measures and to support the sectors transition to a fair and competitive circular economy.

Befesa Zinc Aser, S.A.U., a company belonging to the BEFESA, S.A. group (the Company or BEFESA), submits this contribution on behalf of the group to the European Commissions consultation on the forthcoming Circular Economy Act. Please find attached BEFESA's feedback on the forthcoming Circular Economy Act.

AEFA (Spanish Association of Agronutrient Manufacturers) welcomes the opportunity to contribute to the Call for Evidence on the Circular Economy Act. As a representative organisation of the fertiliser and biostimulant sector, we submit the following observations and recommendations to support the development of a coherent and effective framework for nutrient circularity, soil health and sustainable agricultural…

The Danish Technological Institute, Division for Building and Construction, welcomes and strongly supports the Commissions initiative to advance the Circular Economy Act. Strengthening circularity is crucial for Europes environmental goals, competitiveness, and economic security.

We welcome the European Commissions ambition to establish a truly strong circular economy. The Commission rightly acknowledges that, despite 15 years of discussions, progress towards this goal has been limited. In our view a consumer-centric framework should aim to create a well-functioning market for long-lived products designed for repair, upgrade, reuse, and refurbishment, supported by accessible infrastructures…

The European Tissue sector provides essential hygiene products such as toilet paper, kitchen towels, handkerchiefs, napkins and paper hand towels that safeguard public health and everyday well-being. We are committed to accelerating Europes transition to a circular economy by improving the availability and quality of secondary raw materials, investing in design-for-recycling solutions, and responsibly using…

Circular Economy Act – Call for evidence – Contribution from the Norwegian Environment Agency 6 November 2025 General comments from Norway Norway welcomes the EU agenda to reinforce the single market for waste and secondary raw materials.

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

Circular Economy Act As the largest network for sustainable building in Europe, the German Sustainable Building Council (DGNB) represents more than 2,800 member organizations from all areas of the construction and real estate sector.

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

Europacable Contribution to the Circular Economy Act: Securing the Future of Europe’s Decarbonisation, Digitalisation and Resilience through Cabling Systems Circularity Brussels, 6 November 2025 Europacable calls for a coherent, ambitious framework that supports circularity across the cable value chain.

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

UNESDA Soft Drinks Europe welcomes the Commissions ambition to boost EU competitiveness while accelerating the shift to more sustainable production, circular models, and decarbonisation. We strongly support efforts to: Enable free movement of circular products, secondary raw materials, and waste across Member States.

As one of the few players covering both research and architecture with reclaimed construction materials in Germany, we as Baukreisel have high hopes and expectations in the upcoming Circular Economy Act. The construction sector urgently needs this change as current structures are path dependent in a very unsustainable and mainly linear model.

The Finnish Food and Drink Industries Federation (ETL), representing food industry in Finland, welcomes the opportunity to respond to the European Commissions consultation on the upcoming Circular Economy Act. We welcome the Circular Economy Act (CEA) initiative as a crucial step strengthening Europes resilience, competitiveness, and sustainable transition.

As a European business school committed to sustainable business practices, we welcome the European Commissions development of the Circular Economy Act and are convinced that it represents a historic opportunity to transition to more environmentally sound models of production and consumption. To reap the full benefits of circularity, we believe the Act must incorporate the following seven concepts and approaches: 1.

As a global leader in advanced materials and sustainable technologies, DuPont identifies three priority reforms to accelerate Europes transition to a circular economy: (1) Recognise and enable the use of mass balance approaches for both chemical recycling and biomass balance to certify and scale circular feedstocks across value chains; (2) Harmonise Extended Producer Responsibility (EPR) schemes to ensure…

Bond Beter Leefmilieu wishes to express its concern regarding the gap between what the Circular Economy Act aims to achieve and what it proposes in terms of objectives and policy options. The problems the Act aims to tackle are defined as reducing our dependency on imported raw materials and increasing our resource efficiency, to reduce economic risk and ecological pressures.

MTK finds the overall paper and its goals acceptable and supports them. From the perspective of the Finnish farmers and forest owners the current state of the European circular economy has the following problems: 1. The price of circular material is almost always more than virgin material.

SolarPower Europe welcomes the European Commissions initiative to advance the Circular Economy Act, recognising its strategic relevance for the solar PV sector. As the EU prepares for increasing PV waste volumes in the 2030s, it is essential to define circular economy policies now, which will enable the efficient handling of PV waste and the recovery of strategic and critical raw materials.

We welcome the ECs commitment to developing the Circular Economy Act (CEA). To unlock its transformative potential, the CEA must go beyond a narrow focus on secondary materials, recycling and e-waste. A genuine Circular Economy must address the full hierarchy of R-strategies (refuse, reduce, reuse, repair, etc.) within a systemic approach that safeguards planetary boundaries, strengthens resource sovereignty, and…

The TÜV Association welcomes the European Commissions initiative to establish a Circular Economy Act (CEA) as a key pillar of the Clean Industrial Deal and the Competitiveness Compass. The proposed Act has the potential to significantly accelerate Europes transition toward a resource-efficient, climate-neutral, and competitive circular economy.

Lausunto 11/2025 6.11.2025 1 (1) Lausunto Euroopan unionin Circular Economy Act on keskeinen väline siirryttäessä kohti resurssitehokasta, vähähiilistä ja omavaraisempaa taloutta. EU:n tavoite vähentää neitseellisten luonnonvarojen käyttöä, vahvistaa kriittisten raaka-aineiden saatavuutta ja lisätä kierrätysastetta edellyttää yhteensovitettuja toimia koko arvoketjussa, erityisesti kaivosteollisuudessa ja…

Filed in Finnish · English published by the European Commission

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

In the race for the circularisation of the economy, particular attention must be paid to bio-based industries, as the circular economy is meant to “build on” the life regeneration loops. Research centres and companies active in the field of bio-economy, biological alternatives to conventional processes and products, as well as platforms for scaling-up this production, must be placed at the centre of this…

Filed in French · English published by the European Commission

Opinion of the Quality Association for Drainage Engineering (GET) on the Circular Economy Act of the European Union European Commission Subject: Inclusion of civil engineering/underground infrastructure in the Circular Economy Act Date: 28 October 2025 Ladies and Gentlemen, the Quality Association for Drainage Engineering (GET) welcomes the European Commission’s intention to accelerate the transition to a…

Filed in German · English published by the European Commission

PlasEnSys is a non-profit-making organisation; its object is the study and discussion of scientific, technical, economic, regulatory, and institutional matters, which are of common interest to the European Plastic Energy Storage Systems (ESS) manufacturers; these encompass plastic structures for different energy sources, including (but not limited to) fuel, hydrogen, CNG, Biofuels & E-fuels, Battery-Electric based…

LyondellBasell (LYB) welcomes the initiative to develop a European Circular Economy Act and fully supports the EUs ambition to advance a more sustainable and circular plastics economy. We believe that achieving this goal requires a balanced and forward-looking policy framework.

Please find Recovers feedback on the Circular Economy Act attached. The document outlines our key recommendations to strengthen the proposal, including measures to harmonize EPR schemes, boost the uptake of recycled materials, and ensure supportive conditions for textile circularity across Europe.

06 November 2025 RPE contribution to Circular Economy Act call for evidence Position paper Introduction Reusable Packaging Europe (RPE) welcomes the European Commission’s call for evidence on the future Circular Economy Act (CEA). As operators of Reusable Transport Packaging (RTP) in closed-loop systems, we support its aim to drive forward circular economy measures across the EU.

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

BIC emphasizes the importance of fostering the use of all types of biomass, including primary biomass, should be considered under the EU Circular Economy Act. While underutilized resources like straw, wood residues, and biowaste are important feedstocks, the transition to fossil-free, sustainable chemicals and materials sector in Europe will rely on diverse biomass sources.

The Proposals of the German Association for Waste Management and circular economy (Deutsche Gesellschaft für Abfall und Kreislaufwirtschaft e.V.) -DGAW - on the topics of - critical raw materials and - EU 2030 - The development of waste management into an industrial location factor can be found in the attached document.

Micro-Mobility for Europe’s feedback on the Circular Economy Act 6 November 2025 Micro-Mobility for Europe (MMfE) is the coalition of the leading shared micro-mobility providers, offering electric scooters and bicycles as sustainable urban transport solutions.

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

Convite à Apresentação de Contributos para uma Avaliação de Impacto relativa ao Ato Legislativo sobre Economia Circular A Região Autónoma da Madeira vem, pelo presente, submeter o seu contributo no âmbito da iniciativa identificada em epígrafe.

Filed in Portuguese · English published by the European Commission

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

JX Advanced Metals Corporation, a non ferrous metals enterprise that conducts global operations related to non ferrous metals welcomes the opportunity for the feedback on the Call for Evidences on Circular Economy Act. For more detail, please find the attached PDF documents, Proposal and Position for Call for Evidence on the Circular Economy Act. Warm Regards,

FoodDrinkEurope supports the European Commissions ambition to create a single market for secondary raw material by exploring opportunities for harmonization, incentives for uptake and assessing how waste management practices can be improved.

Jernkontoret is Swedish iron and steel producers' association representing companies that produce highly specialised steel products with a wide variety of applications. Jernkontoret welcome the initiative to prepare a Circular Economy Act (CEA), and to address the slow CE-transition in various parts of society.

FEDEMCO 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 not a waste problem to be managed, but a valuable material stream to be optimised.

The future European Circular Economy Act is an opportunity to move towards a more efficient and sustainable production model, but it must do so without harming the competitiveness and viability of farms. The agricultural sector is not only a waste generator, but a central player in sustainable resource management and circular bioeconomy.

Filed in Spanish · English published by the European Commission

The T&M Coalition represents over 70% of global industrial test & measurement production. Members include Agilent, Fluke, Keithley, Keysight, Thermo Fisher, and Tektronix. Our equipment supports critical sectors including aerospace, defence, automotive, diagnostics, communications, energy, and life sciences.

The Technology Industries of Finland welcomes the initiative for a Circular Economy Act as an opportunity to create a coherent and investment-friendly EU framework for circularity. The Act should strengthen industrial competitiveness and internal market integration, while avoiding overlaps with existing legislation such as ESPR and the CRMA.

Feedback on the proposed Circular Economy Act (CEA) Submitted by Lindab Group, October 2025 Lindab Group welcomes the Commissions proposal for a Circular Economy Act and supports its ambition to strengthen the EUs internal market for secondary materials and reused products.

The European Biogas Association (EBA) welcomes the European Commissions forthcoming proposal for a Circular Economy Act. Biogases systems exemplify the circular bioeconomy in action. Fully bio-based, they rely on sustainable biomass feedstocks such as sequential crops, agricultural residues, animal by-products, bio-waste, industrial organic waste, wastewater and sewage sludge. Their circularity is threefold.

As MATERIALITY, sustainability consultancy, we welcome the Commissions initiative to draft, propose and implement the Circular Economy Act aimed at further enhancement of circular economy in the EU. We would like to point the Commissions attention to the following points which should be addressed through the CEA: 1.

Statement by the Austrian Federal Ministry of Agriculture, Environment and Climate Protection (BMLUK) on the planned Circular Economy Act 1. Legal Form Experience with the EU Battery and Packaging Regulations shows that vague drafting and broad empowerments require Member States to adopt additional national measures, increasing complexity and administrative burden. In line with subsidiarity (Art.

TYRES EUROPE COMMENTS ON THE CIRCULAR ECONOMY ACT The European Tyre Industry (Tyres Europe) plays a key role in advancing sustainability and fostering the principles of circularity within Europe. As the European Union intensifies its efforts to transition towards a Circular Economy, Tyres Europe is committed to contributing expertise, insights, and actionable recommendations to support the development of efficient…

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

As the voice of Refrigeration, Air Conditioning and Heat Pumps (RACHP) in Europe, EPEE represents the whole value chain of heating, cooling and refrigeration for all critical uses of society. While the products we offer are energy efficient and contribute to the decarbonization objective, their end-of-life is also key to ensure that all components are safely treated, and in the cases of refrigerant gases, re-used…

Public consultation - Circular Economy Act (CEA) Response by the Institut Mobilités en Transition (IMT-Iddri) The Institut Mobilités en Transition (IMT) is a spinoff of Iddri (Institute for sustainable development and international relations) initiated in 2021. The organisation is a French independent think tank dedicated to the transition of the transport sector in France and Europe.

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

Circular Economy ACT Call for evidence UTILITALIA · 06 November 2025 · Summary 1. Creating demand for secondary raw materials and products 1.1.“Circular Energy Efficiency Certificates” and “Circular Carbon Credits” 1.2. Other measures to boost secondary raw material market 1.3. Incentive mechanisms for recycling of hard-to-recycle waste fractions, with a focus on mixed plastics from packaging waste 1.3.1.

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

As a major player in the circular economy for more than 160 years, SUEZ recognizes that the EU is at a critical turning point. The EU must either maintain its leadership in the environmental transition or risk losing ground to non-EU countries, both in manufacturing and in material sourcing. The competitiveness of the EU industry as a whole is essential.

Fairphone B.V. welcomes this opportunity to contribute to the EU Circular Economy Act (CEA) consultation, as legislative action is urgently needed to address our global environmental crisis. The global economy has exceeded 7 out of 9 planetary boundaries. This demands immediate action to secure both environmental sustainability and Europes economic resilience.

The European Association of Remote Sensing Companies (EARSC) is a trade association representing over 135 members across Europe in the Earth Observation (EO) downstream industry. Through its involvement in various projects, EARSC has been following the efforts and developments as regards waste management and circular economy and welcomes the plans to propose a Circular Economy Act.

The Circular Economy Forum Austria welcomes the drafting of the Circular Economy Act (CEA) as an important step towards implementing the European Green Deal and the Clean Industrial Deal. Properly designed, the CEA can align resource security, decarbonisation, competitiveness and resilience by creating functioning markets for circular products and secondary raw materials and by rewarding upstream value-preserving…

Date 6 November 2025 IATA Feedback to the call for evidence on the Circular Economy Act The International Air Transport Association (IATA) is the trade association for the world’s airlines, representing some 350 airlines over 80% of global air traffic. We support many areas of aviation activity and help formulate industry policy on critical aviation issues.

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

European Commission Public Consultation: Circular Economy Act GD4S Response to the Call for evidence November 2025 Gas Distributors for Sustainability (GD4S) brings together leading gas distribution operators from nine EU Member States — France, Greece, Ireland, Italy, the Netherlands, Poland, Portugal, Romania, and Spain — plus the UK.

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

VTT welcomes the ambition of the EU Circular Economy Act and recognizes circularity as a vital element of European resilience and environmental sustainability. As Finlands leading Research and Technology Organization (RTO), VTT advances clean and resource-efficient technologies, bridging the gap between research, commercialization, and industrial scale-up.

[email removed] Ref. Ares(2025)9553263 - 06/11/2025 ECCIA’s feedback on the upcoming Circular Economy Act With a deep and long-standing commitment to sustainability and the circular economy, the European Cultural and Creative Industries Alliance (ECCIA) fully supports the European Commission’s objective to foster a competitive and resilient circular economy through the forthcoming Circular Economy Act.

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

If we are serious about creating a sustainable society, we need to start using the raw materials we already have, over and over again. We urge the Commission to start treating waste for what it really is a resource. Today's outdated view of waste prevents the extraction of critical raw materials from the waste and thereby secures Europe's self-sufficiency.

Orano Position Paper on the European Circular Economy Act (CEA) Orano would like to thank the European Commission for organizing this public consultation in view of the adoption of a Circular Economy Act (CEA). As a leading industrial player of the nuclear fuel cycle with a strong ambition to develop capacities in the battery value chain, Orano supports this forthcoming act, which aims to accelerate the transition…

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

Call for evidence – Circular Economy Act Medicines for Europe response Medicines for Europe, representing generic, biosimilar, and value-added medicines, supports the objectives of the Circular Economy Act to enhance circularity across the single market, while underlining the importance of duly considering the specificities of the strictly regulated pharmaceutical sector and the need to ensure consistency with…

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

bobine is a French technology company specializing in the chemical recycling of plastics through catalysis. It is developing a breakthrough solution that efficiently converts plastic waste into new raw materials, while significantly reducing the environmental footprint of the process.

Call for Evidence for the upcoming Circular Economy Act The Swedish Society for Nature Conservation (SSNC) welcomes the opportunity to provide feedback on the Call for evidence for the upcoming Circular Economy Act. SSNC is a non-profit environmental organisation, working with more than 40 organisations around the world, with almost a quarter of a million members and more than 270 local associations.

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

Avery Dennison (NYSE: AVY), is a global materials science and digital identification solutions company operating in 17 EU Member States. We design and develop labeling and functional materials, radio-frequency identification (RFID) inlays and tags, software applications that connect the physical and digital.

Pre-Deconstruction Audits for the Circular Economy Act Executive Summary We welcome the European Commissions initiative to develop a Circular Economy Act (CEA). The Act offers a historic opportunity to make the construction and real estate sector truly circular. To achieve this, Pre-Deconstruction Audits (PDAs) must become a mandatory requirement for demolition and major renovation projects across the EU.

The Province of Zeeland welcomes the developments around the Circular Economy Act by the European Commission. The Dutch provinces have set its target to become fully circular in 2050. We therefore welcome Europes 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.

Europes circular economy needs a clear, harmonised, and practical framework that drives innovation, simplifies compliance, and ensures consistent enforcement. Bitkom emphasizes aligning regulations, leveraging digitalisation, and promoting product longevity to create a transparent, efficient, and competitive circular economy.

The Iren Group highlights the urgent need for a coherent and harmonised European framework to address the crisis currently undermining the recycling sector. Escalating energy costs, competition from virgin and imported materials, and regulatory fragmentation threaten the viability of recycling value chains, with serious implications for Europes industrial competitiveness, resource security, and climate goals.

Euroconsumers and its national members - Testaankoop/Testachats (Belgium), OCU (Spain), Altroconsumo (Italy) and Deco Proteste (Portugal) - welcome the opportunity to provide feedback on the Circular Economy Act. This initiative represents a key opportunity to create a genuine Single Market for Circular Goods and Materials that empowers consumers and strengthens industrial resilience.

The BRV represents more than 110 processing plants for C&D materials and around 80% of the mineral recycling construction materials produced in Austria. 90% of all recycled building materials produced by the companies can obtain early end-of-waste status on the basis of the EU-notified Austrian regulation.

SBSA, the French alcohol-free beverages industry representative, welcomes the European Commissions ambition to enhance the EUs competitiveness while accelerating the transition towards more sustainable production, circular business models, and decarbonization.

The European association for ferro-alloys and silicon producers, Euroalliages, welcomes the European Commissions initiative to strengthen the circular economy and reduce dependency on imported raw materials. The Circular Economy Act has the potential to improve resilience, foster innovation, and cut emissions for the raw materials sector.

APAG Oleochemicals Europe, a sector group of Cefic, represents the European industry that uses plant oils and rendered animal fats (category 3) to produce oleochemicals and stands as a pillar of the European bio-based and circular economy. Oleochemicals are bio-based chemicals derived from fats & oils. They serve as alternatives to fossil-based chemicals contributing to a greener future.

The Finnish Tekstile & Muoti ry (STJM) supports the European Commission’s objective to prepare the Circular Economy Act by 2026. The Finnish textiles and fashion sector has long called for a clear and coherent legislative framework that brings together key circular economy laws, ensures their compatibility and allows for predictable implementation.

Filed in Finnish · English published by the European Commission

AEPIBAL, the Spanish Energy Storage Association, welcomes the European Commissions initiative to promote a circular economy through the forthcoming Circular Economy Act (CEA) and submit the following key recommendations for an effective and harmonised framework for the European energy storage and recycling industry. Regulatory harmonisation.

Filed in Spanish · English published by the European Commission

Headline impact By requiring non-road mobile machinery (NRMM) to be electric-attachment ready and by recording comparable jobsite metrics in the Digital Product Passport (DPP), the Circular Economy Act (CEA) can deliver 0.60 MtCO/year in 5 years (20% uptake) and 1.80 MtCO/year in 10 years (60% uptake) across the EU about 130,000 and 390,000 cars annual emissions, and 220/670 million litres of diesel saved each year.

The Circular Economy Act (CEA) is expected to become a cornerstone of the EUs Clean Industrial Deal, reinforcing Europes strategic autonomy, competitiveness, and sustainability through systemic circularity reforms.

The Finnish Innovation Fund Sitra has been actively promoting a circular economy for the last decade. We have initiated the World Circular Economy Forum, built concrete tools for businesses and led the development of Finlands first national circular economy roadmap.

U.di.Con. APS welcomes the Commission’s circular economy approach and reiterates that the success of the transition depends on putting consumers at the centre: accessible, informed and sustainable purchasing choices, within a harmonised framework that avoids fragmentation in the single market.

Filed in Italian · English published by the European Commission

Call for Evidence: Circular economy act Ericsson feedback and comments Analysis 2025-10-09 Contents 2025-10-09 1 Introduction ........................................................................................................... 3 1.1 Materials and circularity of the information and communication industry (ICT) ...................................................................

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

Position paper on the Circular Economy Act The European Federation of Wooden Pallet and Packaging Manufacturers (FEFPEB) welcomes the opportunity to contribute to the consultation on the forthcoming Circular Economy Act (CE Act). Wooden pallets and packaging are the backbone of European logistics, representing one of the most established models of circularity in practice.

The German saw and wood industry, Bundesverband e.V., welcomes the objective of the planned circular economy act, which aims at further developing the European economy. Wood as a renewable domestic raw material forms the basis of a successful transformation. However, there is a growing incoherence within the European policy orientation.

Filed in German · English published by the European Commission

Circularity is a cornerstone of Europes transition to climate neutrality, industrial resilience, and strategic autonomy. We support the ambition to accelerate circular material flows, reduce dependence on fossil resources, and strengthen the competitiveness of European industry. The chemical sector is central to enabling circularity across all industrial value chains.

Established in 1969, Faerch is a leading provider of circular, rigid food packaging with integrated recycling capabilities, and leads the market with the post-consumer recycled content in our polyethylene terephthalate (PET) plastic trays. Placing approximately 24 billion rigid plastic packaging pieces on the European market annually, Faerch holds a 20% market share in its segment.

Lenovo welcomes the Commissions ambition to develop a Circular Economy Act (CEA) as a unifying framework to deliver the objectives of the Green Deal, the Circular Economy Action Plan, and the recently adopted Ecodesign for Sustainable Products Regulation (ESPR).

EHI represents 90% of the European market for heat and hot water generation, heating controls and heat emitters, 75% of the hydronic heat pump market, 80% of the biomass central heating market (pellets, wood) and 70% of the solar thermal market. EHI Members produce advanced technologies for heating in buildings, including radiators and surface heating & cooling.

Feedback: HOP's input on the Circular Economy Act November 2025 HOP - Stop Planned Obsolescence is a French environment protection association. Since 2015, it advocates for long-lasting products. It is directly linked to the construction of circular economy tools such as the repairability and durability indexes as well as the French repair bonus. It represents a community of more than 60.000 people.

European Commission DG ENV B3 and DG GROW I4 Brussels 6 November 2025 EPF Response - Call for Evidence on the Circular Economy Act The European Panel Federation (EPF), representing the European manufacturers of wood-based panels (WBPs) strongly welcomes the European Commission’s intention to accelerate circularity through 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 European Water Association (EWA) is an independent non-profit NGO dealing with the management and improvement of the water environment. As one of the major professional associations in Europe, it covers the whole water sector, wastewater as well as drinking water and water related waste. EWA aims to contribute to sustainable water management, a safe water supply, and the protection of water and the environment.

Anitec-Assinform welcomed the CEA, recognising its potential to harmonise, digitalise and strengthen policies to support the transition to a more sustainable economy. This requires a clear, coherent and harmonised regulatory framework based on the principles of harmonisation, simplification and flexibility, avoiding fragmentation between Member States and reducing the administrative burden for businesses.

Filed in Italian · English published by the European Commission

CELSA Group, as one of Europe's leading steel producers, 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 EU, and the opportunity to contribute to this public consultation.

We envision a shift from Europe's current linear economic model to a truly circular economy that balances environmental sustainability with economic competitiveness. The overarching direction emphasizes harmonization as the foundation for creating a unified European market that eliminates regulatory fragmentation and reduces administrative complexity.

YTTRANDE/SYNPUNKTER 1 (2) Datum Vårt diarienummer 2025-11-06 RUF250271 Enheten för Näringsliv och kompetensförsörjning [name removed]: [email removed] SYNPUNKTER PÅ EU-KOMMISSIONENS RÄTTSAKT OM DEN CIRKULÄRA EKONOMIN Sammanfattning Region Västmanland och Enheten för Näringsliv och kompetensförsörjning lämnar synpunkter på EU-kommissionens initiativ till en rättsakt om cirkulär ekonomi.

Filed in Swedish · 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 International Zinc Association represents the zinc value chain including zinc mining, production, manufacturing, downstream use and recycling. Globally more than 4 million tonnes of zinc are estimated to be recycled each year. Zinc and the zinc industry are key enablers of the circular economy in Europeboth at the product level and in recycling.

We can only encourage politicians and business leaders to push ahead with further steps in the circular economy. Our timber construction company, which will celebrate its 100th anniversary next year, shows that the circular economy is also economically advantageous.

567 million euro national tax burden destroys effective circular- and climate implementation! A truly circular economy cannot succeed if national tax policies drive waste exports and dismantle domestic recycling and waste management infrastructure. Excessive national levieslike those proposed in the Netherlandsundermine EU climate goals, distort competition, and trigger waterbed effects across borders.

Fraunhofer IPK welcomes the preparation of the CEA as a key lever to accelerate the shift towards an independent circular value creation within the EU. The initial problem description focusses strongly on secondary raw material recovery in the context of waste management highlighting challenges regarding supply, price and quality in comparison to primary material.

Chemical Recycling Europe (CRE) is the association representing the chemical recycling industry at the EU level. Chemical recycling technologies play a crucial role in facilitating the transition towards a more sustainable and circular economy in Europe.

Being founded on the idea of creating sustainable chemicals from organic waste, ChainCraft is great supporter of the circular economy. In the document attached we make some suggestions on what could help the creation of a full circular economy based on our 15 years of scaling up sustainable fatty acid production.

ISOBRO, the Danish Fundraising Association, who represent the voluntary organizations, appreciates the opportunity to contribute to the EU Commissions forthcoming Circular Economy Act (CEA) with this feedback. Several of ISOBROs members work daily with the collection of textiles and other products for reuse. We therefore represent an important link in the circular value chain.

ALMA spa is a leading Italian company in the production of pedestrian carpets for events. For years, in addition to the supply of its own synthetic fibre products, it has also been involved in recovering and recycling materials after use. As an industry active in this sector, we welcome the European Commission to promote a comprehensive review of the regulatory framework for the circular economy.

Filed in Italian · English published by the European Commission

GEIR represents Europes waste oil re-refining industry, accounting for about 80% of the continents capacity. GEIR members collect and regenerate used lubricating oilsthe largest single stream of liquid hazardous waste globallyinto high-quality base oils that match virgin performance.

The European Quality Association for Recycling e.V. (EQAR) is the European association for the mineral recycling industry in the construction sector, which has been committed to quality assurance for mineral recycled construction materials for 20 years.

1. Integrate biodegradation, renewability & regeneration into concept of circularity .Circularity must include the metric of how materials can be returned safely to nature & the regenerative practices of production Biodegradability, renewability & regeneration are core enablers of circularity & must be considered equally with reuse & recycling when defining circularity.

Wooden packaging is already one of the most circular sectors in Europe, combining renewable sourcing with large-scale reuse, repair, and recycling. It supports over 100,000 jobs, underpins the Single Market, and generates billions in turnover, while delivering clear environmental benefits.

We thank the European Commission for the opportunity to contribute to the public consultation on the new Circular Economy Act (CEA). As a Horizon Europefunded project, CirclesOfLife (COL) shares the Commissions vision of stimulating market demand for secondary raw materials and building a unified, competitive single market for waste and secondary resources.

The introduction of the Circular Economy Act is an important opportunity for the European Union to develop a comprehensive legislative framework that accelerates the circular transition that is so urgently needed within Europe.

The City of Rotterdams welcomes the preparation of the Circular Economy Act. Rotterdam is embracing the circular economy not just as a necessity, but as an opportunity to innovate, collaborate and lead towards a sustainable society. Therefore the upcoming CEA should not only focus on waste and recycling, but include as well upstream measures that prevent waste generation.

As a coalition of organizations actively engaged in repair, refurbishment, and reuse activities of Electric and Electronic Equipment across Europe, working together in the Interreg NWE Project E6, we welcome the European Commissions commitment to accelerating the transition towards a circular economy that reduces Europes dependency on raw materials, strengthens competitiveness, and alleviates environmental…

Europump Response – Call for Evidence: Circular Economy Act (CEA) Submission to DG ENV B3 and DG GROW I4 | September 2025 Cover note – ‘Have your say’: Europump, the European Association of Pump Manufacturers, welcomes the Commission’s intention to adopt a Circular Economy Act by end-2026. We provide concise evidence and recommendations focused on industrial pumps.

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

Lei da Economia Circular Resposta CIP à consulta pública pela Comissão Europeia I. Introdução 1. O presente documento contém as observações CIP – Confederação Empresarial de Portugal à consulta pública lançada pela Comissão Europeia em 1 de agosto relativa à futura Lei da Economia Circular, cuja adoção está prevista para 2026. 2.

Filed in Portuguese · 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 Monitor for Circular Fashion SDA Bocconi is a multi-stakeholder project involving leading companies in the fashion industry and players in its supply chain. SDA Bocconis Sustainability Lab is the projects scientific partner. Monitor for Circular Fashion SDA Bocconi welcomes the European Commissions initiative for a Circular Economy Act, a decisive step toward a resource-efficient and climate-neutral Europe.

New construction projects account for only a limited share of total building activities in Europe. Planned maintenance, renovation, and sustainability upgrades of existing buildings have a far greater impact on material-related CO₂ emissions and the degree of circularity.

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

Back2Back is an industry consortium focusing on delivering a scalable framework for take-back solutions. Many companies have identified the need to simplify EU regulations, and in the attached paper we give a concrete suggestion. Our consortium submits this position paper to highlight a critical legislative barrier for the development of scalable circular economy solutions in the European Union.

European Commission Call for Evidence on the Circular Economy Act Danfoss’ vision and commitment Today, 96.8% of the world's resources are not cycled back into the global economy at end of life. At the same time, the global population consumes 1.75 times the resources that the Earth can regenerate, while resource extraction is projected to increase by 60% by 2060.

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

Our Ocean Can't Wait: Priorities for the EU Circular Economy Act The upcoming EU Circular Economy (CE) Act is a critical opportunity to bring our consumption back within planetary boundaries. To truly protect our blue planet, we must move beyond incremental changes and demand bold action now. 1.

As the European Commission develops its proposal of the Circular Economy Act (CEA), the Information Technology Industry Council (ITI), as the premier advocate of the global technology industry, stands firmly in support of this transition. Our sector is not only a driver of digital transformation but also a pioneer in the application of circularity across global value chains.

Cobalt creates a circular economy. It is highly, and endlessly, recyclable. Every day, Europeans are importing cobalt in the form of cars, phones, laptops and industrial goods, meaning that these could potentially be a strategic future source of diversified and secure raw materials supplies.

Position of the Chamber of Commerce of Non-ferrous Metals and Recycling (IGMNiR) representing manufacturers and recyclers in copper, aluminium, zinc, lead, tin and other metal chains. Our members operate competing installations and invest in high-quality recycling.

Filed in Polish · English published by the European Commission

We are concerned that the legislative processes do not have a sufficiently holistic or science-based approach, and that the focus on secondary raw materials and lack of attention to securing reduced environmental impact will hinder the EU to achieve a sustainable and circular textile industry.

The U.S. Cotton Trust Protocol welcomes the opportunity to contribute to the Commissions public consultation on the Circular Economy Act. Our mission is to measure and verify sustainable cotton production practices at the farm level in the U.S., providing brands and retailers with transparent, verifiable data, and driving continuous improvement in virgin cotton's environmental and social footprint.

The LIFE BIOBEST project, Guiding the mainstreaming of best bio-waste recycling practices in Europe, is a 2.5-year LIFE Preparatory Project addressing ad hoc Legislative and Policy Priorities (PLP), funded by the EC (January 2023 June 2025).

Invest-NL As the Dutch Finance and Development Institution (NPI) accelerates and finances societal transitions. We will remove financing bottlenecks, mobilise capital and offer prospects for new sectors. Since the beginning of 2020, Invest-NL has deployed a large team of developers and investors to the Biobased and Circular Economy.

Filed in Dutch · English published by the European Commission

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14812-CircularEconomy-Act_en European Union (EU) animal health rules undermine the aviation sector's ability to make a positive contribution to the circular economy through cabin waste prevention, reuse, and recycling initiatives.

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

Once we talk about circular economy, it is essential to remember the European Waste Framework Directive published in 2008 that establishes the waste hierarchy and defines prevention and reuse as priority treatment modes in comparison with recycling and incinerating. In fact, prevention and reuse are much more virtuous than recycling: they consume less natural resources, energy and produce less waste to treat.

The following points summarise our attached, more detailed feedback: 1. Competitiveness through upstream innovation Binding design requirements should address durability, repairability, recyclability, chemical safety, and software support, with verification via Digital Product Passports. Repair provisions must be practical and enforceable (spare-part availability, bans on anti-repair locks, fair pricing).

We thank the Commission for the opportunity to contribute to this major new policy initiative. In the attached paper, we detail our recommendations. In a nutshell, we propose the following: Add graphite to the EU Batteries Regulation mandatory recycled content targets by 2030 and set clear penalties for non-compliance.

The Natural Polymers Group is a coalition of leading innovators committed to scaling nature-based, non chemically modified substitutes to conventional plastics. The EU Circular Economy Act (CEA) provides a vital opportunity to reduce global plastics demand and support new material innovation.

ISOPA (The European Trade Association for the Producers of Diisocyanates and Polyols) welcomes the Commission's intention to come forward with a proposal for a Circular Economy Act. Such a measure can play a significant role in advancing Europe's circular transition by creating an enabling and predictable policy framework. For a detailed position and policy recommendations, please find ISOPA's feedback attached.

The European Union finds itself at a crossroads. The transition to a low-carbon, circular economy is an absolute necessity. , The dual crisisgeopolitical one in Ukraine and the Middle East and economic one with sluggish growth in Europe and China, which is dumping its production surpluses on export marketsis having a direct impact on the competitiveness of European industry as a whole.

Starting in the mine, the whole raw materials value chain is fundamental to boosting EU decarbonization, strategic autonomy, security, resilience, and competitiveness, and it should be achieved while upholding the EUs high environmental and social standards.

Contribution d’ecosystem sur le Circular Economy Act Novembre 2025 En tant qu’éco-organisme agréé sur les filières de Responsabilité Elargie du Producteur (REP) pour les équipements électriques et électroniques (EEE) ainsi que pour les batteries, ecosystem se réjouit de l’initiative de la Commission européenne pour donner un cadre clair en faveur de l’économie circulaire.

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)

MIRRI-ERIC (Microbial Resource Research Infrastructure European Research Infrastructure Consortium) welcomes the European Commissions initiative for a Circular Economy Act. Microbial resources are powerful enablers of circularity, sustainability, and innovation across key sectors of the bioeconomy.

Ragn-Sells is a family-owned Swedish waste management company, now evolving into a resource producer and detoxifier, focused on driving a future circular economy. Since 2015, we have transformed our approach around three guiding principles: reducing virgin resource use by delivering high-quality materials from urban flows, decontaminating all material flows, and protecting a liveable planet for future generations.

Read must move from waste management to prevention, circularity and territorialisation of flows. Regions, such as Île-de-France, are ready to be operational laboratories for this new circular economy, provided that the European legislative and financial framework evolves to: prioritising prevention and re-use, correcting economic imbalances, recognising the structuring role of territories in circularity. 1.

Filed in French · English published by the European Commission

Perstorp welcomes the European Commissions initiative to develop a Circular Economy Act (CEA) as part of the Clean Industrial Deal. Europe needs a coherent policy framework for sustainable feedstocks, i.e. sustainable carbon.

The Circular Economy Act (CEA) represents a crucial opportunity to address longstanding business challenges through simplification and the strengthening of the Single Market. Its success depends on revising the Waste Framework Directive (WFD) and the Waste Electrical and Electronic Equipment (WEEE) Directive, re-opening some provisions of the Waste Shipment Regulation (WSR) and the Single Market Transparency…

The LEGO Group welcomes the opportunity to provide our input to the Commissions work on this important legislative initiative. At a crucial time for Europes competitiveness and for scaling up a thriving circular economy, we believe this is a major opportunity to deliver real change for consumers, manufacturers, and the future of the planet.

Despite the significant progress achieved during the previous policy cycle, the European plastics recycling industry now stands at a critical crossroads. Ongoing challenges such as market volatility, legal uncertainty, unfair competition, and regulatory fragmentation threaten not only future investments but also the very capacity already built within the sector.

The Shipyards & Maritime Equipment Association of Europe (SEA Europe) represents the European maritime manufacturing industry in 17 countries, encompassing the production, maintenance, repair, retrofit and conversion of all types of ships and floating structures commercial as well as military including the full supply chain with the various producers of maritime systems, equipment material, and services.

With three business segments water, waste & energy Veolia is a key player in the circular economy. The Circular Economy Act represents a major opportunity to enhance the existing regulatory framework for waste, creating a genuine market for recycled materials and ensuring fair competition with virgin and fossil-based materials.

Filed in French · English published by the European Commission

POSITION PAPER Circular Economy Act: Effective, Fair Producer Responsibilities [Brussels, 05 November 2025] EPBA—Consumer Batteries Europe fully supports the objectives of the forthcoming Circular Economy Act (CEA) to harmonise circularity rules, strengthen Extended Producer Responsibility (EPR), and enhance enforcement across the EU.

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

Position of Renewi on the EU Consultation on the Circular Economy Act. Renewi is a waste-to-product company and a leader in sustainability, operating at the heart of the circular economy. As a major player in the waste and recycling sector, Renewi is fully focused on producing high-quality secondary raw materials from waste. Renewi is the market leader in collection, sorting, and recycling in the Benelux region.

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

Circular Economy Act – Call for Evidence The consulting engineering perspective 5 November 2025 The European Federation of Engineering Consultancy Associations (EFCA) has member associations in 27 countries, representing more than 10,000 companies from the European engineering consultancy industry and related fields.

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

I. Bpifrance advocates for mobilising finance to drive circular innovation 1. Expanding the scope beyond recycling: Circularity must be understood beyond recycling. Models that extend product lifespan, such as reconditioning, refurbishment, remanufacturing, and component recovery, require targeted support. Product-as-a-Service and sharing models should also be incentivised to scale alternative consumption patterns.

Holcim and our global waste management business, Geocycle, strongly support the European Commissions ambition to accelerate the transition to a circular economy. We welcome the proposed Circular Economy Act as a critical step toward building a more resource-efficient, competitive, and sustainable industrial ecosystem.

The description of problems with regard to secondary raw materials is good and relevant, but given that the title of this initiative is Circular Economy Act it seems to go back to first steps taken back in the 1980s, where circular economy was mainly understood as recycling.

Please find attached the EEB response to the public consultation and the call for evidence on the Circular Economy Act. A prosperous economy that works for people and planet can be achieved through a system embedded in circular principles: living well within planetary boundaries.

Henkel is supportive of the Circular Economy Act (CEA) and its potential to drive sustainability across Europe. We welcome the Commissions ambition to address deficiencies in waste management, while creating an EU market for secondary raw materials and reducing administrative burden on companies.

Johnson Matthey welcomes the European Commissions initiative to increase circularity within the Single Market. We recognise that strengthening the market for secondary raw materials is crucial to ensure sufficient and secure supply for EU industries and to advance the Unions strategic objectives for sustainability and competitiveness.

Circular Economy Act – position paper Ref. Ares(2025)9527381 - 05/11/2025 CIRCULAR CHALLENGES FOR BUILDINGS • • • • • 1/3 of all raw materials consumed annually in the EU One of the largest generators of solid waste worldwide and 1/3 of the EU’s total waste generation 330 Mtons of construction & demolition waste generated in 2020 35% of the world’s C&DW disposed of in landfills despite 75% having potential added…

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

The Circular Economy Act (CEA) presents a strategic opportunity for the European Union to reinforce its industrial base and assume global leadership in the circular economy. The textile sector, in particular, stands out as a waste stream with significant potential for the development of a robust European secondary raw materials market.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the planned Circular Economy Act. Please find our position paper attached, which includes our comments in three sections: Retail and Wholesale key messages for the Circular Economy Act, our key messages for textiles and our key messages for the WEEE Directive revision.

Groningen, November 5, 2025 Subject: A Circular Economy Act for a strong Circular Chemical Industry Chemport Europe welcomes the European Commission’s initiative for the Circular Economy Act (CEA). The chemical industry is central to the circular economy transition, as it is at the foundation of many other industries.

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

The German steel industry welcomes the initiative of the European Commission to prepare a comprehensive Circular Economy Act (CEA) to accelerate the Unions transition towards a more circular economy. The forthcoming CEA provides the opportunity to becoming a strategic industrial policy tool that strengthens competitiveness, resilience, and climate neutrality.

Attached is the IFSA response to the Consultation. The content of the response is aligned with various stakeholders in the aviation and airline catering sector, including airlines, caterers, airports, as well as other organisations. We urge the European Commission to include provisions within the Circular Economy Act that support regulatory alignment.

Fibre Packaging Europe (FPE), a coalition of seven member associations jointly representing 1,500 companies bringing together Europes forestry, pulp, paper, board, carton packaging production, and recycling industries, has established a strong and well-functioning market for secondary raw materials through the sectors commitment to place on the market sustainably sourced products.

The European aggregates sector fully supports the transition towards a more circular economy that prioritizes resource efficiency, waste reduction, and the responsible management of natural materials. Across Europe, the Aggregates sector has combined its activities with environmental objectives generally, through activities such as nature restoration, water safety, climate adaptation, and biodiversity enhancement.

From the Catalan Nutrient Platform, we are sharing a document signed by several members of the platform, which outlines a series of recommendations to promote the circular economy in the field of nutrient recovery and their application, particularly in the agricultural sector.

Input for EU Circular Economy Act Jeannette van Rijsoort, transition manager Circular Economy Provincial government of Gelderland The Dutch provincial government of Gelderland, like all Dutch provinces, aims to become fully circular in 2050.

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

ESMC feedback to The Circular Economy Act The European Solar Manufacturing Council (ESMC) welcomes the Commissions initiative to strengthen circular economy measures. As solar photovoltaics are poised to become Europes largest energy source, it is critical to address key gaps in PV sustainability.

Opinion of the Innatura gGmbH on the Circular Economy Act: Donations instead of disposing of circular economies are the goal of circular economies, ideally keeping raw materials in circulation at the highest possible aggregate levels for as long as possible. An important lever is the actual use of resources for their intended purpose, so that they are not unnecessarily recycled or even disposed of at an early stage.

Filed in German · English published by the European Commission

Response to the European Commission’s Call for Evidence for the upcoming Circular Economy Act SUBMISSION FROM ENERGY DRINKS EUROPE BRUSSELS | OCTOBER 2025 1 SUMMARY 1 Energy Drinks Europe (EDE) is the leading representative trade association of European Energy Drink producers.

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

A circular economy is indispensable for a future world. By using materials smarter, reducing waste and making the most of raw materials, we are building a society that is not only climate-friendly, but also economically strong and competitive. The urgency to make this transition is widely recognised, but the role of biotech in accelerating it remains underscored.

Filed in Dutch · English published by the European Commission

Glass packaging embodies circular economy principles through its infinite recyclability, high collection and recycling rates, regional sourcing, and a deeply rooted and robust industrial ecosystem. With the right enabling conditions, it can deliver even greater benefits for Europes climate, circularity, competitiveness and strategic autonomy goals.

Metal Packaging Europe (MPE), representing the producers of rigid steel and aluminium packaging across Europe, welcomes the opportunity to provide input to the European Commissions call for evidence on the forthcoming Circular Economy Act (CEA). Metal packaging already embodies the principles of the Circular Economy: high recycling rates, highly recyclable, resource-efficient, and economically valuable.

Bozen, 5. November 2025 Statement for the EU consultation on the “Circular Economy Act” The Konsortium bau.recycle is the South-Tyrolean association for the mineral recycling industry in the construction sector. This applies in particular to the mass waste streams of concrete, asphalt, bricks and masonry, but also to excavated soil and plasterboard waste.

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

DGB-Stellungnahme zum europäischen Kreislaufwirtschaftsgesetz Der Aufbau einer Kreislaufwirtschaft ist ein zentraler Baustein für die sozialökologische Modernisierung der europäischen Industrie und Wirtschaft. Aus Sicht des Deutschen Gewerkschaftsbundes (DGB) leistet sie nicht nur einen wesentlichen Beitrag zum Klima- und Ressourcenschutz, sondern stärkt zugleich die Resilienz industrieller Wertschöpfungsketten…

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

As Director of the Waste Economic Forum, a foundation with a mission to create a narrative for a new economy that meets the needs of all, and creator of upcoming cinematic documentary WASTE JUNKIES, which tells the story of waste and the need for a circular economy, I welcome the Commissions initiative for a legislative act on the circular economy.

A Future-Proof Europe Based on a Circular Economy: Strengthening Europe’s Strategic Position A well-designed Circular Economy Act (CEA) can significantly enhance Europe’s strategic autonomy and resilience, stimulate growth in relevant industries, strengthen competitiveness and contribute to a future-proof economy. Therefore, we welcome the CEA and urge to: 1. Acknowledge and utilize the importance of regions. 2.

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

The Circular Economy Act offers a critical opportunity to address long-standing regulatory barriers that hinder circularity in the aviation sector. Specifically, the current classification of International Catering Waste (ICW) as Category 1 imposes disproportionate restrictions on the treatment of cabin waste, despite the absence of evidence linking ICW to animal disease outbreaks.

Creating a level playing field for mechanical recycling of plastic packaging waste in the European Single Market: Representing family-run companies of the plastic packaging value chain, ALPLA, REMONDIS, and Werner & Mertz welcome the European Commission's initiative to create a well-functioning market for secondary raw materials in the EU.

Grand Port fluvio-maritime de l’axe Seine HAROPA PORT 71 Quai Colbert, 76600 Le Havre (France) [email removed] www.haropaport.com Appel à contributions - Acte législatif sur l’économie circulaire HAROPA PORT – le Grand Port fluvio-maritime de l’axe Seine – remercie la Commission européenne pour l’opportunité de contribuer à la réflexion sur la future initiative en matière d’économie circulaire.

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)

STELLUNGNAHME ÜBER DEN CIRCULAR ECONOMY ACT Vorschlag für eine Verordnung mit dem Titel „Circular Economy Act“ Die Nichteisenmetallindustrie ist ein Schlüsselsektor für Deutschland, da sie maßgeblich zur Bewirtschaftung kritischer und strategischer Rohstoffe beiträgt. Besonders hervorzuheben ist ihre Fähigkeit diese Rohstoffe effektiv im Kreislauf zu halten.

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

Paprec Group, industrial leader of recycling and waste management in Europe, particularly in France but also in Spain and Poland, fully supports the ambition of the Circular Economy Act, to make Europe the world leader in circular economy. To scale up circularity, EU policy must go beyond waste management targets and foster robust single markets for recycled materials.

PFPI comments on a potential Circular Economy Act Response to public consultation, November 6th 2025 Contents/Summary of recommendations Introduction ................................................................................................................. 2 SDGs – but what about the environment? .......................................................................

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

The European Union stands at a pivotal moment in its green and industrial transition. As Letta and Draghi reports state, Circular Economy is not only about protecting the environment, but also about strengthening Europes strategic autonomy and the security of critical materials, ensuring stable and resilient supply chains across the Union.