Circular Economy Act

Stellungnahme des BAV - Bundesverbands der Altholzaufbereiter und -verwerter e.V. zur öffentlichen Konsultation zum EU-Circular Economy Act (CEA) Der BAV - Bundesverband der Altholzaufbereiter und -verwerter e.V. begrüßt die Initiative der Europäischen Kommission, mit dem Circular Economy Act (CEA) den Übergang zu einer europäischen Kreislaufwirtschaft zu beschleunigen.

TNO welcomes the announcement of the Circular Economy Act (CEA) as a timely and ambitious step to strengthen Europes single market for secondary raw materials and accelerate the transition to a truly circular economy.

CEN (the European Committee for Standardization) and CENELEC (the European Committee for Electrotechnical Standardization), as the recognised European Standardisation Organisations (ESOs), welcome the European Commissions initiative for a Circular Economy Act (CEA). Harmonized standards are essential to reach the ambitions of the CEA to build a genuine single market for secondary raw materials and circular products.

Opinion of the BAV – Federal Association of Waste Wood Reprocessing and Recyclers e.V. on the public consultation on the EU Circular Economy Act (CEA) The BAV – Federal Association of Waste Wood Reprocessing and Recyclers e.V. welcomes the European Commission’s initiative to speed up the transition to a European circular economy through the Circular Economy Act (CEA).

Filed in German · English published by the European Commission

The Danish Chamber of Commerce (DCC) welcomes the initiative to establish a Circular Economy Act as a key step toward a more competitive, sustainable, and resilient European economy. To ensure that the circular transition truly takes off, Europe needs a harmonised and predictable regulatory framework that removes barriers to circular business models, creates a well-functioning market for secondary raw materials, and…

The Association of Dutch Municipalities (VNG) supports the ambition of the European Commission to accelerate the transition towards a circular economy through a binding and practical legislative framework. Municipalities play a pivotal role in this transition as waste collectors, regulators, public procurers, and drivers of local circular initiatives.

These recommendations are the result of the research conducted by the group with PI Federico Demaria (University of Barcelona) currently engaged in the DUT project "Circular Grassroots" (https://dutpartnership.eu/projects/circular-grassroots). Circular Economy Act Key Recommendations 1. Adopt a degrowth and social justice perspective o Focus on absolute material flows, not relative recycling rates.

Submission to the public consultation for the Circular Economy Act The preparation of the CEA, including this public consultation, provides an opportunity to the Commission and Member States to improve the market situation for bio-based products across the board.

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

Feedback EU consultation Circular Economy Act The Dutch BioBased Circular Growth Fund Programme accelerates the development and implementation of a new industry where plastic materials are produced from bioresources. BBC welcomes the EU Circular Economy Strategy and supports the EU fully in striving for this industry transition in which circular resources will play a pivotal role.

Austro paper supports the European Union’s ambitions to strengthen the demand for secondary raw materials through the Circular Economy Act and to create a functioning internal market for waste while increasing the resilience of the European economy.

Filed in German · English published by the European Commission

The Better Cotton Initiative (BCI) welcomes the European Commissions ambition to make the Circular Economy Act (CEA) a cornerstone for accelerating the EUs transition to a truly circular economy. By strengthening the Single Market for secondary raw materials, boosting supply and demand for high-quality recycled inputs, and remove regulatory barriers, of the Act aims to double the EU circularity rate from 11.8% to…

The European Moulded Pulp Producers Association EMPPA represents the interests of businesses from the entire moulded fibre value chain. Our mission is to create a level-playing field for circular packaging products made of moulded pulp that is sourced from renewable resources like recycled paper and cardboard and agricultural by-products.

The European Confederation of Woodworking Industries (CEI-Bois) welcomes the European Commissions initiative to develop a Circular Economy Act (CEA) that will strengthen resource efficiency, support decarbonisation, and boost strategic autonomy in Europe. Wood is an indispensable circular material in Europe: renewable, reusable, repairable, recyclable, and capable of long-term carbon storage.

Whether for the call for evidence or the consultation, there are no explicit references to CCU as one of the levers to increase circularity, which is a major missed opportunity. CO2 Value Europe is therefore responding to this consultation (also with an attached position) with a series of arguments highlighting the important role of CCU in reducing reliance from virgin fossil feedstock, the link between CCU and…

The Association Smart Waste Portugal (ASWP) is a non-profit association, founded in 2015, with the mission of Potenciar the Circular Economy in the various value chains, through education, collaboration and the creation of new businesses.

Filed in Portuguese · English published by the European Commission

The Catalan Association of Reuse and Preparation for Reuse Centres and Services (aREca) brings together local authorities and public, social and private organisations that promote waste prevention, reuse and preparation for reuse across Catalonia (Spain). Our members develop reuse and repair initiatives, support citizens and companies in reducing waste, and create quality employment linked to circular activities.

The HVACR industry is increasingly engaged in the circular economy. While we are overall in favour of the increased importance of circular economy, we do want the Commission to be aware of several possible hurdles: - There is a lack of clarity with the definitions, concepts and standards used. - There is need for further harmonisation that will benefit the Single Market.

Brussels, 5 November 2025 Circular Economy Act proposal – Comments by the European Vending & Coffee Service Association (EVA) The vending industry is powered by innovation and committed to sustainable practices There are 4.5 million vending machines in Europe, 65% of which are hot drinks machines. In Europe, the industry employs more than 85,000 individuals directly.

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

1 Position of TomatoEurope on Commission Proposal of Circular Economy Act 4 November 2025 Introduction TomatoEurope represents the EU's tomato processing industry, encompassing over 5,000 companies across the EU, with a significant presence in Italy, Spain, France, Greece, Portugal and Hungary. As a vital sector within the EU's agri-food industry, we are committed to sustainability and circular economy principles.

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

We thank the European Commission for giving us the opportunity to contribute. Please find here below the statement of IVK Europe association. IVK Europe represents the joint interests of 13 European companies producing films and sheets made of different polymers for a multitude of applications. IVK Europe is the voice of its members on political and social level, in Europe as well as in the member states.

We welcome the European Commissions initiative to develop a Circular Economy Act (CE Act). As legal scholars specializing in law and circularity at Utrecht University, TU Delft and the University of Groningen, we research and educate on the most pressing issues hindering the advancement of the circular economy and society.

The circular economy (CE) is a high environmental priority for the Czech Republic. The Czech Republic considers it important that the following priorities are taken into account in this act: Economic instruments for promoting CE and waste prevention. Extended producer responsibility and its applications to other product groups.

Filed in Czech · English published by the European Commission

FEICA, the Association of the European Adhesive & Sealant Industry, welcomes the European Commissions Circular Economy Act as a landmark initiative to accelerate Europes shift to a truly circular model. Adhesives and sealants are essential enablers of circularity and the R-strategies throughout a products life.

The Ministry of Regional Development and Housing of Baden-Württemberg welcomes the European Commission's initiative on the Circular Economy Act. We see a need for improvement in the legal framework for the use of used building components. Components recovered during deconstruction or renovation should be exempt from the scope of the Waste Framework Directive, provided they can be refurbished for further use.

traceless materials GmbH welcomes the European Commissions consultation on the forthcoming Circular Economy Act. As an EU-funded bioeconomy scale-up developing an innovative traceless® material based on chemically unmodified natural polymers, we aim to contribute to a level playing field for new circular material classes.

Sociedade Ponto Verde (SPV), Portugals licensed Producer Responsibility Organisation (PRO) for packaging welcomes the Circular Economy Act (CEA) as an opportunity to make EPR systems performance-based and outcome-driven. SPV is fully aligned with the objective of reducing unnecessary administrative burdens while maintaining high environmental ambition.

The Circular Economy Act represents a unique opportunity to make circularity a true pillar of European industrial policy, strengthening the EUs strategic autonomy and competitiveness. By addressing long-standing barriers that still hinder investment and cross-border trade in secondary materials, the Act can turn circular economy principles into an integrated industrial strategy that benefits citizens, businesses…

We welcome the announcement of the Circular Economy Act (CEA), a key tool to develop a European Single Recycling market and scale effective recycling across the EU. Transport industries, especially the forward-looking sectors of electric mobility, must be considered as a central part of the CEA and the broader policy discussions surrounding Europes transition to a circular economy.

eBay welcomes the opportunity to contribute to the European Commissions preparatory work on the forthcoming Circular Economy Act. The initiative comes at a crucial time for strengthening the resilience, competitiveness and sustainability of the European economy through better use of existing resources.

The global economy has breached 7 out of 9 planetary boundaries. The Planetary Health Check 2025 makes it clear: we have to act now. The EU Circular Economy Act (CEA) is an important opportunity to work towards sustainable resources management. However, Article 114 of the TFEU as the legal basis is far too limited.

We welcome the EU Circular Economy Act (CEA) as a potential for a coherent framework for sustainable resource use. However, in its current direction, the proposal risks falling short of this potential. According to the International Resource Panel (2024), global resource use is projected to grow by 60% by 2060, threatening to derail progress on climate, biodiversity and prosperity.

Microsoft welcomes the European Commissions initiative to accelerate the transition to a circular economy through the proposed Circular Economy Act (CEA). We support the Acts ambition to address regulatory fragmentation, stimulate demand and supply for secondary raw materials, and create a true single market for waste and circular products.

The Brussels-Capital Region is a metropolis of 1.25 million inhabitants that is open to the world thanks to its status as a national and European capital, its multicultural character and its central position at the heart of the large urban region of North-Western Europe (Eurodelta).

Filed in French · English published by the European Commission

The upcoming Circular Economy Act (CEA) aims to put resource efficiency and waste reduction at the centre of sustainable production and consumption across the EU to address the high dependency on imported (critical) raw materials, stagnating circularity rates and single market barriers for recycled materials and recovered waste.

The Leuphana University of Lüneburg makes practical recommendations to strengthen circularity in the maritime sector through the EcoCab (funding code 03SX475) and ReCab (funding code 03SX623D) projects. We recommend making circular product design mandatory, e.g. through disassembly, modular construction and recyclable materials.

Filed in German · English published by the European Commission

Resoins Ref. Ares(2025)9519040 - 05/11/2025 IndustriAll Europe’s reaction to the European Commission’s call for evidence for the impact assessment on the Circular Economy Act Brussels, 16/10/2025 Disclaimer: The below reaction is a preliminary opinion on the upcoming Commission Proposal on the Circular Economy Act, which is based on positions previously adopted by industriAll Europe’s Executive Committee.

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

Ecommerce Europe is committed to shaping a Circular Economy Act that delivers for all industries and businesses involved in the transition from a linear economic model to a circular one. While we see the publication of the Call for Evidence as an important step towards the delivery of the initiative, we note the absence of planned measures to foster the re-use of resources, most notably finished products, including…

Promoting Circularity in the European Lubricants Industry through Re-Refined Base Oils (RRBOs) The European Lubricants Industry, represented by ATIEL and UEIL, supports the EUs 2050 climate neutrality goal and welcomes the Circular Economy Act as a key enabler of the European Green Deal. ATIEL and UEIL also support measures fostering the implementation of the Waste Hierarchy.

Air France-KLM Circular Economy Act Call for Evidence for an Impact Assessment 5 NOVEMBER 2025 Air France-KLM welcomes the opportunity to participate in the call for evidence of the Circular Economy Act and would like to share its contribution from our experience to the better drafting of the text.

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

European Deposit Return Systems Association The European Deposit Return Systems Association supports the initiative of the Commission for a Circular Economy Act (CEA) and welcomes the opportunity to submit its observations. Connecting CEA to competitiveness and growth As the explanation to Consultation states (see letter A.

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

Boosting circularity in Europe is essential to strengthen the EUs economic security, competitiveness and climate leadership. Greater circularity can reduce resource dependency and costs, boost innovation and deliver up to a quarter of the emission reductions needed for climate neutrality, creating quality jobs and enhancing industrial resilience.

Key Policy Recommendations for a Circular Economy in non-ferrous Metals & CRMs. To unlock the full potential of non-ferrous metals and critical raw materials in the EUs circular economy, we need smart, targeted policies: 1) Tailor approaches, no one-size-fits-all 2) Use KPIs that reward strategic recovery 3) Build a true single market for waste 4) Focus on quality recycling, not mandatory content quotas 5) Ensure…

For DAQUAS (Spanish Association of Urban Water) the upcoming Circular Economy Act must recognize and harness the full potential of water services, and in particular wastewater and sludge, for resource and nutrient recovery. These resources contribute to a circular economy, enhance competitiveness and strengthen the EU internal market. However, significant regulatory, market and technologica barriers remain.

Renewables Norway input "Call for evidence" Circular Economy Act Renewables Norway is an interest and labour organization representing over 400 members across the Norwegian renewables industry, including energy producers, grid operators, contractors, suppliers, and advisers.

AEA supports a comprehensive Circular Economy Act that unlocks both supply and demand for verifiable, high-quality secondary materials and addresses single-market fragmentation for waste and secondary raw materials. Alongside the announced flagship on e-waste, the Act should explicitly prioritise construction and demolition waste (CDW) within the single-market pillar.

In our opinion, Circular Economy Act should pay particular attention to the links between waste management, the chemical industry and the energy industry. Material uses within the meaning of CCUS concern waste management as well as lime, cement and chemical industries. The study on coal materials circular economy in Central German Revier shows the chalks of a cross-sectoral perspective.

Filed in German · English published by the European Commission

General remarks on waste legislation and recycling in the EU: 1. Current rules on transboundary waste shipments fragment the Single Market instead of supporting it. 2. Procedures are overly bureaucratic, costly, and time-consuming for both companies and national administrations. 3. Legislation is based on the assumption that all operators may act in bad faith.

Biotechnology and bioeconomy are key cross sectoral circularity enablers that rely on renewable raw materials, enhancing resource efficiency while adding value in the process. The Circular Economy Act must foster a holistic, coherent and supportive policy framework for biotechnologies.

Statement by the Association of lnformation Technology and Telecommunications on the European Commission public consultation on the Circular Economy Act On behalf of its members, the Association of lnformation Technology and Telecommunications (hereinafter referred to as "Association") would like to draw attention to the problematic aspects of monopolies and monopolization in the environment of EPR systems for…

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

WindEurope Response to The Circular Economy Act Public Consultation Introduction The European wind industry welcomes the European Commission’s initiative for a Circular Economy Act. We strongly support its objectives to accelerate Europe’s transition towards a more circular economy while enhancing the EU’s economic security, resilience, competitiveness, and decarbonisation efforts.

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

Bellona Europa welcomes the European Commissions forthcoming proposal for a Circular Economy Act (CEA) under the Clean Industrial Deal. We strongly support its goal to remove barriers in the EU single market for waste and secondary raw materials and to enable sustainable, competitive business models for circularity.

MVO Nederland welcomes the opportunity to contribute to the European Commissions public consultation on the Circular Economy Act (CEA). The CEA represents a crucial step in strengthening and improving the supply and demand for high-quality, recycled materials, and ensuring that Europes economy becomes both circular and competitive.

Dear sirs, Please find attached feedback. We are an SME in Ireland and operate a Construction & Demolition End of Waste / recycling Facilty. We have some observations and evidence based on our experience, including differences in cross-border regulations.

Caffe Inc. B.V., based in Amsterdam, is a circular company dedicated to transforming coffee waste into valuable bio-based products such as coffee oil, natural dyes, and biomaterials. Our sustainable biorefinery supports the EU Circular Economy Act by reducing the use of virgin raw materials that compete with food, strengthening the EU manufacturing independence, and lowering CO emissions.

PepsiCo welcomes the opportunity to contribute to the public consultation on the Circular Economy Act. We support the EUs ambition to accelerate the transition to a circular economy and believe that the Act should provide a robust framework to enable industry-led solutions, foster innovation, and ensure legal certainty.

ECOVIDRIO welcomes the opportunity to participate in the call for evidence of the Circular Economy Act and would like to share some proposals with the aim of contributing from our experience to the better drafting of the text, Hoping that they will be of interest to the European Commission.

Filed in Spanish · English published by the European Commission

Technique Nederland is the Dutch trade association for technical service providers, installation companies and installers, and electrical engineering retailers and repairers. This paper provides perspective on Techniek Nederland’s response as feedback for the public consultation on the Circular Economy Act.

Filed in Dutch · English published by the European Commission

The KU Leuven Institute for Sustainable Metals and Minerals (SIM²) carries out applied research on upcycling processes for raw and secondary resources, advanced resource characterization, sustainable re-and de-manufacturing processes, as well as health, environment, and sustainability assessment.

GCE's response to the Call for Evidence is attached. In summary, Generation Climate Europe (GCE) welcomes the European Commissions initiative on a Circular Economy Act, a very important step forward to enhance the circular economy in the EU. However, we want to highlight that the necessity of rethinking the current economic system must be integrated in the CE Act.

Response Royal Schiphol Group call for evidence Circular Economy Act November 5th, 2025 Introduction Royal Schiphol Group (Amsterdam Airport Schiphol, Rotterdam The Hague Airport, Eindhoven Airport, Maastricht Aachen Airport and Lelystad Airport) welcomes the European Commission plans for a Circular Economy Act. We emphasize the need to create a circular society and aim to be a fully circular airport by 2050.

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

Forest Stewardship Council® (FSC®) welcomes the European Commissions Circular Economy Act (CEA) as an opportunity to reform the EUs resource use, including those forest-based. To ensure long-term resource resilience and ecosystem health, the CEA must recognize and acknowledge the true value of forests and forest fibers, go beyond recycling to induce verified circular flows, and embed robust compliance structures and…

Cradlenet and its members welcome the European Commissions proposal for a Circular Economy Act (CEA) as a crucial step toward strengthening Europes resilience, competitiveness, and environmental sustainability. To be effective, the CEA must set a unified direction for all Member States, define clear and measurable goals, and create strong economic incentives that drive the shift from a linear, extractive model to…

BEWI welcomes the Circular Economy Act initiative and supports its objective to accelerate Europes transition to a circular economy. As a producer of 100% recyclable plastic products and an active user of secondary raw materials, BEWI shares the concern about slow progress.

The Fédération de la Mode Circulaire welcomes the Circular Economy Act as a historic opportunity to make circularity the engine of Europes industrial renewal. By harmonising EPR, clarifying end-of-waste rules, supporting eco-design, repair, reuse, upcycling, rental and recycling, revising customs codes and creating strong fiscal incentives, the CEA can turn circular business models into a true competitive advantage…

EBB is a Brussels NGO promoting the circular bioeconomy and is a partner in the PROSPER project financed through the Horizon CBE JU Grant #101157907. The project researches into advanced technologies for the sorting and recycling of bioplastics and involves 17 partners across the EU (see Prosper).

The upcoming Circular Economy Act presents a pivotal opportunity to accelerate the transition toward circular business models by creating a compelling business case for companies to invest in circularity. By offering targeted incentives and removing structural barriers, the Act can drive meaningful change across industries, particularly in textiles and footwear.

Kaneka Corporation, a global chemical manufacturer with a strong European presence, is committed to advancing the EUs transition towards more circularity and sustainability. Our flagship biopolymer, Green Planet PHBH, is a fermentation-derived polyhydroxyalkanoate (PHA) made from renewable plant and recycled oils.

COCIR members are and have been dedicated to advancing a circular economy in the medical devices sector for years. Through the reuse and refurbishment of parts and equipment, we aim to minimize waste, conserve raw materials, and reduce energy consumptions.

COTANCE’S FEEDBACK TO THE EUROPEAN COMMISSION’S CALL FOR EVIDENCE ON THE CIRCULAR ECONOMY ACT Leather is a renewable, bio-based, and circular material, used in a myriad of consumer products, from footwear, clothing and leathergoods to car interiors and furniture. Tanning performs in our societies the recycling service for one of the by-products arising during the production of meat.

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

6th November 2025 EU Circular Economy Act- Preliminary reflections of Novelis The forthcoming Circular Economy Act (CEA) offers a pivotal opportunity for the European Union to establish a genuine Single Market for secondary raw materials. As the European Environment Agency highlighted in its 2025 Report1, the EU must now actively drive circularity.

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

Construction & Demolition Waste (C&DW) is the biggest waste stream in the EU. It is not regulated properly at EU level, the 70% recovery target is often met with by "backfilling". There is a need for improvement and the Circular Economy Act could be the place to arrange this. What is needed foremost is a recycling target for inert C&DW.

05.11.2025 Consultation: Proposals for the Circular Economy Act Duesenfeld GmbH welcomes the European Commission’s initiative to develop a Circular Economy Act to strengthen Europe’s resource independence and 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)

STANOVISKO ČESKÉ PODNIKATELSKÉ RADY PRO UDRŽITELNÝ ROZVOJ, Z.S. (CBCSD) V RÁMCI VEŘEJNÉ KONZULTACE EVROPSKÉ KOMISE K AKTU O OBĚHOVÉM HOSPODÁŘSTVÍ 1. Úvod Česká podnikatelská rada pro udržitelný rozvoj, z.s. (Czech BCSD) považuje připravovaný Akt o oběhovém hospodářství (AoOH) za mimořádně důležitý pro všechny klíčové zúčastněné strany v Evropské unii: občany, podnikatele, investory, finanční instituce, vzdělávací…

Filed in Czech · English published by the European Commission

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

PVC window profiles without the lead marking contains >= 0.1% lead shall not be subject to any requirements regarding the percentage of recycled material. Customers must retain the right to purchase windows made from lead-free profiles in the future. Mandatory recycling rates with a proportion of post-consumer windows would force customers to purchase windows with lead labelling ("contains >= 0,1% lead").

ECOS welcomes the recognition that reducing the EUs dependency on raw materials, improving competitiveness, and mitigating environmental pressures requires a strong circular economy. We support proposals to expand Extended Producer Responsibility schemes, establish mandatory criteria for circular public procurement, and increase attention on Waste Electrical and Electronic Equipment, and hopefully on waste…

At current huge amounts of mixed waste are still landfilled in the EU. The Circular Economy Act should target these waste streams, such as Municipal Solid waste, inert Construction & Demolition Waste and Commercial & Industrial Waste. These wastes contain considerable amounts of recyclables. Their residues are calorific and can be used to produce Solid Recovered Fuel (SRF).

EXPRA Key Recommendations for the Circular Economy Act Extended Producer Responsibility (EPR) is a cornerstone of the EUs circular economy and waste policy. As the EU prepares the Circular Economy Act, it must protect EPRs integrity so it continues to deliver environmental and economic value. EPR must remain producer-led, fair, and adaptable to challenges such as e-commerce and changing consumer behaviour. 1.

3 November 2025 EDANA Response to the Call for Evidence on the Circular Economy Act EDANA, the voice of the nonwovens and related industries, represents the entire nonwovens value chain. This includes manufacturers of the materials that go into many different product applications, such as hygiene products, automobiles, agriculture, protective clothing, medical clothing and, in healthcare, more broadly.

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

As young EU citizens, students of Environmental Protection Structure want to express their views on the directions of EU legislation on the circular economy. In the appendix, we present the main problems of our class students. Kacper Głubisz Milos Nawolski Patrycja Yędruchovich Julia Siupik Dominik Wojtas

Filed in Polish · English published by the European Commission

In the context of the draft European regulation aimed at enhancing the circularity of secondary raw materials, it is essential to remove regulatory barriers that hinder the recovery of alternative materials from waste, in particular those from dredging or curing.

Filed in French · English published by the European Commission

Madaster is a digital platform that manages product, asset, and portfolio data across several EU markets to enable reuse, cut embodied carbon, and support compliant circular reporting. We welcome the Commissions development of a new Circular Economy Act (CEA). We consistently see the same pattern: decarbonization leads; circularity enables.

It is laudable to create a Circular Economy Act that complements or crowns the existing Directives and Frameworks which guide the EU economy towards the Paris Agreement. The increasingly large WEEE waste stream is a growing and valid concern.

The European Federation of Pharmaceutical Industries and Associations (EFPIA) and its members support the EUs ambition to advance a circular economy and share the objective of fostering sustainability while safeguarding public health and the resilience of global supply chains. We are committed to innovation, sustainable manufacturing, and responsible resource use.

A coherent policy framework should be established, positioning circularity as a cornerstone of Europe's vision for strategic autonomy. The Circular Economy Act must be designed to revitalize and create a future-proof European industry, ensuring competitiveness and sustainability while incorporating the essential factors that enable the circular transition, keeping in mind short-term and long-term goals.

RENAS AS welcomes the European Commissions Circular Economy initiative. We have provided our feedback in the enclosed document. The main points are summarised below: 1. Use the EPR tool to achieve environmental benefits and material-based recycling targets. 2. Expand the WEEE scope to include all electronic equipment, notably industrial cables and professional equipment.

The forthcoming Circular Economy Act presents a critical opportunity to advance Europes transition toward a sustainable, resource-resilient economy. Logitech supports the Commissions objectives and urges targeted, harmonized reforms to ensure the legislation strengthens circularity without creating new administrative burdens.

Vestas and Stena Recycling welcome the Commissions initiative to develop a Circular Economy Act. We endorse the ambition to create a single market for secondary raw materials, increase the supply and demand of high-quality recycled materials, and position Europe as a global leader in circularity by 2030.

From the mining sector, and to achieve competitive development of critical raw material (CRM) projects and their processing value chains, we propose including the following measures in the Circular Economy Act: - Funds for the exploration of CRM mineral deposits to complete feasibility studies for mining projects.

The WEEE Forum are supportive of initiatives that create a fully integrated, efficient, fair and resilient circular economy, securing the supply of critical raw materials, stimulating investment, and supporting long-term environmental, economic, and strategic benchmarks.

Réponse à consultation Circular Economy Act – Contribution de France Nature Environnement Le Circular Economy Act, une opportunité pour agir en faveur de la sobriété matières Parce que l’Union européenne reconnaît la hiérarchie des modes de traitement des déchets, elle doit impérativement donner les moyens à la prévention, au réemploi et à la réparation, qui sont actuellement largement insuffisants, notamment en…

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)

Circular Economy Act call for evidence, contribution from Stockholm Exergi Stockholm Exergi is the energy company serving Swedens capital. We ensure that the region can continue to grow with resource-efficient access to heating, electricity, cooling, and waste treatment services.

The European Federation of Geologists (EFG) welcomes the European Commissions initiative to launch a public consultation for the upcoming Circular Economy Act. As the EU strives to double its circularity rate and enhance the competitiveness of its circular economy by 2030, the EFG underscores the pivotal role of geoscientific expertise in achieving these objectives.

LOréal welcomes the opportunity to contribute to the Circular Economy Act call for evidence. As the worlds largest beauty company, we recognize our unique position and responsibility to drive real, meaningful change. For over 25 years, LOréal has proactively worked towards a sustainable and inclusive future, seeking to protect the planets beauty and empowering communities worldwide.

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

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

Futerro welcomes the EU Circular Economy Act and fully supports and recognizes the significant role such a framework can play to advance decarbonization, reduce fossil dependency, and strengthen European competitiveness. As a pioneer in bio-based chemicals and plastics, Futerro emphasizes the strategic role they play in achieving a truly circular and regenerative economy.

Pre-Deconstruction audits for the CE act Executive Summary We welcome the European Commission’s 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.

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

Since 2015, the remanufacturing and refurbishment sector of the circular economy has enjoyed a period of strong growth, even if some of the product sectors within it have experienced a slower pace of unit growth or even decline (e.g., automotive aftermarket parts, printer cartridges and passenger vehicle tyres).

The German Association of the Automotive Industry (VDA) consolidates around 620 manufacturers and suppliers under one roof. The members develop and produce cars and trucks, software, trailers, superstructures, buses, parts and accessories as well as new mobility offers. As VDA we fully support the advancing of the European Union into a modern, resource-efficient and competitive economy.

English summary in the attached document. Industry Producer Responsibility (NPA) is a producer responsibility organisation for packaging. Welcomes the Commission’s approach to the circular economy; Our views focus on packaging waste and touch upon two themes: Improve the competitiveness of circular raw materials. Create a level playing field for producer responsibility.

Filed in Swedish · English published by the European Commission

Tracegrow operates at the core of the circular economy sector. The company produces micronutrient fertilizers from used alkaline batteries and zinc industry electrolysis waste fraction (anode sludge). Zn and Mn are extracted and purified from these fractions. The company also produces circular manganese sulfate to the battery industry for the raw material of pCAM:s.

First, we at Circular Pirkanmaa (Ecofellows) would like to emphasize that it is positive that a separate new Circular Economy Act (CEA) is in the development. It is very important that circular economy (CE) and resource efficiency are linked to the economy, which is ultimately what the CE is all about. This is very important for eg. security of supply and material self-sufficiency.

The construction sector, as the EUs second-largest industrial ecosystem, is essential to achieving Europes green and digital transition. To realise this potential, the EU must ensure a coherent and predictable regulatory framework that drives circularity, fosters innovation, and strengthens industrial competitiveness.

Vantaan Energia (VE) welcomes the Commissions initiative for a comprehensive Circular Economy Act (CEA). Vantaan Energia is a Finnish energy company that treats non-recyclable waste thermally and recovers waste heat for district heating and electricity. VE operates an extensive district heating network in Vantaa, Finland's fourth-largest city.

RETRIEVE Feedback on the Circular Economy Act Consultation. EU Horizon project RETRIEVE welcomes the Commissions initiative to strengthen circular economy measures. As solar photovoltaics (PV) are poised to become Europes largest energy source, it is critical to address key gaps in PV sustainability: Need for a Harmonized EU Standard for PV Recycling.

The EU-funded RISERS project welcomes the European Commissions initiative for a Circular Economy Act (CEA). The CEA seeks to remove barriers to circularity in the single market and to help create sufficient supply and demand for secondary raw materials (including critical raw materials) and a true single market for waste and secondary raw materials.

We welcome the Commissions ambition to accelerate Europes transition towards a circular and regenerative economy and to strengthen the Single Market for sustainable products. As representatives of the textile sector, we strongly support this goal.

As Dutch Water Authorities, we welcome the upcoming Circular Economy Act. The Dutch Water Authorities share a long history of managing the Dutch regional water system, starting in the 13th century. Today, there are 21 water authorities with their own democratic administration, elections and taxation system. We treat around 2 billion m3 wastewater annually.

The Finnish Association of Architects SAFA suggests the following changes to the Circular Economy Act: Durability and lifecycle design should be promoted. A narrow focus on recycling combined with the free movement of waste materials across borders could lead to waste being shipped to the member state with the least strict regulation on waste handling.

The municipality welcomes the European Unions ambition to strengthen the circular economy and remove barriers within the single market for waste and secondary materials. The proposed measures align with the municipalitys local sustainability goals and ongoing efforts to reduce waste, promote reuse, and support greener forms of production and consumption.

Kemira appreciates the opportunity to provide input on this important regulation, which is critical to Europes resource security, climate neutrality, and competitiveness. Europes circular transition needs coherent regulation, infrastructure investment, and strong market signals. Without harmonized standards and incentives, Europe risks falling behind in resource security and low-carbon innovation.

To meet the Unions climate, resource-efficiency and competitiveness goals, the CEA should explicitly steer the Ecodesign for Sustainable Products Regulation (ESPR) toward non-road mobile machinery (NRMM) used on construction and mining sites. Worksite machinery and its powered attachments (tiltrotators, quick couplers, breakers, compactors etc) are major contributors to fuel use, emissions and noise.

Introduction The RDS Circular Economy Awards, delivered in collaboration with Trinity Executive Education celebrate the innovators leading Ireland’s transition to a regenerative, circular economy. In 2024, the RDS launched the inaugural Circular Economy Awards, highlighting innovation, leadership, and practical solutions that are moving us closer to a regenerative and resilient future.

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

UNI the UNI Italian Standards Body, officially recognised by the Italian State and a member of CEN CENELEC and ISO IEC together with ACCREDIA, the Italian Accreditation Body, welcomes the European Commissions Call for Evidence on the forthcoming Circular Economy Act (CEA).

Advancing the Circular Economy in the Construction Sector The circular economy in construction sector plays a pivotal role in achieving the European Unions climate goals. However, current market conditions, standards and regulations remain largely designed for building new structures from virgin materials.

Flexible Packaging Europe welcomes the Circular Economy Act. The Circular Economy Act is an important opportunity to scale up circular economy in the EU and build a solid end-of-life system for packaging and other products, making the EU a competitive and circular world frontrunner and capturing back the materials that can be used for a wide variety of applications.

The Organic Cotton Accelerator (OCA) welcomes the European Commissions commitment to advancing circularity in the EU through the forthcoming Circular Economy Act. We support the Acts objective to strengthen Europes resource efficiency and resilience.

In our position paper, the European Sustainable Business Federation - Ecopreneur.eu details how the Circular Economy Act could create market demand for secondary materials and establish a single-market for waste, as specified in the mission letter to Commissioner Jessika Roswall.

We thank you for the opportunity to comment and welcome the Commission’s proposal. SATTLER GROUP is a global company with a value chain involving weaving, finishing, coating and making-up of technical textiles. The following contribution is made on behalf of the European companies Sattler SUN-TEX GmbH and Sattler PRO-TEX GmbH. You can find our feedback in the attached file.

Filed in German · English published by the European Commission

AECOC, a multi-sectoral organisation bringing together more than 35.000 partner companies from both industry and distribution, we appreciate the EU’s ambition to boost circularity, improve competitiveness and reduce dependence on primary resources. We consider that the initiative to create a Single Market for high-quality secondary materials, which will strengthen business competitiveness, is appropriate.

Filed in Spanish · English published by the European Commission

The following statement is made by the Federal Institute for Research on Building, Urban Affairs and Spatial Development within the Federal Office for Building and Regional Planning (BBSR), WB 6 In-struments for resource-saving and climate-adapted construction. It addresses the relevance of recy-cling issues to the construction sector in Germany, including related upstream and downstream in-dustries.

Summary - for the full feedback, see attachment WWF Germany welcomes the European Commissions political commitment to developing the Circular Economy Act (CEA). To fully realise its potential, the CEA must go beyond the focus on secondary materials. A genuine Circular Economy requires addressing the full hierarchy of R-strategies, including refuse, reduce, reuse, repair and remanufacturing and recycling.

The PRO Circularity Alliance welcomes the European Commissions (EC) proposal for a Circular Economy Act (CEA) and stresses the central role of Producer Responsibility Organisations (PROs) in enabling efficient, transparent, and harmonised circular systems across the European Union (EU).

The Global Electronics Council (GEC) welcomes the European Commissions proposal for a Circular Economy Act (CEA). GEC is a mission-driven non-profit dedicated to advancing responsible technology, with staff in the EU, Canada, and the USA. It manages EPEAT, a Type I ecolabel (ISO 14024) widely used for sustainable procurement across the EU and globally.

We welcome the Circular Economy Act as a cornerstone of Europes transition but emphasize that finance must be embedded as a structural enabler of circular value. Current accounting, collateral, and credit rules disadvantage long-lived, recoverable assets and delay circular adoption.

In our contribution, we have formulated a number of recommendations based on the experiences with the circular policies of the cities of Leuven and Mechelen, which should ensure that the role of cities in the circular transition is strengthened. We are convinced that cities can play a crucial strategic role in accelerating the circular transition.

Europes transition to a circular economy must go hand in hand with industrial competitiveness, innovation and open markets. The linked paper holds 14 recommendations from the Swedish business community on how to make the circular economy work better for companies, large and small, while strengthening Europes resilience and environmental performance.

OCTOBER 2025 Feedback on the Circular Economy Act CALL FOR EVIDENCE As Europe’s largest network of social enterprises in the circular economy, we welcome the European Commission’s recognition of the circular economy as a driver of resilience and competitiveness in the Union. However, we are deeply concerned by the lack of ambition to promote waste prevention and reuse.

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)

Estonian Green Movement Consultation Response on the proposal for an EU Circular Economy Act The world economy has breached 7 out of 9 planetary boundaries. The Planetary Health Check 2025 makes it clear: increased resource consumption, driven by growth and competitiveness, is destroying our living environment.

The Driving Urban Transitions (DUT) Partnership funds transformative research and innovation projects to accelerate urban transitions towards a climate neutral and resilient future for all. DUT supports the commission's goal to accelerate the circular economy and the development of the Act.

Stellungnahme zur öffentlichen Konsultation der EU-Kommission zum Circular Economy Act Mit dem Circular Economy Act setzt die EU-Kommission ein Zeichen für die Transformation zu einer europäischen Kreislaufwirtschaft. Die Verpackungs-Kreislaufwirtschaft spielt dabei eine zentrale Rolle. Für die Umsetzung der Pläne sind einheitliche und effektive Rahmenbedingungen im Binnenmarkt notwendig.

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)

Pre-Deconstruction audits for the CE act Executive Summary We welcome the European Commission’s 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.

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

Royal Cosun is a leading agricultural cooperative owned by 8,000 crop growers. Our aim is to maximise the valorisation of all components of our growers' crops. On yearly basis we process over 11.000.000 tonnes of biomass. We have been adding value this way since 1899.

In different studies we have analyzed how financial market participants such as banks and ESG rating providers consider plastics and circularity, showing that they currently lack an integration of plastics criteria (https://www.facing-finance.org/en/2025/09/plastic-money-are-banks-turning-a-blind-eye-to-the-plastic-crisis/ …

Dear Members of the European Commission, We appreciate the opportunity to present our feedback regarding the Circular Economy Act (CEA). Drawing from our previous submissions on the ESPR and WFD, we would like to emphasize the following critical topics that are essential for advancing circularity and sustainability within the European market, particularly in the mattress sector.

We welcome the EU Circular Economy Act (CEA) as a potential for a coherent framework for sustainable resource use. However, in its current direction, the proposal risks falling short of this potential. According to the International Resource Panel (2024), global resource use is projected to grow by 60% by 2060, threatening to derail progress on climate, biodiversity and prosperity.

Tarkett has been developing circular flooring solutions for decades. Through its ReStart programme, post-installation and post-use materials can be collected in member states and recycled into new products in Tarketts European factories.

Gestamp welcomes the Circular Economy Act as a landmark initiative to accelerate Europes transition toward a more resource-efficient economy. As a global automotive supplier and one of the largest users of steel and aluminium, we strongly support its ambition. At the same time, its effectiveness would increase by giving greater emphasis to the unique role of metal scrap in the circular economy. 1.

Pre-Deconstruction audits for the CE 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.

Syctom, Europes leading public operator in municipal waste management, welcomes the new Circular Economy Act. With its 6 sorting centres and 3 Waste-to-energy units, Syctom processes 2.3 million tonnes of municipal waste (namely 10% of French municipal waste) from six million inhabitants of the Île-de-France region, including Paris.

The Circular Economy Act (CEA) aims to advance the EUs transition to a circular economy by fostering a single market for circular products, secondary raw materials, and waste. It supports the goals of the Clean Industrial Deal, Competitiveness Compass, and Draghi report by strengthening economic resilience, decarbonisation, and reducing dependency on non-EU raw materials.

Circular Economy Act Call for Evidence The International Wool Textile Organisation (IWTO) is the global authority for standards in the wool textile industry. Founded in 1930, today IWTO has represented 41 members across 28 countries, spanning the entire wool textile pipeline from farm to retail.

CIRCULAR ECONOMY ACT Response to the call for Evidence 31.10.2025 1 INTRODUCTION Sika AG is a specialty chemicals company with a globally leading position in development, production and marketing of systems and products for bonding, sealing, damping, reinforcing, and protection in the building sector and many manufacturing industries.

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

EUROSLAG is an European association with 26 members from 16 countries, which is doing lobbying and communication on the slag-based by-products from the steel industry. These building materials and fertilisers from the steel industry have already made an major contribution to the conservation of natural resources (2000-2025(EU27 + UK) : 1.2 billion tons of natural rock substituted and 400 million tons of CO2…

Input from Norwegian Salmon Rivers (Norske Lakseelver) We welcome the Commissions initiative to strengthen the circular economy through the forthcoming Circular Economy Act (CEA). Norway produces one-third of the worlds Atlantic salmon and has unique experience with the challenges of nutrient losses, unpriced environmental costs, and the need for technological transition in aquaculture. 1.

HoliMed is a Danish-centered initiative dedicated to establishing the infrastructure required for recycling medical devices to enable a circular flow in an otherwise conventional linear value chain. We appreciate the EUs goal to "...facilitate the free movement of circular products, secondary raw materials and waste".

Overall main feedback from FSCA Pilot Study (Startups with Circular Business Models), attached pilot study report. 3 in depth feedbacks also added. If Europe measures circularity with linear metrics, it will fund the past instead of the future. Circular startups and rural innovators are essential to Europes circular transition.

Feedback on Circular Economy Act The Danish Plastics Federation and our Circular Plastic Section welcome the Commission's initiative to develop a Circular Economy Act and offer our feedback. Background A strong focus on the collection and recycling of plastic waste is essential but it cannot stand alone. Plastic recycling only works if the recycled raw materials are actually used again.

The Italian Electrotechnical Committee (CEI), Italys national body for technical standardisation in the electrotechnical, electronic and telecommunications sectors, welcomes the European Commissions consultation on the forthcoming Circular Economy Act. This initiative aims to strengthen the EUs economic security, promote sustainable production models, and support decarbonisation.

The European members and associates of Humana People to People (HPP-EU) welcome the opportunity to contribute to the new Circular Economy Act. The act is a path towards accelerating the transition to a more circular economy, waste reduction, and promote resilient and competitive economies through job creation in circular industries. However, without reuse, the initiative will fail to go further than an ambition.

The International Manganese Institute (IMnI), representing the global manganese industry, welcomes the European Commissions initiative to advance the circular economy and reduce dependence on imported raw materials through the forthcoming Circular Economy Act, expected to be adopted in 2026.

EU Candidate Countries and neighbours like Serbia, North Macedonia and Albania offer opportunities to develop rapidly and drive CE changes. The EU secondary raw materials market does not exist in isolation, it operates within the global context. If 3rd country trading partners are not moving in the same direction, or are actively undermining CE efforts then the EU cannot lead.

In depth feedback no 3 from FSCA Pilot Study. Territorial cohesion understood as balanced and inclusive development across all EU regions must go hand in hand with circular excellence. The principles of a circular economy has always been the natural way to do things in rural Europe, at least until the industrial revolution: repairing, reusing and sharing resources within local communities.

1. Circular Economy (CE) The production system linked to metals must act/react in an agile, strategic and economic manner. This can only be done using physics based approaches, i.e. simulation of the system, supply chains etc. NO EXCEL CE BLA BLA! This only misleads the taxpayer. I have for example discussed in the following over the years, so we have looked in detail at the downward spiral of the CE (since ca.

The City of Stockholm has high ambitions in the field of environment and climate action. The city’s budget, environmental programmes and climate action plan stress the need to reduce consumption-based emissions, in particular from construction, food, IT equipment and textiles. The aim is not only to reduce own emissions, but also to contribute to the sustainable use of resources and circular flows.

Filed in Swedish · English published by the European Commission

In attachment you'll find the statement of the EU-funded project RETAIN (https://www.retain-project.eu/). RETAIN is driven by a strong international collaboration, bringing together 15 partners from 7 EU countries with the common goal to demonstrate effective circular value chains for complex plastic materials and enable a circular use of tarpaulins through combined environmental, economic, and social impact…

Soilfood Ltd welcomes the European Commissions initiative to strengthen the circular economy framework across the EU. The transition toward a resource-efficient, low-emission economy requires clear, coherent and enabling regulation that supports the safe and sustainable reuse of materials.

In the context briefing for the Circular Economy Act we - AMS Institute (a scientific institute of Delft University of Technology, Wageningen University and MIT) - would like to see a strong connection between Circular Economy and Biobased Economy principles.

The Italian manufacturing system, based on highly specialised industrial districts and small and medium-sized enterprises, is already today an efficient model of production, waste reduction and resource recovery. In this context, the transition to a circular economy is not only an environmental challenge, but a strategic lever for industrial competitiveness, technological novation and security of supply chains.

Filed in Italian · English published by the European Commission

This is feedback from the Environmental Board in Malmö, Sweden (see attached file). The feedback was decided at a Board meeting on 23 October 2025. Malmö City also supports the feedback that will be shared by ICLEI (Circular Cities frontrunner Group) as well as the project consortium Let’s Go Cicular! (Urbact).

Filed in Swedish · English published by the European Commission

CNA welcomes the European Commissions initiative for a Circular Economy Act, a decisive step toward a resource-efficient and climate-neutral Europe. MSMEs, the backbone of the EU economy, already contribute to circularity through repair, reuse, recycling, eco-design, and sustainable production, but often face complex procedures and high compliance costs.

Germanwatch welcomes the Circular Economy Act but urges a broader approach beyond recycling to unlock the potential of circularity for resource protection, resilience, more independence from insecure raw material imports and the innovation potential for the European industry. Demand-side measures (reducing material use) must accompany supply-side strategies (strengthening recycling) to improve circularity rates.

LPC SA proposals for the Circular Economy Act November 2025 Introduction The Groupement Européen de l’Industrie de la Régénération (GEIR) represents Europe’s waste oils re-refining industry, comprising of member companies actively engaged in the collection of waste lubricating oils, the largest amount of liquid hazardous waste in the world, and their re-refining into valuable lubricant base oils.

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

The circular economy is too often associated with the end of a product's life and related issues such as recyclability. However, these actions come very late in the cycle, and there are many powerful levers upstream related to eco-design of products, such as extending their lifespan. These elements must be robustly integrated into regulations in order to promote products with a reduced environmental impact.

The Circular Economy Network comprising numerous companies and organisations in Italy committed to advancing the transition towards a circular economy is submitting this document as a contribution to the public consultation launched by the European Commission in preparation for the adoption of the Circular Economy Act by the end of 2026. Please refer to the attached position paper for further details.

Filed in Italian · English published by the European Commission

EurEau welcomes the Commissions initiative to develop a Circular Economy Act. Water services are central hubs for recovering nutrients, energy, materials and water. With clear EUwide criteria, market demand and safeguards against contamination, water services can scale safe resource recovery and strengthen Europes competitiveness, resilience and climate goals.

We welcome the Commission's initiative for a Circular Economy Act (CEA), as we share the concern that progress towards circularity has been insufficient. The CEA's aim to "get the economics right" is the single most critical factor for success.

Our Circular Future: A Youth Vision for Europe Input to the EU Consultation on the Circular Economy Act Submitted by the Dutch Youth Climate Movement (Jonge Klimaatbeweging) Our vision a truly circular economy We are the generation that will live with the consequences of todays decisions.

Cisco strongly supports the European Commission's ambition for a Circular Economy Act, recognizing its potential for significant economic and environmental benefits. To unlock the EU's circular economy potential, we recommend establishing a true Single Market for waste and recycling, stimulating demand and supply for secondary raw materials, and facilitating favorable market conditions and investment.

In depth feedback no 2 from FSCA Pilot Study. Europes circular transition depends on the ability of early circular innovators to scale. Yet most circular startups still fall into a financing gap that mirrors the Valley of Death long recognised in Deep Tech.

In depth feedback nr 1 from FSCA Pilot Study. Circular startups play a decisive role in Europes transition to a sustainable and competitive circular economy. Yet they remain structurally under-supported, caught between innovation policy designed for linear technologies and funding logic built on short-term returns.

As the largest network of social economy re-use businesses in Austria, we fully support the feedback on the Circular Economy Act (CALL FOR EVIDENCE) from our umbrella association RREUSE – see attached document. We would also like to refer in particular to the objectives of the Austrian Circular Economy Strategy…

Filed in German · English published by the European Commission

Please find the feedback attached. Title of the contribution: Integrating Environmental Communication and Civic Awareness Initiatives such as the European Week for Waste Reduction (EWWR) into the new Circular Economy Act of the European Commission An Independent Initiative by AICA (Associazione Internazionale per la Comunicazione Ambientale / International Association for Environmental Communication, EWWR - Italy…

ESPP (European Sustainable Phosphorus Platform) supports the need for a Circular Economy Act to accelerate recycling, facilitate the market for secondary materials and incentivise their use. This Act should address nutrients and the biobased economy, as well as EU Critical and Strategic Raw Materials.

Please find the feedback attached. We recommend on the European Commission to: Introduce mandatory Pre-deconstruction Audits as a precondition for demolition or major redevelopment permits. Ensure alignment with European standards (CEN/TC 350/SC 1/WG 8) for harmonised implementation. Link public procurement and EU funding to the existence of a PDA to foster circular market demand.

Please find the feedback attached. We recommend on the European Commission to: Include mandatory Pre-deconstruction Audits as a legal requirement in the Circular Economy Act, as a prerequisite for demolition or major redevelopment permits. Align the implementation of PDAs with the standardisation activities developed by CEN/TC 350/SC 1 WG8 to ensure harmonisation and legal certainty.

I am excited about this Act, and offer this feedback based on my quarter century of historical research into secondary material streams and industrial design systems in hopes of improving the final legislation. A truly circular economy will not only focus on maximizing recycling but also reduce production.

Cities are the engines of Europes circular economy. From waste prevention and reuse to green job creation and resilient local supply chains, cities are already leading the way in delivering the innovation the Circular Economy Act aims to succeed. As the primary managers of waste and the closest link to citizens, cities have the insight and capacity to turn policy ambitions into impact, if given the right tools.

RE&UP Technologies, a textile-to-textile recycling company based in the Netherlands, welcomes the European Commissions initiative for the Circular Economy Act (CEA) and strongly supports a harmonised, market-enabling legislative framework to accelerate the transition towards a circular and resource-efficient economy in Europe.

Copper is a key material for achieving a climate-neutral and resilient economy. It is recognized as a strategic raw material that enables electrification, energy efficiency, and renewables and is widely used in most decarbonisation technologies. Copper plays a crucial role in a circular economy as a sustainable and inherently recyclable material.

Erion is Italys leading Extended Producer Responsibility (EPR) system and one of the largest non-profit compliance organizations in Europe. Since the early 2000s, we have been managing the end-of-life of products across six regulated streams including Waste Electrical and Electronic Equipment (WEEE), Batteries and Accumulators, Packaging, Textiles and Tobacco products waste.

We fully support initiatives aimed at fostering a circular economy, as they represent an important step toward sustainability. However, we believe these measures should be designed in a way that does not compromise the competitiveness of European industries. It is essential to avoid excessive complexity or administrative burdens that could hinder operational efficiency.

FEEDBACK TO CALL FOR EVIDENCE Circular Economy Act NABU (The Nature and Biodiversity Conservation Union), is the biggest environmental NGO in Germany with around 960,000 members and 70,000 active volunteers. We welcome the European Commission’s plan to propose a Circular Economy Act (CEA) and thank for the opportunity to comment on this call for evidence.

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

The attached document provides a description of the crisis that is currently hitting the European plastic recycling industry and identifies the main legal principles applying in the context of the circular economy, which should be pursued in the drafting of the CEA. It also presents the measures that should be adopted regarding the following areas of intervention: A.

Dear Sir or Madam, Royal Bouwend Nederland thanks the European Commission for the opportunity to provide input on the forthcoming Circular Economy Act. Please find attached our written response to the policy initiative. We appreciate the Commissions continued efforts to strengthen the internal market for secondary raw materials and waste, and to advance the transition towards a circular economy.

Citeo would like to provide feedback to the European Commission in order to leverage its expertise in the circular economy for the development of ambitious, pragmatic Circular Economy Act that can ensure a competitive and circular European economy.

The Digital Health in a Circular Economy consortium (DICE Grant agreement ID: 101060184 & DOI 10.3030/101060184) welcomes the opportunity to provide input to the public consultation on the future Circular Economy Act (CE Act) and wants to highlight four points that will support the circular transitioning of healthcare. 1.

DECO, as a consumer protection organisation in Portugal, welcomes the European Commission’s intention to adopt a legislative act on the Circular Economy, as part of the Clean Industrial Deal and the Competitiveness Compass.

Filed in Portuguese · English published by the European Commission

The current regulation distinguishes the management of primary/semi-finished products from virgin raw materials from that of by-products and secondary or recycled raw materials. In the first case, they are managed by REACH and CLP.

Filed in Spanish · English published by the European Commission

To provide more context on our circular product innovation and the challenges that come with it, Novatech has focused strongly over the past two years on developing debondable adhesives for construction applications. In doing so, we aim to eliminate one of the main drawbacks of adhesives in terms of circularity. The main challenge we face lies in collaboration within the value chain (downstream).

EBB is a Brussels NGO participating in several EU funded projects promoting the circular bioeconomy. This involves the use of renewable feedstocks to produce materials that currently are generally manufactured from fossil fuels, notably chemicals, textiles and plastics with multiple uses in consumer and industrial applications.

31.10.2025 Circular Economy Act Promotion of Circular Economy in Construction Projects The Finnish Property Owners Rakli (Transparency Register id 727236253172-92) is association of Finland’s most prominent owners of residential and commercial properties and infrastructure, property investors, largest cities in Finland, as well as construction clients. Our members include both private and public sector entities.

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

The call for evidence reflects several theoretical weaknesses that risk undermining the EUs circular economy ambitions. First, circularity must be driven from the design phase rather than treated as an end-of-life problem: waste treatment and secondary-material uptake should be outcomes of upstream regulation that embeds reuse, reparability and remanufacturing into product design.

The En Boite Le Plat France network, which brings together 9 local associations in France to develop re-use in take-away sales, welcomes the Commission’s initiative for a legislative act on the circular economy. Like you, we see that the transition is still too slow and that an ambitious European framework is indispensable to create a genuine single market for circularity.

Filed in French · English published by the European Commission

FuelsEurope fully supports the European Commission ambitions to reinforce the single market for waste and secondary raw materials and increase the supply and demand for high quality secondary raw materials at competitive prices.

Climate Foundation Skive welcomes the EU Circular Economy Act. We support promoting circular business models and resource efficiency to reduce dependence on primary raw materials, boost economic security, and create opportunities for SMEs and larger companies. We stress the importance of sustainable production and industrial decarbonisation, with clear CO reduction requirements and incentives for circular solutions.

IKEM urges the European Commission to ensure that the Circular Economy Act becomes a strategic Single Market framework for circularity that strengthens Europes industrial competitiveness, innovation capacity, and climate ambitions.

I support the initiative a lot. In the textile sector, all related initiatives don't help at all though, if we allow – often Chinese – ultra fast fashion provider to byepass all rules and laws. IF we don't lift the value limits for customs duty free imports immediately (NOW!), in 2027 a currently well functioning textile sorter and recycler infrastruture across Europe – critical e.g.

Filed in German · English published by the European Commission

TIC Council, the global association of the Testing, Inspection and Certification (TIC) sector, would like to provide recommendations to the European Commission on the upcoming Circular Economy Act. We recommend that the Act considers the existing and successful market practices and international standards that are currently driving the circularity within companies.

Position paper Contribution of the Metropolitan Region of Amsterdam (MRA) to the call for evidence for the Circular Economy Act Date: 31 October 2025 Submitted by: Metropolitan Region of Amsterdam (MRA) Contact: Najat Azogagh, Strategic Advisor, [email removed] 1. Introduction The Metropolitan Region of Amsterdam (MRA) welcomes the European Commission’s consultation on the Circular Economy Act (CEA).

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

The International Alpaca Association (IAA) supports international efforts aimed at strengthening a circular economy that promotes environmental sustainability, ecosystem regeneration, and social equity. Based on our experience within the natural fiber value chain, we consider it essential that regulatory frameworks and public policies recognize the strategic role of renewable, biodegradable, and low-impact materials…

Chemelot Position Statement on the Circular Economy Act: Chemelot fully supports the ambition of the Circular Economy Act and urges the Commission to: 1. recognise waste as feedstock and support industrial symbiosis; 2. harmonise end-of-waste and by-product criteria, ensuring EU-wide recognition; 3. enable design and regulation for recycling by addressing the application of specific materials and combinations; 4.

You need: encourage the use of bio-based products, including wood, in public procurement – promote and develop the bioeconomy that will fuel the circular economy – ensure consistency of the texts and the technical and economic feasibility of the proposed measures – support businesses in implementing them and provide aid for investment and innovation

Filed in French · English published by the European Commission

Sonoco, a global leader in sustainable packaging with a significant presence in Europe, welcomes the forthcoming Circular Economy Act (CEA) as a key step toward a more circular and sustainable economy. The company urges harmonised, EU-wide rules on Extended Producer Responsibility (EPR) to reduce administrative burdens, ensure fair treatment of all packaging materials, and streamline reporting through digital tools…

It is essential that RoHS allows the reuse, remanufacturing and remanufacturing of equipment already in circulation, and this grandfathering prevents immense environmental damage caused by melting and remanufacturing, as well as huge economic damage.

Filed in German · English published by the European Commission

Circular Economy Act, Réflexions IFPEN autour du recyclage des plastiques, IFP Energies nouvelles (IFPEN) est un acteur public majeur de la recherche et de la formation dans les domaines de l’énergie, du transport et de l’environnement. Depuis les concepts scientifiques en recherche fondamentale jusqu’aux solutions technologiques en recherche appliquée, l’innovation technologique est au cœur de son action.

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)

The International Marine Contractors Association (IMCA) welcomes the opportunity to provide input on the European Commissions Call for Evidence regarding the forthcoming Circular Economy Act (CEA). IMCA represents more than 800 companies globally, including over 400 based in Europe.

A legislative act on the circular economy must also take into account the specificities of the construction sector. Construction waste is the largest waste stream across all sectors. This is approximately 8 times the amount of domestic and commercial waste. The bulk of construction waste in Bavaria, totalling around 50 million tons/year, consists of excavated soil (approx.

Filed in German · English published by the European Commission

Europes clean transition and strategic autonomy depend on a resilient, circular supply of CRMs, like REEs for permanent magnets in wind turbines and electric vehicles. Currently, Europe lacks a harmonized framework for efficient recovery, reuse, and circulation of recycled REEs, measures essential to meet future demand from secondary sources and reduce import dependency.

Celanese welcomes the European Commissions legislative initiative on the Circular Economy Act and fully supports its objectives to improve resource efficiency and industrial value chains. In this context, we wish to underline the critical importance of explicitly including Carbon Capture and Utilisation (CCU) or carbon recycling as a key pillar of the act. CCU technologies are circular by nature.

be considered.5 Moreover, as highlighted by the EEA, EU circular policies often [neglect] social dimensions.6 As a consequence, they provide insufficient safeguards for the role of social enterprises in reuse systems. Finally, governance structures within EPR schemes are too often limited exclusively to producers.

The European Electronics Recyclers Association (EERA) welcomes the opportunity to respond to the European Commissions consultation on the Circular Economy Act (CEA). Our responses draw on EERAs established policy positions on the Waste Shipment Regulation, Critical Raw Materials recovery, plastics recycling and end-of-waste criteria, Extended Producer Responsibility (EPR), and the recommendations set out in 'Towards…

Fastighetsägarna welcomes the European Commissions ambition to establish a Circular Economy Act as part of the Clean Industrial Deal. The property and construction sector supports this transition but stresses that circularity must be built on value creation, prevention and market functionality, not on new administrative layers or overlapping quota systems.

Please find attached UCM's Position Paper for the Circular Economy Act. UCM is the leading organisation representing French-speaking SMEs and self-employed individuals in Belgium and a member of SMEUnited. In this paper, we call on the Commission to be ambitious so that the future framework unifies the market, corrects competitive distortions with the linear economy, stimulates demand, secures supply, and places…

DRS welcomes this opportunity to provide feedback to the impact assessment of the European Commission's Circular Economy Act (CEA) initiatives, which aim to accelerate EUs transition towards circularity, focusing on its potential to increase circularity in the single market. DRS operates the Danish national deposit and return scheme for single-use plastic beverage bottles and cans.

Reloop has set out six recommendations for Europes forthcoming Circular Economy Act. Our position paper aims to advance Europes circular economy, boost material recovery and promote investment in practical, scalable solutions.

i-Foria has developed an advanced technology capable of recovering up to 100% of the materials in Absorbent Hygiene Products (AHPs), diapers, sanitary pads and incontinence items, producing certified secondary raw materials such as plastics and cellulose.

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

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

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

On behalf of the Exit Kunststoff civil society alliance, I am submitting the Alliance’s position paper on the circular economy. It is essential for us not only to limit the circular economy to recycling and recycling strategies, but to look more comprehensively and to focus strictly on the waste hierarchy: Prevention before recovery, single-use reuse, quality before mass, transparency before ambiguity…

Filed in German · English published by the European Commission

The Ministry of Development and Technology would like to thank you for starting work on the Circular Economy Act and giving you the opportunity to comment on the Impact Assessment prepared for the Circular Economy Act. Please find enclosed the detailed opinion.

Filed in Polish · English published by the European Commission

As an industrial company with more than 550 employees and a turnover of more than EUR 100 million, we are deeply committed to the EU’s objectives for a circular economy. We are currently implementing our second pilot project for a circular business model for one of our main product lines and actively developing processes for withdrawal, testing and remanufacturing.

Filed in German · English published by the European Commission

We consider it useful to establish in the CEA at European level an appropriate certification system developed specifically for the waste management and circular economy with sector-specific requirements. For more than 25 years, waste disposal specialist certification (EFB certification) has been a recognised and proven certification system (sector standard) for waste disposal and resource management companies in…

Filed in German · English published by the European Commission

SWM warmly welcomes the European Commission’s intention to present a Circular Economy Act by the end of 2026. As a company actively engaged in this sector and particularly focused on developing biodegradable cellulose fiber solutions, we strongly support the Commission’s initiative to involve all relevant stakeholders in this process.

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

Cascade, vereniging van Oppervlaktedelfstoffenwinners Van Pallandtweg 11 4182 CA Neerijnen [email removed] www.cascade-zandgrind.nl Regarding: Cascade’s position on the Circular Economy Act Date: 29-10-2025 Dear sir/madam, Cascade, the Dutch association of aggregate producers, represents over ninety percent of the national production of construction raw materials such as sand, gravel and clay.

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

The Circular Economy Act should maximise the retrieval of secondary raw materials while remaining technology-neutral and environmentally ambitious. A systematic change should be made with innovation, resource efficiency and the environment at the top of mind. AVR is an innovative Waste-to-Energy (WtE) treatment facility based in Rotterdam and Duiven (NL).

With EPR systems adapted to each country Agriplastics contribute to food production with real benefits in terms of yields, labour intensity, and the environment. Among other things, agriplastics enable better control of weather-related risks, longer growing seasons, improved preservation of Fode, mechanation of harvesting operations, and reduced consumption of chemical inputs and irrigation water.

Filed in French · English published by the European Commission

EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, welcomes the European Commissions initiative to strengthen the circular economy and to reinforce the single market for waste and secondary raw materials through the proposed Circular Economy Act.

AMFEP, the Association of Manufacturers and Formulators of Enzyme Products, representing 90% ‎of ‎the EU enzyme market, welcomes the opportunity to ‎comment on the Circular Economy Act call ‎for evidence. This initiative represents an important ‎opportunity to build on existing recognition of ‎enzymes as key contributors to the EUs transition towards a circular and competitive economy.

Instead of new and specific circular economy legislation, it would be better to focus on removing obstacles arising from existing legislation. One of the key challenges is related to waste legislation and the definition of waste, where the resulting restrictions or obligations put waste-derived materials at a disadvantage compared to virgin materials. More about this in attached document

Portuguese farmers welcome the initiative for a European Commission (EC) legislative act to be adopted by the end of 2026 with the aim of speeding up the transition to circularity. However, the document raises some comments, which are sent in ANNEX and summarised below: — The regulatory and economic causes, accentuated by differences in interpretation and heterogeneous application of EU rules by Member States, are…

Filed in Portuguese · English published by the European Commission

Advancing the circular economy is imperative for Europe. Beyond its core benefit of waste and resource-use reduction, it is also a strategic lever to boost competitiveness, rejuvenate industrial capacity, and minimise import dependency. This is why ACR+ ( https://acrplus.org ) welcomes the European Commissions commitment to introduce a Circular Economy Act by 2026.

We are pleased to take the opportunity to participate in the Call for Evidence and would like to draw the Commission’s attention to the current problems and weaknesses. The EU is at a crossroads and has to decide whether to take the circular economy seriously and vigorously, or to stay with lip credential.

Filed in German · English published by the European Commission

The Greek Bioeconomy Council (GBC) welcomes the European Commissions initiative for the Circular Economy Act and fully supports the establishment of a coherent and science-based framework that will accelerate Europes transition towards circular and bio-based practices.

The Critical Raw Materials Alliance welcomes the objectives of the forthcoming Circular Economy Act (CEA) and its ambition to move away from the traditional one-way model of resource extraction, production, and disposal toward a genuinely circular economy. This initiative has the potential not only to drive sustainability but also to reinforce the Single Market and strengthen Europes resilience.

Contribution of NaTran to the Call for evidence on the Circular Economy Act We welcome the opportunity to respond to this call for contribution. NaTran is the leading gas transmission system operator in France and the second largest in Europe.

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

The EPMFs Key Asks for the Circular Economy Act 1. Create a strong and efficient European single market for waste 2. Ensure consistency between the EUs circular, climate, and chemical objectives 3. Prioritise harmonisation for waste rules and turn the Waste Electrical and Electronic Equipment Directive (WEEE) into a regulation 4.

Public procurement accounts for approximately 14% of a country's GDP; If circular award criteria were to be included in public tenders (in addition to the classic criteria such as price,..), an enormous lever would be triggered. This can be rolled out throughout Europe, given that the legislation is regulated at European level.

The Circular Economy Act must consider the Bioeconomy as one of its main pillars. With the adoption of the new EU Bioeconomy Strategy in 2025, EU aims to radically change the EUs approach to the ways we produce, consume, process, store, recycle and dispose of biological resources.

As sole director of GREEN ARK srl-sb, I propose the new process of chlorophyllian photosynthesis, using a patented and internationally certified negative carbon bioreactor, which makes it possible to: absorbing CO2 and air pollutants to release oxygen to produce biomass to reduce water consumption to reduce microplastics to support and help existing trees

Filed in Italian · English published by the European Commission

From Engraw a wool peiner located in Uruguay and working more than 70 years ago, we support the European Commission’s objective of boosting the circular economy and strengthening the single market, but proposes that it also integrate biological circularity, recognising the essential role of renewable, biodegradable and regenerative materials.

Filed in Spanish · English published by the European Commission

To whom it may concern, Attached please find EPPAs feedback on the Circular Economy Act. Should you require any clarifications on the matter, please feel free to get in touch. Best regards, [name removed] on behalf of the European PVC Window Profile and Related Building Products Association (EPPA)

Encory welcomes the initiative to create an EU law on circular economy. As a company that specialises in circular economic solutions in an operational and advisory capacity, we support the objectives of the envisaged act, including the development and operation of efficient backward logistics systems, the recycling of high-voltage batteries in partnership with the BMW Group, the distribution of remanufactured…

Filed in German · English published by the European Commission

The Amsterdam Chemistry Network strongly supports the European Commissions ambition to accelerate the transition towards a circular and sustainable economy. As a regional innovation ecosystem of public and private organizations, we advocate for a green industrial policy that enables the transformation of todays fossil-based chemical industry into a sustainable, carbon-based chemical industry.

Via Pöppelmann Pöppelmann, a family plastic processing company founded in 1949 is a family company with approximately 2500 employees. We are developing plastic solutions for automotive, food, medicine, industry and horticulture. In our German plants, we already use about 40 % post-consumer recyclates and 10 % post-industrial recyclates to produce our products.

Filed in German · English published by the European Commission

The Association of Austrian Land and Forest Owners acknowledges the importance of decarbonizing EU economy and working towards independence of raw materials. For many materials, increased circularity would be beneficial to climate change mitigation.

The world economy has breached 7 out of 9 planetary boundaries. The Planetary Health Check 2025 makes it clear: increased resource consumption, driven by growth and competitiveness, is destroying our living environment. The EU Circular Economy Act (CEA) is an important opportunity to work towards sustainable resource management contributing to the EUs climate and socio-environmental objectives.

1/4 Ref. Ares(2025)9077172 - 23/10/2025 Date 21st October 2025 Yara’s feedback to the call for evidence: Circular Economy Act Yara International, a global leader in crop nutrition, ammonia and essential industrial solutions, welcomes the European Commission’s initiative to increase circularity in the EU single market.

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

Dear Ladies and Gentlemen, Laws and ordinances are currently not coordinated. This prevents motivated manufacturers from actively supporting the circular economy. Therefore, we demand privileges for motivated manufacturers that do not hinder the implementation of circular economy activities.

The Circular Economy Act is an important instrument to transition in a responsible way to a circular economy, reduce resource dependency and create a market for secondary materials. The Nutrient Platform hopes that this act improves food system resilience and simplifies the production of circular fertilizers.

The European Commission's Clean Industrial Deal (CID) presents a plan to tackle both the EUs decreasing competitiveness as well as the environmental challenges. It recognizes the crucial role that circularity should play and states that the EU must be world leader in circular economy by 2030. The upcoming Circular Economy Act (CEA) will play a crucial role in this respect.