European Commission Opens Consultation on Upcoming Circular Economy Act – Feedback Welcome Until 6 November 2025

by Diana Radovan, Director, Sustainability Policy

On 1 August 2025, the European Commission launched its long-anticipated public consultation and call-for-evidence for the upcoming Circular Economy Act (CEA), expected in Q4 2026. The consultation remains open until 6 November 2025, providing industry stakeholders ample time to contribute. The CEA is a central pillar of the EU’s Clean Industrial Deal and is co-led by DG Environment (B3 – From Waste to Resources) and DG GROW (I4 – Sustainable Products). It focuses on strengthening the circular economy within the European Single Market, particularly in the area of electronic and electrical equipment (e-waste).

What’s in the Consultation?

The questionnaire includes around 30 questions across key themes:

  • General perspectives on the circular economy

  • Challenges and opportunities for e-waste

  • Barriers to circular business models in the Single Market

  • Supply and demand for secondary raw materials

  • Improving waste management and circular processes

This is a critical opportunity to shape a legislative framework that supports innovation, investment certainty, and cross-border compliance for circular business practices.

Why It Matters

The circular economy is seen by EU policymakers as essential to economic security, competitiveness, resilience, and decarbonisation. Despite existing legislation (e.g. Waste Framework Directive, Ecodesign Regulation, and Packaging Waste Regulation), progress toward circularity has been limited. The Commission is seeking to address this by removing market barriers and enhancing supply and demand for high-quality, affordable secondary raw materials, including critical raw materials.

The CEA builds on recent political momentum—including the Antwerp Declaration, Budapest Declaration, and reports by Letta and Draghi—as well as priorities outlined in the 2024–2029 Political Guidelines, Competitiveness Compass, and the Clean Industrial Deal.

What’s Being Proposed?

The CEA will focus on two key intervention areas:

  • Tackling e-waste, the fastest-growing waste stream in the EU, with less than 40% currently recycled. The initiative may involve updating existing legislation to improve collection, recycling, and market uptake of secondary raw materials.

  • Creating a true Single Market for secondary raw materials and waste, through:

    • Reforming end-of-waste criteria

    • Simplifying and digitalising extended producer responsibility (EPR) schemes

    • Introducing targeted criteria for public procurement to stimulate demand for circular goods and services.

Both legislative and non-legislative measures are on the table, with a focus on reducing administrative burdens and improving economic viability for circular systems.

GEA Members: Help Shape the CEA

This is your chance to contribute to one of the EU’s most significant upcoming sustainability frameworks. The Global Electronics Association will be coordinating feedback on behalf of members. To have your say, contact Diana Radovan, Global Electronics Association Director of Sustainability Policy, at DianaRadovan@electronics.org.