The following comments were submitted on the 6th of November 2025 to the European Commission’s public consultation on the Circular Economy Act. This initiative aims to create a Single Market for secondary raw materials, boost the availability of high-quality recycled materials, and stimulate their use across the EU.

CLC welcomes the ambition of the EU Circular Economy Act (CEA) and recognizes circularity as a vital element of European resilience and environmental sustainability as well as competitiveness.

Circularity and access to materials is critical for the EU’s industry. The EU needs to secure access to such materials and reduce dependence on unreliable suppliers. Integrating circularity in decarbonisation strategy is crucial to making the most of the EU’s limited resources. 

Establishing a circular economy requires returning substantial quantities of high-quality secondary raw materials to productive use. For the circular economy to function, there must be sufficient demand for recycled materials that can compete with the quality standards and prices of virgin materials — prices that still do not adequately reflect the full life cycle environmental impacts of virgin materials.

Our recommendations for the Circular Economy Act

1. Create stable demand outlook for the circular economy

The CEA should scale-up industrial demand for secondary raw materials by putting in place incentives for manufacturers to replace virgin materials with recycled materials, combined with legally binding targets on recycled content in key sectors of the economy. Use of mandatory recycling quotas, minimum recycled content requirements as well as public procument should be used to create demand for secondary materials. 

2. Adjust economic and fiscal incentives to support circularity and upscaling

Policy frameworks should focus on end-products rather than production methods, ensuring technology neutrality. Fiscal measures—such as avoidance of multiple taxation on recycled materials, taxing some virgin raw materials, lowering taxes on secondary materials, repairs and reused products - can stimulate demand further. Support is also needed for first-of-a-kind products which are costly.

It is important to recognize that the cost of recycled materials is not solely determined by production efficiency but also by the scale of operations. Demonstration and early-stage facilities—especially first-of-their-kind plants—often face higher costs compared to high-volume virgin material production. In addition to strong demand prospects, it is necessary to ensure sufficient investment support for new technology facilities in order tofacilitate upscaling.Additionally, attention must be paid to the issue of multiple taxation on recycled materials, which can hinder competitiveness.

3. Strengthen EU’s autonomy over its supply of resources

Every effort should be undertaken to make sure that the secondary raw materials being reintroduced into the European industrial feedstock are sourced and recycled in the EU. This will not only guarantee shorter circuits for material transformation, but also reinforce Europe’s strategic autonomy and access to critical raw materials. The CEA should require that all imported products placed on the EU market are subject to the same rules and requirements as products developed in the EU. Such a policy would recognize,that all products placed on the market in the EU contribute equally to the EU’s circular economy ambition. In addition, the lack of enforcement of this principle is deterring EU industry to act as frontrunners for the circular economy (e.g. dumping of virgin and recycled plastics)

4. Unlock circular economy value for the climate and biodiversity

The circular economy plays an important rolefor achieving the climate and biodiversity goals. Likewise, the development of valuechains through carbon capture and use (CCU), sustainable biobased materials, mechanical and chemical recycling can all boost the development of non-fossil feed - stock to substitute fossil fuels in carbon-based products. The CEA should introduce a mechanism that recognizes avoided emissions of the waste management industry and of recycled materials to enhance the competitiveness of the industry.

5. Efficient implementation of existing legislation

Implementing existing waste management legislation across all EU Member States, will be a sizeable challenge in the years to come. Without proper enforcement, the risk is that ambitious objectives fall flat.The implementation should be monitored more closely than at present in order to realize the synergetic benefits of the single market. For example, the EEA could take on this role.

6. Ensure competitive market for waste management

Fair and transparent markets for waste are essential to encourage private sector investment. The CEA should therefore exclude forms of preferential treatment of public entities over private entrepreneurs and ensure that the principles of the Single Market are maintained, in particular in relation to rules on state aid with regard to public undertakings and avoiding legislation that establishes ownership or restricted access over specific waste streams, thereby restricting the free market and competition.

Download the statement as a PDF below.