Circular Economy Act: EEB response to the public consultation

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Types: Response
Published: 6 November 2025
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EEB response to the public consultation and the call for evidence on the Circular Economy Act

In its response to the consultation on the Circular Economy Act, the EEB express concern regarding the clear gap between the Act’s stated goal to “accelerate the transition to a more circular economy, increasing the EU’s economic security, resilience, competitiveness and decarbonisation”, and the narrow scope of the policy options included in the consultation. While the questionnaire explores in depth the barriers for recycling and secondary raw materials markets, it overlooks the obstacles faced by the reuse and repair sectors, as well as by other circular business models focused on prevention. Crucially, the questionnaire fails to recognise the issues of Europe’s systemic overproduction, overconsumption and overdependence on material extraction.

This detailed accompanying document builds on the EEB’s position paper on the CE Act: Prevention is better than cure: how circularity can put Europe ahead of the game.