Following today’s High-Level Dialogue on the Circular Economy Act, the European Environmental Bureau (EEB) warns that the European Commission is heading in the wrong direction – and that there is still time to correct the course.

The long-awaited Circular Economy Act is expected after the summer, but key elements remain absent from the Commission’s planning, and today’s dialogue did little to reassure that the legislation will live up to its promises.

Notably, the Commission’s focus has been heavily skewed towards recycling and market harmonisation, while letting off the table overproduction, overconsumption, and unsustainable resource use. Yet, these are the very issues exposing the EU to new geopolitical vulnerabilities and material dependencies which threaten the resilience of our societies and the long-term competitiveness of European industry, warns the EEB.

The consultation processes leading up to the Act have imposed a narrow, blinkered vision, sidelining the aspects that have the biggest potential to create quality jobs [1] and deliver the highest returns for both industry and consumers at the lowest environmental cost: waste prevention, reuse, and repair.

Marco Musso, Deputy Policy Manager for Circular Economy at the EEB, who attended the Dialogue, said:

“What we are seeing looks far more like a waste management law than a genuine circular economy act. Recycling has its place, but it’s a last resource, not the only strategy. A true circular economy starts with prevention, reuse and repair, but those are almost entirely missing from the Commission’s approach. If this is the direction of travel, the Act will remain a broken promise.” 

A wide range of civil society organisations [2], businesses [3], and even EU Member States [4] – have called for prevention, reuse, and responsible resource management to be central to the Act.

Back in 2024 the European Environmental Agency had also urged policy makers to move beyond a waste-management based approach and address resource use more directly [5].

The Commission has heard the message, the question is whether it will act on it, says the EEB.

“There is still time to correct the course,” Musso added. “The Act has not been published yet. The Commission can still broaden its ambition, listen to the chorus of voices calling for genuine circularity, and deliver legislation that addresses the real drivers of unsustainable resource management.” 

The EEB will continue to monitor the Commission’s proposals closely and calls on decision-makers to deliver an Act that is truly worthy of the circular economy label.

Note to editors:

[1] The European remanufacturing sector alone is projected to generate 500,000 new jobs by 2030 – a concrete contribution to the sustainable reindustrialisation Europe urgently needs.
Source: https://www.eea.europa.eu/en/newsroom/news/creating-win-win-for-business-and-people-key-to-success-of-circular-economy

[2] Civil society’s joint letter on the EU Circular Economy Act: https://eeb.org/en/library/joint-letter-on-the-eu-circular-economy-act/

[3] Ecopreneurs’ Position Paper: A Circular Economy Act to drive competitiveness and investment in circular business: https://ecopreneur.eu/2025/06/16/cea-position/

[4] Back in December, Member States called for further incentives to increase the durability, repairability, and reuse of products, and emphasised the importance of establishing non-toxic material cycles by rapidly phasing out harmful substances and fully implementing the Chemicals Strategy for Sustainability, with a particular focus on revising REACH. However, these key aspects are visibly missing from the Commission’s current approach to the Circular Economy Act.

Council conclusions: https://data.consilium.europa.eu/doc/document/ST-16856-2025-INIT/en/pdf

Council’s press release: https://www.consilium.europa.eu/en/press/press-releases/2025/12/16/europe-s-environment-council-urges-accelerated-transition-for-a-climate-resilient-and-circular-europe-by-2030/

[5] The assessment of the European Environmental Agency was equally unambiguous: “European Union circular economy policies have been reinforced over recent years, but they still need to become more binding and target oriented to accelerate the uptake of a more regenerative economy in Europe. This means moving beyond the current strong focus on waste to address resource use more directly”.

EEA’s press release: https://www.eea.europa.eu/en/newsroom/news/now-is-the-time-to/