Written by Marc Lütz
Dear reader,
As Europe moves into the summer, the EU’s sustainability agenda is entering a more practical and politically sensitive phase. The focus is increasingly shifting from setting broad environmental objectives to building the regulatory and market conditions needed to deliver them. Circularity, resource efficiency and industrial resilience remain central themes, but the debate is becoming more concrete: how to strengthen secondary raw materials markets, reduce strategic dependencies, simplify compliance, and maintain environmental ambition without adding unnecessary complexity for businesses and public authorities.
The spotlight
The Circular Economy Act takes shape around competitiveness and market integration
As preparations for the Circular Economy Act (CEA) accelerate, recent statements from the European Commission provide an increasingly clear indication of the direction the proposal is likely to take. Positioned as a key component of the EU’s competitiveness, resilience and economic security agenda, the CEA is expected to focus on strengthening markets for secondary raw materials, improving the functioning of the Single Market, and reducing Europe’s dependence on virgin and imported resources.
Recent comments by Environment Commissioner Jessika Roswall and Executive Vice-President Stéphane Séjourné suggest a strong emphasis on addressing structural barriers that continue to limit the development of circular business models across the Union. Both Commissioners highlighted fragmentation in end-of-waste and by-product rules, obstacles to the cross-border movement of secondary raw materials, and inconsistencies in Extended Producer Responsibility (EPR) schemes as key challenges that undermine market integration and investment certainty. In parallel, they stressed the need to stimulate demand for recycled and circular products and to create a stronger business case for circularity beyond public support mechanisms.
As discussions progress, the emerging direction of the proposal is beginning to generate debate among stakeholders. While the Commission’s focus on market integration and secondary raw materials is gaining political momentum, questions remain regarding the balance between economic objectives and environmental safeguards. In this context, a coalition of 43 NGOs has raised concerns about aspects of the future framework, highlighting the broader discussion surrounding the design of the Circular Economy Act.
While the Commission has yet to present its formal proposal, recent indications suggest that the CEA will focus primarily on creating the conditions for a well-functioning market for secondary raw materials, supported by greater regulatory coherence across the Union. As preparations continue ahead of the expected September 2026 proposal, the coming months are likely to determine how the Commission balances its objectives on competitiveness, circularity and environmental protection within a single legislative framework.
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Policy updates
EUDR: May package simplifies compliance and administrative burden
In May 2026, the European Commission published a comprehensive simplification review for the EU Deforestation-free Products Regulation (EUDR). The package includes an updated guidance document, a detailed FAQ and a draft delegated act proposing revisions to the product scope.
This package aims to clarify and streamline mandatory due diligence rules for stakeholders, notably by introducing a highly simplified regime for Micro or Small Primary operators. Additionally, the Commission confirmed that the EU Information System is now fully operational and has been updated to reflect the most recent revisions, meaning the regulation is on track to officially apply from 30 December 2026 for most operators.
Commission adopts Fertiliser Action Plan to support farmers and EU industry
On 19 May, the European Commission adopted its Fertiliser Action Plan in response to persistently high fertiliser costs, supply chain vulnerabilities and Europe’s strong dependence on imported fertilisers. The plan aims to improve the availability and affordability of fertilisers, while strengthening domestic production and reducing strategic dependencies. On 2 July, the European Commission presented the Fertiliser Action Plan in the EP’s AGRI Committee.
For industry, the plan links fertilisers more directly to Europe’s strategic autonomy and clean industrial policy. The Commission will explore lead markets for low-carbon and bio-based fertilisers under the upcoming Biotech Act II. It will also assess further flexibility under the upcoming ETS review and refine CBAM implementation for the fertiliser sector. At the same time, the plan aims to improve farmers’ access to affordable fertilisers and strengthen partnerships across the European fertiliser value chain.
Reactions have been mixed, with farming organisations welcoming the focus on resilience and affordability, while over 70 organisations signed an open letter arguing that the fertiliser crisis is fundamentally a fossil fuel crisis.
Waste incineration faces renewed scrutiny in circular economy debate
On 12 May, the European Commission hosted a stakeholder meeting on the ETS review, attended by over 60 representatives from industry and civil society. Discussions also covered whether waste incinerators should be subject to pollution limits under the EU Emissions Trading System (ETS). The question sits within a broader debate about the role of incineration in the EU’s circular economy ambitions.
On 7 May, 43 NGOs wrote to Environment Commissioner Roswall to express concern over the Commission’s plans for the Circular Economy Act, warning against classifying incinerator bottom ash as a circular secondary raw material. They cited risks to human health and the environment, calling on the Commission to await independent, long-term safety evidence before promoting its use. Meanwhile, PlasticsEurope’s 19 May report on the Circular Economy for Plastics, finds that despite rising recycling rates, 70% of collected plastic waste continues to be incinerated or landfilled.
EPR suspension proposal intensifies debate over PPWR implementation
On 28 May, the Parliamentary rapporteur Ingeborg Ter Laak (EPP, NL) published her draft reports on the proposal suspending the application of the rules on the appointment of an authorised representative for Extended Producer Responsibility (EPR) for batteries and waste batteries and packaging and packaging waste, as well as the draft report on the EPR for waste, waste electrical and electronical equipment and single use plastic waste. The suspension is part of the Environmental Omnibus simplification package, which aims to ease EPR administrative requirements under the Packaging and Packaging Waste Regulation (PPWR) – a regulation that has proven contentious.
As the date of its application approaches, the debate around the regulation has intensified. On 29 April, 138 business leaders wrote to the Commission calling for a postponement of the revision and a targeted review of key requirements. Zero Waste Europe pushed back a day later, warning that reopening the PPWR would set a “dangerous precedent” for EU environmental legislation. On 13 May, more than 160 NGOs, consumer groups, businesses, and universities urged the Commission to maintain the August 2026 application date and uphold key provisions, arguing that any delay would pose a major health risk. Industry voices, however, continue to push back: a June report by the Consumer-Portion Packaging Innovation Coalition calls for a delay to the PPWR’s 2030 ban on single-portion condiment packaging.
These opposing calls come against a challenging market backdrop: in a 19 May report, Plastics Europe highlighted a slowdown in the production of circular plastics, both recycled and bio-based. While overall demand for plastics continues to rise, the growth of circular plastics has fallen from 13.6% between 2018 and 2022 to just 1.2% between 2022 and 2024.
Blog
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