A broad coalition of European packaging organizations has called on EU policymakers to anchor the upcoming Circular Economy Act (CEA) in the legal framework of the EU Single Market. The request comes in a joint statement co-signed by Europen and around 70 other industry associations representing companies across the packaging value chain.
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Industry Coalition Urges Harmonized Waste Rules Across Europe
The signatories argue that the legislation should rely on Article 114 of the Treaty on the Functioning of the European Union (TFEU), which provides the legal basis for measures that strengthen and harmonize the Single Market. According to the industry, this approach would help accelerate progress toward a circular economy by creating consistent waste management rules across all member states.
Fragmented Waste Management Remains a Major Obstacle
Industry representatives say Europe’s waste management systems remain highly inconsistent. with significant differences in landfill use and recycling performance across countries. Currently, nearly half of EU member states still landfill more than 30% of their municipal waste, with several report rates exceeding 60%.
Recycling performance also varies widely. According to commission reports and recent audits, only nine member states were projected to meet the EU’s 2025 municipal waste recycling targets. This discrepancy underscores the urgency of the Circular Economy Act, as the industry now faces the PPWR 2025/40 mandate requiring all packaging to be recyclable by 2030. For many stakeholders, this highlights the need for stronger and more uniform rules at the EU level.
The coalition argues that fragmented national legislation not only slows environmental progress but also creates barriers within the Single Market. Diverging regulatory frameworks can limit the movement of secondary raw materials and make it harder for companies to scale circular solutions across borders.
CEA Seen as Opportunity to Align Rules
The joint statement emphasizes that the forthcoming Circular Economy Act could address structural weaknesses that earlier reforms have not fully resolved. The targeted revision of the Waste Framework Directive, while important, did not fully overcome the structural gaps in Europe’s waste management systems, according to the industry.
By establishing common rules for waste collection, recycling and material recovery, the CEA could help ensure that all member states contribute to circular economy goals. Industry groups argue that harmonization would allow lagging countries to catch up with those already performing well, while ensuring a level playing field for businesses operating across the EU.
In addition, a unified regulatory framework could support the development of a stronger market for secondary raw materials. Stakeholders say this would reduce Europe’s dependence on imported resources while supporting the growth of circular value chains.
Concerns Over Alternative Legal Basis
The industry coalition also warned against shifting the legal basis of the CEA toward Article 192 of the TFEU, which relates primarily to environmental policy. According to the statement, relying on this legal framework could increase regulatory fragmentation by allowing wider national variation in implementation.
Industry groups argue that this could introduce legal uncertainty for businesses and undermine efforts to create a consistent market for recycled materials. They maintain that the internal market framework provides the most effective route to aligning environmental objectives with economic competitiveness.
Balancing Circularity and Competitiveness
The debate around the legal basis of the CEA reflects a broader discussion about how Europe should manage the transition to a circular economy. For the packaging industry, harmonized legislation is viewed as essential for scaling recycling infrastructure, improving waste management performance and strengthening Europe’s industrial competitiveness.
With negotiations on the Circular Economy Act expected to intensify in the coming months, industry organizations are urging EU institutions to maintain a strong Single Market foundation for the legislation. They argue that consistent rules across Europe will be critical to building an effective circular economy, enabling efficient waste management and supporting the development of a competitive market for recycled materials.
Conclusion
With negotiations on the Circular Economy Act expected to intensify in the coming months, industry organizations are urging EU institutions to maintain a strong Single Market foundation for the legislation. They argue that consistent rules across Europe will be critical to building an effective circular economy, enabling efficient waste management and supporting the development of a competitive market for recycled materials.
