Circular Economy Act: Towards a circular economy and responsible resource consumption within planetary boundaries

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What is the Circular Economy Act about?

The EU is facing a growing “triple planetary crisis” – climate change, pollution and biodiversity loss – driven largely by increasing resource use. 

At the same time, the EU remains off track to meet its 2030 circular material use targets, highlighting the limits of current policies. 

Against this backdrop, the European Commission is preparing a Circular Economy Act (CEA) for 2026, intended to accelerate the shift from a linear (“take–make–waste”) economy to a circular one and strengthen EU competitiveness and resilience.

The upcoming EESC exploratory opinion on the matter will feed directly into this process, offering civil society recommendations on how to align resource use with planetary boundaries while maintaining economic and social balance. The opinion has been requested by the European Commission and will be presented and adopted at the EESC plenary session in June 2026.

What is at stake?

The debate goes beyond recycling or waste management. It raises fundamental questions about:

  • How much the EU consumes, not just how efficiently;
  • Dependence on imported raw materials, affecting strategic autonomy;
  • Whether economic growth can be reconciled with ecological limits;
  • Fairness across society, including impacts on workers, consumers and SMEs.

In simple terms: the CEA will shape how Europe produces, consumes and competes in a resource-constrained world.

What does the EESC say is missing today?

The Committee points to several structural weaknesses in current EU policy:

  1. Too much focus on supply, not enough on demand: Existing measures prioritise efficiency and recycling, but do not sufficiently address overconsumption and material demand.
  2. Slow progress at Member State level: Many countries are not on track to meet circularity targets, indicating implementation gaps.
  3. Weak markets for secondary raw materials: Barriers persist in the single market for recycled materials, including price, quality and regulatory issues.
  4. Limits of existing tools: Instruments such as Extended Producer Responsibility (EPR) have not delivered sufficient incentives for circular design and waste reduction. 

What does the EESC propose? What are its key messages?

1. Put resource use reduction at the centre

The EESC opinion calls for demand-side policies and primary material reduction to complement recycling and efficiency. This marks a shift from “better use” to “use less”.

2. Introduce material footprint targets

The EESC supports developing targets to limit the EU’s overall resource use, aligned with planetary boundaries. Similar to climate targets, but focused on materials and consumption.

3. Build a well-functioning market for secondary materials

The CEA should address:

  • Supply and demand imbalances;
  • Price competitiveness of recycled materials;
  • Regulatory barriers across Member States.

The goal: make recycled materials the default choice.

 4. Strengthen circular governance across EU policies

The opinion calls for integrating a resource-use perspective into all EU policies (industry, trade, digital, etc.). Circularity becomes a horizontal principle, not a niche policy.

5. Address systemic barriers and real economy impacts

The EESC highlights the need to:

  • Analyse material flows and price mechanisms;
  • Understand impacts on business models and consumers;
  • Consider social justice and fairness.

Transition must be economically realistic and socially fair.

6. Support waste prevention and better recycling systems

While going beyond waste, the opinion still stresses:

  • Better collection and recycling systems;
  • Tackling inefficiencies in EPR schemes.

Waste remains important—but not sufficient alone.

7. Recognise links with strategic autonomy

Reducing material use and scaling circularity will:

What is new in this approach?

Compared to previous circular economy debates, the EESC opinion introduces a clearer shift towards:

  • Absolute reduction in resource use (not just efficiency);
  • Planetary boundaries as a policy benchmark;
  • System-wide change across production and consumption;
  • Stronger integration with competitiveness and security agendas.

This reflects a broader EU narrative: circularity is no longer only environmental policy, but also economic and geopolitical strategy.

Are there any voices from the EESC?

Cillian Lohan, President of the EESC Civil Society Organisations' Group, one of the initiators of the European Circular Economy Stakeholder Platform (ECESP), and rapporteur for the EESC opinion (requested by the European Commission to inform their proposal), stated:

We cannot continue with a system where we take resources, make products and then simply dispose of them. Humans are amazing when we collaborate, work together and share ideas and resources. Circularity may be a new term, but the concept is natural and ancient. The circular economy is one of those transformative ideas that can change the world for the better.

For EESC Civil Society Organisations' Group and broader civil society, the CEA will influence:

  • Consumer rights and affordability of products;
  • Jobs and skills in circular sectors;
  • Access to resources for local economies;
  • Participation in shaping sustainable production models.

The EESC positions civil society as a key actor in designing and implementing circular solutions on the ground.

What's the bottom line?

The Circular Economy Act represents a turning point:

  • From improving waste management;
  • To redefining how much and how we produce and consume.

The EESC’s message is clear:

The EESC considers the Circular Economy Act (CEA) a strategic and urgent step to position the EU as a global leader in the transition to a circular economy, calling for a comprehensive, coherent framework that integrates existing policies and accelerates implementation. It emphasises the need to move beyond recycling towards a systemic approach focused on reducing material use, strengthening markets for secondary raw materials, and supporting circular business models such as reuse, repair and remanufacturing. The Committee highlights the importance of strong incentives, harmonised extended producer responsibility schemes, eco-design, and public procurement as key levers, alongside better traceability and data on material flows. It also underlines the critical role of investment, innovation, and new indicators to close the circularity gap and enable informed decision-making. Crucially, the EESC frames circularity as not only an environmental and economic priority, but also a social and geopolitical one, stressing the need for a just transition with decent working conditions, affordable circular products and active participation by civil society, communities and social economy actors, supported by tools such as the ECESP to scale solutions and overcome implementation barriers.

Without reducing overall resource use, the EU will not stay within planetary boundaries—nor achieve a truly resilient circular economy.

What's next?

The upcoming negotiations on the Circular Economy Act are likely to focus on:

  • Binding vs. voluntary resource targets;
  • Impact on industry competitiveness and costs;
  • Distributional effects across Member States and sectors;
  • Balancing environmental ambition with social acceptance.

European Parliament position on the Circular Economy Act: At this stage, the European Parliament has not yet adopted a formal legislative position on the Circular Economy Act (as the Commission proposal is still forthcoming in 2026).

As with the EU budget debate (MFF), the key question will be: how ambitious can the EU be—and who will bear the cost of the transition?

Key sources, further reading and other voices from civil society 

Cillian LOHAN (Ireland)

Cillian LOHAN (Ireland)

EESC rapporteur, NAT/986 Circular Economy Act

President, EESC Civil Society Organisations' Group

CEO, Green Economy Foundation

© EU/EESC