Later this year, possibly at the end of September or beginning of October, the European Commission is expected to adopt the long-awaited Circular Economy Act (CEA). The preparations for this key milestone in the EU’s policy on the circular economy, and possibly quite encompassing piece of legislation, have already started last year. Since then, communications and public references have been made about the state of play of the ongoing legislative work shaping the CEA proposal. Based on this information, Ecommerce Europe puts together a summary of the likely plans of the Commission for the upcoming CEA.
Policy background and gradual definition of the CEA scope
Since the start of the new EU mandate, the CEA has been conceived as a policy tool expected to boost the European competitiveness and reduce administrative burden, including by digitalising and simplifying existing rules. Early references to the concept of “circular economy” came with the publication of the Commission’s political guidelines for 2024-2029, where the CEA was framed as an instrument to achieve “market demand for secondary materials and a single market for waste […]”.
Around six months later, the Clean Industrial Deal provided more information about the scope and timeline of the CEA. The act would encompass a revision of existing rules on e-waste, the harmonisation of end of waste criteria, as well as the simplification, digitalisation and expansion of Extended Producer Responsibility (EPR). Improvements to recycling capacities in the EU, notably to retail critical raw materials (CRM) in the EU were also mentioned. In a meeting of the Expert Group on Circular Economy and Sustainable Production and Consumption, the structure of a CEA based on three possible pillars was introduced: (1) changes to the Waste Framework Directive and Landfill Directive; (2) tweaks to WEEE Directive; and (3) so-called ‘flanking measures’ (e.g., industrial policy measures).
Finally, in May 2025, the Single Market Strategy 2025 confirmed that the CEA would address fragmentation across EPR schemes, including by setting up a “digital one-stop shop for information, registration and reporting”. In addition, measures reforming end-of-waste and by-product criteria should be expected, nearby the facilitation of cross-border shipments of waste feedstocks for recycling.
The expected content of the Circular Economy Act
In summer 2025, the Commission launched a public consultation and Call for Evidence on the Circular Economy Act, officially opening the legislative process to stakeholders’ feedback. The encompassing public consultation questionnaire gave a practical overview of the specific policy actions considered by the Commission under the revision of the WEEE Directive, as well as the harmonisation, simplification and digitalisation of EPR schemes. The general consultation was followed by a targeted one, closing in early December 2025, where a team of consultants mandated by DG ENV requested input on 14 distinct topics which might be in the scope of the CEA.
On 30 April 2026, a stakeholders’ workshop on the CEA proposed three specific objectives of the initiative, although potential and non-confirmed by the Commission: (1) reducing the dependency of the EU’s economy on imports of critical raw materials; (2) removing barriers to the Single Market for waste, including EPR fragmentation; (3) strengthening the secondary raw material markets and improve access to feedstock in the EU.
In parallel, public statements by different Commission’s officials have completed the picture. For example, William Neale, Advisor for the Circular Economy at DG ENV, when asked about financing repair and reuse measures in the CEA, explained that taxation and SME support are primarily national competencies, leaving EPR schemes as the main instrument available at EU level. In another event, Aurel Ciobanu-Dordea, Director for the Circular Economy at DG ENV, indicated that the Commission is considering broadening the mandatory uses of EPR fees to cover for price differential between virgin and secondary raw materials.
To sum up, the CEA is extremely likely to include horizontal measures to tackle the fragmentation of EPR schemes, as well as the revision of the WEEE Directive, and measures boosting the production of secondary raw materials and their movements within the EU.
Relevance of the Circular Economy Act for e-commerce
While the potential impact of the upcoming measures on the e-commerce sectors will be clearer whenever the initiative is published (expected in September/ October 2026), it is safe to assume that modifications in EU-regulated EPR schemes are likely to positively impact compliance costs for companies selling online and cross-border. Via increased digitalisation and harmonisation, both across Member States and within national EPR schemes, enterprises selling to more than one country will benefit from faster and streamlined compliance processes. The revision of the WEEE Directive might also bring about some changes for online retailers, namely in terms of take-back obligations. Finally, measures boosting the reuse of products could be beneficial for the numerous e-commerce businesses facilitating resales and the trade of second-hand products.