On 1 August 2025, the long-awaited Call for evidence and public consultation on the future Circular Economy Act (CEA) were released. These procedures mark the beginning of the legislative process. Stakeholders contributing to maintaining the value of products, materials and resources (at their highest value) for as long as possible, optimising end of life, and reducing unavoidable waste and pollution are invited to participate.
In this article, we summarise the content of the consultations and highlight the potential implications of the CEA for e-commerce.
Circular Economy Act to address primarily waste and secondary raw materials
The Call for evidence sheds light on the priority areas on which the upcoming legislation will focus. These mostly include interventions to stimulate the Single Market for waste (including waste of electronic and electrical equipment or “e-waste”) and secondary raw materials. Among the initiatives are the reform of end-of-waste criteria as well as the simplification, digitalisation and extension of extended producer responsibility (EPR) schemes.
This is in line with statements by the Commission in the last year. In fact, references to the European Commission’s intention to legislate in the field of the circular economy were made very early in the process leading to the second mandate of President von der Leyen. Commissioner for Environment, Water Resilience and a Competitive Circular Economy, Jessika Roswall, mentioned in autumn 2024 that the CEA would include measures on e-waste, Single Market for waste and secondary raw materials, as well as the “promotion of circular products and business models”. The objective of the CEA to foster the free movement of circular products in the Single Market was also mentioned in the Commission Communication on the Clean Industrial Deal.
Scope of the consultations and policy measures considered by the Commission
The Commission is seeking both general opinions on the topic of circularity in the Single Market as well as more targeted views on specific questions.
On the one hand, the Call for evidence provides background to the initiative, and lays out the problems to be tackled. The main issue is the slow transition to circularity in the EU, measured through the circular material use rate (CMUR). This is due to shortcomings such as regulatory fragmentation, high prices of secondary raw materials, behavioural biases and unaccounted waste streams. Now, only EU-level actions can ensure a level playing field in the Circular Single Market and create the conditions for the necessary economies of scale.
On the other hand, the public consultation delves into specific questions, for example around waste electrical and electronic equipment (WEEE), including the possibility to mandate online sellers to offer free WEEE take-back for delivered electronics. Each question includes potential measures, to which stakeholders can express the degree of importance according to their views. Concerning digitalisation measures to simplify EPR schemes, proposals for action such as setting national webpages for EPR systems, allowing EU-level online registration and setting up an EU-level online platform are put forward.
Relevance and priorities for e-commerce
The relevance for the e-commerce sector of aspects such as digitalisation, harmonisation of EPR-related matters and cross-border movement of resources is evident. As outlined in a study Ecommerce Europe recently published, titled “Extended Producer Responsibility Administrative Burden and One-Stop Shops”, fragmented national EPR regulations pose challenges for business compliance, generating high costs.
To address such complexity, the study evaluates the potential of an EU-level EPR one-stop shop, designed to streamline compliance through a single digital platform. The report notably highlights the opportunities that centralised, accessible information on EPR obligations and a unified registration, reporting, and payment experience could bring, if accompanied by ambitious harmonisation efforts.
Call to partake in the consultation
As a result, e-retailers and online marketplaces are warmly invited take part in the consultations to make sure that the upcoming Circular Economy Act considers their interests. Ecommerce Europe is currently preparing its own submission, developing on our Strategy Paper on the Circular Economy. We are committed to reflecting the priorities and the diversity of the e-commerce branch, contributing to the construction of a competitive, Digital and Circular Single Market.