The undersigned industry associations express their strong support for the European Union’s ambitions for circularity. To achieve a true circular economy and a functioning European market for secondary raw materials, the upcoming New Circular Economy Act (CEA) must be grounded in an internal market legal basis (Article 114 TFEU).

Ambitious circular economy goals can only be met through harmonised rules driving a step-change in waste management across all of the EU. Today’s waste management landscape across the EU remains extremely fragmented, marked by uneven performance and divergent national regulatory frameworks.

Nearly half of all EU countries still landfill more than 30% of their municipal waste, with four touching peaks between 60% and 80%¹. When it comes to recycling, only nine Member States are expected to meet the 2025 recycling target².

The recent targeted revision of the Waste Framework Directive (WFD) ultimately fell short in resolving the deep-rooted structural shortcomings that continue to hinder the efficiency of European waste management systems.

The New CEA represents a unique opportunity to address these structural deficiencies by putting forward common rules to ensure that all Member States, rather than only a few front-runners, deliver against their respective circular economy goals. The lack of harmonised rules on waste management is not only undermining Europe’s ability to meet these goals collectively, but it is equally preventing it to create a Single Market for secondary raw materials.

As acknowledged by the European Commission in the Single Market Horizontal Strategy³, divergent waste rules are among the most reported Single Market barriers, so-called ‘Terrible Ten’. The implications of these barriers are thus environmental, economic and also geopolitical, because the result is increased external dependencies.

We strongly believe that the Commission must stand firm in the drafting of CEA and push-back on any attempts to weaken its ambition disguised as flexibility, under the pretext of defending national specificities. The end goal should be to ensure that the laggards catch-up with the front-runners and that, ultimately, all Member States do their parts in achieving the circular economy goals. Any calls for the introduction of Article 192 TFEU (environmental protection) as a legal basis should be rejected as this will further exacerbate the current situation, create legal uncertainty about the residual responsibilities of Member States and adversely impact efforts to support the EU’s transition to a circular and climate-neutral economy.

With broad stakeholder support across Europe, we urge the EU Commission and co-legislators to uphold in its entirety the internal market legal basis, which is best suited to serve the objectives of the future CEA.

The complete list of the signatory associations in alphabetical order:

• AESGP - The Association of the European Self-Care Industry
• AGMPM - Association of Greek Manufacturers of Packaging & Materials
• AIM - European Brands Association
• A.I.S.E. - International Association for Soaps, Detergents and Maintenance Products
• Aluminium Closures Group
• AMAPLAST - Italian Plastics and Rubber Processing Machinery and Molds Manufacturers Association
• AmCham EU - American Chamber of Commerce to the European Union
• ARAM - The Association for Packaging and the Environment in Romania
• AVU - Allianz Verpackung und Umwelt
• The Brewers of Europe
• Business Europe
• CCIA Europe - Computer & Communications Industry Association
• CEC - European Footwear Confederation
• CEEV - Comité Européen des Entreprises Vins
• CEPE - European Council of the Paint, Printing Ink and Artists' Colours Industry
• Cepi - European Paper Industry
• CICPEN - Czech Industrial Coalition for Packaging and the Environment
• CITPA - The International Confederation of Paper and Board Converters in Europe
• Conseil National de l’Emballage
• Cosmetics Europe - The personal care association
• EAFA - European Aluminium Foil Association
• ECMA - The European Carton Makers Association
• EDANA - The Voice of the Nonwovens Industry
• EDRA - European DIY Retail Association
• EFCC - European Federation for Construction Chemicals
• EFIC - European Furniture Industries Confederation
• EFPIA - European Federation of Pharmaceutical Industries and Associations
• EKO-PAK - Packaging Industry Union of Employers
• ELIPSO - Les entreprises de l'emballage plastique et souple
• EPLF - European Producers of Laminate Flooring Association
• EPPA - European Paper Packaging Alliance
• EUMEPS - European Manufacturers of Expanded Polystyrene
• EuPC - European Plastics Converters
• EuroCommerce
• European Aluminium
• EUROPEN - The European Organisation for Packaging and the Environment
• EVA - European Vending & Coffee Service Association
• EXPRA - Extended Producer Responsibility Alliance
• FBCA - The Food & Beverage Carton Alliance
• FDE - FoodDrinkEurope
• FEC - Federation of the European Cookware, Cutlery and Houseware Industries
• FEFCO - The European Federation of Corrugated Board Manufacturers
• FEPE - Federation of European Producers of Envelopes and Light Packaging
• FESI - Federation of the European Sporting Goods Industry
• FEVE - The European Container Glass Federation
• FINAT - The Association for the European Label Industry
• FPE - Flexible Packaging Europe
• Freshfel - European Fresh Produce Association
• IK - Industrievereinigung Kunststoffverpackungen
• INCPEN - The Industry Council for Packaging & the Environment
• Independent Retail Europe
• Istituto Italiano Imballaggio
• IVSH - Association of the German Cutlery and Housewares Industries
• MedTech Europe - The European trade association for the medical technology industry
• MMFA - Multilayer Modular Flooring Association
• MPE - Metal Packaging Europe
• NATRUE - The International Natural and Organic Cosmetic Association
• NMWE - Natural Mineral Waters Europe
• PAKKAUS - The Finnish Packaging Association
• PET EUROPE - Producers’ Association
• PETCORE EUROPE
• Plastics Europe
• Pro Carton - European Association of Carton and Cartonboard manufacturers
• PROSPA - Producer Responsibility Organisations Packaging Alliance
• SfPE - Steel for Packaging Europe
• spiritsEUROPE
• SZZV - Slovak Association for Branded Products
• VinylPlus

References

¹ Municipal waste landfill rates in Europe by country (2010 and 2023) | Diversion of waste from landfill in Europe | European Environment Agency (EEA)

² A 2025 report from the EU Court of Auditors on municipal waste management found that only 9 out of 27 Member States are likely to meet their 2025 recycling target of municipal waste, with many Member States facing challenges to progress towards circularity, mainly due to financial constraints and weaknesses in planning and implementation. It added that, despite having strengthened targets and other legal requirements, the Commission was late in initiating infringement proceedings regarding missed waste targets. See here

³ The Single Market: our European home market in an uncertain world. A Strategy for making the Single Market simple, seamless and strong” here; Section 6 Fragmented rules on packaging, labelling and waste.