This contribution was the topic of the week in the newsletter of Week 15 in 2026.

The EU Commission now wants to create a framework law with a "Circular Economy Act" that could significantly transform the market for circular products and secondary raw materials. Stronger circular economy efforts are seen as a central approach to reducing dependencies, securing resources and lowering emissions. The CEA is intended to set political guidelines and could in future require more transparency about materials used, binding minimum levels of recycled materials, or circular economy guidelines in public procurement. The European market for circular products is to become more reliable and comparable. The current EU plans aim to increase Europe's circular quota from around 12 per cent to 24 per cent by 2030.

Do not obstruct functioning market processes

While political goals such as greater product transparency or a guaranteed minimum level of recycled materials cannot be achieved without clear rules, many circular business models are already developing market-driven today. According to a recent DIHK‑survey, more than half of businesses have already taken measures like recycling concepts or new business models such as trading refurbished equipment, lending or repair services.

© yaviphoto

New obligations must therefore be practical from the perspective of businesses, so they do not impede functioning processes or create additional bureaucracy. "That's why the German Chamber of Commerce and Industry (DIHK) will accompany the entire legislative process and evaluate and comment on the EU Commission's proposal," says Kathrin Riedler, expert for European environmental and resource policy at the DIHK in Brussels. "We will bring in the experiences of businesses early – so that possible obligations remain legally secure, competitive and feasible for companies of all sizes."

Moreover, anyone who wants to make processes or products more circular must first invest – in new materials, digital transparency systems, production adjustments or collaboration with partner companies. Whether their customers will later demand and pay for circular products is still unknown to businesses. Therefore, it is all the more important that at least the political framework conditions are reliable and a functioning market actually emerges. Hence, DIHK calls for clear rules that create planning security, avoid unnecessary bureaucracy and enable economically viable solutions.

Standards reduce effort and create legal certainty

For the CEA to actually be a value add for businesses, it must above all achieve one thing: unify the diversity of national rules. Today, sometimes completely different requirements apply in EU countries – for example, from when a material is no longer considered waste or what product and disposal data companies must report to authorities. Companies marketing products or secondary raw materials across borders, therefore, need to adapt their processes multiple times, submit data in different formats or meet varying authority requirements. A uniform European framework could reduce this effort significantly, advance the internal market and provide more legal certainty. Bureaucracy would not automatically disappear with unified standards, but it would become more predictable and efficient as processes and requirements ideally work the same everywhere.

It is also important that new requirements can be enforced vis-à-vis imports from third countries. Practical experience already shows today that enforcement for imports from non-EU countries can sometimes be demanding. Should products entering the EU be subject to less stringent rules than those from European manufacturers, competitive disadvantages arise, and the CEA goals are undermined. 

"Do not create new bureaucracy"

In recent years, the EU has already created numerous regulations – such as sustainable product design, repairability, packaging waste or supply chains. For many companies, this regulatory landscape is difficult to understand, so new requirements must be closely aligned with existing ones. 

"The Circular Economy Act must not further increase this complexity," says Riedler. "Where new requirements ask for information already provided, existing obligations must be removed. The goal should be to simplify and align rules – not create new bureaucracy."

Documentation effort is already high for many businesses: Several hours a week are spent on environmental and reporting obligations – in the DIHK‑Environmental Barometer 2025, one in three companies reported investing up to five hours per week for this. For more than a quarter of the surveyed businesses, the time required increases to over eight hours per week.

It is correspondingly important that the impact of new rules on different industries and company sizes are systematically assessed. Only in this way can it be ensured that obligations remain economically viable and do not overwhelm small and medium-sized enterprises. 

Now it’s decided how the rules will look

With the publication of the Commission’s legislative proposal, the pivotal phase of the legislative process will likely begin in autumn 2026. Afterward, Council and European Parliament will still have the opportunity to change the draft – so there is still room for entrepreneurial influence. 

"Businesses will be able to actively participate – and it is very important that they do," stresses Riedler. "Only when practice is heard, do rules emerge that work and do not cause unintended damage." DIHK is reviewing the EU Commission’s proposal in detail and bringing the views of businesses into statements, discussions with EU parliamentarians and through the European umbrella association Eurochambres into the process, the Brussels expert explains.