Joint Letter: Putting Demand for Recycled Materials at the Heart of the Circular Economy Act

Dear President Von der Leyen,

The Circular Economy Act (CEA) represents the key opportunity to establish a genuine Single Market for secondary raw materials and address structural barriers. To deliver on the EU’s circularity ambitions, the CEA must place stronger and more predictable demand for recycled materials at the centre of its framework through robust and harmonised demand-side measures.

The undersigned organisations call on the European Commission to prioritise:

• Financial support for the incorporation of recycled materials in new products through
  Extended Producer Responsibility (EPR) eco-modulation;
• A level playing field that promotes the uptake of European recycled materials and strengthens
  Europe’s circular value chains.

The CEA should establish a coherent framework to stimulate the uptake of recycled materials produced and processed in Europe. This should include harmonised minimum eco-modulation criteria within EPR schemes that incentivise the use of European recyclates. It should also strengthen the integration of circularity criteria into Green Public Procurement (GPP), including procurement criteria that prioritise European recycled content in purchasing decisions. Similarly, the Green VAT initiative should be expanded beyond second-hand products by introducing reduced VAT rates for products containing recycled content and support for recycling activities.

These measures are urgently needed. Demand for European secondary raw materials is weakening, while recyclers face increasing pressure from volatile prices, high operating costs, and low-cost imports of virgin and recycled materials from third countries. Without stronger market incentives, investment in Europe’s recycling capacity and circular value chains will remain at risk.

By creating strong and predictable market signals, the EU can unlock investment, strengthen domestic recycling capacity, increase resource resilience, and accelerate progress towards resource independence in the current geopolitical context. The undersigned organisations, therefore, urge the European
Commission to ensure that the CEA delivers a robust and coherent set of demand-side measures that place recycled materials at the centre of Europe’s circular transition.

Sincerely,

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations and associate members, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be