With the EU officially launching public consultation on the Circular Economy Act in August 2025, Europe is accelerating its move towards a "new era of circular economy" with efficient resources, green and low carbon. This framework legislation, which is to be issued in 2026, will be from Electronic waste management and Construction of single market for secondary raw materials Start with the two pillars and systematically reshape the world circulation system. For the plastic recycling industry, this not only means new compliance challenges, but also indicates High-quality recycled materials are about to usher in system endorsement and market explosion . Whoever can make plans in advance will be able to seize the initiative in this green revolution.

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From "Action Plan" to "Framework Law": Why is it now?

Over the past 15 years, the cycle rate in Europe has only 10.7% Lift to 11.8% , progress is weak, The externalities of linear economic models are becoming increasingly unbearable . August 1, 2025, The European Commission officially launched the Circular Economy Act (CEA) public consultation and certification , Feedback as of November 6, 2025 ,and Plans are proposed and adopted in 2026 . CEA is considered a one-time basis on the existing Circular Economy Action Plan (CEAP) System level upgrade : From "decentralized special legislation" toward A unified market and governance framework ,by Establish a "single market for secondary raw materials" , Improve the supply of high-quality recycled materials and Create stable domestic demand with demand-side tools .

More importantly, CEA has been included in the Clean Industrial Deal with industrial competitiveness as the key point. ,and ESPR (Eco-design Regulations for Sustainable Products) , PPWR (Packaging and Packaging Waste Regulation) , Key Raw Materials Method (CRMA) wait Coordinated promotion , means to the plastic recycling industry The superposition of policy synergy and market certainty.

Key points speed reading : Inquiry will be launched on August 1 → end on November 6 → adopt the target for 2026 → drive with the dual-wheel drive of "single market for secondary raw materials, high-quality recycled materials supply and demand" .

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CEA focuses on the four keywords of "law ontology"

To avoid "singling" with other regulations, here only focuses on it CEA "Bill Text/Consultation Text itself" The direction has been clarified or officially described.

1) Single Market

The primary goal of CEA is Establish a true “single market” for waste, secondary raw materials and their use in products . This is not a slogan, but Boundary definition, quality standards, certification and mutual recognition, circulation rules Broaden the differences between member states and break the fragmentation of regulatory "you are waste/I am raw material". For plastics, this is equivalent to rPET, rPP , rPE Cross-border circulation of recycled materials Reduce costs and speed .

2) "Two-way force" of supply and demand

CEA puts " Increase the supply of high-quality recycled materials "and" Stimulate demand ”Link: Upstream pass Standards, certifications, traceability Make “quality and credibility” practical; Downstream pass Demand-side tools such as public procurement Form a stable order pool. For the plastics industry, this is Turning the "regeneration content" from "shouting slogans" to "can be compared, investigated, and paid" trading language .

3) Two policy pillars

• Pillar A: Electronic Waste (WEEE) priority breakthrough . The EU named electronic waste that increased by about 2% annually and the recycling rate of less than 40% is the current waste stream with a "painful" feeling. Plastic recycling and the electronic and electrical industries (E&E) have a wide intersection (shells, components, mixed plastics, flame retardant systems, etc.), Quality and traceability rating of E&E It will spill quickly to the plastic recycling end.

• Pillar B: The "combination punch" of the single market of secondary raw materials . CEA will consider Reform the "End-of-Waste, EoW" standard , Simplify and digitalize EPR (Extended Producer Responsibility) , Introducing mandatory standards for recycled goods/services in public procurement etc.

4) "Breakthrough" rather than "replacement" with existing legal systems

CEA positioned as "umbrella/frame method" :it Not replaced ESPR, PPWR, WEEE, Waste Transport (WSR) and other special methods, but Obstacles at the market level (circulation, mutual recognition, verification, price signal) Unify , let the "product side" ESPR/ DPP , the EPR and waste transportation rules of the "chain side", and Packaging and food contact recycled plastics Special methods True collaboration .

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How to "name" and "side pressurize" plastic recycling

Although CEA is not a "plastics special law", The four contacts of the plastic chain will be significantly amplified :

1) EoW standard and quality threshold : When “waste → non-waste” The judgment is more unified, Recycled plastic "waste outlet" is smoother ;at the same time "high quality" The word is repeatedly emphasized, meaning Pollutant limit, foreign matter ratio, melting finger/mechanics/odor/optics and other indicators All may be included in a clearer Pass/failure threshold.

2) Digital traceability and cross-border mutual recognition : CEA focuses Market credibility , DPP (bearing by ESPR) and EPR digitalization On the plastic side, it will be verifiable links that are "source-process-quality-purpose". Cross-border orders The "trust cost" has decreased, Bad money drives out good money The space is narrowed.

3) Demand-side tool overlay : Member States Green public procurement It is expected to be Regeneration content ratio , Recyclability design Then write "hard terms", Plastic products B2G/B2B order The bid evaluation logic will be "default tendency loop".

4) "Uncoupled tracks" of recycled plastics in contact with food : Regulation (EU) 2022/1616 Still compliant for food-contact recycled plastics (such as rPET)” Hard threshold ”. CEA will not change EFSA to process SOL/Authorization path, but It will create a more friendly environment for "cross-border circulation and demand side after market access" .

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Explain clearly the "industry idea" and "official text" separately

There are many around CEA Industry plan concept (For example: Public procurement of recycled materials ratio threshold, circular credit transactions, CBAM deductions, soft landing clauses for micro-enterprises, and mass balance accounting chemical recycling wait). These It is of great significance to refer to the plastics field , but from Strict text Look, this kind of mechanism Most of them are "policy tools/options to consider" , No draft bill has been written yet .

Pragmatic advice : When communicating externally or making internal decisions, Please use "Officially defined" and "Industry Proposal/Possible Options" to do AB layering :

• Layer A (cleared) : Consultation has been launched - dual-pillar direction - single market target - synergistic with ESPR/PPWR, etc. - 2026 adoption path .

• Layer B (possible option) : EoW reform, EPR digitalization, and mandatory standards for public procurement wait" Evaluation in progress ” intervention; Circular Credit, CBAM Coupling, Mass Balance Calculation Details wait For industry proposals or interpretations ,need Wait for subsequent draft or authorization bill Decide again after landing.

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The “Eight Influence Channels” of Plastics Industry

(Sorted by "Determinism → Uncertainty")

1) The certainty of cross-border circulation increases : Unified EoW and mutual recognition, "Qualified Recycled Materials" for mechanical/chemical recycling are easier to sell across borders .

2) Quality and data thresholds are raised : Traceability - Verification - Price comparison Become the new normal, "High-quality recycled material" There will be better bargaining power.

3) EPR digitalization improves efficiency and reduces costs : Expected Integration of registration/declaration/verification , multinational sales Compliance friction reduce.

4) "Demonstration Demand" Expansion of Public Procurement : Formation of recycled plastic products (including recyclable content, repairable/recyclable design, recycling service) Stable chassis .

5) "Breakthrough" with ESPR/DPP : Product side data (Formula, Recyclability, Recycling Content, Carbon Footprint) and Market-side verification Linkage, DPP becomes the "data pass" to enter the "circulating market" .

6) WEEE reform spillover : E&E Plastics (including flame retardant system and mixture) quality and destination management are stricter, High-quality sorting/pre-processing Technology benefits.

7) Price system reshaping : "Complied and High Quality" Recycled Material The price difference between "low quality/high risk control" recycled materials has widened, Certification and third-party testing Become a standard transaction.

8) Calculation and location of chemical recycling ( High uncertainty ): Mass balance method and other accounting rules are still To be clarified by legislation ; Boundaries such as "fuel use exemption" It will affect the feasibility study and investment rhythm of the project.

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Enterprise "90-day action list"

(Up to 2025-11-06)

• Submit "Evident Feedback" :around EoW barriers, cross-border circulation costs, quality standards and mutual recognition, EPR digital interface, data acquisition costs supply Quantitative cases .

• Run through the evidence chain of "high-quality recycled materials" :according to Raw materials - process - quality - use Path, preparation Batch data, third-party reports, customer-side acceptance records .

• Benchmarking ESPR/DPP requirements :Establish Material master data—cyclic data—carbon data of Unified account book , first rPET or main product On the pilot.

• Open up the EPR digital interface : Clothing EPR obligations of member states ,Bundle Registration/Declaration/Invoice/Verification Pre-set to ERP/ PLM in the system.

• Compliance map and chapter : Single column Food contact recycled plastics Compliance chapter ( EU 2022/1616 EFSA SOL ) to avoid misunderstanding with general purpose.

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Plastic track segment: Strategy positioning and risk control tips

• rPET (bottle to bottle/sheet grade) :exist Food Contact and DPP/traceability Compare Easy to run "high-quality" narrative ;The shortcomings are Waste bottle source stability and Deodorization/purification ability .

• rPP/rPE (packaging and appliance housing) : Complex formula, legacy of additives bring Mass fluctuations ; It is recommended to promote "recyclability design" and "recipe transparency" ,match Graded pricing.

• E&E hybrid plastics :by WEEE prioritizes breakthrough Influence, Flame retardant system identification and removal , High optical/mechanical index modification It is a differentiated competition point.

• Chemical recycling : In "Stable Quality - Pollutant Threshold - Large-scale Supply" Have advantages in terms of Regulatory accounting boundaries and Economics still need to be carefully evaluated; First do a combination strategy with mechanical recycling .

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Timeline and milestones (only listed as "official caliber")

• August 1 - November 6, 2025 : CEA Public Consultation and Evidence Collection ; Wide coverage of objects (Enterprise, industry association, NGO, public).

• 2026 : Plan to adopt CEA (Then enter the matching/authorization bill period).

• 2030 : Double the cycle rate target to about 24% (Clean Industrial Deal target) .

Note: ESPR and DPP For parallel system, the specific DPP Product range and rhythm Depend on ESPR Work Plan and Authorization Law Promote; CEA will be with it Alignment and collaboration , However, the CEA does not directly specify the DPP time point of all products .

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Three "must-answer questions" for industry decision makers

1) Can the recycled materials in our hands be recognized as "high-quality, verifiable, and mutually recognizable" in the context of "single market"?

2) Can our data link (including DPP docking/EPR digitalization) turn "quality and compliance" into "certainty" that customers are willing to pay?

3) Does our investment rhythm match the regulatory rhythm of "CEA official text - authorization law - member state implementation"? (Don't regard "industry vision" as "legislated".)

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New observation tips: present "text" and "interpretation" layer by layer

For the public readers, It is recommended to use CEA's "clear matters" to build a narrative framework first , and then the industry is hotly discussed Circular credit, CBAM coupling, mass balance wait Presented as "Possible Options/Industry Proposals" , avoid causing "misunderstanding of regulatory expectations". Especially important for plastics companies, because Investment Window and Compliance Window often" One step ahead "and" One step later "It's all expensive.