Circular Economy Act and Communication 805: What the European Path Toward the Circular Economy Provides

The European Union Moves Toward a More Circular Economy with Communication COM (2025) 805 and the upcoming Circular Economy Act, expected in 2026, the transition will no longer focus solely on waste management, but also on the ability of companies to design, qualify, and use safe, traceable, and compliant circular materials.

The circular economy is entering a more mature phase. After years in which attention focused mainly on increasing collection and recycling rates, the European debate is now shifting toward a broader issue: how to make recovered materials truly usable by industry.

The challenge is no longer simply recovering resources at the end of their life cycle, but ensuring that these resources can re-enter production processes as reliable, competitive secondary raw materials suitable for their intended applications.

Within this context, the European Commission’s Communication COM (2025) 805 and the future Circular Economy Act, announced for 2026, represent important milestones. Both initiatives confirm the European Union’s intention to strengthen the market for circular materials by addressing some of the critical issues that currently limit the stable use of recycled materials within industrial supply chains.

What Communication COM (2025) 805 Provides

Communication COM (2025) 805 marks an important step in Europe’s path toward a more circular economy. The document highlights the need to accelerate progress by addressing the structural barriers that still hinder the development of fully functioning circular markets.

Its central message is clear: circularity can no longer be treated solely as an environmental or waste-management issue, but must become an integral part of European industrial policy. From this perspective, the Commission links the future Circular Economy Act to three main objectives: addressing existing barriers, creating a single market for waste and secondary raw materials, and stimulating demand for circular products, services, and solutions.

For businesses, this shift in perspective is particularly significant because it changes the focus of compliance requirements. It will no longer be enough simply to demonstrate proper waste management or the use of a percentage of recycled content. Increasingly, companies will need to document the origin of materials, their technical characteristics, their suitability for intended applications, and the consistency of business processes with European circularity requirements.

The Future Circular Economy Act

The Circular Economy Act, expected in 2026, will translate these principles into more concrete measures. The European Commission has already launched a public consultation to collect contributions for the upcoming legislative initiative, opened on August 1, 2025, and closed on November 6, 2025.

According to the Commission, the Circular Economy Act will support Europe’s ambition to become a global leader in the circular economy by 2030 and to double the EU’s circularity rate. The initiative is therefore expected to act both on the supply side, by increasing the availability of high-quality recycled materials, and on the demand side, by creating more favorable conditions for companies to use them.

One of the most significant aspects concerns the concept of a single market for secondary raw materials. Today, recovered materials may face different obstacles depending on the Member State, the application sector, or the regulatory classification involved. The future European framework aims to promote greater harmonization, making it easier for recovered materials to circulate within the Union and reducing the uncertainties that currently limit investment and industrial adoption.

Beyond Recycling: The Challenge of Material Quality

The direction outlined by the European Union confirms the growing importance of material management throughout the entire life cycle. Companies are facing a structural transformation in which the use of recycled materials will become increasingly central, together with the need to demonstrate their quality, safety, and compliance with regulatory requirements. At the same time, the importance of material traceability and the ability to integrate circularity principles into production processes will continue to grow.

Recycling is an essential element of the circular economy, but it is not sufficient on its own. For a system to be truly circular, recovered materials must be capable of being reintroduced into the economy with adequate, controllable, and repeatable characteristics.

For many companies, the choice between virgin raw materials and recycled materials is not driven solely by environmental goals. It also depends on technical, performance-related, economic, and regulatory factors: material quality, consistency of characteristics, safety, available documentation, and compliance with applicable requirements.

Secondary Raw Materials: Why Suitability for Use Must Be Demonstrated

To be used in manufacturing processes, recycled materials must guarantee characteristics consistent with their intended application. It is not enough to indicate their origin or recycled content percentage; it must also be possible to demonstrate that the material complies with specific performance, safety, and regulatory requirements.

Depending on the application, this may involve mechanical characteristics, physico-chemical properties, composition, contaminant presence, long-term behavior, compatibility with specific applications, or suitability for food contact.

For companies, the ability to document these characteristics will become increasingly important. The use of recycled materials can represent a significant opportunity, but it also requires rigorous management of information, controls, and traceability throughout the supply chain.

Toward Verifiable Circularity

The Circular Economy Act therefore represents an important step toward a more concrete form of circularity, based on material quality, supply-chain traceability, and verifiable compliance.

For companies, the challenge will be to integrate these principles into their processes, transforming circularity from an environmental objective into an industrial criterion. In this context, testing, inspections, and certifications will play a fundamental role in supporting informed decision-making, reducing risks, and enhancing the value of materials and products within increasingly sustainability-oriented supply chains.

Laboratory testing makes it possible to analyze material characteristics and verify performance. Inspection activities can support the control of processes, traceability, and the consistency of business practices. Certification helps provide objective evidence of compliance with standards, schemes, or specific requirements.

For this reason, conformity assessment is not merely a technical step, but an enabling factor for the development of the circular economy. Without reliable data, adequate controls, and shared criteria, the market for secondary raw materials risks remaining fragmented and insufficiently competitive.