Unleashing the Potential of a Circular Single Market

The European Commission’s new Single Market Strategy sends promising signals to the recycling industry. However, further action is needed if the EU is to meet its ambitious target of doubling the circular material use rate to 24% by 2030, as set out in the Clean Industrial Deal. 

The Single Market Strategy aims to create a simpler, more seamless, and stronger European internal market. For the recycling sector and the broader circular economy, most relevant measures are found under the first pillar, which focuses on removing the most harmful market barriers. 

Public procurement as a market driver 
One key initiative is the planned revision of the Public Procurement Framework to promote the use of non-price criteria, such as sustainability and carbon reduction, when awarding contracts. This could significantly boost demand for recycled raw materials by making circularity a competitive advantage in public tenders. 

Tackling fragmentation: Packaging, labelling, and waste 
The Strategy identifies fragmented rules on packaging, labelling, and waste as a major obstacle. Harmonized packaging labels for consumer sorting are essential for achieving high-quality waste streams through effective separate collection prerequisite for meaningful recycling rates. Similar harmonization efforts are expected for textiles, which are much needed and widely welcomed. 

Extended Producer Responsibility (EPR): A double-edged sword 
The Commission also intends to address the fragmentation of the single market for waste through greater harmonization and integration of Extended Producer Responsibility (EPR) schemes. While this is a positive development, it is critical that the Commission also ensures fair competition. Without proper safeguards, EPR schemes risk dominating national markets and crowding out independent recycling operators. EPR systems should only be introduced where necessary, particularly for waste streams with negative economic value. 

Cross-Border waste shipments and end-of-waste status 
Easing the rules for cross-border shipments of waste for recycling is another important goal. This initiative deserves strong support, but the Strategy lacks detail on how it will be implemented. Much will depend on the effective rollout of the new Waste Shipment Regulation, set to apply from May 2026. Another crucial measure mentioned is the establishment of clear end-of-waste criteria for recycling feedstocks, an area that also has the full support of the recycling industry. 

A circular economy act on the horizon 
High expectations are placed on the upcoming Circular Economy Act, expected in Q4 2026, which is anticipated to address many of the challenges outlined above, and more. While the current proposals are important enablers for creating a true single market for waste, they are not sufficient on their own. The Commission’s current focus is largely on municipal waste. To achieve the EU’s circularity targets, a similar level of ambition must be extended to industrial waste streams.