The EU Circular Economy Act is intended to help Europe use resources more efficiently by keeping valuable materials in circulation for longer, increasing the use of recycled raw materials and reducing dependence on newly extracted resources. Yet as Brussels prepares the legislation, a more difficult question is moving to the centre of the debate: can Europe become genuinely circular without confronting the sheer quantity of material it consumes?
The distinction matters. Recycling can reduce demand for virgin resources, but an economy can improve its recycling rate while continuing to consume ever greater quantities of raw materials. For the EU, whose material footprint remains high despite more than a decade of circular economy policy, that creates a problem which stronger secondary-material markets alone may struggle to solve.
What Is the EU Circular Economy Act?
The European Commission plans to adopt the EU Circular Economy Act before the end of 2026. Its stated objectives include facilitating the cross-border movement of recycled products, materials and waste, increasing the supply of high-quality recycled materials and stimulating demand for them within Europe.
The Commission increasingly views circularity not simply as an environmental objective, but as a matter of competitiveness, resource security and industrial resilience. It also wants the EU circular material use rate to reach 24% by 2030.
Europe’s Material Footprint Remains High
The concern is that circularity percentages tell only part of the story.
A material footprint measures the raw materials extracted from nature, inside and outside the EU, to make the goods and services consumed in Europe. According to the European Environment Agency, the EU material footprint stood at 14.1 tonnes per person in 2024.
That equates to roughly 38.6 kilograms of material per person every day.
Despite years of circular economy initiatives, the figure fell by only 5.5% between 2010 and 2024. The EEA considers the present level unsustainable and says a significant reduction over the coming decade appears unlikely without much stronger action.
That is the uncomfortable background against which the EU Circular Economy Act will arrive.
Recycling Rates Can Hide Rising Consumption
A higher circularity rate does not necessarily mean an economy consumes fewer primary resources.
Consider a simplified example. If an economy consumes 100 tonnes of material and 12 tonnes come from recycled or reused sources, its circularity rate is 12%. If total consumption later rises to 150 tonnes while circular materials increase to 36 tonnes, circularity reaches 24%.
Yet primary material consumption has also risen, from 88 tonnes to 114 tonnes.
The figures are illustrative, but the principle matters. A circularity target measures the composition of material consumption. It does not place a ceiling on how much material an economy consumes.
The Circular Economy Needs More Than Recycling
None of this diminishes the importance of recycling. It clarifies its place within a functioning circular economy.
Where unnecessary material use can be prevented, prevention should come first. Products should remain useful through durability, repair and reuse. When that is no longer practical, their constituent materials should remain economically useful wherever possible.
The difficulty emerges when greater efficiency simply enables greater consumption. Europe can become better at recovering materials while overall demand grows quickly enough to offset those gains.
For the EU Circular Economy Act, success will depend on recognising both sides of that equation.
Plastics Expose Europe’s Circularity Problem
Few materials illustrate the challenge better than plastics.
They are indispensable across packaging, construction, transport, healthcare and manufacturing. Yet Europe still depends heavily on virgin polymer production while losing substantial quantities of potentially recoverable plastic through incineration and landfill.
Plastics Europe estimates that circular sources accounted for 15.8% of European plastics production in 2024. The recycling rate for collected plastic waste reached 29.6%, but 70.4% of collected material still went to landfill or incineration.
Europe therefore faces two problems simultaneously. It needs to reduce unnecessary virgin plastic consumption while improving its ability to capture, trade and reuse the polymers already circulating through its economy.
Doing one without the other leaves the system incomplete.
European Recyclers Face a Capacity Crisis
There is also an uncomfortable industrial reality beneath the policy debate.
Just as Europe wants greater quantities of secondary raw materials, parts of its recycling industry are contracting.
Plastics Recyclers Europe reported that sector turnover fell by 5.5% in 2024. Preliminary figures subsequently indicated a sharp rise in facility closures, with nearly one million tonnes of European recycling capacity lost over three years.
Low-cost virgin polymers, cheaper imported recyclates, high operating costs and uncertain demand have placed European facilities under pressure. Europe cannot reduce its dependence on virgin resources if the infrastructure producing credible alternatives becomes commercially unviable.
Secondary Raw Materials Need Real Markets
This is where the EU Circular Economy Act could have its greatest immediate effect.
Recyclers need manufacturers willing and able to use the material they produce. Manufacturers, in turn, need access to material of the right grade, specification, volume and provenance.
That requires clearer quality standards, credible traceability, workable end-of-waste rules and confidence that recycled material genuinely meets the requirements claimed for it.
It also means addressing a fragmented market in which suitable material may exist in one country while a buyer elsewhere struggles to find it, qualify it or move it lawfully.
WasteTrade operates in that space. Its marketplace connects waste producers with verified recyclers and end users, while integrating logistics, compliance and secure payments into the transaction.
The relevance to the EU Circular Economy Act is practical: secondary raw materials only displace primary resources when they can move from the businesses that hold them to the businesses that can use them.
Circularity Depends on Material Movement
Policy language can make secondary raw materials sound abstract. In reality, circularity depends on commercial decisions.
A recycler may have a viable stream of HDPE, PET or polypropylene. A manufacturer may need precisely that material. Unless the two can find each other, agree the specification, establish trust, satisfy waste-shipment requirements and arrange transport, the material does not become a circular transaction.
WasteTrade was built around that market problem. The platform connects verified buyers, sellers and hauliers across international markets and manages the compliance and logistics surrounding trades. Listings are mapped to relevant Basel and HS classifications, helping businesses establish how materials can move lawfully between jurisdictions.
That function becomes more important as the EU tries to create a genuine Single Market for secondary raw materials. Recycling capacity alone will not deliver circularity if usable material cannot reach the right end user.
Traceability Is Becoming Part of the Material
Greater demand for recycled material also raises questions about provenance and quality. Manufacturers need confidence in what they buy, while regulators need reliable evidence when recycled-content requirements become mandatory.
WasteTrade’s model reflects that shift. Verified counterparties, structured material information and integrated compliance reduce some of the uncertainty surrounding international waste trading. Its Digital Product Passport capability is designed to preserve information about material provenance as a consignment moves through the value chain.
The more valuable recycled content becomes under European legislation, the more important credible verification will become.
Circular markets depend on trust as much as tonnage.
Lower Consumption Still Needs Recycled Material
The debate can easily drift into a false choice between reducing consumption and improving recycling.
Europe needs both.
A lower-material economy would still require plastics, metals, paper and other resources. The objective should not be to eliminate material use, but to avoid unnecessary primary resource consumption and extract maximum value from materials already within the economy.
That requires markets capable of treating waste as feedstock rather than simply as something to discard.
By connecting businesses that hold recoverable material with recyclers and end users that can give it another productive life, WasteTrade addresses one of the basic commercial conditions of circularity: valuable material must have somewhere useful to go.
The EU Circular Economy Act Must Address Both Sides
The EU Circular Economy Act has an opportunity to correct one of the persistent weaknesses in European resource policy.
A stronger recycling market is essential. Europe needs viable recyclers, dependable secondary-material supply, greater manufacturing demand and rules that allow recovered resources to move efficiently across borders.
But recycling more material cannot become an excuse for continually consuming more of it.
If Europe doubles its circularity rate while its overall material footprint remains stubbornly high, the achievement will be significant but incomplete.
A credible circular economy must ultimately reduce the need for primary resources while preserving the value of those already extracted.
WasteTrade cannot deliver that transition alone. Its significance lies in making one essential part of the system work more effectively: connecting material with demand and supporting the compliant movement required to keep it in productive use.
The real test of the EU Circular Economy Act will be whether it connects those parts of the system, creating an economy that does not merely become better at dealing with waste, but fundamentally better at using material in the first place.
