Theresa Mörsen, Policy Manager at Zero Waste Europe, argues that the EU’s Circular Economy Act must break free from import dependencies and cut down on material use if it wants to spearhead a successful circular transition.
Discussions on the circular economy are heating up in Brussels as the European Commission prepares to publish its proposal for the Circular Economy Act in autumn.
But EU decision-makers risk repeating past mistakes by presenting recycling as a silver bullet to meet material needs and tackle the waste crisis.
Instead, Europe needs more serious strides towards decreasing its import dependency and ensuring resources are used more strategically.
Why the current approach isn’t enough

The EU imports almost twice as much material by weight as it sends out, and every day, each EU citizen is responsible for 38.6 kg of raw materials extracted from the earth, on average.
To put that into perspective, making the smartphone in your pocket requires mining 10-15kg of ore. The ecological damage is immense: biodiversity loss, pollution, and climate change.
In fact, our current thirst for raw materials makes a comfortable life within planetary boundaries less and less likely for our children and grandchildren.
Much of our material needs come from a persistent throw-away culture. Each year, the EU discards millions of single-use vapes, 16 billion single-use coffee cups, and 5.8 million tonnes of clothing.
These products contain valuable materials from cotton, polyester, and paper, to aluminium, lithium, and cobalt.
While they can be recycled in theory, in practice, collection is insufficient, losses occurring during recycling are inevitable, and many products contain hazardous substances or weren’t designed to be recycled in the first place.
This means that these materials are either burned in an incinerator or buried in a landfill. This is exactly the kind of preventable waste the Circular Economy Act has a chance to address, but only if it goes further than what is currently on the table.
A Circular Economy Act for a secure and innovative Europe
The EU already has an ambitious target to double circularity from 12.2% to 24% by 2030 – set in the Clean Industrial Deal in 2025. But hitting that 24% target requires confronting two issues that remain largely absent from the debate:
- Circularity is still not prioritised as a driver of competitiveness and resilience, but rather as a burden for businesses.
- The absolute consumption of materials needed for the EU economy is too high to be substituted with circular materials alone.
This is the core gap the upcoming Act has to close: it must address both circularity and the absolute demand for materials while creating new opportunities for businesses.
Reusing and recycling materials is important, but reuse without absolute reduction is like trying to empty a bathtub without turning off the tap; the water level keeps rising, as do the risks for people and planet.
In an increasingly volatile world that frequently sees the disruption of supply chains, using the materials that are already available to us more strategically is what should guide policy-making.
As the European Commission finalises the proposal, we’re calling for the Circular Economy Act to incorporate the following measures:
- Increasing circularity by prioritising reuse, repair, and refurbishment over recycling to harness the full potential of keeping products in use for as long as possible. Reuse and preparation-for-reuse targets, as well as economic incentives like EPR, can make second-hand products more attractive.
- Managing demand by swapping single-use items for reusable ones, especially by phasing out short-lived electronic appliances.
- Introducing measures to tackle the overall material consumption by putting a fair price on the environmental externalities of new materials entering the EU, taking inspiration from existing EU carbon pricing mechanisms (ETS/CBAM).
- Setting a science-based material footprint target to guide the long-term transition towards a resilient economy and a sustainable level of material use in the EU. In 2024, all Member States called on the Commission to assess such a target. Following the approach taken in the European Climate Law, ambitious and binding targets on primary material use should be supported by concrete policy measures.
The economic advantage of the circular transition
This is not only about saving resources and limiting environmental impacts. The strategic use of materials also paves the way towards a new economy, creating local, circular jobs in reuse, repair, and refurbishment businesses.
Around 4.3 million Europeans already work in the circular sector – that’s more than the entire workforce in Denmark. With the right regulatory support from the Circular Economy Act, it could become the economic engine that powers the transition to a more resilient, competitive, and resourceful European economy.
