Europe isn’t waiting for 2026 to go circular – is business ready? 

Circularity isn’t new in Europe. Over the past decade, two Circular Economy Action Plans (2015 and 2020) laid the groundwork through targets on waste, recycling and product design. But these were strategic roadmaps, not binding legislation. That’s why companies have treated 2026 as the real turning point, when the European Commission is expected to table its flagship Circular Economy Act (CEA) in Q3 2026 – the first legislative framework to make circularity a core pillar of EU industrial policy.  

Now, new signals from Brussels suggest the shift could begin sooner. 

According to a document shared with Member States ahead of the 23 October European Council, the Commission is preparing a “Mini Circular Economy Package” for Q4 2025, designed to bring forward parts of the transition before the full Act arrives. 

Earlier in October, Commissioner Jessika Roswall hinted at what’s coming during an EPC event, calling the plastics sector a first testing ground for short-term measures. Two weeks later, she hosted a high-level roundtable with the plastics industry to turn those ideas into action. Together, these exchanges are now widely seen as feeding directly into the design  of the forthcoming mini-package. 

Meanwhile, a public consultation on the CEA is open until 6 November 2025, giving companies a window to help shape the framework that follows. Supporting it, an Environmental Omnibus expected on 3 December 2025 will simplify and harmonise environmental reporting – quietly paving the way for faster implementation. 

Taken together, these developments point in one direction: Europe isn’t waiting for 2026. Circularity is already becoming part of its industrial playbook, and for business, the real shift may start much sooner than expected. 

But what exactly is Brussels signalling with this acceleration, and why now? 

The signal behind the policy 

This isn’t just about “more recycling”; it’s about linking sustainability and competitiveness. The EU now sees circularity as both an environmental necessity and an industrial strategy for: 

In short, circular policy has evolved from an environmental goal to a framework for economic resilience. And while the rules are still being written, frontrunners are already acting as if they’re in force. 

Building the circular market 

Some companies aren’t waiting for Brussels to legislate; they see where the market is heading and are moving early. These frontrunners are connecting the full circular chain: 

Design. Producers and manufacturers are rethinking how products are made, integrating recycled content, planning for reuse, and preparing for new traceability obligations. The Digital Product Passport (DPP), rolled out under the Ecodesign for Sustainable Products Regulation (ESPR), is accelerating this shift by requiring detailed data on composition, origin and recyclability; redefining what “good design” means across value chains. 

Use. Service providers and retailers are extending product lifetimes through maintenance, repair and resale, linking design with recovery. Then comes recovery. Recyclers and PROs are upgrading to deliver high-quality, traceable secondary raw materials and to translate policy into measurable outcomes. 

Demand. Public buyers sit at the centre of the circular chain, using their purchasing power to connect what’s made with how it’s used. From the Netherlands’ national circular procurement targets to city-level pilots in Tampere embedding circular criteria in tenders.  

Together, these actions are bringing the circular economy to life across European industries. However, these frontrunners can only go so far on their own. To turn these examples into a functioning single market, Europe needs harmonisation. Today’s patchwork of national criteria, from end-of-waste rules to product standards, still slows cross-border trade. The CEA is where those threads can finally be tied together. 

Why acting early matters for business 

By the time the CEA lands in 2026, market dynamics will already have shifted. The rules may simplify reporting, but expectations will rise. The new framework will reward companies with transparent material flows, reliable data, and traceable supply chains, those able to turn compliance into competitive advantage. Europe’s circular rules aren’t just a checklist; they mark a shift in how competitiveness is measured.  

In other words, the rules are changing, and so are the frontrunners. The companies that see this shift are already treating materials as a strategic asset, much as they once did with energy. They know what is in their products, where it goes, and how to get it back, recapturing value that would once have been lost. By 2026, leaders will set the benchmarks while latecomers chase them. The real risk is not the Act itself, but arriving late to a game that has already started.  

What should companies do now? 

With the Circular Economy Act expected in Q3 2026, companies should: 

If you’d like to understand how upcoming circular legislation could affect your organisation or how to prepare for it, reach out at: iaranguren@political-intelligence.com  

Inés Aranguren Idigoras – Consultant, Brussels