In our overview of the latest developments from national and European regulators, we provide information on the opportunities, background, and public consultation of the Circular Economy Act, give an overview of the status of EPR systems in Europe and the revision of the EU Waste Framework Directive, inform you about the publication of the 2025 edition of the minimum standard for measuring the recyclability of packaging by the Central Agency Packaging Register (ZSVR), as well as the latest developments regarding the Green Claims Directive and the comprehensive packaging reform planned in Switzerland. We also present the new PCR modulation introduced by France.
Circular Economy Act – Opportunities, Background & Public Consultation
Preparations are currently underway for the Circular Economy Act (CEA). It is intended to promote investment in recycling capacities and remedy deficits in waste management. Important points include the standardization of extended producer responsibility (EPR) and the harmonization of national EPR systems. In addition, the CEA is intended to ensure that the fees paid are reinvested in recycling and infrastructure.
Strategic importance
The planned Circular Economy Act is intended to accelerate the transition to a circular economy in the EU and double the European circularity rate by 2030. From a global perspective, the CEA is intended to manifest the EU’s leading role in circular models.
Single market for secondary raw materials
The aim of the CEA is to create a genuine common market for high-quality recycled materials. This should increase supply, stimulate demand, and make Europe less dependent on imports, especially of critical raw materials.
Political support
The most important political impetus includes the recommendations from the Letta and Draghi reports, the Antwerp Declaration, the Budapest Declaration of the EU Council, and the positive stance taken by the European Parliament.
Challenges of the current recycling rate
Between 2010 and 2023, the EU’s recycling rate rose only from 10.7 to 11.8 percent. The CEA aims to change this by overcoming regulatory fragmentation, unattractive prices for secondary raw materials, and a lack of transparency.
Approaches
The act aims to harmonize extended producer responsibility (EPR systems) across Europe, modernize waste management (including Waste of Electrical and Electronic Equipment (WEEE) and the Waste Framework Directive), promote the mainstreaming of recycling, and introduce digital tools for reporting and traceability.
Public consultation
On August 1, 2025, the European Commission launched a public consultation and call for evidence on the Circular Economy Act. Companies, NGOs, public authorities, and interested members of the public are invited to contribute their experiences, ideas, and evidence.
- The questionnaire covers around 30 key topics, ranging from e-waste and business models to raw material supply and demand.
- The consultation will run until November 6, 2025.
- Participation is possible via the EU Commission’s “Have Your Say” online portal.
Green Claims Directive – Still in play despite announced withdrawal
The aim of the Green Claims Directive was, and still is, to protect consumers from misleading environmental claims. This is to be achieved through independent verification of statements such as “climate neutral” or “recyclable”.
Background
The European Parliament (March 2024) and the Council of the European Union (June 2024) had adopted positions with which they entered trilogue negotiations, which ran from January to June 2025. However, the final negotiations were then suspended.
Political controversy
On June 20, 2025, the Commission announced that it was withdrawing the proposal for a directive. This decision was prompted by strong pressure from conservative forces and criticism that the directive would place an excessive burden on SMEs. However, a formal withdrawal was never made.
Current status
The process is therefore in limbo but potentially still active. A compromise – especially with exemptions for small and micro-enterprises – could form the basis for a resumption of talks.
Important
The EU legislative package against greenwashing contains two interlocking sets of rules. In addition to the Green Claims Directive, this also includes the EmpCo Directive (“Empowering consumers for the green transition”). Regardless of the current status of the Green Claims Directive, the EmpCo Directive applies and will come into force in September 2026! All companies should check their sustainability communications for content that may then be prohibited. This applies to both on-pack and on websites, etc.
Status of EPR systems in Europe – An overview
Extended producer responsibility (EPR) is a key instrument for promoting the collection, sorting, and recycling of packaging. Our compact overview here is just an appetizer. In the next issue of our BP Consultants newsletter, we will take a more detailed look at all EPR systems.
Fragmented landscape
There are currently numerous, sometimes very different EPR models in the 27 EU member states. Differences include fees, the materials covered, and the responsibilities of those involved.
Status
According to the EU Commission, 10 member states are at risk of missing the 65 percent recycling target by 2025. At the same time, infringement proceedings are underway against all 27 states to enforce compliance with EU requirements.
New tool
An interactive EUROPEN online tool provides the first overview of the current EPR systems in all member states and highlights differences in stakeholders, transparency, and how they work.
Conclusion
Harmonization and investment in infrastructure are crucial to putting Europe on track toward a circular economy. The planned Circular Economy Act offers an opportunity to lay the foundations for this.
Switzerland plans comprehensive packaging reform (VerpV)
Will this become the PPWR in Switzerland? The Federal Council of the Swiss Confederation has sent the Packaging Ordinance (VerpV) out for consultation. The aim is to strengthen the circular economy and reduce the environmental impact of packaging throughout its entire life cycle. It is still a draft, but it is very reminiscent of a slimmed-down version of the PPWR.
General requirements for packaging (Art. 3)
Manufacturers and distributors must ensure that packaging
- is minimally sized (volume and mass),
- is designed for recycling (so that no technical problems or high costs arise during collection and recycling) and
- contains the highest possible proportion of recycled materials.
Flexible plastic packaging: take-back and recycling (Art. 4-6)
The following shall apply to single-use plastic packaging (e.g., flexible film packaging):
- take-back obligation from 2028 if no industry solution exists.
- Take-back must be available during all opening hours.
- The packaging must be recycled as far as technically possible.
- Obligation to provide information on take-back options at points of sale.
- Recycling rate: at least 55 percent.
- If this is not achieved, a deposit requirement or advance disposal fee may be imposed.
Reporting requirements (Art. 21-22)
Manufacturers of products in single-use packaging (other than beverage packaging) must report the following data annually:
- the packaging materials used (by weight),
- for plastic packaging, the types of polymers used (PET, PE, PP, PS, PVC), and
- recycling data (weight taken back and recycled).
- These requirements apply only to companies with a turnover or payroll of more than CHF 1 million that are not subject to a fee for glass packaging in accordance with Art. 7.
Schedule for entry into force
- January 2027: General entry into force.
- January 1, 2028: Take-back obligation for plastic packaging.
- January 1, 2029: Reporting obligation for other single-use packaging.
ZSVR publishes 2025 edition of minimum standard
The Central Agency Packaging Register (ZSVR) has published the 2025 edition of the minimum standard for assessing the recyclability of packaging designs.
- The methodology remains unchanged in the new minimum standard.
- In order to prepare companies for the new requirements of the PPWR at an early stage, the minimum standard has been restructured and the future regulatory system of the PPWR has been integrated.
- Based on this, the packaging categories have been brought to the fore – sorted according to the predominant material of the main packaging component.
- All relevant information on assessing the recyclability of packaging is now bundled in Annex 2.
The current edition of the 2025 minimum standard for assessing the recyclability of packaging designs, along with accompanying practical guidance, is available for download here (pdf).
France introduces PCR modulation
On September 5, 2025, after months of uncertainty, the French government published the long-awaited Arrêté on PCR modulation. It will come into force on January 1, 2026, and is intended to support the use of PCR materials. France is thus sending a strong signal for more circular economy and localized value creation in plastics recycling.
Scope of application
This applies to packaging, printed materials, furniture, electrical appliances, sports and leisure items, gardening and DIY products, and toys, among other things.
Consequences
Producers can have differentiated contributions credited as a bonus on their EPR fees, depending on the quantity and origin of the recycled material used.
Financial incentives
- €450/t for recycled material from another EPR stream
- €550/t for recycled material from the same stream
- €1,000/t for plastics in food packaging that are difficult to recycle
Beverage bottles
Minimum quotas apply to beverage bottles
- for PET: 25 percent PET by the end of 2029 and 30 percent from 2030
- for HDPE: 30 percent from 2030 (which contradicts the PPWR targets)
Lokalisation & borders
- All stages from collection to sorting and recycling to use must take place within a radius of 1,500 km from the geographical center of France and within the EU.
- This includes neighboring countries such as Germany, Italy, and Spain. The Baltic states and Cyprus, for example, are excluded.
Exclusions & Sanctions
There will be no bonus
- for PVC recyclate,
- for recycling rates below 50 percent, or
- if disruptive substances are present.
Status of the revision of the EU Waste Framework Directive
On September 9, 2025, the European Parliament approved the current draft of the Waste Framework Directive.
The aim of the EU Waste Framework Directive is to support the circular economy through better traceability, clear demarcation, and a stronger focus on resources.
Key content
- The basic terms “waste,” “by-product,” and “end-of-waste status” remain in place – with clear legal criteria.
- The revision takes the opportunity to make definitions more precise and introduce new concepts such as “chain of custody mass balance”.
- Food waste reduction: Binding targets have been set for the first time for 2030 (compared to the annual average for 2021-2023):
- 10 percent in processing and manufacturing
- 30 percent per capita in retail, catering, and private households
- EPR regulations for textiles: Manufacturers of textiles and shoes will in future have to pay fees to finance the collection, sorting, and recycling of their products. The contributions will be modulated based on the sustainability and lifespan of the products (eco-modulation).
- Micro-enterprises benefit: Small businesses with fewer than 10 employees will be given an additional 12 months to implement the regulations, i.e., up to 3.5 years after the directive comes into force.
Next steps
- The provisional agreement must still be formally confirmed by Parliament and the Council before it can enter into force.
- The plenary vote has been postponed to October 2025, which is significantly later than originally planned.
- Once adopted, Member States will have 20 months to transpose the regulations into national law.
