Ms. Ursula von der Leyen
President of the European Commission
Rue de la Loi 200, 1049, Brussels, Belgium
Cc:
Ms. Teresa Ribera, Executive Vice-President for a Clean, Just and Competitive Transition
Mr. Stéphane Séjourné, Executive Vice-President for Prosperity and Industrial Strategy
Ms. Jessika Roswall, Commissioner for Environment, Water Resilience and a Competitive Circular Economy

Dear President Von der Leyen,

The Circular Economy Act (CEA) represents the key opportunity to establish a genuine Single Market for
secondary raw materials [1] and address structural barriers. To deliver on the EU’s circularity ambitions, the
CEA must place stronger and more predictable demand for recycled materials at the centre of its framework
through robust and harmonised demand-side measures.

The undersigned organisations call on the European Commission to prioritise:

• Financial support for the incorporation of recycled materials in new products through
  Extended Producer Responsibility (EPR) eco-modulation;

• A level playing field that promotes the uptake of European recycled materials and strengthens
  Europe’s circular value chains.

The CEA should establish a coherent framework to stimulate the uptake of recycled materials produced
and processed in Europe. This should include harmonised minimum eco-modulation criteria within EPR
schemes that incentivise the use of European recyclates. It should also strengthen the integration of
circularity criteria into Green Public Procurement (GPP), including procurement criteria that prioritise
European recycled content in purchasing decisions. Similarly, the Green VAT initiative should be expanded
beyond second-hand products by introducing reduced VAT rates for products containing recycled content
and support for recycling activities.

These measures are urgently needed. Demand for European secondary raw materials is weakening, while
recyclers face increasing pressure from volatile prices, high operating costs, and low-cost imports of virgin
and recycled materials from third countries. Without stronger market incentives, investment in Europe’s
recycling capacity and circular value chains will remain at risk[2].

By creating strong and predictable market signals, the EU can unlock investment, strengthen domestic
recycling capacity, increase resource resilience, and accelerate progress towards resource independency
in the current geopolitical context. The undersigned organisations, therefore, urge the European
Commission to ensure that the CEA delivers a robust and coherent set of demand-side measures that
place recycled materials at the centre of Europe’s circular transition.

Sincerely,

The undersigned organisations:

[1] The Clean Industrial Deal: A joint roadmap for competitiveness and decarbonisation, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions.

[2] Plastics Value Chain Demands Immediate Action to Save EU Industry, Plastics Recyclers Europe.