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★Mark us as a preferred sourceBarely three weeks before the European Commission is expected to present its proposal, Europe’s producers and packaging industry have condensed into a single document what they want from the Circular Economy Act (CEA). On 22 October 2026 the European Footwear Confederation (CEC) published a joint statement signed by CEC and 45 other European and national industry associations – from the brand manufacturers’ association AIM, through FoodDrinkEurope and EuroCommerce, to Plastics Europe and the container glass federation FEVE.
The core message is that an EU market for secondary raw materials cannot be built on 27 different national extended producer responsibility (EPR) systems. The signatories therefore want the Circular Economy Act to introduce a directly applicable, horizontal EU EPR regulation. Several of the detailed demands, however, go to the heart of Hungary’s concession-based system – at the very moment the concession itself is under review.
In short: In their joint statement on the Circular Economy Act, CEC and 45 industry associations call for a single EU EPR regulation, producer-led schemes, transparency along the whole waste chain and EPR funds ring-fenced by waste stream. The signatories argue that EU law should not legitimise state-run systems in which producer contributions can be treated as taxation, which bears directly on the Hungarian model.
Who signed it, and why now?
The list of signatories says a lot about whose money the debate is about. Most of the 46 organisations represent packaging: paper and board through Pro Carton, ECMA, CITPA and EPPA; glass through FEVE; metal through Metal Packaging Europe, Steel for Packaging Europe and European Aluminium; plastics and flexible packaging through Plastics Europe, Flexible Packaging Europe, CEFLEX and VinylPlus.
Alongside them are brand owners and retail (AIM, FoodDrinkEurope, EuroCommerce, and the DIY retail association EDRA), plus sectors that already fall, or soon will fall, under EPR: home appliances (APPLiA), textiles and clothing (EURATEX, EBCA), footwear (CEC), furniture (EFIC), toys (TIE), sporting goods (FESI) and paints (CEPE). Seven national organisations also signed – packaging associations from Czechia, Poland, Greece, France, Italy, Finland and the UK – but there is no Hungarian signatory.
CEC’s role is no coincidence. Following the 2025 targeted revision of the Waste Framework Directive, member states must set up mandatory EPR schemes for textile and footwear products by April 2028, bringing the footwear industry under producer responsibility for the first time. How far this goes beyond paperwork is clear from the JRC’s proposed end-of-waste criteria for textiles and footwear, and from the fact that in textile-to-textile recycling finance the targeting of EPR money is precisely the bottleneck.
The timing is straightforward: according to EUWID, the Commission’s provisional timetable puts the presentation of the Circular Economy Act proposal on 11 November 2026. Originally planned for the third quarter, it slipped after the Commission’s Regulatory Scrutiny Board raised concerns about the impact assessment. The statement is therefore a coordinated, last-minute industry message.
Six demands for the Circular Economy Act
The statement sets out the producer side’s requests in six points. The summary below renders the content in our own words.
1. A single, directly applicable EU EPR regulation
The signatories want a horizontal EU EPR regulation that sets a harmonised baseline for EU-mandated EPR schemes and waste streams, complemented by sector-specific rules. They see the legal basis in Article 114 TFEU – internal market harmonisation – with the aim of removing regulatory divergence, ensuring a level playing field and allowing secondary materials to move freely across the Union.
2. Producer-led governance and independent decision-making
According to the statement, EPR works when responsibility, financing and decision-making are aligned. Public authorities would have oversight, but decision-making power would stay with producers. The signatories also say EU law should not legitimise state-run producer responsibility organisations where producer contributions risk being treated as taxation rather than as fees for collection, sorting and recycling services. Decision-making roles should be independent of anyone who directly or indirectly receives EPR funding.
3. Transparency along the entire waste chain
Producer responsibility organisations would publish annual information on their performance, ownership and membership, fee structures, eco-modulation criteria, budget allocation and the use of producer contributions. Transparency would not stop there: public authorities, municipalities and waste management operators receiving EPR funds would also report on how the money was used and what services were delivered. In competitive systems, clearing houses would handle this.
4. Ring-fenced EPR funds and a consistent net cost principle
Fees paid for a product category or waste stream would have to finance the net costs of managing that same category, with no cross-subsidisation. Revenues from selling secondary raw materials and other recovered outputs would be deducted from the costs covered by producers, with safeguards against double counting. The signatories also want EPR money to go first and foremost to collection, sorting and recycling – and not to fund prevention and reuse objectives where dedicated EU sectoral legislation already exists.
5. Less administration
Registration would be harmonised and limited to the essential data needed to verify producer status, drawing on already-verified sources where possible, with detailed product-level data deferred to later reporting stages. For packaging, member states could require authorised representatives only from third-country producers, not from producers established in the EU.
6. Separate collection and public information
No reliable collection means no reliable supply, and no reliable supply means no market for secondary raw materials – that is the logic of the sixth point. Member states’ separate collection obligations would be strengthened where necessary, with regular reporting on coverage and any derogations applied. EPR schemes, together with member states, would co-finance public information campaigns, with regular assessment of their impact.
Producer-led or state-run: the most sensitive point
The sharpest sentence in the statement sits in the second point, and it is not hard to see who the signatories have in mind. A comparative study of all 27 member states’ packaging EPR systems, produced by CIRCPACK by Veolia for EUROPEN and published in June 2026, classified Hungary together with Croatia as state-managed systems in which fees flow into a state fund. That group’s average packaging recycling rate was 47.4 percent; Hungary’s was 42.8 percent (Eurostat, 2023), the second-lowest in the EU.
The picture is, however, more nuanced than “producer-led good, state-run bad”. The same study concluded that performance depends not on the level of fees but on their structure, and not on the governance model as such but on governance quality – clear responsibilities, strong oversight, reliable reporting and traceable financial flows. The authors located the main cause of Hungary’s gap in missing collection and sorting infrastructure rather than in regulation.
It is also worth noting that the producer side has pushed back against state models before: in September 2025, EUROPEN, Cepi, Flexible Packaging Europe and Pro Carton criticised the Polish environment ministry’s plans for a fully state-controlled EPR model. The statement is therefore an attempt to write a general principle into EU law rather than a move against a single member state.
The usual case for a state or concession model is that a single operator can cover the entire country, including unprofitable areas, while public services remain under direct state control. Supporters of producer-led systems argue that where those who pay cannot decide how the money is spent, the incentive for efficiency and better product design weakens. Which way the Commission leans will be one of the key questions of the 11 November proposal.
Ring-fenced money, net costs – and what it would not pay for
The fourth point carries two distinct messages. The first – ring-fencing by waste stream and the net cost principle – is acceptable to almost every stakeholder: it is hard to argue that fees paid for packaging should cover a shortfall in another stream, or that revenue from recovered materials should not reduce the burden on producers.
The second message signals open disagreement. The signatories do not want EPR funds used for prevention and reuse. In February 2026, Zero Waste Europe proposed the opposite: split EPR fees – a waste management fee plus a separate waste reduction fee – along with a transition fund requiring producer responsibility organisations to earmark a mandatory minimum share of their budget for repair and reuse systems. One of the main fault lines of the coming legislation will therefore be whether EPR remains a narrowly defined waste management funding tool or also finances the upper tiers of the waste hierarchy.
It is also worth noting what the statement emphasises less. Eco-modulation appears only among the transparency requirements, qualified with “where applicable” – even though the CIRCPACK study cited above found fee structure, differentiated by material, format and recyclability, to be the strongest driver of performance.
The fifth point could bring changes businesses actually feel. The European Parliament’s October 2026 position – covered in detail in our analysis of EPR simplification for small businesses – would exempt only EU-based small and micro enterprises with fewer than 50 employees and an annual turnover or balance sheet total of up to €10 million from appointing an authorised representative, until 2035 or until the Circular Economy Act is adopted.
The statement goes further: for packaging, no EU-established producer could be required to appoint national representation, regardless of size. In Hungary, Government Decree 80/2023 (III. 14.) makes an authorised representative mandatory only for foreign producers selling through e-commerce, so domestically the change would mainly affect online shops in other member states that ship directly to Hungarian customers. The open question is the same as with the Parliament vote: without a representative, how will authorities identify, invoice and check foreign obligated parties if national registers are not connected?
What does this mean for Hungary’s system?
The statement arrives while the future of Hungary’s own EPR system is open. As we reported in our piece on the waste management concession review, on 8 October twenty-one Hungarian professional organisations – food, beverage and packaging industry associations among them – issued a joint statement calling for transparent costs and revenues, a clear separation of costs by material stream, and meaningful involvement of producer and professional associations in decision-making. By their estimate, the total cost of the 35-year concession could be around HUF 15,000 billion, of which roughly HUF 8,000 billion would be EPR fees at current rates. On 15 October, László Gajdos, Minister for the Living Environment, said that the renegotiation of the concession contract could begin within weeks.
The overlap between the Brussels and Budapest demands is striking. Transparency and separation by material stream are central to both, and both could be delivered within the current concession framework. The difference lies in governance: if the Circular Economy Act made producer-led governance and decision-making independent of fund recipients a binding principle, Hungary’s model – in which the concession company both coordinates the EPR system and receives its funds – would require structural change, not just a contract amendment.
The third point would also directly affect waste management operators. If reporting duties extended to every party receiving EPR funds, that would mean new data obligations for the regional public service providers working as subcontractors within the concession system – even though transparency of financial flows may well be in their own interest. On the collection side, the sixth point is particularly relevant: the CIRCPACK study located the main cause of Hungary’s gap precisely in missing collection and sorting capacity. For where Hungary stands on the latest figures, see our summary of Eurostat’s 2024 packaging waste data.
What the statement leaves out
The title promises a strong EU market for secondary raw materials, but the content is almost entirely about the supply side – financing collection and sorting. Demand-side tools – mandatory recycled content beyond packaging, harmonised end-of-waste rules, green public procurement – barely feature. This is notable because, according to Environment Commissioner Jessika Roswall, the Regulatory Scrutiny Board’s main criticism was that the draft did not sufficiently address the demand side. Our analysis of cross-border waste shipments and recycling also showed that a single market depends not only on EPR rules but on shipment procedures and the actual movement of materials.
Nor are the interests neutral. Producer-led governance means the signatories themselves would decide how the money they pay in is spent, while the independence clause would exclude from decision-making those – waste operators and municipalities – who actually deliver the service. That is a defensible position on conflicts of interest, but it is no accident that waste management and environmental organisations approach the same question with different emphases.
Finally, the signatories would strengthen member states’ separate collection obligations only “where necessary”. That allows flexibility, but leaves open who decides where it is necessary, and by what yardstick.
What happens next?
Under the Commission’s provisional timetable, the proposal could be tabled on 11 November and is expected to address EPR harmonisation, waste classification and definitions, and end-of-waste rules. Parliament and Council will then have to form their positions, so the final text will be settled at the end of the legislative process. In parallel, the trilogue on the Environmental Omnibus provisions on authorised representatives is under way, and the 2028 deadline for textile and footwear EPR is approaching.
In our assessment, the statement’s harmonisation logic is convincing: 27 different rulebooks are a real barrier to a single market for secondary raw materials, and transparency and ring-fencing by material stream are demands that Hungarian professional organisations have made too. The debate over producer-led governance, however, is not technical but a question of power – of who decides how producer contributions are spent, which in Hungary alone are estimated at around HUF 8,000 billion over the life of the concession. For Hungary the stakes are twofold: renegotiating the concession now can either create a framework that fits the emerging EU rules or make yet another overhaul necessary within a few years.
FAQ – the Circular Economy Act and the joint industry EPR statement
What do CEC and 45 industry associations want from the Circular Economy Act?
They want a single, directly applicable EU EPR regulation based on the internal market legal basis, Article 114 TFEU. They also call for producer-led schemes, transparency along the whole waste chain, EPR funds ring-fenced by waste stream, simpler registration and stronger separate collection obligations, so that a genuine EU market for secondary raw materials can emerge.
When will the European Commission present the Circular Economy Act proposal?
Under the Commission’s provisional timetable, on 11 November 2026. Originally planned for the third quarter, the proposal slipped after the Commission’s Regulatory Scrutiny Board raised concerns about the impact assessment. Parliament and Council will then negotiate it, so the final text will only be settled at the end of the legislative process.
Why does the statement matter for Hungary’s EPR system?
Because the signatories argue that EU law should not legitimise state-run systems where producer contributions can be treated as taxation, and that decision-making must be independent of those receiving EPR funds. The CIRCPACK study classified Hungary as a state-managed system, while the review and renegotiation of the Hungarian waste concession are currently under way.
What does ring-fencing EPR funds mean?
It means fees paid for a product category or waste stream could only finance the net management costs of that same category, without cross-subsidisation. Revenues from selling secondary raw materials would be deducted from those net costs. The signatories also oppose using EPR money for prevention and reuse objectives where dedicated EU sectoral legislation already exists.
What would change for authorised representatives?
Under the statement, for packaging member states could require authorised representatives only from third-country producers, not from EU-established ones. That goes further than the European Parliament’s October 2026 position, which would exempt only EU small businesses with fewer than 50 staff and up to €10 million turnover, until 2035 or until the Circular Economy Act is adopted.
🔗 Official sources and references: 👉
- European Footwear Confederation (CEC): A Circular Economy Act delivering a strong EU market for secondary raw materials (22 October 2026)
- Full text of the joint statement: A Circular Economy Act delivering a strong EU market for secondary raw materials (PDF) (October 2026)
- EUWID Recycling and Waste Management: Circular Economy Act proposal expected on 11 November
- EUROPEN: New study shows what must be fixed to close Europe’s recycling gap (CIRCPACK by Veolia, 18 June 2026)
- Packaging Europe: Report urges EU to close national EPR gaps via Circular Economy Act
- Packaging Europe: Circpack and SAP collaborate on EPR reporting and recyclability assessment service (on industry criticism of Poland’s state EPR model)
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