Brussels, 05 Oktober 2025 – As part of the European Commission’s stakeholder consultation on the upcoming EU Circular Economy Act (expected in Q3 2026), the PRO Circularity Alliance has submitted its first official policy position. This marks an important milestone for our newly established association and a key moment in shaping the policy conversation on circularity in Europe.

The position paper reflects the shared views of our members – Producer Responsibility Organisations (PROs) from across Europe – and outlines how PROs can contribute to a coherent, effective and implementable framework for advancing circularity at EU level.

While the Act is still in early stages of development, the consultation offers an opportunity to provide input on how product design, reuse systems, waste prevention, and extended producer responsibility (EPR) should be integrated into a broader and more unified circular economy policy.

Our key messages include:

• Reaffirming producer-led PROs: Responsibility must remain with those placing products on the market, within flexible, innovation-driven and transparent governance frameworks.
• Harmonising reporting and data systems: A harmonised or centralised EU-wide register for PROs and producers would improve transparency, reduce duplication, and simplify compliance.
• Promoting fair competition and efficiency: Competitive system structures should be encouraged where they contribute to innovation, cost-efficiency and improved performance.
• Strengthening cross-border cooperation among PROs: Enabling mutual recognition and shared infrastructure can support regional circularity hubs and create economies of scale.
• Integrating new PRO responsibilities: PROs should play a role in R&D, eco-modulation, consumer communication, and coordination with waste operators.
• Anchoring EPR in the EU’s strategic autonomy goals: Efficient PRO systems are vital for securing secondary raw materials and reducing Europe’s reliance on virgin resources.

This is the Alliance’s first major policy contribution – and the starting point for what we hope will become an ongoing dialogue with EU institutions and stakeholders. As the legislative process unfolds, we will continue to advocate for the practical, material-specific expertise of PROs to be recognised and integrated into the EU’s circular transition.

Read the full postion paper here.