Analysis & Commentary · Circular economy

The EU Circular Economy Act — and is there a UK one?

The EU Circular Economy Act is a European Commission proposal expected in Q3 2026, aiming to double the bloc’s circular material use rate to 24% by 2030 — and it reaches UK exporters through market access, not UK law.

There is no single UK statute of that name: England, Scotland and Wales each legislate separately.

This page covers the EU proposal, the nation-by-nation disambiguation, and the UK instruments that actually bind businesses today.

Updated 28 July 2026 · Independent analysis · SRS Report
Q3 2026
EU Circular Economy Act — Commission proposal expected
EU [1]
24% by 2030
EU circular material use target (from ~12%)
EU [1]
None
UK statutes named "Circular Economy Act"
legislation.gov.uk [3]
£223.69/t
Plastic Packaging Tax rate from 1 Apr 2025
HMRC [7]
The EU proposal

The EU Circular Economy Act

The EU Circular Economy Act is a forthcoming European Commission legislative proposal, expected in Q3 2026, and a pillar of the Commission’s Clean Industrial Deal[1].

Its headline goal is to double the EU’s circular material use rate to 24% by 2030 (from around 12% today) and to build a single market for secondary raw materials[1].

It works through three pillars: amending the Waste Framework and Landfill Directives, amending the WEEE Directive, and additional flanking measures still being scoped[2].

A call for evidence ran from August 2025, and phased sector implementation has been signalled from 2028[2].

The Act’s UK relevance is about market access, not UK law: it applies to products placed on the EU market regardless of where they are manufactured, so a UK business exporting into the EU will need to meet its requirements even though the UK is not bound by EU legislation[1].

Our read: this is the proposal to watch if your supply chain touches the EU. It is not yet law — the Commission has not published legislative text — but a Q3 2026 proposal with an 8-year run to the 2030 target gives exporters a genuine planning window, unlike England’s Growth Plan, which is already overdue.
Disambiguation

Is there a UK Circular Economy Act?

No.

There is no single UK statute called the “Circular Economy Act” — and, unlike the EU proposal above, each UK nation legislates on this separately[3].

The UK's circular-economy instruments, nation by nation
NationInstrumentStatus
EnglandCircular Economy Growth PlanUnpublished as of July 2026 — see our dedicated page
ScotlandCircular Economy (Scotland) Act 2024Enacted — a real "Act", but Scotland-only
Wales"Beyond Recycling" strategyPublished strategy, not an Act
UK-wideEnvironment Act 2021Framework powers for EPR and deposit schemes — see below

For the full story on England’s overdue plan — the taskforce behind it, the delay, and what businesses should prepare now — see our Circular Economy Growth Plan explainer.

Scotland’s 2024 Act and Wales’s Beyond Recycling strategy are each their own devolved instrument[4][5] — never blur them into a single “UK act”.

The UK framework

The Environment Act 2021 and what it enables

The Environment Act 2021 is the closest thing the UK has to a circular-economy framework law, and it applies UK-wide rather than to one nation.

Rather than setting detailed rules itself, it grants powers that ministers then use through regulations[3].

Two of those powers matter most.

The Act allows the government to make producers responsible for the costs of managing the packaging they place on the market — the legal basis for extended producer responsibility — and to establish a deposit return scheme for drinks containers[3].

It also underpins resource-efficiency and eco-design requirements, and consistent recycling collections in England.

The practical effect is that the detail arrives through statutory instruments, not through a single headline Act.

The Environment Act 2021 and the measures it enables
PowerWhat it enablesStatus (July 2026)
Producer responsibilityExtended producer responsibility for packaging (pEPR)Live — fees from Oct 2025
Deposit schemesDeposit Return Scheme for drinks containersPlanned start 1 Oct 2027
Resource efficiencyEco-design and recyclability requirementsDeveloping through the Growth Plan
Recycling collectionsConsistent household and business recycling in EnglandHouseholds from March 2026
The live obligation

Extended producer responsibility for packaging

Extended producer responsibility (EPR) shifts the cost of managing packaging waste from local authorities to the businesses that place packaging on the market.

The UK packaging EPR scheme — pEPR — is the single most significant live circular-economy obligation for most companies.

The scheme administrator, PackUK, published the confirmed 2025 base fees on 27 June 2025, and the first invoices to producers were issued from October 2025[6].

Fees are charged per tonne of household packaging placed on the market, and vary by material — from glass at the lower end to fibre-based composites at the higher end[6].

From the 2026–27 assessment year, fees will be modulated by recyclability, so packaging that is harder to recycle will cost more.

Selected confirmed 2025 packaging EPR base fees (£ per tonne)
MaterialBase fee 2025–26Direction of travel
Glass£192Lowest of the main materials
Paper and card£196Below plastic
Steel£259Mid-range
Plastic£423High — modulation will widen the gap
Fibre-based composite£461Highest in the published set
Note: these rates apply to household packaging placed on the market and are recovered from obligated producers. They are not a tax on consumers, and they sit alongside — not instead of — the Plastic Packaging Tax described next.
The fiscal lever

The Plastic Packaging Tax

The Plastic Packaging Tax is a separate instrument, run by HMRC rather than DEFRA.

It targets plastic packaging that contains less than 30% recycled content, creating a financial incentive to design in recycled material.

The rate is £223.69 per tonne from 1 April 2025, having risen each year from £200 per tonne when the tax began in 2022[7].

From 1 April 2026 the rate rises again to £228.82 per tonne, uprated in line with CPI inflation[9].

Registration is triggered by volume, not by liability: a business must register if it manufactures or imports 10 tonnes or more of finished plastic packaging in a 12-month rolling period, even where all of it meets the 30% recycled threshold and no tax is due[7].

Plastic Packaging Tax — key thresholds and rates
ParameterValueSource basis
Rate (2025–26)£223.69 per tonneHMRC PPT statistics
Rate (from 1 Apr 2026)£228.82 per tonneAutumn Budget 2025 (CPI uprating)
Recycled-content thresholdLess than 30% recycled plasticHMRC guidance
Registration threshold10 tonnes in 12 monthsHMRC guidance
Coming next

The Deposit Return Scheme

The deposit return scheme (DRS) adds a refundable deposit to in-scope drinks containers, reclaimed when the empty is returned.

All four UK nations plan to start their schemes on 1 October 2027[8].

In England, Scotland and Northern Ireland the scheme will cover single-use containers between 150ml and 3 litres made from PET plastic, steel and aluminium — but not glass[8].

Wales plans to include glass on a different basis.

A flat 20p deposit has been confirmed for England, Scotland and Northern Ireland.

The legal powers come from the Environment Act 2021, with Scotland relying on the Climate Change (Scotland) Act 2009[8].

England’s instrument

England’s Circular Economy Growth Plan

England has not consolidated its circular-economy measures into one Act, but it is building a plan.

An independent Circular Economy Taskforce, chaired by Andrew Morlet, was established in late 2024 to co-design what is now called the Circular Economy Growth Plan — formerly the “circular economy strategy”[10].

The taskforce has focused on priority sectors including agri-food, construction, chemicals, electronics, textiles and transport[10].

The Growth Plan remains unpublished as of July 2026 — a GOV.UK milestone once said “early 2026”, over 50 businesses wrote to DEFRA urging publication in May 2026, and DEFRA says only “soon”. For the delay history, what the plan is expected to cover, and the policy context businesses can act on now, see our dedicated Circular Economy Growth Plan page.

It is policy, not statute: when published it will shape future regulations rather than itself create a single Circular Economy Act — that distinction is exactly why the EU’s proposal, above, and England’s plan should not be conflated.

Common questions

Circular economy law: frequently asked questions

What is the EU Circular Economy Act?

The EU Circular Economy Act is a European Commission legislative proposal expected in Q3 2026, forming a pillar of the Clean Industrial Deal. It aims to double the EU’s circular material use rate to 24% by 2030 (from around 12% today) and build a single market for secondary raw materials, through three pillars: amending the Waste Framework and Landfill Directives, amending the WEEE Directive, and additional flanking measures. A call for evidence ran from August 2025. Because it governs products placed on the EU market regardless of where they are made, it has direct relevance for UK businesses exporting to the EU.

Is there a UK Circular Economy Act?

No — there is no single UK statute called the "Circular Economy Act". England’s equivalent instrument is the forthcoming Circular Economy Growth Plan, still unpublished as of July 2026. Scotland has its own Circular Economy (Scotland) Act 2024. Wales’s strategy is called "Beyond Recycling" rather than an Act. Each nation’s circular-economy obligations otherwise sit inside the Environment Act 2021 (a UK-wide framework law), the packaging EPR scheme, the Plastic Packaging Tax and the Deposit Return Scheme.

What law makes producers responsible for packaging waste?

The Environment Act 2021 gives ministers the power to introduce extended producer responsibility (EPR). The packaging EPR scheme (pEPR) is now operating: the scheme administrator, PackUK, published the confirmed 2025 base fees on 27 June 2025, and the first invoices to producers were issued from October 2025. Fees are charged per tonne of household packaging placed on the market, by material.

How much is the Plastic Packaging Tax?

The Plastic Packaging Tax applies to plastic packaging containing less than 30% recycled content. The rate is £223.69 per tonne from 1 April 2025, rising to £228.82 per tonne from 1 April 2026 (uprated by CPI). A business must register if it manufactures or imports 10 tonnes or more of finished plastic packaging in a 12-month period, even if no tax is ultimately due.

When does the Deposit Return Scheme start?

All four UK nations plan to start a deposit return scheme (DRS) for drinks containers on 1 October 2027, using powers under the Environment Act 2021 (and, in Scotland, the Climate Change (Scotland) Act 2009). England, Scotland and Northern Ireland will cover single-use PET plastic, steel and aluminium containers between 150ml and 3 litres — but not glass. A flat 20p deposit has been confirmed for England, Scotland and Northern Ireland.

How does circular-economy policy connect to sustainability reporting?

Circular-economy measures cut waste and resource use, which feeds directly into climate and sustainability disclosures. Resource efficiency, packaging and waste data increasingly appear in ESG and climate reporting, and the UK Sustainability Reporting Standards bring resource use and circularity into formal disclosure for in-scope companies. The two agendas — circular economy and sustainability reporting — are converging.

Related analysis
Circular Economy Growth PlanEngland’s still-unpublished plan: the taskforce, the delay, and what to watch for.Circular economy theoryThe principles behind EPR, deposit schemes and the design-out-waste agenda.Circular economy consultancyWhere outside help earns its place on packaging fees, recycled content and waste data.
Sources & primary references
  1. EU circular economy strategy European Commission · EU Circular Economy Act proposal expected Q3 2026; 24% circular material use target by 2030; three pillars
  2. The EU Circular Economy Act (EPRS briefing 782628) European Parliamentary Research Service · Clean Industrial Deal pillar; Waste Framework/Landfill/WEEE Directive amendments; call for evidence Aug 2025
  3. Environment Act 2021 legislation.gov.uk · Powers for resource efficiency, EPR (Schedule 4) and deposit schemes (Schedule 8)
  4. Circular Economy (Scotland) Act 2024 legislation.gov.uk · Scotland’s own circular-economy statute — distinct from England’s Growth Plan
  5. Beyond Recycling — a strategy to make the circular economy in Wales a reality Welsh Government · Wales’s circular-economy strategy, distinct from an "Act"
  6. Extended Producer Responsibility for Packaging: 2025 base fees GOV.UK / DEFRA / PackUK · Confirmed base fees published 27 Jun 2025; first invoices from October 2025
  7. Plastic Packaging Tax (PPT) statistics: background and references GOV.UK / HMRC · £223.69 per tonne from 1 Apr 2025; less than 30% recycled content; 10-tonne threshold
  8. Deposit return schemes (research briefing CBP-10453) House of Commons Library · DRS start 1 Oct 2027; PET, steel and aluminium 150ml–3L; powers under Environment Act 2021
  9. Circular Economy Taskforce GOV.UK / DEFRA · Established late 2024 (chair Andrew Morlet) to co-design England’s Circular Economy Growth Plan
  10. Plastic Packaging Tax: Budget 2025 rate change GOV.UK / HMRC (Autumn Budget 2025) · Rate rises to £228.82 per tonne from 1 Apr 2026, uprated by CPI
Book a free consultation