VERE submitted its opinion on the EU legislation on the Circular Economy Act on 6 November 2025.
As the "Association for the Take-Back and Recycling of Waste Electrical and Electronic Equipment", VERE is the largest German association of its kind with almost 4,000 members. Since its foundation in 2003, it has been working on behalf of producers, sellers and importers of electrical and electronic equipment and other non-food products to reduce bureaucracy and strengthen the circular economy. As the initiator of take-e-way GmbH, VERE has extensive experience in the development of digital systems for the implementation of environmental obligations.
VERE welcomes the EU Circular Economy Act as an important step towards reducing Europe's dependence on politically questionable trading partners and securing access to secondary raw materials.
However, given that 99 per cent of the companies affected aresmall and medium-sized enterprises, VERE warns against further overregulation that would jeopardise their competitiveness. Instead of creating new laws, the EU should consistently implement existing regulations and oblige member states to enforce them effectively.
Only through the consistent application of measures that have already been adopted can the circular economy function effectively. It is particularly important to meet the target of a 25 per cent recycling rate set out in the Critical Raw Materials Act and to strictly apply the Waste Shipment Regulation in order to keep valuable secondary raw materials within the EU.
At the same time, the public sector in particular should set a good example and create stable demand for recycled materials by taking sustainability criteria and minimum recycled content quotas into account in its procurement.
The European Commission should set clear guidelines for Member States on the control of imported products so that distortions of competition and free riders can finally beeffectively prevented.
VERE rejects a central EU-wide reporting platform for extended producer responsibility, as it does not reflect the actual needs of European producers and sellers, but instead opens the door to the European market wide, especially for distributors based outside the EU, while at the same time weakening national systems, incurring high costs and creating data protection and liability problems.
An overly bureaucratic system cannot be relieved by overlaying it with a digital layer while overly bureaucratic structures continue to prevail underneath.
Instead, VERE advocates gradual harmonisation and digitisation, with EU-wide uniform data standards, standardised interfaces and open-source reference systems to relieve the burden on companies in a targeted, rapid and efficient manner. In the area of product and packaging labelling, VERE advocates pragmatic solutions, as complete EU-wide harmonisation is difficult to implement legally and linguistically due to national differences.
The harmonised labelling of packaging and collection containers provided for in the PPWR is viewed positively. VERE is generally in favour of the digital product passport, but standardised minimum data formats and cross-sector guidelines for labelling are also useful, not least to reduce the administrative burden.
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