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. It has been working to reduce bureaucracy and strengthen the circular economy on behalf of producers, sellers, and importers of electrical and electronic equipment and other non-food products since its establishment in 2003. 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 sees the EU Circular Economy Act as a significant move toward diminishing Europe's reliance on trading partners of dubious political nature and to ensuring access to secondary raw materials.
VERE cautions against additional overregulation that could threaten the competitiveness of small and medium-sized enterprises, noting that they make up 99 per cent of the affected companies. Instead of creating new laws, the EU should consistently implement existing regulations and oblige member states to enforce them effectively.
For the circular economy to function effectively, it is essential that existing measures are applied consistently. In order tokeep valuable secondary raw materials within the EU, it is especially crucial to achieve the 25 per cent recycling rate established by the Critical Raw Materials Act and to strictly enforce the Waste Shipment Regulation.
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.
To effectively prevent competition distortions and free riders, the European Commission ought to establish clear guidelines for member states regarding the regulation of imported products.
VERE rejects the establishment of a central EU-wide reporting platform for Extended Producer Responsibility, arguing that it would weaken national systems, lead to high costs, and create data protection and liability issues by opening the European market to traders from outside the EU.
A system that is excessively bureaucratic cannot be improved simply by adding a digital layer, as long as such structures continue to exist beneath the surface.
Instead, VERE advocates gradual harmonisation and digitisation, with EU-wide consistent data norms, standardised interfaces and open-source reference systems to relieve the burden on companies in a targeted, rapid and efficient manner. VERE promotes practical solutions for product and packaging labelling, as achieving complete EU-wide harmonisation is challenging from both legal and linguistic perspectives 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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