The European Union has positioned itself as the global leader in circular economy regulation, implementing one of the most comprehensive legislative frameworks for sustainable production and consumption worldwide. For global companies manufacturing or selling products in the EU market, understanding these regulations is no longer optional but a fundamental business imperative. The EU's circular economy regulations affect virtually every product category, from electronics and textiles to packaging and construction materials, creating both significant compliance obligations and substantial market opportunities for businesses that adapt successfully.
The regulatory landscape has evolved rapidly since the adoption of the second Circular Economy Action Plan in March 2020, with major legislation entering into force throughout 2023, 2024, and early 2025. The Ecodesign for Sustainable Products Regulation entered into force in July 2024, the Batteries Regulation came into effect in August 2023, and most recently, the Packaging and Packaging Waste Regulation entered into force in February 2025. These regulations are not merely environmental requirements but strategic economic instruments designed to reduce Europe's dependency on primary raw materials, strengthen the internal market for secondary materials, and position the EU as a competitive, resource-efficient economy.
This comprehensive analysis examines the key EU circular economy regulations that global companies must navigate, including specific compliance requirements, implementation timelines, and the business implications of these transformative policies.
The EU Circular Economy Action Plan Framework and Strategic Objectives
The EU Circular Economy Action Plan, adopted in March 2020, serves as the overarching strategic framework guiding Europe's transition from a linear "take, make, dispose" economy to a circular model where resources remain in productive use for as long as possible. The action plan is described by the European Commission as one of the main building blocks of the European Green Deal, Europe's agenda for sustainable growth that aims to make the continent climate-neutral by 2050.
The strategic objectives underlying the circular economy framework are threefold. First, the regulations aim to embed circularity throughout product lifecycles by impacting manufacturing processes, extending product durability and reparability, and ensuring materials remain in productive circulation rather than becoming waste. Second, the framework targets key value chains where environmental gains are greatest and regulatory clarity is required to drive investment, including packaging, batteries, electronics, textiles, and construction. Third, the regulations strengthen EU strategic autonomy by reducing dependency on primary raw materials from outside the bloc, fostering resilient secondary markets, and promoting Europe-wide synergies in research, innovation, and standard-setting.
The implementation progress has been substantial. All 54 actions under the initial circular economy action plan have been delivered or are being implemented. Most legal acts foreseen under the second Circular Economy Action Plan have been adopted and entered into force. Looking ahead, the European Commission launched a public consultation in August 2025 on the upcoming Circular Economy Act, which will build on the second Circular Economy Action Plan by reinforcing and broadening its measures to accelerate Europe's shift to a resource-efficient, low-waste, and climate-neutral economy.
The EU has set an ambitious target to double its circularity rate from approximately 12% in 2023 to 24% by 2030. This target is part of the EU's Clean Industrial Deal and represents a significant acceleration in the pace of circular economy adoption across member states.
EU Circular Economy Action Plan Implementation Status (2020-2025)
| Legislative Initiative | Adoption Date | Entry Into Force | Status |
|---|---|---|---|
| Batteries Regulation | July 2023 | August 2023 | Implemented |
| Ecodesign for Sustainable Products Regulation (ESPR) | June 2024 | July 2024 | Implemented |
| Packaging and Packaging Waste Regulation (PPWR) | December 2024 | February 2025 | Implemented |
| Waste Shipments Regulation | April 2024 | May 2024 | Implemented |
| Industrial Emissions Directive (IED 2.0) | 2024 | August 2024 | Implemented |
| Right to Repair Directive | 2024 | July 2024 | Implemented |
| Empowering Consumers Directive | March 2024 | March 2024 | Implemented |
Ecodesign for Sustainable Products Regulation (ESPR) Requirements and Compliance
The Ecodesign for Sustainable Products Regulation, which entered into force on July 18, 2024, represents perhaps the most far-reaching product sustainability regulation in global commerce. The ESPR is described by the European Commission as the cornerstone of its approach to more environmentally sustainable and circular products, and it fundamentally transforms how products must be designed, manufactured, and marketed within the European Union.
The ESPR replaces the previous Ecodesign Directive from 2009, which applied only to energy-related products. The new regulation extends this scope dramatically to cover virtually all physical products placed on the EU market, including components, intermediary products, and integrated digital content. Only a few product categories are exempt, including food and feed, medicinal products, and certain products where ecodesign requirements are not suitable or necessary to contribute to sustainability.
The regulation establishes a framework for setting ecodesign requirements on specific product groups through delegated acts adopted by the European Commission. These requirements can be developed vertically for specific product groups or horizontally across broader categories that share similar technical characteristics. The ESPR enables the setting of both performance requirements, which establish quantitative or qualitative requirements on products to achieve certain performance levels, and information requirements, which mandate disclosure of sustainability data to consumers and authorities.
ESPR Product Priorities and Implementation Timeline
The European Commission must adopt a working plan by April 19, 2025, outlining how to implement the ESPR. This working plan will identify priority products for setting ecodesign requirements and estimated timelines for adoption. Eleven product groups have been prioritized in the first working plan: iron and steel, aluminum, textiles, furniture, tires, detergents, paints, lubricants, and chemicals.
The first ESPR delegated act establishing specific product requirements is expected at the earliest in 2026 for textiles and steel, with a minimum transition period of 18 months before becoming effective. This means the first product-specific ecodesign requirements will likely apply around 2027 to 2028. Additional products from the 2022-2024 Ecodesign and Energy Labelling Working Plan, which already covered 35 products, will continue to be developed, with 19 energy-related products carrying over into ESPR implementation.
The regulation addresses approximately 20 potential product parameters that ecodesign requirements can target, including durability, reusability, upgradability, repairability, energy efficiency, recyclability, presence of substances inhibiting circularity, recycled content, carbon footprint, and environmental footprint. This comprehensive approach allows the Commission to set requirements tailored to the specific environmental impacts and improvement opportunities for each product category.
ESPR Key Compliance Deadlines for Businesses
| Requirement | Deadline | Applicable To |
|---|---|---|
| ESPR Entry Into Force | July 18, 2024 | Framework regulation effective |
| First Working Plan Publication | April 19, 2025 | Identifies priority products |
| Digital Product Passport Registry Operational | July 19, 2026 | All in-scope products eventually |
| Prohibition on Destroying Unsold Consumer Products (Large Enterprises) | July 19, 2026 | Major enterprises |
| First Delegated Acts (Product-Specific Requirements) | 2026-2027 | Textiles, steel, iron, aluminum |
| Effective Application of First Product Requirements | 2027-2028 | First priority products |
| Prohibition on Destroying Unsold Consumer Products (Medium Enterprises) | July 19, 2030 | Medium-sized enterprises |
Digital Product Passport and Information Transparency Requirements
A central innovation within the ESPR is the Digital Product Passport, a digital identity card for products, components, and materials that stores relevant information to support sustainability, promote circularity, and strengthen legal compliance. The DPP will be technologically neutral, meaning there is no prescribed method for compliance, but it must make product sustainability information accessible to consumers, supply chain actors, and regulatory authorities.
The DPP information can include a unique product identifier, Global Trade Identification Number, user manuals, EU declarations of conformity, technical documentation, and information for consumers and other operators on product maintenance and repair. The specific information required in the DPP will be specified in delegated acts for each product group, following a product category approach.
The DPP information will be stored in a central DPP registry with a searchable web portal accessible to consumers and authorities. This registry must be operational by July 19, 2026, though product-specific DPP requirements will phase in as delegated acts are adopted for individual product categories.
EU Packaging and Packaging Waste Regulation (PPWR) Mandates
The Packaging and Packaging Waste Regulation entered into force on February 11, 2025, replacing the previous Packaging Directive from 1994. The PPWR represents a fundamental transformation in how packaging is regulated across the European Union, establishing directly applicable requirements that harmonize national measures and create a unified legal framework for all 27 member states.
The regulation's objectives are ambitious: make all packaging on the EU market recyclable in an economically viable way by 2030, safely increase the use of recycled plastics in packaging, decrease the use of virgin materials, and put the packaging sector on track to climate neutrality by 2050. The regulation establishes a new set of requirements covering the entire packaging lifecycle from product design to waste handling, with implementation timelines stretching through 2040.
The PPWR applies to all packaging placed on the EU market, even if produced, supplied, or sold from outside the EU. This means non-EU companies shipping directly to EU consumers must comply with the regulation's requirements, including appointing an authorized representative within the European Union. The regime imposes obligations on manufacturers of both packaging and packaged products, suppliers, importers, distributors, authorized representatives, and fulfilment service providers.
PPWR Recyclability and Design Requirements
The regulation establishes a phased approach to recyclability requirements. By 2030, all packaging placed into the EU market must be designed for recycling. By 2035, packaging must be recycled at scale, meaning it must be collected, sorted, and processed by real-world infrastructure rather than just theoretically recyclable.
To support implementation, the European Commission must adopt delegated acts by January 1, 2028, setting Design for Recyclability criteria and recyclability performance grades. The legislation introduces recyclability performance criteria in Annex II, establishing grades A through E. From January 1, 2030, only packaging graded A, B, or C may be marketed in the EU. This restriction tightens further by January 1, 2038, when only grades A and B will be permitted, effectively phasing out all lower-performing packaging.
The PPWR also mandates that packaging be designed with minimal materials and dimensions necessary for functionality. Packaging structures like double walls, false bottoms, and unnecessary layers that increase the perception of volume will be banned. Empty space in e-commerce parcels must not exceed 40% unless technically unavoidable. These requirements push companies toward light-weighting and refill packaging opportunities to meet compliance obligations.
Mandatory Recycled Content Requirements for Plastic Packaging
One of the most significant compliance challenges in the PPWR involves mandatory minimum percentages of post-consumer recycled content in plastic packaging. These requirements vary by packaging type and implementation date, with targets increasing between 2030 and 2040.
For contact-sensitive PET packaging, which includes food packaging other than PET single-use beverage bottles, minimum recycled content must reach 30% by 2030 and increase to 50% by 2040. Contact-sensitive plastic packaging other than PET must contain a minimum of 10% recycled content by 2030 and 25% by 2040. PET single-use beverage bottles face even stricter requirements under existing legislation.
The regulation provides an exemption for healthcare and other sensitive uses where safety and product integrity must be prioritized over the use of recycled content. This exemption is currently in place indefinitely. Packaging exempted from recycled content requirements also includes compostable packaging and any plastic part representing less than 5% of the total weight of the whole packaging unit.
To support compliance, the European Commission must establish harmonized methods to measure recycled content and provide clarification on mass balance approaches for chemically recycled content. These methodologies are critical for companies to verify compliance and for authorities to conduct enforcement.
PPWR Recycled Content Targets by Packaging Category
| Packaging Category | 2030 Minimum Recycled Content | 2040 Minimum Recycled Content | Exemptions |
|---|---|---|---|
| Contact-Sensitive PET (excluding beverage bottles) | 30% | 50% | Healthcare, parts <5% of total weight |
| Contact-Sensitive Non-PET Plastics | 10% | 25% | Healthcare, parts <5% of total weight |
| Non-Contact-Sensitive Packaging | 35% | 65% | Parts <5% of total weight |
| PET Beverage Bottles (existing rules) | 25% | Not specified under PPWR | Medical packaging |
Reuse Systems and Waste Reduction Targets
The PPWR sets binding reuse targets for various types of packaging, fundamentally shifting the packaging industry toward reusable systems. Some beverage categories will require a minimum of 10% reusable packaging by 2030, increasing to 40% by 2040. For transport packaging, 40% of packaging used for transporting products within the EU must be reusable by 2030, escalating to 70% by 2040.
Grouped packaging in the form of boxes must achieve 10% reusability within a reuse system by 2030, increasing to 25% by 2040. These requirements create significant obligations for companies to develop and implement take-back systems, cleaning infrastructure, and reverse logistics capabilities to support reusable packaging models.
For e-commerce specifically, online sellers must offer a reusable shipping option at checkout from 2030 onward. This alternative must be presented clearly and cannot be made less attractive than single-use options through pricing, presentation, or convenience differences. This requirement applies to online marketplaces, direct-to-consumer brands, and companies involved in distributing packaged goods through digital channels.
Hazardous Substance Restrictions and Labeling Requirements
The PPWR prohibits food-contact packaging containing per- and polyfluoroalkyl substances above specified concentration limits from being placed on the EU market effective August 12, 2026. The limit values are 25 parts per billion for any single PFAS as measured with targeted analysis and 250 ppb for the sum of PFAS measured as the sum of targeted analysis. These restrictions address the presence of harmful "forever chemicals" that persist in the environment and present potential health risks.
The regulation maintains existing heavy metal restrictions for lead, cadmium, mercury, and hexavalent chromium, with a combined concentration limit of 100 mg/kg for all four heavy metals in packaging or packaging components. By December 31, 2026, the European Commission, assisted by the European Chemicals Agency, must prepare a report on substances of concern in packaging to determine their impact on reuse and recycling and potential health risks.
From 2028, the PPWR introduces harmonized labeling requirements to make it easier for consumers to sort waste correctly and combat misleading environmental claims. All packaging will require labels showing material composition and clearly identifying which parts can be recycled in which waste stream. The European Commission is developing standardized pictograms that will appear on both packaging and corresponding waste bins to create consistent sorting guidance across all member states.
EU Batteries Regulation and Supply Chain Traceability
The EU Batteries Regulation came into force in August 2023, repealing and replacing the prior Batteries Directive. The regulation applies to all battery types sold in the EU, including portable batteries, industrial batteries, electric vehicle batteries, light means of transport batteries, and starting, lighting, and ignition batteries, regardless of their origin. It introduces obligations on all manufacturers, producers, importers, and distributors throughout the battery value chain.
The Batteries Regulation will be phased in with key deadlines spanning 2024 to 2036, depending on the types of obligations, battery categories, and economic operators involved. The regulation aims to ensure that batteries placed on the EU market are sustainable and circular throughout their whole life cycle, from production through end-of-life management.
Critical requirements include carbon footprint declarations for electric vehicle and rechargeable industrial batteries, mandatory minimum levels of recycled content in battery manufacturing, due diligence requirements for raw material sourcing, and performance and durability requirements to extend battery lifespan. The regulation also establishes collection targets, with portable batteries required to achieve 45% collection rates by 2023, increasing to 63% by 2027 and 73% by 2030.
Battery producers must establish extended producer responsibility schemes covering the costs of collection, treatment, and recycling. Recycling efficiency targets vary by battery chemistry, with lithium-ion batteries required to achieve 65% recycling efficiency by 2025, increasing to 70% by 2030. Material recovery targets specify minimum percentages for cobalt, copper, lead, lithium, and nickel that must be recovered from waste batteries.
Digital Battery Passport and Traceability Requirements
Similar to the ESPR's Digital Product Passport, the Batteries Regulation introduces a Digital Battery Passport requirement for electric vehicle batteries, light means of transport batteries, and rechargeable industrial batteries with capacity above 2 kWh. The battery passport must contain information about the battery's manufacturing, composition, carbon footprint, supply chain, and performance characteristics.
The battery passport must be made available through an electronic data carrier, such as a QR code, that provides access to information stored in a centralized database. Required information includes battery model identification, manufacturer information, manufacturing place and date, battery status and expected lifetime, composition including hazardous substances, carbon footprint, and information on supply chain due diligence for raw materials.
These requirements create transparency obligations throughout battery supply chains, requiring manufacturers to collect and verify information from upstream suppliers about raw material sourcing, processing, and environmental performance. For global companies manufacturing or selling batteries in the EU market, establishing systems to collect, validate, and report this information represents a significant compliance undertaking.
Extended Producer Responsibility and Circular Business Model Requirements
Extended Producer Responsibility schemes represent a cornerstone of EU circular economy policy, shifting end-of-life management costs from municipalities and taxpayers to producers. EPR programs create economic incentives for recyclability in product design while funding the collection and processing infrastructure necessary to capture and recycle products at end-of-life.
The PPWR expands EPR requirements significantly, mandating that member states establish extended producer responsibility schemes for packaging by 2030 with eco-modulation of fees. Eco-modulated fees correlate EPR costs with recyclability performance grades, meaning packaging with better recyclability grades A and B will face lower producer responsibility fees compared to lower-performing grades C, D, and E.
While individual EU countries will set specific fee levels, the regulation establishes the framework requiring that fees reflect true end-of-life costs and incentivize circular design. Producers that place packaging on the EU market must cover the costs of collection, sorting, and recycling through EPR schemes established by each member state. This requirement applies regardless of company size, with no general exemption for micro or small enterprises.
A 2025 amendment to the Waste Framework Directive established a specific EPR regime for textiles, requiring that producers making textiles available in the EU cover the costs of collection, sorting, and recycling through new schemes to be established by each member state. These textile EPR systems aim to address fast fashion, improve separate collection and recycling, and ensure producers take greater responsibility for the lifecycle impacts of their products.
EU Extended Producer Responsibility Implementation by Product Category
| Product Category | EPR Status | Key Requirements | Implementation Timeline |
|---|---|---|---|
| Packaging | Implemented | Cover collection, sorting, recycling costs; eco-modulated fees | Eco-modulation by 2030 |
| Batteries | Implemented | Collection targets, recycling efficiency, material recovery | Phased 2024-2036 |
| Textiles | Implementing | Collection, sorting, recycling costs; address fast fashion | Member state schemes by 2025-2026 |
| Electronics (WEEE) | Implemented | Collection targets, recovery rates, financing obligations | Existing directive requirements |
| Vehicles | Under revision | New regulation proposed 2023; enhanced circularity requirements | Expected 2025-2026 |
Right to Repair and Consumer Empowerment Regulations
The Directive on repair of goods, establishing the "right to repair," entered into force in July 2024, fundamentally changing consumer rights around product maintenance and repair. The directive aims to make it easier and cheaper for consumers to repair products instead of purchasing replacements, addressing planned obsolescence and extending product lifecycles.
The right to repair legislation establishes several key consumer protections. Manufacturers must make spare parts available for reasonable prices for specified periods after product purchase. Repair information, including technical documentation and diagnostic tools, must be provided to professional repairers and, in some cases, to consumers themselves. Products must be designed to facilitate repair, with common tools sufficient for disassembly and component replacement.
The Directive empowering consumers for the green transition, adopted in March 2024, complements the right to repair by ensuring consumers receive better information at point of sale about product durability and reparability. Specific requirements include mandatory disclosure of expected product lifespan, availability of spare parts and repair services, and reparability scoring where applicable. The directive also bans greenwashing practices and misleading environmental claims, requiring substantiation of any environmental benefits claimed by manufacturers.
Substantiation of Green Claims and Anti-Greenwashing Measures
In March 2023, the European Commission submitted a proposal for a Directive on substantiating green claims, which remains under legislative consideration. This directive will complement the empowering consumers directive by proposing more specific rules on environmental claims, including substantiation, communication, and verification requirements.
The proposal addresses the proliferation of unverified or misleading environmental claims by requiring that any explicit environmental claim made by a company must be substantiated through scientific evidence following standardized methodologies. Independent verification of claims will be required before products can be marketed with environmental benefits highlighted. The directive aims to create a level playing field where genuine environmental performance is rewarded while preventing companies from gaining competitive advantage through misleading sustainability marketing.
These anti-greenwashing measures intersect with the PPWR's labeling requirements and the ESPR's information obligations, creating a comprehensive framework where product environmental claims must be accurate, verifiable, and substantiated through standardized methodologies. For global companies marketing products in the EU, this requires robust systems to collect environmental performance data, conduct lifecycle assessments where applicable, and verify claims through accredited third parties.
Waste Shipment Regulations and Export Controls
The new EU Regulation on Waste Shipments entered into force in May 2024, aiming to ensure that the EU does not export its waste challenges to countries with inadequate waste management infrastructure. The regulation modernizes and tightens control of waste movements within, into, and out of the European Union.
The regulation strengthens rules on waste exports to non-OECD countries, effectively prohibiting the export of plastic waste, e-waste, and other problematic waste streams to developing nations. Only waste destined for recovery operations in facilities meeting EU environmental standards can be exported. The regulation also enhances efficiency of waste circulation within the EU internal market, facilitating the movement of waste for recycling and recovery between member states.
For companies operating international supply chains, these requirements create obligations to verify that waste destined for export meets regulatory requirements, ensure receiving facilities have appropriate environmental controls, and maintain documentation demonstrating compliance with shipment regulations. The regulation includes measures to combat illegal waste trafficking, with enhanced inspection requirements and penalties for non-compliance.
Compliance Strategies and Business Preparation for Global Companies
For global companies manufacturing or selling products in the European Union, navigating this complex regulatory landscape requires strategic planning, cross-functional coordination, and significant investment in compliance infrastructure. Several critical strategies emerge from analysis of the regulatory requirements.
First, companies must conduct comprehensive product portfolio assessments to identify which regulations apply to each product category they manufacture or sell. The ESPR alone will eventually cover virtually all physical products, while specific regulations like the PPWR, Batteries Regulation, and sector-specific directives create overlapping requirements for many product categories. Understanding which requirements apply, when they take effect, and what compliance evidence is necessary forms the foundation of an effective compliance strategy.
Second, businesses should establish robust data collection and management systems to capture the sustainability information required under various Digital Product Passport and labeling requirements. This includes material composition data, carbon footprint calculations, recycled content verification, substance of concern disclosures, and supply chain traceability information. Many companies find that their existing data systems cannot capture this information at the necessary level of detail, requiring significant investment in new enterprise resource planning modules, supplier data collection platforms, and verification systems.
Third, companies must engage upstream suppliers to ensure compliance with recycled content requirements, substance restrictions, and supply chain due diligence obligations. The Batteries Regulation's raw material due diligence requirements and the PPWR's recycled content mandates create dependencies on supplier performance and transparency. Companies that establish early supplier engagement programs, provide technical assistance to suppliers, and build collaborative relationships tend to achieve better compliance outcomes compared to those that approach supplier requirements through purely contractual mandates.
Fourth, businesses should monitor delegated act development processes and participate in stakeholder consultations where opportunities exist. The European Commission conducts extensive stakeholder engagement when developing product-specific requirements under the ESPR and other regulations. Companies that participate in these processes can influence requirement design, ensure their operational constraints are understood, and gain early insight into upcoming obligations that allows for longer preparation timelines.
Fifth, global companies must consider whether to pursue compliance through authorized representatives for non-EU operations or establish EU entities with direct compliance responsibility. The PPWR explicitly requires non-EU companies shipping directly to EU consumers to appoint authorized representatives, while other regulations create similar obligations. The choice between authorized representatives and direct EU presence depends on business scale, product complexity, and strategic objectives for the European market.
Timeline for Prioritized Compliance Actions
Given the staggered implementation of various requirements, global companies can prioritize compliance actions based on the following timeline considerations. In 2025, the focus should be on understanding ESPR working plan priorities when published in April, preparing for PPWR general application in August 2026, and establishing battery passport systems for batteries subject to early requirements.
For 2026, priorities include complying with PPWR substance restrictions that take effect in August, implementing systems to meet the prohibition on destroying unsold consumer products for large enterprises effective July 19, and ensuring readiness for Digital Product Passport registry operation. Companies should also prepare for the first ESPR delegated acts expected to be adopted for textiles and steel.
In 2027 to 2028, the first ESPR product requirements will take effect after the minimum 18-month transition period, PPWR digital labeling requirements begin, and Design for Recyclability criteria are established. This period represents the beginning of substantive product compliance obligations under the new framework.
From 2030 onward, major compliance milestones include PPWR recyclability grades A through C requirement, mandatory recycled content minimums for plastic packaging, reusable packaging targets for beverages and transport packaging, and e-commerce reusable shipping options. All packaging must be designed for recycling, and EPR eco-modulated fees correlate with recyclability performance grades.
Conclusion: Strategic Implications for Global Business
The EU's circular economy regulations represent the most comprehensive and stringent product sustainability framework globally. For companies selling into the European market, compliance is not optional but a fundamental prerequisite for market access. The regulations affect virtually every aspect of product design, manufacturing, supply chain management, marketing, and end-of-life management.
However, these regulations also create significant business opportunities for companies that move beyond minimum compliance to embrace circular economy principles strategically. The transition to circular business models can reduce material costs through recycled content use, create competitive differentiation through superior sustainability performance, access growing consumer demand for sustainable products, and position companies favorably for similar regulations expected to emerge in other major markets including the United States, United Kingdom, and Asia-Pacific regions.
The staggered implementation timeline, with major requirements phasing in between 2026 and 2040, provides a window for strategic preparation. Companies that begin building compliance capabilities now, invest in sustainable product design, establish supplier collaboration programs, and develop robust data management systems will be best positioned to meet requirements as they take effect while capturing the competitive advantages that circular economy leadership provides.
The EU has positioned itself as a regulatory pioneer in circular economy policy, and these regulations will likely influence global standards for years to come. For global companies, understanding and preparing for EU circular economy regulations is not just about European market access but about positioning for a fundamentally different global economy where circularity, resource efficiency, and product sustainability become universal expectations rather than regional requirements.
The regulatory complexity requires sustained attention, cross-functional coordination, and significant investment, but the alternative of non-compliance carries risks of market exclusion, penalties, and competitive disadvantage that far outweigh the costs of proactive preparation. As the EU's circularity rate targets of 24% by 2030 drive implementation forward, the question for global businesses is not whether to comply but how quickly and how strategically they can transform their operations to thrive in the circular economy the EU is creating.

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