ECOS | Environmental Coalition on Standards

18 November 2025

EU Circular Economy Act: Essential need for a dual legal basis

In this joint position paper we warn that relying exclusively on the internal market legal base fundamentally misrepresents the environmental objectives and historical context of Circular Economy policy. We instead advocate the adoption of a dual legal basis incorporating Article 114 TFEU (Internal Market) alongside an appropriate environmental legal basis, e.g. Article 192 TFEU.

Our joint position paper

ECOS is co-funded by the European Commission and EFTA Funded by the European Union. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or EISMEA. Neither the European Union nor the granting authority can be held responsible for them.

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