The circular economy is shifting from slogan to strategy on both sides of the Atlantic—but the policy routes and corporate tactics now diverge sharply.
The European Commission (EC) has opened a public consultation to inform a new Circular Economy Act, with adoption targeted for 2026. The consultation, running on the EC’s “Have Your Say” portal until 6 November 2025, is designed to surface what currently blocks circular practices and which policy levers could unlock more reuse, repair, remanufacturing, and recycling. Crucially, the Act is being positioned as market infrastructure rather than a standalone green initiative, tied to the ‘Competitiveness Compass,’ the ‘Single Market Strategy,’ and the ‘Steel and Metals Action Plan,’ while complementing regulations such as eco-design for sustainable products, packaging rules, and the ‘Critical Raw Materials Act.’
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If done well, the prize is big: less fragmentation across member states, clearer product rules, aligned waste definitions, and easier cross-border trade in “circular” goods and secondary raw materials. That could translate into higher confidence for investors in recycling capacity and stronger demand signals for recycled content through standards and incentives. The risk is familiar too—weak enforcement, burdensome reporting, or overly complex compliance could slow adoption and blunt impact. Still, the direction is clear: Europe wants circularity to function like a single market.
The US story is messier. ‘Right to Repair’ is accelerating at the state level while federal momentum cools. Washington’s HB 1483—signed in May 2025—brings broad electronics and home appliance coverage and takes direct aim at “parts pairing,” the software-based practices that can limit device functionality after third-party repairs. The law’s manufacturer requirements kick in on 1 January 2026. Pennsylvania’s HB 1512 has passed the US House and awaits US Senate committee review, requiring parts, tools, and documentation on “fair and reasonable” terms while restricting software barriers unless justified by safety or legal compliance—though it carves out major categories such as medical devices, vehicles, and video game consoles.
Meanwhile, an August 2025 US Executive Order rescinded the July 2021 directive that had nudged agencies toward coordinated, competition-focused action on repair. With that guidance gone, the FTC and USDA may default to narrower antitrust tools and case-by-case enforcement, cutting the odds of national rulemaking. The likely result: a patchwork of state requirements that raises compliance complexity for manufacturers and service networks.
Against that backdrop, companies are moving faster than regulators. Apple’s $500m supply agreement with MP Materials is a bet on domestic rare-earth security—and on recycling as an industrial capability, not just a sustainability claim. A planned California recycling production line could turn end-of-life electronics and scrap into magnet-ready feedstock, reducing exposure to volatile global markets and export controls. But scaling will depend on reliable collection volumes and viable recovery yields.
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By GlobalDataMeta, by contrast, is using circularity for customer acquisition. Its US trade-in offer lets consumers swap not only older smart glasses, but also Apple and Samsung earbuds, for discounts on Meta glasses. The message is competitive and ecosystem-driven: Replace what you wear in your ears with what you wear on your face—at a lower switching cost.
