Preparation of the new Circular Economy Act is underway – what does it mean for producer responsibility for packaging?

A working group has been established to prepare the Circular Economy Act, which will complete its work this year. After that, officials will prepare a draft government proposal, which will go for consultation at the beginning of 2026. 

“Consultations will take place next spring, and if everything goes according to plan, the bill will be presented to parliament in autumn to be approved ahead of the elections,” says Jussi Kauppila, Senior Ministerial Adviser at the Ministry of the Environment. 

The current Waste Act was drafted 15 years ago, and it has changed significantly over the years. 

“The law is no longer a clear, systematic entity. That is the main reason the legislation is now being reformed,” says Kauppila. 

As well as clarifying the law, the new bill will also include technical revisions. The new Circular Economy Act could come into force at the beginning of 2028 at the earliest.

The EU Packaging & Packaging Waste Regulation (PPWR) introduces new requirements for packaging producers. 

The Circular Economy Act will incorporate recently changed and currently prepared EU regulations and directives. 

“The implementation of EU regulations will be covered in the new legislation to the extent that the implementation schedules match the preparation schedule of the Circular Economy Act,” says Kauppila.  

When it comes to packaging, EU legislation will not introduce any new requirements to the Act. This is at least partly due to the fact that the Packaging Directive was replaced by the Packaging Regulation, which is included in the legislation of Member States. 

The Packaging Regulation came into force on 11 February 2025 and will apply in Member States from 12 August 2026. The regulation will introduce significant new requirements for the packaging industry. 

“The amount of new packaging waste must be reduced, the reuse of packaging must be increased and all packaging must be recyclable from 2030 onwards. The regulation also stipulates that a certain proportion of the raw material used to produce plastic packaging must be recycled material,” says Juha-Heikki Tanskanen, CEO of Rinki. The packaging regulation requirements will be clarified in the coming years with the commission’s implementation guidelines. 

The goal of the Packaging Regulation is to make packaging easier to recycle, reduce the use of virgin raw materials and promote circular economy.

Additional regulations for circular economy and recycling are being considered. 

A big question in the preparation of the Circular Economy Act is whether the new law can promote circular economy and what legislative measures could be taken to achieve this. 

“Finland is behind in its targets for recycling municipal waste, and the working group is aiming to find new steering methods to increase the recycling rate,” says Kauppila. 

Finland has been given an early warning that it is not meeting its recycling targets for municipal waste and plastic packaging waste. Ways to promote recycling and curb the incineration of waste will be considered, and their potential impacts will be examined during the preparation process. 

The Ministry of the Environment will conduct an LCA assessment of the impact of expanding the collection of packaging waste to properties with fewer than five households. 

“It’s good that the impacts of expanding collection are being systematically examined. Our assessment is that this is not an effective way to improve the recycling rate of plastic packaging. The actual collection rates indicate that extending collection from Rinki points to the courtyards of properties only slightly increases consumers’ eagerness to recycle. However, it would increase the cost of producer responsibility by tens of millions of euros a year, as packaging waste would be collected from individual properties instead of Rinki eco-points,” says Tanskanen. 

The business community has prepared a statement on the preparation of the Circular Economy Act. Its main message is that the most effective ways to increase the recycling rate are encouraging consumers to recycle and companies to sort plastic packaging for recycling instead of putting it into energy waste.