The concept of material circularity in upcoming policy debates

by Metka Cavka Luciani, Head of EU Affairs

Circular thinking is often viewed through the lens of product redesign or improving waste management. But the foundation of any circular system is the material’s ability to circulate at high quality, indefinitely, with minimal loss.

Legislators are increasingly recognising that certain materials - so-called permanent materials - are inherently better suited to true circular loops than others. With the European Commission set to present a Circular Economy Act in 2026, the recently adopted CCMI Opinion 246 on permanent materials (3 December) represents a key milestone. It places permanent materials, such as steel, at the forefront of Europe’s next major push towards circularity.

Permanent materials that can be recycled endlessly without degradation, retaining its quality, magnetic properties, and value. This inherent “infinite recyclability” contrasts with materials whose performance declines after each cycle or that require complex, energy-intensive processes to be recycled at scale. As policymakers consider long-term targets for recyclability and resource efficiency, the intrinsic circularity of the material will increasingly matter.

Upcoming EU policies - from the next phases of PPWR implementation to the European Circular Economy Act - will increasingly reward packaging systems that demonstrate clear, verifiable circular benefits across their entire life cycle. But policymakers need to be encouraged to look at system-level circularity, not merely single-use avoidance or lightweighting - approaches that may reduce material mass but harm recyclability or recovery quality.

Future legislation that rewards materials with high-quality, repeated circular loops will accelerate Europe’s green-steel transition - anchoring climate and circularity objectives within a single framework.

By championing the concept of material circularity now, the industry can help shape a legislative environment that rewards sustainable choices, supports innovation, and strengthens Europe’s circular economy from its very foundations.

Read more about steel as a permanent material here

Learn more about the Permanent Materials Alliance here