European trade unions have issued a joint statement urging policymakers to place workers at the centre of the forthcoming Circular Economy Act. The call comes as the European Commission prepares legislation intended to boost recycling, repair and reuse while reducing the bloc's reliance on imported raw materials.

The unions argue that without clear guarantees on employment quality, occupational safety and public‑service resources, the law could merely shift environmental burdens onto precarious labour and distant waste‑receiving countries.

Why the act matters for jobs and skills

Designers, factory staff, maintenance crews, waste collectors and recyclers all form the backbone of a circular system. Their expertise determines whether products can be safely dismantled, hazardous substances are contained and secondary materials are recovered efficiently. Yet, according to the union coalition, the current policy debate has focused almost exclusively on market access, material security and competitiveness, leaving the human factor largely invisible.

"Circularity will not happen by itself," said Francesca Rossi, spokesperson for the European Federation of Trade Unions (ETUC). "It depends on people who design, build, repair and sort. If we ignore their rights and safety, the whole project collapses."

The statement calls for the act to embed "quality employment" as a core objective. This would mean that new green jobs created in recycling plants, repair workshops or material‑recovery hubs must come with stable contracts, fair wages, full social protection and the right to collective bargaining.

Union leaders stress that the transition should not become a race to the bottom, where low pay and insecure contracts are accepted as the price of sustainability. They point to recent growth in "bogus self‑employment" schemes across Europe, where workers are classified as independent contractors to avoid paying social contributions and to sidestep union representation.

To avoid such outcomes, the unions propose a set of labour‑related indicators that would be monitored alongside material‑recycling targets. These would include average wages in circular sectors, the share of workers covered by collective agreements, rates of occupational injuries and the proportion of employees receiving recognised qualifications.

Safety built into products, not added later

Workers handling waste, batteries or electronic scrap are routinely exposed to chemicals, heavy machinery, fire risks and biological hazards. The unions note that many of the new materials slated for large‑scale reuse, such as lithium‑ion batteries and advanced composites, carry risks that are still poorly understood.

"Occupational safety must be designed into the product life‑cycle from day one," argued Jens Müller, head of the German Metalworkers' Union. "If a device is meant to be repaired, the manufacturer must ensure that dismantling can be done without endangering the technician."

They call for mandatory access to safety data sheets for all components, stricter limits on hazardous substances and robust inspection regimes. The unions warn that diluting safety standards in the name of "simplification" would undermine both worker health and environmental protection, as accidents often lead to spills and secondary pollution.

Extended producer responsibility (EPR) schemes, already a feature of EU waste policy, are seen as a lever to make manufacturers internalise the full cost of safe design, repairability and end‑of‑life handling. The unions want EPR to be expanded so that producers also bear the social and health costs associated with their products, not just the environmental ones.

Public funding tied to social conditions

Much of the financing for circular projects, from grants for recycling infrastructure to tax incentives for repair networks, will come from EU and national budgets. The unions argue that any public money should be conditional on compliance with labour standards, collective‑bargaining agreements and tax obligations throughout the supply chain.

"If a company receives EU funds but underpays its workers or skirts safety rules, the public interest is betrayed," said Maria Silva, a representative of Portugal's Public Services Union. "Funding contracts must include claw‑back clauses if social conditions are breached."

They also stress that public authorities need adequate staffing and expertise to enforce these conditions. Under‑funded inspection services, a legacy of austerity measures, could render the most ambitious regulations ineffective.

Preventing a race to export waste

The statement warns against the temptation to meet recycling targets by shipping waste to countries with lower environmental or labour standards. While the EU already bans the export of hazardous waste to non‑OECD nations, the unions say loopholes remain for mixed or "non‑hazardous" streams that can still pose health risks.

"We cannot achieve circularity on paper while dumping dangerous work onto the Global South," warned Ahmed El‑Mansouri**, a union delegate from Morocco who works with European partners on cross‑border labour issues. "Exporting waste to places where workers lack protection simply shifts the problem, not solves it."

Instead, the unions call for investment in domestic repair, reuse and recycling capacities, arguing that such facilities would create stable, well‑paid jobs and reduce the need for long‑distance waste shipments.

Social dialogue as a legal requirement

One of the most concrete proposals is to embed a permanent mechanism for social‑partner involvement in the governance of the Circular Economy Act. This would give unions a seat at the table when the European Commission drafts implementing measures, monitors compliance and revises targets.

"Collective bargaining is not a nice‑to‑have, it is essential for a just transition," said Elena Petrova**, a senior official of the Bulgarian Confederation of Trade Unions. "Without it, companies can impose restructuring plans that leave workers without retraining or income support."

The unions stress that any workforce‑planning exercise must include paid training during working hours, income guarantees for displaced staff and targeted support for regions heavily dependent on traditional manufacturing.

Balancing competitiveness with fairness

Industry groups have welcomed the push for a more circular economy, citing the need to reduce dependence on raw‑material imports from geopolitically unstable regions. However, they caution that overly stringent labour rules could raise production costs and make European products less competitive on global markets.

In response, the unions argue that a level playing field already exists when competitors outside the EU are not bound by the same health, safety and social standards. "If we raise the bar for workers, we also raise the bar for responsible producers," said Rolf Andersen**, director of the Nordic Confederation of Trade Unions. "That is a fair competition, not a disadvantage."

They also point out that higher wages and better conditions can boost productivity, reduce turnover and foster innovation, factors that can offset higher labour costs.

What comes next?

The European Commission is expected to present the final text of the Circular Economy Act later this year. If adopted, the law will set recycling targets for 2030, introduce new EPR obligations and allocate billions of euros for green‑jobs programmes.

Union representatives say they will monitor the legislative process closely and will mobilise members for a coordinated campaign if the final version falls short of their demands. They plan to organise a series of consultations with workers in waste‑management, repair and manufacturing sectors across the EU to gather concrete recommendations.

"The choices we make now will decide whether Europe's circular transition creates decent work and resilient industry, or simply a new arena for precarious labour," concluded Francesca Rossi**. "We must act now to embed social justice into the heart of the circular economy."