EU launches eight-week public consultation on VAT and the circular economy
Impact level
🟡 Consider
Deadline / window:4 November 2026 [1]
What happened
On September 10, 2026, the European Commission launched a public consultation on VAT and the circular economy as part of the forthcoming Circular Economy Act. It focuses on three areas: the treatment of second-hand goods, the destruction of usable goods, and VAT deductions for business use of cars. The eight-week consultation is open through the Have your Say portal until November 4, 2026. The assessment and impact assessment are expected to conclude in early 2027, and their results will inform a legislative proposal to revise the VAT Directive. [1]
Seller impact
- FactThe consultation phase creates no mandatory obligations. EU VAT rules and the treatment of second-hand goods and destruction remain unchanged, so cross-border sellers do not need to adjust their current reporting or destruction practices because of this development. [1]
- ScenarioIf legislation is later adopted, changes to the VAT treatment of second-hand goods or inventory destruction rules could affect the tax costs of returns and unsold inventory. The direction, scale, and effective date depend on the results of the 2027 assessment and cannot currently be quantified. [1]
Suggested action
Submit comments through the Have your Say portal by November 4, 2026, if relevant; after the deadline, only track the results of the assessment expected in early 2027.
Evidence that would disprove the assessment
- Assessment 1:This assessment no longer applies if the European Commission publishes a formal legislative proposal to revise the VAT Directive or announces transitional arrangements.
- Assessment 2:This scenario would not apply if the assessment in early 2027 clearly concludes that no revisions to the rules on second-hand goods or destruction are involved.