Can the Circular Economy Act deliver for Europe’s raw materials?

Can the Circular Economy Act deliver for Europe’s raw materials?

Written by Audrey Quintin, Senior Policy Analyst, and Abreham Mauri, EU Policy Intern, this event readout summarises the key discussions from Euractiv's event on the upcoming Circular Economy Act and its role in strengthening Europe's access to critical raw materials.

Experts explore the Circular Economy Act’s potential to deliver the EU’s critical raw materials needs  

On 25 June, Euractiv hosted the event From E-Waste to Strategic Autonomy: Can the Circular Economy Act Deliver for Europe’s Raw Materials?, which explored how the upcoming Circular Economy Act (CEA) could strengthen the EU’s strategic autonomy in critical raw materials by promoting circularity, particularly through improved e-waste recycling. 

Participants, spanning the mining and recycling industries, manufacturing, and environmental NGOs, broadly agreed that recycling should be a key component of Europe’s raw materials strategy, while complementing domestic mining, processing, and reliable international partnerships. It was recalled that only 1% of CRMs were currently recycled in Europe (out of a 12% recycling rate), highlighting a significant untapped potential.  

Panellists further stressed the importance of a coherent regulatory framework that facilitates material recovery, removes Single Market barriers, and supports the competitiveness of Europe’s industrial base. 

During the panel discussion, Paulina Dejmek Hack, Head of Cabinet for Commissioner Jessika Roswall, confirmed that the Commission plans to present the CEA by the end of the third quarter of 2026, with the aim of boosting critical raw materials recycling. She stressed that the geopolitical context reinforces the need to unlock Europe’s secondary raw materials potential by improving e-waste collection and recovery rates, clarifying the definitions of waste and by-products, and reducing regulatory fragmentation across Member States.  

She also underlined the importance of ensuring coherence between the CEA and existing legislation, including the Critical Raw Materials Act (CRMA) and the Ecodesign for Sustainable Products Regulation (ESPR), while supporting investment in recycling infrastructure, addressing energy costs and permitting challenges, and discouraging landfill at the national level. 

From an industry perspective, Anna-Maria Karjalainen (International Copper Association Europe) and Macarena Gutiérrez (Atlantic Copper) emphasised that copper demand is expected to continue rising (to double by 2050), making recycling necessary but insufficient on its own. They argued that Europe must pursue a comprehensive strategy combining recycling, sustainable mining, domestic processing, and innovation, while preserving the competitiveness of European operations. They highlighted high energy prices, barriers to waste shipments, overgrowing reliance on higher-carbon imports from China, and an uneven international playing field as major obstacles, warning that Europe risks losing strategic industrial capacity if these challenges are not addressed.  

Daniel Peltonen (Boliden Smelters) stressed that maintaining competitive, low-carbon metal production in Europe would also require stable climate policies, notably through the EU Emissions Trading System, as European producers increasingly compete with expanding Chinese smelting capacity. 

Industry representatives pointed to the primary aluminium sector as a cautionary example, arguing that high energy prices have led to the closure of around half of the EU’s production facilities over the past year. As production has increasingly relocated to China, the EU has become more dependent on aluminium imports with a higher carbon footprint, undermining both its strategic autonomy and industrial competitiveness. 

Representing the appliances industry, Korrina Hegarty, Senior Policy Director at APPLiA Europe, outlined the importance of urban mining and noted that large volumes of valuable raw materials in discarded appliances remain unrecovered. She said the CEA should strengthen waste tracking, improve enforcement, and increase the recovery of metals from waste streams.  

She also highlighted the challenges of collecting small appliances and called for better enforcement of producer and retailer collection obligations, as well as greater consumer awareness and additional collection infrastructure. She argued that the Act should be aligned with the Ecodesign for Sustainable Products Regulation to ensure that new design requirements enhance the quality of future waste streams while avoiding regulatory duplication. 

Finally, Valeria Botta, Programme Director at Environmental Coalition on Standards (ECOS) stressed that the Act should strengthen upstream circularity by promoting prevention, reuse, and repair alongside recycling, improve the tracking of critical raw materials through tools such as Digital Product Passports (DPPs), and establish clearer recovery objectives for critical raw materials. In her view, binding targets should be set for prevention, reuse, and repair, as well as a minimum CRM recovery target in the design of products.  

While speakers reflected different perspectives from industry and civil society, the discussion revealed broad convergence on the need for a more integrated approach to critical raw materials. Participants agreed that the Circular Economy Act should help unlock the untapped potential of secondary raw materials while complementing broader efforts to strengthen domestic mining, processing, and manufacturing, thereby enhancing both Europe’s competitiveness and its strategic resilience. 

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