In 2022, 14.4 million tonnes of electrical and electronic equipment were placed on the EU market, while Member States collected only 5 million tonnes of e-waste, equivalent to 11.2 kilograms per person. The gap between what enters the market and what is recovered for recycling represents one of the most tangible expressions of Europe’s critical materials supply problem: an enormous volume of copper, rare earths, precious metals, and other strategic inputs is leaving the productive economy through inadequate collection and processing, even as the clean energy transition drives demand for exactly those materials sharply higher.
Copper illustrates the scale of the issue most directly. Recognised as a strategic raw material under the Critical Raw Materials Act, copper is embedded throughout the infrastructure of the energy transition: electricity grids, wind turbines, heat pumps, EV drivetrains, solar inverters, and digital infrastructure all depend on it. Demand is expected to roughly double by 2050, driven by the simultaneous electrification of transport, heating, and industry. Europe’s primary copper mining capacity is insufficient to meet that demand trajectory, and the continent’s processing capacity is concentrated in a small number of countries that face their own regulatory and social licence constraints on expansion. Secondary copper from e-waste recycling is therefore not a theoretical complement to primary production, but a practical necessity, and the current collection and recovery performance falls materially short of what the demand trajectory requires.
What the Commission Is Being Asked to Do
The European Commission’s forthcoming Circular Economy Act is the legislative vehicle through which these dynamics are expected to be addressed. The regulation is being drafted against a backdrop of existing e-waste rules, including the WEEE Directive, that have produced the current collection performance of 5 million tonnes annually but have not resolved the fragmentation of recovery rates, collection schemes, and recycling quality standards across Member States. The Commission’s stated priorities for the legislation are removing Single Market barriers to the movement of secondary raw materials, improving collection rates, and supporting high-quality recycling that recovers materials at specifications suitable for reintroduction into industrial supply chains.
The Single Market barriers point is significant and underappreciated in the public debate about e-waste. Secondary raw materials that cross internal EU borders face regulatory classification questions, transport restrictions, and divergent national requirements that make it operationally and commercially complex to move recovered materials to the processing facilities best equipped to handle them. A copper smelter in one member state capable of processing e-waste-derived concentrate may not be able to source efficiently from collection systems in neighbouring countries due to these regulatory frictions. Harmonising the framework for secondary materials movement across the Single Market would address one of the structural reasons why Europe’s theoretical recovery capacity does not translate into actual material flows.
The Recycling Ceiling and the Investment Gap
A Bruegel policy brief referenced in discussions at the Euractiv event makes a point that the more optimistic framing of the Circular Economy Act sometimes obscures: recycling cannot by itself satisfy Europe’s rapidly growing demand for critical raw materials. The mathematics of secondary supply is constrained by the volume of material already in circulation. Even if collection rates improved substantially and recycling efficiency reached best available technology standards across all European processing facilities, the volume of copper, lithium, and other critical materials recoverable from current e-waste streams would not close the gap between European demand and European production capacity in the timeframe that the energy transition requires.
The implication is that the Circular Economy Act, however well designed, must be understood as one element of a supply security strategy that also includes domestic mining and processing development, investment in processing capacity in partner countries with resource endowments, and diversification of supply chains away from their current concentration in China. China dominates processing across several critical raw materials value chains, and Europe’s exposure to that concentration is not primarily in mining but in the intermediate processing steps that convert mined ore into battery-grade cathode materials, refined copper, and other industrial inputs. Strengthening European circular economy performance addresses part of this exposure but leaves the processing concentration question largely untouched unless the legislation is accompanied by specific investment in European smelting and refining capacity.
The Industry Position and Its Internal Tension
Industry representatives at the Euractiv discussion emphasised investment certainty alongside regulatory coherence, a pairing that points to a genuine tension in how the Circular Economy Act can be expected to function in practice. Atlantic Copper’s position, that a competitive Europe needs secure access to both primary and secondary copper backed by a coherent regulatory framework, correctly identifies that recycling investment and primary mining investment are complements rather than substitutes. Processing facilities that can handle e-waste-derived materials at scale require capital commitments with multi-decade payback horizons, and those commitments require regulatory stability, long-term market signals, and viable economics that current secondary material pricing does not always provide.
Boliden Smelters’ framing around market incentives being as important as smart policy captures a structural weakness in how European industrial policy approaches secondary materials. The economics of high-quality recycling that recovers materials at primary-grade specification are often marginal relative to the economics of simpler, lower-recovery processing or export of collected material to third-country facilities with lower environmental standards and lower operating costs. Without price signals or regulatory requirements that value material recovery quality rather than just collection volume, the investment case for upgrading European processing to best available technology standards remains challenged.
The WEEE Directive’s existing collection targets have driven collection volume but have not consistently driven collection quality or recovery purity. E-waste collected through some national schemes ends up downcycled or exported in forms that do not yield the high-purity secondary materials that battery manufacturers and grid equipment producers require. A Circular Economy Act that establishes quality standards for recovered materials alongside collection targets would address this gap, but it would also impose costs on collection operators and processors that the current economics of secondary materials may not support without additional policy mechanisms.
The Alignment Problem Between Critical Materials Policy and Circular Economy Policy
The Critical Raw Materials Act identified copper and a defined list of other materials as strategic, establishing targets for domestic production, processing, and recycling but without providing the investment mechanisms to reach those targets on the required timeline. The Circular Economy Act is being developed in parallel without a formal requirement that its design be optimised around the materials identified as highest supply risk under the CRMA. Bruegel’s recommendation that strategic projects focus more closely on the materials for which Europe remains most dependent on a single third-country supplier reflects the gap between how critical materials risk is assessed and how circular economy legislation is typically structured.
Designing collection and recycling obligations, quality standards, and market incentives around the specific supply risk profiles of CRMA-listed materials would require the Commission to make explicit trade-offs about which materials to prioritise, what recovery quality standards to require, and how to sequence investment in collection infrastructure and processing capacity. That is a more operationally specific legislative design than the Commission’s stated priorities of removing barriers and improving collection suggest, and whether the forthcoming legislation reaches that level of specificity will determine whether it functions as an industrial policy instrument or primarily as an environmental management framework with supply security framing.
