FEAD answer to the Call for Evidence on the Advanced Materials Act
FEAD, the European Waste Management Association, welcomes the European Commission’s initiative to develop an Advanced Materials Act. Advanced materials will play a central role in decarbonisation, clean technologies and strategic value chains. At the same time, they are already creating new and increasingly complex waste streams that challenge existing collection, sorting, treatment and recycling systems.
FEAD notes positively that the Commission explicitly identifies reuse, remanufacturing, repurposing and recycling, as well as disassembly, dismantling and sorting technologies, as integral elements of the advanced materials ecosystem. This recognition provides a strong basis for ensuring that innovation policy and end-of-life management develop in a coherent and mutually reinforcing manner.
For FEAD, the success of the Advanced Materials Act will depend on whether it fully integrates circular economy and waste management considerations, ensuring that advanced materials can include recycled content and can be safely, efficiently and economically recycled at end-of-life, and that recycling capacity is recognised as a strategic pillar of EU resilience.
Circularity must be thought from the design phase
Advanced materials frequently combine multiple substances, additives and functions in order to deliver high performance. While beneficial during the use phase, this complexity often reduces recyclability and increases costs, risks and uncertainty at end-of-life. For FEAD, the Advanced Materials Act should therefore ensure that circularity is translated into practical, enforceable outcomes by integrating design-for-recycling and design-for-disassembly considerations at an early stage, supporting not only research and innovation but also industrial-scale recycling, sorting and pre-treatment capacity, and aligning advanced materials targets with the technical realities of waste management operations.
Without such an approach, there is a significant risk that advanced materials will become future problem waste streams rather than contributors to a truly circular economy.
Moreover, the design phase should incorporate the concept of recycled content, with the aim of developing advanced materials that use recycled sources in their production. This would reduce their environmental impact and limit reliance on primary raw materials, which are not always available in Europe.
Recycling and waste treatment facilities as strategic infrastructure
If the Advanced Materials Act introduces the concept of strategic projects, FEAD considers it essential that waste management and recycling installations are eligible on an equal footing with upstream production and manufacturing sites. Recycling provides a reliable domestic source of secondary raw materials, reduces dependence on imports and directly contributes to supply security and industrial resilience. Recognising recycling facilities as strategic infrastructure would also help unlock investment, support scale-up and demonstration projects, and ensure that circular solutions are embedded across advanced material value chains.
Regulatory simplification must include end-of-life stages
The Advanced Materials Act’s ambition to reduce regulatory burden and accelerate procedures is welcome. However, simplification efforts must also address the persistent barriers faced by recycling and waste treatment operators. These include lengthy and fragmented permitting procedures, legal uncertainty around the waste or product status of recycled advanced materials, and inconsistent implementation of rules governing cross-border movements of waste destined for recycling. Measures such as fast-track permitting, regulatory sandboxes or innovation deals should therefore explicitly cover recycling and reprocessing activities, rather than focusing exclusively on upstream innovation.
Secure supply chains require strong recycling markets
Measures envisaged under the Advanced Materials Act to address shortages, stockpiling or joint procurement should explicitly recognise recycling as a key domestic source of advanced and critical materials. Policies that focus predominantly on primary supply risk overlooking cost-effective and sustainable circular solutions. A strong and well-functioning recycling market is essential to strengthening EU resilience, reducing dependencies and achieving long-term industrial competitiveness.
Conclusions
FEAD considers the Advanced Materials Act a key opportunity to better align innovation, industrial policy and circular economy objectives. To deliver on its promises, the Act must ensure that recyclability and end-of-life management are treated as core design criteria for advanced materials and that waste management and recycling capacity are recognised as strategic assets for the European Union.
A genuinely circular Advanced Materials Act will not only accelerate innovation, but will also prevent future waste challenges, strengthen EU competitiveness and contribute to a resilient and sustainable European industrial system.
FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 21 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 500,000 local jobs, fuelling €5 billion of investments into the economy every year. For more information, please contact: info@fead.be