Waste streams with a high potential to recover critical raw materials

FEAD, the European Waste Management Association, welcomes the Commission’s draft Delegated Act regarding the list of waste streams with high critical raw material recovery potential under Article 26 of the Critical Raw Materials Act (CRMA). This list marks a significant advancement in acknowledging the pivotal role of the recycling industry in ensuring Europe’s strategic autonomy with regard to critical raw materials. However, FEAD wishes to highlight several key concerns that must be addressed to ensure the success of mandatory national programmes under Article 26, while preventing unintended burdens on the waste management sector.

First and foremost, national programmes must prioritise the economic viability of CRM recovery. While the potential CRM content of most identified waste streams is well established, the reality is that sorting specific components and recovering specific critical raw materials can be complex and costly, yielding only marginal to no returns under current market conditions1. National programmes must therefore consider the economic viability of the CRM recovery process and avoid imposing measures such as the mandatory removal or sorting of specific components if this is not economically viable for waste operators.

As outlined in Article 26(1), these national programmes must propose a holistic approach to CRM recovery that tackles the entire value chain. This approach should involve the implementation of policy instruments that help to bridge the investment gap, cover increased operational costs, encourage the uptake of recovered materials and enable recovery operators to compete on a level playing field. Such financial support and policy incentives are needed to ensure that recovered CRM are competitive on a global market with virgin materials2. Without strong support mechanisms, CRM recovery will remain limited to a very few high-value fractions.

Secondly, extended producer responsibility (EPR) systems – when they already exist or their existence is justified – must play a central role in the delivery of these national programmes. Existing and future EPR schemes – especially for batteries, electrical and electronic equipment (EEE) and vehicles – should be designed to provide technical and financial support for the downstream recycling infrastructure to identify, sort and extract CRM-rich waste streams, and therefore cover the additional costs of improving sorting,

dismantling and CRM recovery in the identified waste streams. Ecomodulation should be employed to encourage the use of recycled CRM and the ecodesign of CRM-containing products. This kind of collaboration is essential for creating an efficient and predictable supply chain for critical secondary raw materials.

Additionally, FEAD would like to emphasise that producers should be the main target of this consultation, as producers are much more aware than waste management operators of where to find CRM in products and therefore in which waste streams it could potentially be found – regardless of whether recovery is feasible and economically viable. Producers must also improve the design of their products to make them easier to disassemble to identify and extract CRM-rich components.

Finally, the elaboration of the national programmes under Article 26 must be coherent with the broader EU waste policy framework. It is essential to ensure that CRM recovery objectives are not pursued in isolation from existing obligations under the Waste Framework Directive, the WEEE Directive, the Batteries Regulation, and any other product specific legislation. National programmes should aim to reinforce — not duplicate or conflict with these EU legal instruments. Consistency is also needed across Member States to avoid fragmentation of internal markets and regulatory uncertainty for operators working across borders. In this respect, harmonised monitoring tools and guidance from the European Commission would be highly beneficial.

That said, the proposed Implementing Act, which lists the relevant waste streams and components, is a valuable initiative: it clearly signals Europe’s intention to capitalise on the untapped potential of its waste streams in order to strengthen the resilience of the CRM supply chain and promote circularity.

FEAD agrees with the proposed list in the draft Implementing Act with the reservations expressed above, especially as the following information, which has been brought to us from field experience, is already covered by the list:

• Aluminium is mostly found in small equipment and non-refrigerating equipment, such as household appliances, computer equipment, televisions, small electronic devices and other electrical devices, as well as in air conditioning devices and radiators. Some aluminium is also found in construction and demolition products (light structure profiles) and incineration bottom ash.
• Copper is mostly found in cables and coils. These are used in motors, cathode ray tubes, refrigerator dehydration filters and compressors. Copper can also be found in incineration bottom ash.
• Rare earths are mostly found in permanent magnets, which can be found in light means of transport, speakers, and hard disk drives3.
• Silicon metals can be found in solar panels.

Phosphorus can be found in digestate or compost from sewage sludge and sludges from the agri-food industry. Additionally, over 80,000 tonnes of phosphorus could be recovered from biowaste in municipal solid waste4. To reach this potential, it is essential that biowaste is separately collected efficiently, so that it is diverted from other waste treatment methods that would also destroy the contained phosphorus.

In addition, the inclusion of key streams such as WEEE, end-of-life vehicles, construction and demolition waste, incineration ashes, sewage sludges from urban and industrial wastewater treatment and digestate from separately collected biowaste is especially welcome, as these represent known sources of CRM that are already within the operational scope of many private waste management companies.

In conclusion, FEAD reiterates its support for Article 26 of the Critical Raw Materials Act, which establishes national circularity programmes designed to enhance the recovery of CRM from waste. If these programmes are implemented as outlined in this position paper, they could unlock significant investment, improve access to valuable secondary materials and stimulate innovation in the recycling sector. FEAD is ready to assist the Commission and Member States in developing the appropriate policies to enable the recycling and waste management sector to play a pivotal role in achieving the EU’s CRM objectives.

1 For example, door seals in fridges sometimes contain permanent magnets, e.g. neodymium. However, these magnets are not common in waste streams as most fridges have steel-iron magnets. Removing these magnets manually takes 5–10 minutes and costs €800 per tonne. This activity is not economically sustainable and can only be carried out with the financial support of the producers, in respect of the polluter pays principle.

2 In most cases, virgin CRM materials are cheaper than secondary raw materials (e.g. manganese).

3 For example, hard disk drives can be difficult to extract from appliances, so a WEEE treatment plant would struggle to separate this component from the waste stream. Furthermore, critical raw materials (e.g. permanent magnets) are found in various components within the hard drive, adding an extra layer of complexity to CRM extraction, which cannot always be carried out manually.

4 https://www.compostnetwork.info/wordpress/wp-content/uploads/2025.07_ECN-Feedback-on-CRM-draft- implementing-regulation.pdf

FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 20 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.