This is a summary of T&E's response to a public consultation on the Circular Economy Act. To find out more, download the full response.
Ahead of the upcoming Circular Economy Act (CEA), T&E urges the European Commission to use this opportunity to efficiently scale Europe’s recycling industry - across batteries, steel and aluminium. Building up local recycling companies and getting recycling production going will be key in developing a sustainable electric vehicle industry, driving new industrial opportunities, and creating resilient European supply chains that reduce external dependencies.
T&E analysis shows that there is huge potential to unlock Europe’s recycling capacity to power new vehicles with secondary materials. However, the EU is currently not prepared to fully capitalise on this opportunity. Europe’s existing recycling capacity is 10 times below where it needs to be by 2030, and almost half of planned battery recycling projects are at risk.
There is now a unique opportunity to get the CEA right to scale effective recycling across the EU and drive greater material recovery in Europe. T&E calls on the European Commission to:
1. Introduce recycled content targets coupled with “Made in Europe” requirements
The Circular Economy Act should make greater use of recycled content targets - eg for steel and aluminium in new electric vehicles - and crucially, link these targets with local sourcing requirements to ensure European recyclers and manufacturers benefit. Recycled content targets for batteries should also be tied to local material sourcing to help create a strong, circular European market.
2. Simplify intra-EU waste shipment rules to reduce costs and administrative burden
The Act should further streamline the Waste Shipment Regulation, harmonise waste criteria, and allow recycling partnerships where multiple actors within the same waste stream can operate as a single administrative entity. This would reduce bureaucracy, cut costs, and speed up the flow of materials for recycling across borders.
3. Prevent waste and material leakage from the EU
The Commission should take action to ban or significantly limit waste material shipments outside the EU including scrap and end-of-life products related to batteries, steel, and aluminium. This could be achieved through export bans, more harmonised waste classifications, or export levies that make overseas shipments more costly and less attractive. Keeping materials in Europe is essential to strengthen circularity and safeguard valuable resources.
4. Establish clearer standards and classification systems for recycled materials
To increase the uptake of recycled inputs across industries and encourage collaboration between recyclers and manufacturers, the CEA should set clear, EU-wide definitions and quality grades for recycled products. For example, in the steel sector, different purity levels are required depending on the end use. The CEA could help by defining two or three standard grades of recycled steel based on copper contamination thresholds.
5. Commit to revising the Extractive Waste Directive and enable responsible re-mining
To bring Europe’s outdated mining waste rules in line with best practice, the CEA should transform the Extractive Waste Directive into a new European Circular Extractive Waste Regulation. This should include harmonised implementation across Member States, rules for re-mining, and the introduction of clear, objective principles backed by best available technologies to promote safe and efficient reprocessing of mining waste.
