Where is the ecodesign and circularity of electronics headed in Europe?

Christine Nikander
Dec 29, 2025
18 min read

An analysis of the direction EU regulations and policymaking on electronics circularity need to take if Europe wants to continue to compete on the global market.

This edition of “The E-Waste Newsletter” was written by Christine Nikander.

Regulating for electronics circularity

Most manufacturing processes today still use the approach of using new materials for new products. Over time it has, however, become clear that the use of primary raw materials can come with a variety of environmental, social, ethical, economic, and geopolitical challenges.

The fact that most raw materials are finite also creates a key issue. By 2050, the consumption globally is expected to reach levels that would require three times the amounts of resources found on Earth.[i] A fully linear economy, therefore, cannot work in the long run on a planet with finite resources. In this context, prolonging the life of products and reducing waste through better design and repurposing raw materials domestically might be solutions worth considering and implementing.

In many ways, the progress towards a circular economy lays at the nexus of sustainability, technology, and regulation. Laws and policies can play a key role in accelerating the transition to a circular economy – and this holds especially true for the metals, minerals, and other critical raw materials used in electronics. On the flipside, poorly designed laws and policies can act as barriers to the circular economy by creating false incentives or blocking progress. In other words, to achieve circularity, policies and laws have to be drafted with a thorough understanding of the market and with attention to the nuances found therein.

Recycling targets for critical raw materials in the EU

Under the EU’s Critical Raw Materials Act, at least 25% of the critical raw materials used in the EU must come from recycling by 2030.[ii] Under the EU’s Batteries Regulation, there is also a minimum non-virgin content for industrial, EV, as well as starting, lighting and ignition (SLI) batteries that must be reached by 2031.[iii]

In line with this, the EU has set up a number of targets for the collection of batteries. By the end of 2025, 80% of the nickel-cadmium, 75% of the lead-acid, 65% of the lithium, and 50% of other waste batteries must be recycled. By the end of 2027, 90% of the copper, cobalt, lead, and nickel found in waste batteries must be recovered. Additionally, 50% of the lithium must be recovered. By August 2031, a minimum level of 85% recycled lead, 16% recycled cobalt, 6% recycled lithium, and 6% recycled nickel must be used in batteries in the EU.[iv]

The EU continues to struggle with closing the loop for metals and minerals

Despite having put in place numerous recycling targets, “[r]ecycled material accounted for only 12.2% of material used in 2024 in the EU”, according to EU Environment & Climate.[v] In 2015, this rate was 11.2%, which demonstrates how slow the overall progress in recycling has been in the EU.[vi] When the recycled content for 2024 is subdivided by material group, recycled materials accounted for 23.4% of the metal ores and for 14.3% of the non-metallic minerals used in the EU.[vii]

A key issue in Europe’s circular economy is that the EU continues to export valuable secondary raw materials abroad – with Turkey, the UK, India, Egypt, and Switzerland having been the largest export destinations for the EU’s recyclable raw materials since 2023. In 2024, the EU exported 35.7 million tonnes of recyclable raw materials to non-EU countries. This includes “recyclable waste and scrap as well as other secondary raw materials” or by-products. In 2023, the EU even exported 38.9 million tonnes of recyclable raw materials – making it a record year for recyclable raw material exports from the EU, with the highest export rate of the past two decades. While there was an 8.2% decrease in recyclable raw material exports from the EU between 2023 and 2024, it is worth noting that the amount of materials exported in 2024 was still 58.5% higher than in 2004. Concretely, the EU exported 13.2 million tonnes more recyclable raw materials in 2024 than it did in 2004.[viii]

Metals were the highest exported recyclable raw material from the EU in 2024. More than half – namely 53.3% – of all recyclable raw materials exported from the EU were metals. All in all, this means that 19 million tonnes of recyclable metals were exported from the EU to non-EU countries in 2024 alone.[ix]

The Right to Repair in Europe

From an environmental perspective, it is worth noting that the annual disposal of repairable consumer goods in the EU produces 35 million tons of waste and 261 million tons of CO2e emissions.[x] It also creates EUR 12 billion in costs for consumers buying replacements.[xi] According to the European Commission, “77% of EU citizens would prefer repairs to purchasing new products” – demonstrating why creating a better repair framework would be strongly in the interest of EU consumers.[xii]

A few regulations and measures to this effect have been put in place over the past few years. Under the EU’s Right to Repair Directive, sellers are – for example – required to offer repairs within the guarantee period – unless a replacement of the broken or faulty device should be cheaper. Beyond the guarantee period, manufacturers must repair broken or faulty devices at a reasonable price and speed. They must also provide consumers with access to spare parts, tools, and repair information. The directive also sets out that there should be online platforms accessible to make it easier for consumers to find repair services.[xiii]

The French Anti-Waste Law for a Circular Economy or “AGEC” law, which came into force in 2020, creates a consumer “repair bonus” for electronics no longer under guarantee. Consumers are given EUR 10-45 for their repair, depending on the appliance. The aim is to increase annual electronics repairs in France by 20%, with the government putting forward a budget of EUR 410 million for this until 2027.[xiv]

Beyond this, several measures have also been put into place to create repairability scores and indexes in Europe. The Energy Labelling Regulation, for example, sets out a reparability score.[xv] Under the AGEC law, there has been a reparability index in France since 2021,[xvi] and under Belgian decrees, there has been a reparability index in Belgium since May 2025.[xvii]

Ecodesign Regulations in the EU

The design phase determines up to 80% of a product’s environmental impacts.[xviii] Beyond the right to repair, there are therefore also several regulations in the EU that address ecodesign. Under the EU’s Ecodesign for Sustainable Products Regulation (ESPR), for example, both product durability and reparability are addressed. In practice, aspects such as the ease of dismantling, the availability of technical (repair) information and spare parts, as well as the delivery times and prices of spare parts for products are regulated. Additionally, the regulation also sets out rules around the energy and resource-efficiency, as well as the recycled content, of products.[xix]

Beyond the ESPR, the EU’s Energy Labelling Regulation, which applies to energy-related products, sets out product information requirements, on – for example – the carbon and environmental footprints of products. Additionally, it outlines the Digital Product Passport and energy labels via the European Product Registry for Energy Labelling (EPREL).[xx] Moreover, under the EU’s Batteries Regulation, both the removal and the replacement of batteries should be made easier as of 2027. There may also possibly be a phase-out of non-rechargeable portable batteries by 2030. When it comes to consumer labelling, the regulation addresses battery components and recycled content. It introduced the battery passport and the requirement to have a QR code on certain batteries.[xxi]

To improve the design of given products, the European Commission also created the voluntary safe and sustainable by design (SSbD) framework in 2022. The recommendation applies specifically to chemicals and materials for their (re-)design phase and assessment phase. To make it easier for companies to design products sustainably, it aims to align regulatory obligations, foster innovation, and minimize the use of “substances of concern”.[xxii]

The EU’s new Circular Economy Action Plan

Within the EU, the “circular material use rate” is currently only at 11.8%.[xxiii] Through its new Circular Economy Action Plan, the EU now, however, plans to increase demand for recycled materials and improve the market for secondary raw materials.[xxiv] In line with this, under the Clean Industrial Deal, the EU concretely set itself the target to double its circular material use rate to 24% by 2030.[xxv]

While Europe has limited amounts of critical raw materials located in its ground, the EU hopes to be able to use recycling and circularity as tools to avoid future shortages. Through its new Circular Economy Act, the European Commission says it aims to create an EU internal market for secondary raw materials.[xxvi] The EU also hopes to boost the economic security, resilience, and competitiveness of Europe through the plan, all while continuing to decarbonize the market.[xxvii]

The upcoming Circular Economy Act is set to be adopted by the end of 2026. By implementing new policies and measures, the EU plans to “remove obstacles to circular practices”. The EU also plans to speed up its transition to a circular economy “[b]y focusing on key sectors and introducing targeted practical measures”.[xxviii] The aim is “to make the EU the world leader on the circular economy” by 2030.[xxix]

The EU’s RESourceEU Action Plan

In light of recent geopolitical developments, the EU has put a key focus on securing critical raw materials and decreasing its dependency on China for rare earth materials. Through its new RESourceEU action plan from 3 December 2025, the EU plans to spend an additional €3 billion to secure critical raw materials for permanent magnets, batteries, and defense. It is planned that a European Critical Raw Materials Centre will be set up by 2026 to jointly monitor, purchase, and store raw materials. The European Commission is also planning to amend the Critical Raw Materials Act to include information requirements – for example, on the sources of the critical raw materials that companies use. Through a European Raw Materials Platform, the EU then aims to also help companies coordinate around critical raw materials.[xxx]

The overall aim of RESourceEU is to boost EU competitiveness by securing critical raw materials. The EU says it created RESourceEU in the “context of increasing geopolitical competition”. With its action plan, the EU hopes to avoid situations where trade dependencies “jeopardise security, public order, competitiveness, and the EU economy”. Across the board, European companies are said to be dependent on third countries for 90% of the critical raw materials that they use. Through partnerships with Australia, Canada, Norway, South Africa, and Ukraine, the EU now hopes to be able to improve its access to and stocks of critical raw materials.[xxxi]

The plan is to reduce dependencies by up to 50% by 2029. That said, the European Commission has stated that its current focus is on preventing short-term disruptions in critical raw materials. It then later hopes to “progressively reduc[e] risky dependencies and avoi[d] new ones” from arising. Given the European Commission’s heavy focus on securing resources for the defense sector, there are, however, currently concerns about sensitive data potentially landing in the wrong hands. Balancing the security-oriented approach of the action plan with upholding the EU’s free market is also seen as tricky. Moreover, another key area of concern for the European Commission is whether the EU’s member states will truly act in synchrony as a team.[xxxii]

Increasing vehicle circularity in the EU

While the EU is preparing to cancel the 2035 phase-out of combustion engine cars, there are plans to strengthen the circularity of vehicles. The EU is, notably, planning to create “requirements to ensure that new vehicles are designed to facilitate the recycling, reuse and remanufacturing of parts and components”.[xxxiii]

In line with this, the EU plans to set out a mandatory recycled plastic content in new vehicles and to set future recycling targets for steel, aluminum, magnesium, and other critical raw materials. The EU also wants to strengthen the extended producer responsibility for vehicles and to ban the export of non-roadworthy vehicles after 5 years under the new rules. Beyond this, the plan is also to make the rules on when a vehicle becomes waste clearer and to clampdown on so-called “missing vehicles” and the illegal dismantling of vehicles.[xxxiv]

Regulatory direction changes in the EU

As the European Commission has repeatedly stated in the context of the upcoming Circular Economy Act, circularity and the wise use of the EU’s limited raw materials play a key role in enhancing the EU’s economic security and competitiveness, as well as in reducing the EU’s carbon emissions.[xxxv] Yet, while the new Circular Economy Act’s plan to create a single market for recycled materials is a step in the right direction, true circularity will require a lot more action and innovation in Europe.

If Europe wants to retain its significance and competitiveness on the global market, the EU needs to truly put its money where its mouth is. This concretely means that the EU needs to take meaningful action – beyond prioritizing the recycling of materials – to accelerate its shift to a circular economy. A circular Europe needs to be educating its population to adopt circular practices, it needs to fund circular research and the scaling of circular innovations and solutions, and it needs to truly “close the loop” by putting an end to the export of valuable raw materials.

In this context, it is worth noting that companies – and especially the so-called “green economy” – play a key role in making the circular economy a reality in Europe. A report from the World Economic Forum’s Alliance of CEO Climate Leaders and Boston Consulting Group from 2 December 2025 found that the size of the global green economy has passed USD 5 trillion a year. The report also found that the green economy is on track to reach upwards of USD 7 trillion by 2030. This effectively means that, over the past decade, the green economy has been the second-fastest growing market – right after the technology sector.[xxxvi] This also means that if Europe wants to have a say on the global market of the future, it should be making sure its green economy is keeping up with, if not outperforming, the global green economy. In practice, this means that the innovation that Europe needs is not going to be found in funding and refining its outdated fossil fuel-based infrastructure and industry. Instead, the way forward must be in investing in the building of “green” and future-proof skills, competences, infrastructure, and intellectual property that can compete on the global market.

Taking this into consideration, it seems particularly contradictory that, over the course of 2025, the European Commission presented one proposal after the next to “simplify” or eliminate large parts of the EU’s Green Deal and branded these measures as key steps to increase the “competitiveness” of the EU. Typically, after all, one would not expect an economy looking for growth to eliminate the very rules that support a high-growth and high innovation market. In light of this, it would therefore make sense to see the European Commission shift its priorities back over to creating and strengthening a market for companies pushing the circular economy forward throughout 2026 and beyond.

How electronics companies can act as catalysts for the circular economy

In the electronics sector, circularity requires companies to design electronics for circular use and to keep metals and minerals in their production loops. While the export of secondary raw materials remains a key area for improvement within EU policy and lawmaking, it is worth noting that there are companies taking the initiative to either keep secondary raw materials in the EU or to even import these from abroad to the EU.

Roughly 46.7 million tonnes of recyclable raw materials were imported from non-EU countries to the EU in 2024. This was an increase of 7 million tonnes or 17.5% compared with 2023. Compared with 2004, imports to the EU increased by 3.1 million tonnes or 7.2% in 2024. Some of the imported materials were metals and minerals. Concretely, in 2024, the EU imported 6.8 million tonnes of recyclable minerals – amounting to 14.5% of the EU’s total recyclable raw material imports – and 6.3 million tonnes of recyclable metals – amounting to 13.5% of the EU’s total recyclable raw material imports. The EU’s largest import sources for recyclable raw materials in 2024 were notably Brazil, Argentina, the UK, Ukraine, and Indonesia.[xxxvii]

Resource extraction and processing notably causes 90% of the biodiversity loss globally. By shifting over to circular practices, it is however possible to reduce this biodiversity loss. Circularity also makes it possible for companies to manage their resources responsibly and in a future-proof way, all while reducing greenhouse gas emissions.[xxxviii] In this context, it is worth noting that both the 100 People & Organizations in Circularity to Follow in 2025 list and Sitra’s Circular Solutions For Nature Handbook For Businesses can offer inspiration and insights on measures that companies looking to move circularity forward can concretely take.

The next newsletter will explore the changing role of the Global South in the critical raw materials market. If you want to be notified when it comes out, please subscribe to our mailing list.

About the author

Christine Nikander is the founder of the environmental and social sustainability consultancy, Palsa & Pulk. She frequently speaks and writes about the environmental and human rights issues that arise through global supply chains, the energy transition, and the mining of critical raw minerals. Christine studied law at the universities of Columbia (New York), Edinburgh (Scotland), and Leiden (the Netherlands). She has been writing The E-Waste Column weekly since 2022 and she co-created The E-Waste Learning Hub that was launched in September 2025.

About The E-Waste Column

The E-Waste Column is a weekly column about e-waste, transition minerals, and critical raw materials. It touches on a range of topics including ESG, sustainable development, circular economy, EU law and policymaking, corporate social responsibility, the transition to renewable energy, the EU Green Deal, supply chain due diligence and auditing, human environmental rights, business and human rights, climate law, and corporate sustainability.

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[i] European Commission, Circular Economy, https://environment.ec.europa.eu/strategy/circular-economy_en (18.12.2025).

[ii] European Commission, Critical Raw Materials Act, https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal/green-deal-industrial-plan/european-critical-raw-materials-act_en; European Commission, Critical Raw Materials Act, https://single-market-economy.ec.europa.eu/sectors/raw-materials/areas-specific-interest/critical-raw-materials/critical-raw-materials-act_en; European Commission, Factsheet on European Critical Raw Materials Act, https://ec.europa.eu/commission/presscorner/detail/en/fs_23_1663; Official Journal of the European Union, Regulation (EU) 2024/1252 of the European Parliament and of the Council of 11 April 2024 establishing a framework for ensuring a secure and sustainable supply of critical raw materials and amending Regulations (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1724 and (EU) 2019/1020 (Text with EEA relevance), https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401252.

[iii] European Commission, Circular Economy: New rules to boost recycling efficiency and material recovery from waste batteries, https://environment.ec.europa.eu/news/new-rules-boost-recycling-efficiency-waste-batteries-2025-07-04_en (18.12.2025); European Commission, Batteries, https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en (18.12.2025); Official Journal of the European Union, COMMISSION DELEGATED REGULATION (EU) 2025/606 of 21 March 2025 supplementing Regulation (EU) 2023/1542 of the European Parliament and of the Council by establishing the methodology for calculation and verification of rates for recycling efficiency and recovery of materials from waste batteries, and the format for the documentation, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500606; Official Journal of the European Union, Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing Directive 2006/66/EC, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1542.

[iv] European Commission, Batteries, https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en (18.12.2025); European Commission, Circular Economy: New rules to boost recycling efficiency and material recovery from waste batteries, https://environment.ec.europa.eu/news/new-rules-boost-recycling-efficiency-waste-batteries-2025-07-04_en (18.12.2025).

[v] Eurostat, Over 12% of materials in the EU come from recycling, https://ec.europa.eu/eurostat/en/web/products-eurostat-news/w/ddn-20251119-1 (18.12.2025); EU Environment & Climate, How much recycled material is used in the EU?, https://www.instagram.com/p/DRbvbBrCGqC/ (18.12.2025).

[vi] European Commission, New package of measures to boost circular economy and strengthen Europe's plastic recycling, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_3151 (23.12.2025).

[vii] Eurostat, Over 12% of materials in the EU come from recycling, https://ec.europa.eu/eurostat/en/web/products-eurostat-news/w/ddn-20251119-1 (18.12.2025); EU Environment & Climate, How much recycled material is used in the EU?, https://www.instagram.com/p/DRbvbBrCGqC/ (18.12.2025).

[viii] Eurostat, Exports in recyclable raw materials decreased in 2024, https://ec.europa.eu/eurostat/fr/web/products-eurostat-news/w/ddn-20250424-2 (18.12.2025).

[ix] Eurostat, Exports in recyclable raw materials decreased in 2024, https://ec.europa.eu/eurostat/fr/web/products-eurostat-news/w/ddn-20250424-2 (18.12.2025).

[x] European Council, Council of the European Union, Right to repair products, https://www.consilium.europa.eu/en/policies/right-to-repair-products/ (18.12.2025); European Parliament, Right to repair: Making repair easier and more appealing to consumers, https://www.europarl.europa.eu/news/en/press-room/20240419IPR20590/right-to-repair-making-repair-easier-and-more-appealing-to-consumers (18.12.2025).

[xi] European Parliament, Right to repair: Making repair easier and more appealing to consumers, https://www.europarl.europa.eu/news/en/press-room/20240419IPR20590/right-to-repair-making-repair-easier-and-more-appealing-to-consumers (18.12.2025).

[xii] European Parliament, Right to repair: MEPs want more durable and more easily repairable products, https://www.europarl.europa.eu/news/en/press-room/20220401IPR26537/right-to-repair-meps-want-more-durable-and-more-easily-repairable-products (18.12.2025); European Parliament, Making durable, reparable goods for consumers and tackling planned obsolescence, https://www.europarl.europa.eu/news/en/press-room/20170530IPR76313/making-durable-reparable-goods-for-consumers-and-tackling-planned-obsolescence (18.12.2025).

[xiii] European Commission, Directive on repair of goods, https://commission.europa.eu/law/law-topic/consumer-protection-law/directive-repair-goods_en; European Parliament, Right to repair: Making repair easier and more appealing to consumers, https://www.europarl.europa.eu/news/en/press-room/20240419IPR20590/right-to-repair-making-repair-easier-and-more-appealing-to-consumers (18.12.2025); Official Journal of the European Union, Directive (EU) 2024/1799 of the European Parliament and of the Council of 13 June 2024 on common rules promoting the repair of goods and amending Regulation (EU) 2017/2394 and Directives (EU) 2019/771 and (EU) 2020/1828, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401799.

[xiv] European Union, European Circular Economy Stakeholder Platform, https://circulareconomy.europa.eu/platform/en/strategies/french-act-law-against-waste-and-circular-economy; French Republic, LOI n° 2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et à l'économie circulaire (1), https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000041553759.

[xv] Your Europe, Energy Label, https://europa.eu/youreurope/business/product-requirements/labels-markings/energy-labels/index_en.htm (18.12.2025); European Commission, Ecodesign and Energy Label, https://energy-efficient-products.ec.europa.eu/ecodesign-and-energy-label_en (18.12.2025); Official Journal of the European Union, Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32017R1369.

[xvi] European Union, European Circular Economy Stakeholder Platform, https://circulareconomy.europa.eu/platform/en/strategies/french-act-law-against-waste-and-circular-economy; French Republic, LOI n° 2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et à l'économie circulaire (1), https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000041553759.

[xvii] Tom Heremans and Elisa Le Grelle, The Repairability and Durability Index: a New Challenge for Industry Players, https://www.lexology.com/library/detail.aspx?g=ddfe5879-9a79-4071-ab0d-e7f74bd539b2 (18.12.2025).

[xviii] European Commission, Circular Economy, https://environment.ec.europa.eu/strategy/circular-economy_en (18.12.2025).

[xix] European Commission, Ecodesign for Sustainable Products Regulation: Making sustainable products the norm in the EU, https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en; Official Journal of the European Union, Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401781.

[xx] Your Europe, Energy Label, https://europa.eu/youreurope/business/product-requirements/labels-markings/energy-labels/index_en.htm (18.12.2025); European Commission, Ecodesign and Energy Label, https://energy-efficient-products.ec.europa.eu/ecodesign-and-energy-label_en (18.12.2025); Official Journal of the European Union, Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32017R1369.

[xxi] European Commission, Circular Economy: New rules to boost recycling efficiency and material recovery from waste batteries, https://environment.ec.europa.eu/news/new-rules-boost-recycling-efficiency-waste-batteries-2025-07-04_en (18.12.2025); European Commission, Batteries, https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en (18.12.2025); Official Journal of the European Union, COMMISSION DELEGATED REGULATION (EU) 2025/606 of 21 March 2025 supplementing Regulation (EU) 2023/1542 of the European Parliament and of the Council by establishing the methodology for calculation and verification of rates for recycling efficiency and recovery of materials from waste batteries, and the format for the documentation, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500606; Official Journal of the European Union, Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing Directive 2006/66/EC, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1542.

[xxii] European Commission, Safe and sustainable by design, https://research-and-innovation.ec.europa.eu/research-area/industrial-research-and-innovation/chemicals-and-advanced-materials/safe-and-sustainable-design_en (18.12.2025); Carla Caldeira et al., Safe and sustainable by design chemicals and materials - Framework for the definition of criteria and evaluation procedure for chemicals and materials, https://publications.jrc.ec.europa.eu/repository/handle/JRC128591 (18.12.2025).

[xxiii] European Commission, Circular Economy, https://environment.ec.europa.eu/strategy/circular-economy_en (18.12.2025).

[xxiv] European Commission, Circular Economy, https://environment.ec.europa.eu/strategy/circular-economy_en (18.12.2025).

[xxv] European Commission, Circular Economy, https://environment.ec.europa.eu/strategy/circular-economy_en (18.12.2025).

[xxvi] European Commission, Commission adopts RESourceEU to secure raw materials, reduce dependencies and boost competitiveness, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2891 (18.12.2025); European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, RESourceEU Action Plan, Accelerating our critical raw materials strategy to adapt to a new reality, https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en; European Commission, Regulation of the European Parliament and of the Council amending Regulation (EU) 2024/1252, https://single-market-economy.ec.europa.eu/document/download/be9c88be-bfee-459a-a1d6-f04bd36e1e5f_en; Lisa O’Carroll, EU looks at legally forcing industries to reduce purchases from China, https://www.theguardian.com/world/2025/dec/03/eu-strategy-raw-materials-rare-earths-supply-chain-resourceeu (18.12.2025); Enrico Pascarella, Brussels launches RESourceEU to break free from Chinese raw materials, https://www.eunews.it/en/2025/12/03/brussels-launches-resourceeu-to-break-free-from-chinese-raw-materials/ (18.12.2025); Andreas Budiman, RESourceEU: Militarised mineral strategy will erode rights, pollute our freshwater and increase long-term insecurity, https://eeb.org/en/resourceeu/ (18.12.2025).

[xxvii] European Commission, Circular Economy, https://environment.ec.europa.eu/strategy/circular-economy_en (18.12.2025).

[xxviii] European Commission, New package of measures to boost circular economy and strengthen Europe's plastic recycling, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_3151 (23.12.2025).

[xxix] European Commission, Commission launches consultation and call for evidence for upcoming Circular Economy Act, https://environment.ec.europa.eu/news/commission-launches-consultation-upcoming-circular-economy-act-2025-08-01_en (18.12.2025); European Commission, New package of measures to boost circular economy and strengthen Europe's plastic recycling, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_3151 (23.12.2025).

[xxx] European Commission, Commission adopts RESourceEU to secure raw materials, reduce dependencies and boost competitiveness, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2891 (18.12.2025); European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, RESourceEU Action Plan, Accelerating our critical raw materials strategy to adapt to a new reality, https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en; European Commission, Regulation of the European Parliament and of the Council amending Regulation (EU) 2024/1252, https://single-market-economy.ec.europa.eu/document/download/be9c88be-bfee-459a-a1d6-f04bd36e1e5f_en; Lisa O’Carroll, EU looks at legally forcing industries to reduce purchases from China, https://www.theguardian.com/world/2025/dec/03/eu-strategy-raw-materials-rare-earths-supply-chain-resourceeu (18.12.2025); Enrico Pascarella, Brussels launches RESourceEU to break free from Chinese raw materials, https://www.eunews.it/en/2025/12/03/brussels-launches-resourceeu-to-break-free-from-chinese-raw-materials/ (18.12.2025); Andreas Budiman, RESourceEU: Militarised mineral strategy will erode rights, pollute our freshwater and increase long-term insecurity, https://eeb.org/en/resourceeu/ (18.12.2025).

[xxxi] European Commission, Commission adopts RESourceEU to secure raw materials, reduce dependencies and boost competitiveness, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2891 (18.12.2025); European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, RESourceEU Action Plan, Accelerating our critical raw materials strategy to adapt to a new reality, https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en; European Commission, Regulation of the European Parliament and of the Council amending Regulation (EU) 2024/1252, https://single-market-economy.ec.europa.eu/document/download/be9c88be-bfee-459a-a1d6-f04bd36e1e5f_en; Lisa O’Carroll, EU looks at legally forcing industries to reduce purchases from China, https://www.theguardian.com/world/2025/dec/03/eu-strategy-raw-materials-rare-earths-supply-chain-resourceeu (18.12.2025); Enrico Pascarella, Brussels launches RESourceEU to break free from Chinese raw materials, https://www.eunews.it/en/2025/12/03/brussels-launches-resourceeu-to-break-free-from-chinese-raw-materials/ (18.12.2025); Andreas Budiman, RESourceEU: Militarised mineral strategy will erode rights, pollute our freshwater and increase long-term insecurity, https://eeb.org/en/resourceeu/ (18.12.2025).

[xxxii] European Commission, Commission adopts RESourceEU to secure raw materials, reduce dependencies and boost competitiveness, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2891 (18.12.2025); European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, RESourceEU Action Plan, Accelerating our critical raw materials strategy to adapt to a new reality, https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en; European Commission, Regulation of the European Parliament and of the Council amending Regulation (EU) 2024/1252, https://single-market-economy.ec.europa.eu/document/download/be9c88be-bfee-459a-a1d6-f04bd36e1e5f_en; Lisa O’Carroll, EU looks at legally forcing industries to reduce purchases from China, https://www.theguardian.com/world/2025/dec/03/eu-strategy-raw-materials-rare-earths-supply-chain-resourceeu (18.12.2025); Enrico Pascarella, Brussels launches RESourceEU to break free from Chinese raw materials, https://www.eunews.it/en/2025/12/03/brussels-launches-resourceeu-to-break-free-from-chinese-raw-materials/ (18.12.2025); Andreas Budiman, RESourceEU: Militarised mineral strategy will erode rights, pollute our freshwater and increase long-term insecurity, https://eeb.org/en/resourceeu/ (18.12.2025).

[xxxiii] Council of the European Union, Circular economy: Council and Parliament strike deal on rules for vehicle circularity and management of end-of-life vehicles, https://www.consilium.europa.eu/en/press/press-releases/2025/12/12/circular-economy-council-and-parliament-strike-deal-on-rules-for-vehicle-circularity-and-management-of-end-of-life-vehicles/ (18.12.2025).

[xxxiv] Council of the European Union, Circular economy: Council and Parliament strike deal on rules for vehicle circularity and management of end-of-life vehicles, https://www.consilium.europa.eu/en/press/press-releases/2025/12/12/circular-economy-council-and-parliament-strike-deal-on-rules-for-vehicle-circularity-and-management-of-end-of-life-vehicles/ (18.12.2025).

[xxxv] European Commission, New package of measures to boost circular economy and strengthen Europe's plastic recycling, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_3151 (23.12.2025).

[xxxvi] Boston Consulting Group, Green Economy Surpasses $5 Trillion: New Report Highlights Path to $7 Trillion by 2030, https://www.bcg.com/press/2december2025-green-economy-path-7-trillion-2030 (18.12.2025); Boston Consulting Group, BCG-WEF Project: CEO Climate Leaders, https://www.bcg.com/about/partner-ecosystem/world-economic-forum/ceo-guide-net-zero (18.12.2025); World Economic Forum, The $5 trillion green economy is growing. Here’s how CEOs can turn opportunity into long-term growth, https://www.weforum.org/stories/2025/12/the-5t-green-economy-is-growing-here-s-how-ceos-can-turn-opportunity-into-long-term-growth/ (18.12.2025).

[xxxvii] Eurostat, Exports in recyclable raw materials decreased in 2024, https://ec.europa.eu/eurostat/fr/web/products-eurostat-news/w/ddn-20250424-2 (18.12.2025).

[xxxviii] European Commission, Circular Economy, https://environment.ec.europa.eu/strategy/circular-economy_en (18.12.2025).