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Circular Economy & the Environment

Circular Economy


The new Circular Economy package contains a combination of both legislative and non-legislative elements, such as new and revised legislative proposals on waste, clear targets for waste reduction – such as the common EU target for recycling 65 per cent of municipal waste by 2030 – and proposed actions to “close the loop” and tackle all phases in the lifecycle of a product: from production and consumption to waste management and the market for secondary raw materials. It also contains a list of proposed actions that will target market barriers in specific sectors or material streams, such as critical raw materials, as well as horizontal measures in the areas of innovation and investment.

Critical Raw Materials have also been identified as a priority area in the new package. According to the European Commission, existing EU legislation encourages the recycling of electronic waste, including through mandatory targets; but only high-quality recycling can ensure the recovery of critical raw materials. As a result, the EU is focusing on improving the economic viability of the recycling process and encouraging member states to promote the recycling of critical raw materials in its revised proposals on waste. As a result, the Commission is taking a series of actions to encourage recovery of critical raw materials, including producing a report on best practices and options for further action.

CRM Alliance Position


Enhanced recycling of CRMs in the EU is helpful to reduce import dependency however, in many cases the high technical recyclability of CRMs is jeopardized by insufficient collection and inappropriate pre-treatment of CRM bearing material. In other cases, recycling alone offers very little impact on the value chain as the extraction of CRMs from recycling of alloys may not be commercially viable or attractive due to the low percentage of CRM in the scrap or waste streams. It is important that Waste legislation should not include disincentives for usage of CRMs.



REACH is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can imposed by chemicals, whilst enhancing the competitiveness of the EU chemicals industry. It also promotes alternative methods for the hazard assessment of substances in order to reduce the number of tests on animals.


Currently, the regulation applies to chemical substances which are manufactured or imported into the EU in quantities of 100 tonnes or more per year but with the new phase-in period it will be reduced to 1 tonne or more. It also applies, more generally, to all individual chemical substances on their own, in preparations or in articles (if the substance is intended to be released during normal and reasonable foreseeable conditions of use from an article). As a result, the REACH regulation has an impact on most companies across the EU, even those who may not think of themselves as being involved with chemicals.

According to the European Chemicals Agency, the following economic operators are most likely to be affected by REACH:


  • Manufacturers, even where those economic operators make chemicals to export;

  • Importers of individual chemicals, mixtures for onwards sale or finished products like clothes, furniture or plastic goods; and

  • Downstream users, as most companies use chemicals, sometimes even without realising it, they will generally have some responsibilities under REACH where they handle any chemicals in their industrial or professional activity.


For those companies established outside the EU, they are not bound by REACH, even if their product reaches the customs territory of the European Union. Instead, the responsibility for fulfilling the requirements of REACH, such as pre-registration or registration, lies with the importers established in the European Union, or with the only representative of a non-EU manufacturer established in the European Union.


Other REACH Processes:


  • Evaluation – ECHA and the Member States evaluate the information submitted by companies to examine the quality of the registration dossiers and the testing proposals and to clarify if a given substance constitutes a risk to human health or the environment.

  • Authorisation – The authorisation procedure aims to assure that the risks from Substances of Very High Concern are properly controlled and that these substances are progressively replaced by suitable alternatives while ensuring the good functioning of the EU internal market.

  • Restrictions – tools to protect human health and the environment from unacceptable risks posed by chemicals. Restrictions may limit or ban the manufacture, placing on the market or use of a substance.


(Source: European Chemicals Agency)

CRM Alliance Position


Legislation affecting CRMs should require a socio-economic analysis of any potentially harmful impacts to the supply and use of CRMs on upstream European producers as well as to downstream European supply chains as a first step in the regulatory process.

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