Analysis of critical raw materials policy for electrical and electronic equipment: Planning for a truly circular economy

The European Union's objectives under the Green and Digital transitions, are contingent on the decarbonisation of essential sectors such as energy, transportation, and communications. At present, the EU does not have sufficient identified mineral resources, nor processing capacity, to supply many of its strategically defined materials. The success of these objectives hinges on the EU's ability to secure a stable and consistent supply of critical raw materials (CRM). Using a systematic three-part assessment of mandated and non-mandated EU policies, European Commission communications, and a review of CRM, the findings reveal that despite efforts to enhance local supply and diversify foreign sources of CRM, there is a lack of cross-sector coherence across social, economic, and technical aspects of recycling. This is further exacerbated by inefficient retention of waste-hosted critical raw materials. Failure to adopt integrative policy measures may result in the EU's continued dependency on undiversified foreign sources for its supply of critical raw materials, thereby compromising its strategic autonomy as well as the goals of the Green and Digital transitions. Improved design of electrical and electronic equipment and processing of waste from these products could conceivably provide a mechanism for a continuous and retained supply of critical raw materials, culminating in a potentially significant resource stream for the Union. The EU can improve resource efficiency, reduce its dependence on imports, and facilitate a truly circular economy by adopting a comprehensive and symbiotic policy framework that quantifies material resources in waste and that recognises the product design stage as an integral facet of the product recycling stage, herein referred to as “forwardcycling”. • Critical raw materials play a crucial role in Europe's twin Green and Digital transitions. • Without accounting for CRM in product manufacturing, the “circular” economy remains linear and unsustainable. • Most CRM within electronic and electrical equipment is ultimately lost beyond recovery, over the lifecycle of the product. • Forwardcycling is a necessary concept in smart manufacturing to address critical raw material retention in WEEE. • Achieving a true circular economy in the EU is a wicked problem.