Building a critical minerals circular economy: Conceptualising new ways to maximise the potential of extended producer responsibility (EPR)

This paper examines the regulatory mechanisms required to advance circular economy solutions amid the escalating crisis in technology critical minerals (TCMs). The paper's analysis focuses on extended producer responsibility (EPR), evaluating its effectiveness in delivering circularity and exploring how it can be adapted to address new materials challenges raised by the technology transition. Spiralling demand for TCMs, vital for green technologies and other digital and defence sectors, has intensified global trade and tariff tensions while also leading to significant negative environmental impacts. Establishing a TCM circular economy is therefore essential to secure these valuable resources and mitigate the risks of the technology revolution. Drawing on EPR and circular economy theory, this research identifies several challenges that limit the power of EPR to achieve TCM circularity. These include the product-specific and recycling-focused orientation of EPR regulation, collective rather than individual producer responsibilities and weak enforcement mechanisms. Building on this analysis, the paper offers specific recommendations to strengthen EPR and harness its full potential in resolving the TCM crisis.