Over the past two years, the European Union has built, one step at a time, a regulatory framework around a concept that until recently was largely confined to specialist industry reports: critical raw materials.
Copper, silicon metal used in photovoltaic manufacturing, rare earth elements and lithium — together with other strategically important materials such as silver — are essential to Europe’s energy and digital transitions. Yet the EU remains heavily dependent on imports from outside Europe, often concentrated in a single supplying country.
The European Commission sets out the scale of the challenge clearly in the Critical Raw Materials Act: European demand for rare earth elements is expected to increase sixfold by 2030, while demand for lithium could increase twelvefold.
Against this background, increasing recycling capacity is no longer solely an environmental objective. It has become a matter of security of supply, industrial resilience and strategic autonomy.
The first regulatory pillar is Regulation (EU) 2024/1252, the Critical Raw Materials Act, which entered into force on 23 May 2024.
It establishes clear benchmarks for 2030:
For recycling operators, however, the most significant figure is not only the 25% benchmark. The regulation begins to address not just how much material is recycled, but also what is actually produced by the recycling process.
It introduces the first binding information and labelling requirements relating to the recyclability and recycled content of permanent magnets. The initial scope is specific, but the underlying principle is clear and is likely to extend to other materials and product categories.
It also supports the broader transition towards end-of-waste status: the point at which a processed waste stream becomes a genuine secondary raw material with its own recognised legal and commercial status.
The second regulatory pillar is expected in 2026. The European Commission closed its public consultation on the Circular Economy Act in November 2025, and adoption of the initiative is scheduled for this year.
Its stated objective is explicit: to establish a genuine European Single Market for secondary raw materials, increase the supply of high-quality recycled materials and, above all, stimulate demand for them.
This represents an important change in perspective. Until now, European policy has focused primarily on those collecting and recycling waste. From now on, it will increasingly address the companies purchasing and using recovered materials — and the evidence required to demonstrate that those materials provide a reliable alternative to virgin raw materials.
The Circular Economy Act is also expected to include the revision of the WEEE Directive. The European Commission published its evaluation of the existing directive in July 2025, identifying the need to improve collection, treatment, critical-material recovery and market incentives.
This revision directly concerns companies processing end-of-life photovoltaic panels, printed circuit boards, electrical cables and other WEEE streams.
In operational terms, the direction is clear: recycling companies will increasingly be expected to declare — and substantiate — what their processing lines actually produce, rather than what they might produce under ideal test conditions.
This is the same principle behind some of the most widely read articles published on our blog in recent months.
When we explained that photovoltaic panel recycling does not directly produce solar-grade silicon — because that level of purity requires processing in a furnace at approximately 2,000°C followed by treatment in a Siemens reactor at approximately 1,100°C — we were applying this same approach.
The real output of the mechanical recycling process is a silicon-rich concentrate. In the batches analysed by us using X-ray fluorescence spectroscopy, silver concentrations ranged from 2,500 to 4,800 ppm.
By reporting the actual composition of the recovered output, rather than presenting the most commercially favourable interpretation, we were already applying the logic that the European regulatory framework is now beginning to formalise.
It is important to be clear on one point: these figures come from our analyses of specific batches. They are not universal reference values for the industry.
The concentration of silver and other precious metals can vary significantly according to the module manufacturer, production technology and year of manufacture. The quantity that can actually be recovered from a particular batch may produce unexpected results in either direction, even for operators with many years of industry experience.
The same principle of caution applies to copper granules recovered from electrical cables. There can be a substantial difference between a recovery rate declared under laboratory conditions and the result measured after dozens of operating hours with heterogeneous, real-world feedstock.
This is precisely the type of information that existing technical frameworks — including the CENELEC EN 50625 series for WEEE treatment — and future measures under the Circular Economy Act will make increasingly central, verifiable and comparable between technology suppliers.
One interpretation of this regulatory direction is more convincing to us than any other.
For years, we have chosen to report real operating results rather than catalogue figures. We have explained the physical limits of what a recycling plant can achieve and used specific ppm values and percentages instead of relying on generic claims about “high quality”.
We made this choice as part of our commercial positioning. We call it industrial honesty.
With the Critical Raw Materials Act already in force and the Circular Economy Act approaching, this same transparency is gradually moving from an optional competitive advantage to a condition for participating in the European market for secondary raw materials.
Companies that have already built their processes and communications around verifiable data are starting from a stronger position.
Those whose market positioning relies primarily on commercial promises will eventually need to close the gap between what they claim and what a certification body, an industrial customer or European legislation expects to be able to verify.
We remain convinced that the right question in response to every new European recycling regulation is not only what it requires on paper, but what it demands in practice from a plant processing real, heterogeneous material every day of the year.
If you work in photovoltaic panel, electrical cable or WEEE recycling and would like to discuss what these changes mean in practical terms, we are open to a technical conversation.
What is the Critical Raw Materials Act?
The Critical Raw Materials Act is Regulation (EU) 2024/1252, in force since 23 May 2024. It establishes 2030 benchmarks for the extraction, processing and recycling of strategic raw materials, as well as for the diversification of imports. It also introduces initial binding information requirements relating to recyclability and recycled content.
What is the Circular Economy Act, and when will it take effect?
The Circular Economy Act is a forthcoming EU legislative initiative scheduled for adoption in 2026. It is intended to establish a European Single Market for secondary raw materials, increase the supply of high-quality recycled materials and stimulate demand. Its final entry-into-force timetable will depend on the form of the legislation and the completion of the European legislative process. The initiative is also expected to include a revision of the WEEE Directive.
What are critical secondary raw materials?
They are critical raw materials — including copper, silicon metal, rare earth elements and lithium — recovered through recycling processes rather than extracted from primary sources. Recycling can also recover other strategically and economically important materials, including silver.
Why is recycled-material quality becoming a regulatory issue rather than only an industrial concern?
The EU aims to establish a functioning market for recycled materials. Without measurable and verifiable quality standards, industrial buyers have little reason to choose a secondary raw material instead of a virgin one.
Does photovoltaic panel recycling produce silicon that can be reused in new modules?
Not directly. Mechanical recycling does not produce solar-grade silicon ready for use in new photovoltaic cells. Achieving the required purity involves additional high-temperature and chemical refining processes, including treatment at approximately 2,000°C and purification in a Siemens reactor at approximately 1,100°C.
The direct output of recycling is a silicon-rich concentrate. Its principal economic value currently lies in the silver it contains, which can be recovered through hydrometallurgical processes.
31-07-2026
This website uses cookies
We use cookies to improve user experience, analyse site traffic and personalise content. By clicking "Accept all" you consent to the use of all cookies. You can manage your preferences via "Cookie settings". For more information, read our Cookie Policy.
Strictly necessary cookies
Required for the website to function. No consent needed.
Analytics cookies
Google Analytics — anonymous statistics about site usage.
By continuing to browse without making a selection, you consent only to strictly necessary cookies. Read our Privacy Policy and Cookie Policy. You can update your preferences at any time from the footer of this website.
