The proposed list seeks to identify waste streams which are rich in CRM and establish national programmes across Member States to recover them for the purposes of the Critical Raw Materials Act.
The association urged the European Commission to ensure the economic validity of the recovery of CRMs as it further develops the draft Delegated Act.
FEAD warned that without careful implementation, the initiative could burden the waste sector and fail to achieve its aims.
It emphasised that several crucial considerations must be addressed to ensure the initiative’s success.
The association added that it is ready to collaborate with the European Commission and Member States to ensure that the waste and recycling industry plays a central role in achieving the EU’s critical raw materials goals.
Economic viability must be a priority
FEAD stressed that national CRM recovery programmes must be economically viable.
While the presence of CRM in waste streams is well-documented, the process of identifying, sorting, and recovering these materials can be technically challenging and financially unrewarding under current market conditions.
The association cautioned against imposing mandatory removal or sorting requirements on waste operators where recovery is not economically feasible.
Instead, it recommended that policy frameworks should provide financial and operational incentives to make CRM recovery commercially attractive.
Call for holistic and supportive national programmes
Under Article 26(1), national programmes are expected to adopt a comprehensive approach covering the entire value chain.
FEAD argued that bridging the investment gap, offsetting operational costs, and supporting the uptake of recovered materials are essential.
Without adequate support mechanisms, CRM recovery will remain confined to a limited number of high-value materials.
FEAD also called for measures to ensure a level playing field between recycled and virgin materials, including financial support schemes and market-based incentives.
The role of producers and Extended Producer Responsibility
The association underlines the critical role of extended producer responsibility (EPR) schemes in enhancing CRM recovery.
It added that existing and future EPR systems for batteries, electrical and electronic equipment (EEE) and end-of-life vehicles must support the downstream recycling infrastructure.
This support should include the funding of sorting, dismantling and CRM extraction processes.
FEAD advocated for the use of ecomodulation to encourage product design that facilitates recycling and prioritises the use of recycled CRM.
Additionally, FEAD pointed out that producers – not waste operators – are best placed to identify CRM-rich components in products.
As such, producers must be the primary focus of stakeholder consultations and should improve product design to facilitate disassembly and material recovery.
Need for policy coherence and harmonisation
FEAD stressed that CRM recovery efforts must align with the broader EU waste policy framework.
It pointed specifically to existing legislation, such as the Waste Framework Directive, the WEEE Directive and the Batteries Regulation.
To support this, FEAD calls for harmonised monitoring tools and guidance from the European Commission.
Support for proposed waste stream list
FEAD said it supported the draft Implementing Act that lists waste streams and components with high CRM recovery potential.
The association notes that the list reflects field data and includes key materials such as:
- Aluminium – found in household appliances, computer equipment, and construction products.
- Copper – present in cables, motors, and incineration bottom ash.
- Rare earths – located in permanent magnets used in electronics and light transport.
- Silicon metals – found in solar panels.
- Phosphorus – recoverable from sewage sludge, agri-food sludge, and separately collected biowaste.
FEAD particularly welcomes the inclusion of waste electrical and electronic equipment (WEEE), end-of-life vehicles, construction and demolition waste, incineration ashes, and sewage sludges – which are already handled by many private waste companies.
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