New EU Circular Economy Act On the Way

This blog was originally posted on 4th February, 2025. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY MICHELLE WALSH, SENIOR LEGAL TEAM LEADER, COMPLIANCE & RISKS

I had the privilege of presenting at the International Electronics Recycling Conference (IERC) on 22 January 2025 in Salzburg, Austria. My presentation focused on the Right to Repair and the Circular Economy, particularly the growing trend of regulations that producers need to deal with across different key regions. 

The conference was informative, eye-opening, and inspiring as different voices of industry went head-to-head on the key issues surrounding the future of e-waste.

Below are some highlights discussed at the conference.

New EU Circular Economy Act

Very exciting news was announced by Guillemette Vachey – EU Commission Policy Officer for DG environment that the EU Commission is working on a New Circular Economy Act.

The purpose of this new Circular Economy Act (CEA) will be to help create market demand for secondary materials and a single market for waste, notably in relation to critical raw materials (CRMs).

This new CEA will also include a revision to the EU WEEE Directive 2012/19/EU which will focus on four main challenges of collection, recovery of CRMs, extended producer responsibility and treatment.

Also announced, was that the EU Commission will deliberately move towards the use of Regulations (which are directly effective in the EU Member States) rather than Directives (which need EU Member State implementation at a national level) to reduce administrative burden and reporting obligations in particular.

The new Circular Economy Act is expected by the end of 2026!

New Amendment to the Basel Convention on Transboundary Movement of e-Waste

Another hot topic under discussion was the new amendment to the Basel Convention on Transboundary Movement of e-waste which entered into force on 1 January 2025.  This amendment means that e-waste (whole equipment, components, most fractions) both hazardous and non-hazardous, are subject to the prior informed consent (PIC) controls. 

The problem is that rather than this being a positive win for the environment, there are major industry concerns over timelines the PIC procedure is going to have on approvals with intra-country shipments in particular being delayed for months. 

Also, the fact the US is not a party to the Basel Convention, and has no intention to ratify this agreement any time soon, is a nightmare particularly for Latin American countries and neighboring islands. 

Other Key Trends

• Complexity, fragmentation, and lack of coherence between global regulations leading to compliance challenges
• Consumer behaviour is changing with the demand for refurnished products and remanufactured products on the rise
• Right to repair could be an opportunity to create strong partnerships between recyclers and repairers
• High concerns over of the risk of fire and safety of batteries in WEEE
• Proposed UN Global Plastics Treaty currently under negotiation by 175 countries on legally binding treaty addressing plastics pollution across full life-cycle of plastics
• Use of AI technology for Waste Sorting Plants (WESORT.AI)
• INCREACE Project – looking at increased use of recycled plastics in value added products
• The medical devices sector has moved back to a linear model rather than a circular model due to risk of contamination and patient health safety risks. (Digital Health in Circular Economy (DiCE project))
• The Royal Mint provided an inspiring example of their sustainable journey from gold coins to using e-waste to create jewellery
• New technologies that can be used for Phase Characterization of E-scrap (Dr. Laurance Donnelly, Alfred H Knight)
• Is plastic really fantastic or not from an environmental perspective?

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