Regulatory Analysis for the EU Circular Economy and Water Facility (DG INTPA) on CRM Recycling and Recovery Partnerships

Critical Raw Materials (CRMs) are central to the European Union’s green, digital and industrial transitions, shaping the competitiveness of strategic industries from clean technologies to automotive, aerospace and electronics. As the EU works to secure sustainable access to these materials, circularity and the recovery of secondary raw materials have become key pillars of its industrial policy agenda. The Critical Raw Materials Act sets ambitious recycling targets, and the forthcoming Circular Economy Act aims to build a more integrated Single Market for secondary raw materials. These sit alongside sector-specific rules on waste shipment, batteries and end-of-life products, which affect how CRM-rich materials circulate between the EU and partner countries.

TULIP Consulting is providing expert advice to the European Commissions’s Circular Economy and Water Facility (CEWF) to support the analysis of this evolving regulatory landscape, with a particular focus on the EU frameworks that shape partnerships with third countries on CRM recycling and recovery. CEWF is a technical and policy advisory service providing clear, timely, flexible and tailored support to the European Commission Directorate General for International Partnerships, and to the partner countries and partner institutions of the European Union, on circular economy and water. CEWF is the successor of the SWITCH to Green and Water Facilities.

TULIP’s role draws on its trade law and policy expertise to help clarify the regulatory environment in which these partnerships operate, identifying both the constraints and the opportunities that EU rules create for investment in circular CRM value chains. Through this engagement, TULIPcontinues a track record of providing expert support to the facilities backing the EU’s circular economy agenda, from its early work with the SWITCH to Green Facility through to its current role with CEWF.