Circularity as a pillar of the EU’s critical raw materials strategy: Promises and pitfalls

Circularity has moved from the margins of the EU’s critical raw materials (CRMs) strategy to its core. The Clean Industrial Deal, the RESourceEU Action Plan, and the forthcoming Circular Economy Act represent the most coordinated effort to date to build a functioning circular economy for CRMs in Europe. This policy brief examines both the promises and the pitfalls of this shift.

The brief unpacks key measures across four pillars: i) facilitating the cross-border flow of waste and secondary materials by tackling single market fragmentation; ii) boosting CRM recovery from priority waste streams while creating demand-side pull through tools like recycled-content mandates; iii) retaining CRM-rich materials within the EU through a layered set of export restrictions and monitoring of waste flows; and iv) engaging trading partners through trade agreements and new partnership models.

Yet the promises of circularity come with significant blind spots. The strategy remains heavily centred on recycling, which faces hard structural limits and cannot bridge the gap between surging demand and available secondary supply. The international dimension is comparatively underdeveloped, with partnerships still oriented toward securing primary supply. And the growing use of export restrictions, while in line with a broader global trend of ‘circular resource nationalism’, carries risks of trade friction, unintended environmental outcomes, and a deepening ‘circular divide’ between high-income and lower-income economies. 

Addressing these blind spots will require ambitious action at both domestic and international levels – notably in the context of the upcoming Circular Economy Act – broadening the policy focus beyond recycling, embedding circularity in international partnerships and trade instruments, and confronting the harder question of the EU’s own material consumption.