The EU is a leading market on the world stage, yet it remains an area of heavy dependence for its raw materials, particularly strategic and critical ones. Aware of this risk, the European Commission had the Critical Raw Materials Act[1] adopted on 11 April 2024, which entered into force the following month: a regulation that draws up a first official mapping of the materials deemed strategic and critical, and that sets targets to secure their supply by 2030. Extract at least 10% of its consumption on European soil, process 40% of it, recycle 25% of it, and no longer depend on a single non-EU country for more than 65% of any strategic material: the ambition is clear. One target in particular remains — that of recycling, the only one of the four that depends neither on geological deposits nor on diplomatic agreements, but on the Union’s capacity to turn its own waste into resources. With less than four years to the deadline, is this 25% target achievable? And can the circular economy really secure European supply in critical materials and become a decisive matter of sovereignty?
A wide disparity in meeting the Critical Raw Materials Act’s targets
The regulation sets a single target — recycle at least 25% of annual consumption of strategic materials by 2030 — but this aggregate figure masks radically different situations depending on the material. Some have already far exceeded it; others are light-years away.
For example, copper today shows an end-of-life recycling rate of 55% in the European Union, the highest of all strategic raw materials[2]. In this particular case, the circular economy is a well-established industrial reality.
Aluminium, whose global production has tripled in twenty years and is today dominated by China (56.7% of world primary production[3]), illustrates a more nuanced situation. Its recycling requires only 5% of the energy of primary production, and it already supplies nearly 60% of French consumption[4]. But this recycling success does not solve the upstream dependence: the Union still imports 87% of its bauxite.
The platinum-group metals, found for instance in catalytic converters, illustrate an even more ambiguous case. Their real recycling rate, across all uses, comes to only 12% of European consumption — less than half the 2030 target2.
At the other end of the spectrum, the rare earths used in permanent magnets — wind turbines, electric vehicles, hard drives — offer the harshest counter-example. Less than 1% of the rare earths present in end-of-life vehicles or electronic waste are currently recycled in Europe[5]. Unlike copper, no binding regulatory framework imposes a recovery rate for these materials. Pilot projects funded by the Union exist — a pilot plant has demonstrated closed-loop recycling with a 50% reduction in climate impact compared with Chinese primary production[6] — but we remain at the demonstration stage, far from an industrial sector. Between copper and rare earths, the gap comes down to the structure of the deposit, the presence or absence of a binding regulatory framework, and the maturity of the sector.
Why will the ambition be difficult to meet?
The European Court of Auditors’ report identifies several structural obstacles common to the entire sector. First, a problem of cost and scale: recycling is today profitable and well established for metals consumed in large tonnages, such as aluminium or copper. It is much less so as soon as a material appears in a product’s composition only as a trace, or is buried in a complex assembly: recovery then often costs more than it brings in2. Next, a problem of critical mass in the face of competition: according to the International Energy Agency, for lack of sufficient volumes, European recyclers struggle to reach the economies of scale enjoyed by their Chinese competitors, which are vertically integrated and backed by a cheaper workforce2.
A more fundamental problem concerns the very design of the European targets. Set in aggregate form, with no distinction between abundant materials and rare materials, they do not encourage recyclers to recover the most critical materials and the hardest to extract: shredded electric-motor components are generally not subject to any selective sorting to extract the rare earths they contain, any more than an automotive electronic component is treated to recover the palladium in it2. Finally, even the free movement of waste within the single market remains hindered: around 90% of waste is today treated in the country where it was produced, which limits the economies of scale needed for the viability of recycling plants2.
The circular economy: a major challenge
Why is the Union so worried about its dependence on raw materials? The 2010 episode stands as a precedent: China, which then accounted for more than nine tenths of world rare-earth production, restricted its exports, sending prices soaring and plunging global supply into shortage2.
This risk does not belong to the past. In April 2025, Beijing made the export of seven rare earths used in the manufacture of permanent magnets — a key sector for wind power in particular — subject to prior authorisation. Between August and early September of the same year, out of 141 applications filed by European companies, only 19 had received a favourable response from the Chinese authorities2. At the same time, demand keeps growing: for the wind sector alone, European demand for rare earths could increase sixfold by 20302.
This is precisely what distinguishes recycling from the regulation’s two other levers. Diversifying imports requires convincing non-EU countries; increasing extraction requires having workable deposits, which is not always the case on European soil. Recycling, by contrast, depends only on the Union’s capacity to organise its own value chain. It is, moreover, a matter of European sovereignty: becoming a leader in the circular economy means offsetting the weakness of our extraction capacities.
The catalytic converter and the lead battery: the nuance hides in the figures
The automotive catalytic converter is a case of technical recycling that has long been celebrated — and with good reason: once it reaches a refiner, the metallurgical yield is excellent, on the order of 92 to 99% for platinum, palladium and rhodium. This success is no anecdote, since the catalytic converter is the world’s leading outlet for platinum, ahead of jewellery and the chemical industry[7]. But this process yield does not show up in the overall statistics: as we have seen, the platinum-group metals show a real recycling rate of only 12% at European level. The gap plays out upstream of refining — according to Johnson Matthey’s market review, the real recovery rate on catalytic converters, in the current so-called “open-loop” recycling circuits, tends to cap at 50 to 70%, and recycled platinum — across all sources — represents only around 23 to 25% of total world supply[8]. In Europe, the theft of catalytic converters and the export of end-of-life vehicles to non-EU countries degrade this figure further.
Lead batteries offer what is probably the most accomplished case. Thanks to a sector organised since the 1990s, structured and highly efficient, the industry shows a high recycling rate for all its components[9]. In the United States, the Environmental Protection Agency (EPA) confirms a combined collection and recycling rate of 99% for end-of-life lead batteries each year[10]. In Europe, an academic study published in the peer-reviewed journal Sustainability, drawing on Eurostat data, shows that most countries far exceed the minimum regulatory target of 65% and that several reach more than 90% material recycling yield[11]. Unlike the platinum-group metals, lead is not dispersed across a multitude of secondary uses that escape collection: the bulk of its consumption remains concentrated on this same application, which explains why the material recycling rate comes so close to the product recycling rate. It is probably the model closest to what the circular economy promises in theory — and it took nearly thirty years to reach it.
The example of the electric battery: a European ecosystem that collapsed before it had really existed
In 2022, the landscape nonetheless seemed written. Sweden’s Northvolt was inaugurating a recycling plant of 25,000 tonnes per year, attached to its own gigafactory in Skellefteå, with the ambition of reaching 50% recycled materials in its new batteries by 2030[12]. This project, named Revolt, was presented as the showcase of “the greenest battery sector in Europe.”
The edifice collapsed in a little over two years. In June 2024, BMW broke a 2 billion-euro contract[13]. Northvolt’s positioning on NMC cells was also weakened by the rapid progress of LFP batteries, cheaper and increasingly preferred in certain market segments[14]. In March 2025, the company filed for bankruptcy and the Revolt project was abandoned in its wake.
This failure was also aggravated by European volumes of batteries and electric vehicles lower than the initial expectations. In 2024, Germany, the continent’s leading automotive market, registered only 380,609 electric vehicles, down 27.4% year on year after the end of purchase subsidies. Norway, by contrast, reached an 88.9% electric market share over the full year[15]. A third factor worsens the picture: even the batteries that were collected saw their value slip away to Asia through the export of “black mass,” the intermediate product of shredding that concentrates lithium, cobalt and nickel — a leak the Commission corrected only in March 2025, by classifying black mass as hazardous waste in order to ban its export outside the OECD[16][17].
This observation is all the more striking in that the proof has been made elsewhere
What makes Northvolt’s failure particularly bitter is that it in no way invalidates the technical feasibility of recycling high-performance batteries — quite the contrary. In China, Brunp, a subsidiary of the giant CATL, processes more than 120,000 tonnes of used batteries per year and posts recovery rates of 99.6% for nickel, cobalt and manganese, and 96.5% for lithium — at industrial scale, not in the laboratory[18]. In the United States, Redwood Materials, founded by Tesla’s former chief technology officer, processes more than 20 GWh of batteries per year — the equivalent of 250,000 electric vehicles, or about 70% of all battery packs recycled in North America — with a recovery rate above 95% for nickel, cobalt, copper, aluminium, lithium and graphite[19][20].
In other words: the question is no longer whether recycling batteries at more than 90% is possible. It is, and it has been demonstrated at industrial scale, elsewhere. What Northvolt’s failure reveals is therefore not a technological limit: the same processes work, at industrial scale, in China and the United States. The difference plays out elsewhere — in the European company’s own trajectory against its competitors.
The precedent of photovoltaics could have prompted the opposite caution
Recent history nonetheless offers an instructive counter-example. For years, a stubborn received idea circulated about solar panels: they were supposedly not recyclable, and would end up in landfill as the installed base aged[21]. This belief long fed scepticism — and, with it, a form of underinvestment in a sector judged doomed to failure before it had even been tested at scale.
Yet the facts ended up contradicting this scepticism: a photovoltaic panel is today recovered at more than 94%, with recovery rates reaching 80 to 90% for glass and 95% for aluminium[22]. The sector was only able to reach this result because certain players — in France notably, with the eco-organisation Soren, formerly PV Cycle — built the collection and treatment system as early as 2014, without waiting to be certain that the technological and economic bet would fully pay off.
The French case is telling: in 2010-2011, the Sarkozy government cut the feed-in tariff for solar electricity, contributing to the collapse of demand and the fall of Photowatt, France’s pioneer in the sector[23]. This political decision came to accelerate a sector already weakened by Asian competition and the rapid fall in panel prices. It nonetheless illustrates how much public choices can affect an industrial ecosystem’s capacity to reach the critical mass needed for its competitiveness[24].
The parallel is direct: on batteries, Europe had the chance to do what solar ultimately proved possible — build the sector before being certain it would hold at scale. But the momentum of the electric vehicle was more modest than expected, because of the reluctance of certain market players or certain national policies. Investment remained more limited in Europe, while others kept investing despite the uncertainty — and today hold the industrial lead on this segment.
The circular economy is not yet at the centre of investment
Northvolt is therefore not an isolated case: several of the same obstacles — fragmented financing, investment delay, absence of binding targets — are found at the scale of the continent. The gap is visible in the regulation itself: in 2024, when Brussels set the target of recycling 25% of strategic materials by 2030, the European sector was already recycling only around 12% of them — so existing capacity would have to more than double in a little under six years to reach it2. Of the 26 raw materials deemed essential to the energy transition, ten are not recycled at any significant scale2.
Financing, for its part, remains scattered rather than concentrated on this challenge: the Union has mobilised around 1.8 billion euros for initiatives linked to critical raw materials over the 2014-2027 period — a sum spread across numerous programmes and directorates-general, whose concrete effects on security of supply the Commission itself acknowledges it does not measure2. The Court itself recommends that the Commission consider binding recycling targets, material by material[25] — proof that the problem is identified at the top of the European apparatus without yet being corrected. The political will exists; its translation into an industrial sector is still to come..
[1]European Commission, European Critical Raw Materials Act, April 2024, https://commission.europa.eu/topics/competitiveness/green-deal-industrial-plan/european-critical-raw-materials-act_en
[2]European Court of Auditors, Special Report 04/2026 — Critical raw materials for the energy transition, December 2025, https://www.eca.europa.eu/ECAPublications/SR-2026-04/SR-2026-04_FR.pdf
[3]IFPEN, Aluminium in the energy transition: what future for this “king of the modern world” metal?, https://www.ifpenergiesnouvelles.fr/article/laluminium-transition-energetique-quel-avenir-ce-metal-roi-du-monde-moderne
[4]INAS France, Aluminium and French industrial sovereignty, anatomy of a reversible dependence, April 2026, https://inas-france.fr/laluminium-et-la-souverainete-industrielle-francaise-anatomie-dune-dependance-reversible/
[5]ADEME Infos, Recycling permanent magnets: a strategic sector, January 2026, https://infos.ademe.fr/magazine-janvier-2026/recyclage-des-aimants-permanents-une-filiere-strategique/
[6]CORDIS (European Commission), Gearing up for high-performance magnet recycling in Europe, https://cordis.europa.eu/article/id/442156-gearing-up-for-high-performance-magnet-recycling-in-europe/fr
[7]Elemental Group, The global platinum supply stands at a critical juncture, September 2025, https://www.elemental.biz/fr/the-global-platinum-supply-stands-at-a-critical-juncture/5793/
[8]Johnson Matthey / World Platinum Investment Council, PGM Market Report, cited in Platinum — Prices, Production, Reserves, Producers, https://hub.truesourcemetals.com/metals/platinum
[9]AFDIB (French Battery Industry Association), Lead batteries: a high-performance circular-economy model, https://afdib.fr/blog/batteries-au-plomb-un-modele-deconomie-circulaire-a-haute-performance/
[10]US Environmental Protection Agency, Battery Collection in Action Case Study: The Lead-Acid Battery Collection Network, https://www.epa.gov/electronics-batteries-management/battery-collection-action-case-study-lead-acid-battery-collection
[11]Sustainability (MDPI), Environmental Impact of Lead-Acid Batteries: A Review of Sustainable Alternatives for Production and Recycling Based on Life Cycle Analysis, https://www.mdpi.com/2071-1050/17/23/10815
[12]Connaissance des énergies, Where do the recycling sectors for electric-vehicle batteries stand?, September 2024, https://www.connaissancedesenergies.org/questions-et-reponses-energies/recyclage-des-batteries-des-vehicules-electriques
[13]L’Automobiliste, Electric car: red alert for the European battery specialist Northvolt, 17 March 2025, https://lautomobiliste.fr/17/03/2025/voiture-electrique-faillite-northvolt/
[14]Journal de l’Automobile, Northvolt throws in the towel and declares bankruptcy, 12 March 2025, https://journalauto.com/constructeurs/northvolt-jette-leponge-et-se-declare-en-faillite/
[15]Le Grand Continent, In Norway, 88.9% of new cars sold in 2024 were electric, 11 January 2025, https://legrandcontinent.eu/fr/2025/01/11/la-norvege-est-sur-le-point-datteindre-son-objectif-de-ne-plus-vendre-de-voitures-thermiques-neuves-dici-fin-2025/
[16]European Commission, Battery-related waste codes update set to boost circular economy, 5 March 2025, https://environment.ec.europa.eu/news/battery-related-waste-codes-update-set-boost-circular-economy-2025-03-05_en
[17]EUWID Recycling, EU classifies black mass as hazardous waste, effectively barring exports to non-OECD countries, March 2025, https://www.euwid-recycling.com/news/policy/eu-classifies-black-mass-as-hazardous-waste-effectively-barring-exports-to-non-oecd-states-110325/
[18]CnEVPost, CATL unit Brunp achieves over 96% recovery rate for recycled battery materials, 22 October 2025, https://cnevpost.com/2025/10/22/brunp-96-recovery-rate-recycled-battery-materials/
[19]Redwood Materials, Battery Recycling — Consumer Program, https://www.redwoodmaterials.com/recycle-with-us/
[20]TSG Invest, Redwood Materials Stock: $6B Valuation — A Buy?, April 2026, https://tsginvest.com/redwood-materials/
[21]Hellowatt, Everything you need to know about solar-panel recycling, April 2025, https://www.hellowatt.fr/panneaux-solaires-photovoltaiques/recyclage-panneaux-solaires
[22]Geodis Énergies, Recycling solar panels: fact and fiction!, August 2025, https://www.geodis-energies.fr/conseils-et-actualites/recyclage-panneaux-solaires
[23]Le JDD, Photowatt: Sarkozy as “firefighter-arsonist”, 14 February 2012, https://www.lejdd.fr/Economie/Photowatt-Sarkozy-en-pompier-pyromane-486622-3224177
[24]Les Jours, Photowatt: the solar crime, https://lesjours.fr/obsessions/solaire-echec-france/ep7-photowatt-edf/
[25]Regulation (EU) 2024/1252 of the European Parliament and of the Council of 11 April 2024 establishing a framework for ensuring a secure and sustainable supply of critical raw materials, OJ L 2024/1252, 3 May 2024, https://eur-lex.europa.eu/eli/reg/2024/1252/oj?locale=fr
