Gestamp Automoción, S.A.
Gestamp
Gestamp es una multinacional especializada en el diseño, desarrollo y fabricación de componentes metálicos de alta ingeniería para los principales fabricantes de vehículos.
ID: 369731496244-65
Lobbying Activity
Response to Circular Economy Act
3 Nov 2025
Gestamp welcomes the Circular Economy Act as a landmark initiative to accelerate Europes transition toward a more resource-efficient economy. As a global automotive supplier and one of the largest users of steel and aluminium, we strongly support its ambition. At the same time, its effectiveness would increase by giving greater emphasis to the unique role of metal scrap in the circular economy. 1. Metal Scrap as Secondary Raw Materials, Not Waste While waste may apply to many end-of-life streams, steel and aluminium scrap must be treated differently: they are strategic secondary raw materials. Recognising this distinction simplifies cross-border procedures and strengthens Europes resilience by reducing reliance on imported primary resources. What may appear discarded is, for industry, a valuable input. Managing scrap as a resource reinforces the circular economys industrial base. 2. Differentiating Between Materials Uniform rules cannot reflect each materials characteristics. For many, recycling is complex, costly and leads to quality loss. Metals recycle efficiently through mature processes with minimal property degradation. Steel and aluminium already achieve high recovery rates and balanced markets. The Act should acknowledge these differences and design measures that leverage metals advantage, ensuring traceability and large-scale reintegration into value chains. 3. Preserving Value, Not Just Recycling Volume Circularity is not only about reducing waste but about preserving materials intrinsic value. High-grade steel, essential for safety components, should stay in cycles that maintain its quality rather than being downcycled. Scrap should be treated as a high-value resource whose integrity is retained through successive uses. The Act should move beyond quantitative targets and promote quality-driven recycling that allows metals to return to high-performance applications. 4. Balancing Circular and Linear Realities Vehicles remain in service for around 14 years, so there is no direct match between new production and available scrap. The Act should support a balanced coexistence of linear and circular models, recognising that circularity strengthens gradually and complements existing industrial flows. 5. Circularity as a Driver of Decarbonisation Circularity is a key enabler of Europes climate goals. In sectors where decarbonisation is difficult, such as steel and aluminium, using scrap cuts emissions substantially compared with primary production. Yet todays market price does not reflect this benefit. The Act should include mechanisms to value and reward the carbon savings of recycled metalsthrough fiscal incentives, carbon credits or certification systems. Frameworks such as mass-balance accounting in renewable electricity could guide how recyclings emission savings are recognised, highlighting the role of automotive manufacturers in reintegrating secondary materials. Such tools would boost investment in scrap use, support industrial decarbonisation and enhance Europes competitiveness. Conclusion Gestamp supports the ambition of the Circular Economy Act. For it to succeed, metal scrap must be recognised as a high-value enabler of circularity and decarbonisation, not as waste. By differentiating materials, prioritising quality, balancing linear and circular realities and reflecting emission savings in recycled inputs, the Act can evolve from a waste-management framework into a lever for industrial competitiveness, innovation and sustainabilitystrengthening Europes circular economy and its long-term resilience.
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