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Indaver Holding

Indaver

Indaver is a reliable partner to both industry and public authorities for ecologically and economically responsible waste management.

Lobbying Activity

Response to Commission Implementing Regulation on the list for the purposes of Article 26 of Regulation (EU) 2024/1252

10 Jul 2025

Dear Committee As a member of CEWEP and speaking on behalf of Indaver, a pioneer in advanced materials recovery and sustainable waste management, we applaud the European Commission's initiatives to improve the EU's resilience and circularity by identifying waste streams with the potential to recover critical raw materials (CRM), as specified in Regulation (EU) 2024/1252. Regarding Item 8: "Industrial Catalysts" in the current listing, we would like to provide a helpful critique. The lack of further definition for this category at the moment runs the risk of ignoring the variety of ways that industrial catalysts can appear in different waste streams and industries. One important but frequently disregarded source of critical metals is homogeneous catalysts, which are frequently found in liquid industrial waste streams. Advanced chemical recycling technologies, like those created and used on an industrial scale by Indaver, can effectively recover these substances. We encourage the Commission to make sure that the scope of CRM recovery strategies explicitly takes into account all types of industrial catalysts, including those that are dissolved or solubilised in liquid matrices. We propose to define the term "industrial catalyst" in Annex II of the Regulation to encompass both homogeneous and heterogeneous catalysts, paying particular attention to those that are incorporated into liquid or complex waste streams that necessitate specialised recovery procedures. By acknowledging this diversity, the CRM Regulation will be implemented more thoroughly and successfully, waste treatment technology innovation will be encouraged, and Europe's circular economy will be strengthened. We remain at your disposal for further technical input or clarification. Indaver nv
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