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Ragn-Sellsföretagen

Ragn-Sells

Ragn-Sells is a Swedish waste management company driving the transition to a circular economy.

Lobbying Activity

Response to Circular Economy Act

5 Nov 2025

Ragn-Sells is a family-owned Swedish waste management company, now evolving into a resource producer and detoxifier, focused on driving a future circular economy. Since 2015, we have transformed our approach around three guiding principles: reducing virgin resource use by delivering high-quality materials from urban flows, decontaminating all material flows, and protecting a liveable planet for future generations. These principles are not just guiding, but form the foundation of our shift from waste management to enabling a circular society. We contribute to this transition by pioneering solutions that recover valuable materials from waste - for example, by producing clean phosphorus from sewage sludge, transforming fish waste from aquaculture into energy and fertiliser, and extracting potassium from incineration ash. Ragn-Sells strongly supports the Commissions initiative for a Circular Economy Act. However, to achieve a truly circular economy, it is essential to not only recycle but to stimulate demand for recycled content in new products and ensure the quality of materials recirculated. Upcoming policies must increase demand for recycled content while providing tools that ensure resource efficiency, material quality, and detoxification. This requires the Commission to adopt a holistic legislative approach, with the Circular Economy Act promoting flexible, function-based requirements that support the transition to a circular economy. Waste has traditionally been viewed as a problem, something that needs to be removed, preferably at the lowest possible cost. This has led to waste being treated as an isolated issue and governed by separate legislation. The EU is largely dependent on the import of the listed materials in the Critical Raw Materials Act, for example, most phosphorus mines are located outside of Europe. According to the UN, the extraction and treatment of raw materials are liable for half of the world's climate emissions, 90% of the water shortage, and 90% of the threat to biodiversity. Today's outdated view of waste prevents the extraction of critical raw materials from the waste and thereby secures Europe's self-sufficiency. It also hinders the transition towards a circular economy. Only with a new approach to waste, where it is fully seen as a source of sustainable raw materials, can we tackle both problems at the same time. Europe and the rest of the world have to close the cycles of critical raw materials needed for the green and digital transitions, as well as the agri-food sectors. By closing the cycles, we can contribute to a more resilient agriculture and a safer supply of food and biomaterials, and reduce the extraction of virgin finite resources. Achieving the EUs environmental goals demands that all sectors move towards greater sustainability and circularity. This transformation depends on repeatedly using resources and redefining waste as a resource. Ragn-Sells urges the Commission to shift policy and mindsets from disposal to circular resource use.
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Ragn-Sells seeks CBAM expansion to include fertilizer raw materials

25 Aug 2025
Topic — Consultation on extending the carbon border adjustment mechanism to certain downstream products.
Message — Ragn-Sells supports covering downstream steel and aluminium but wants fertilizer raw materials included. They urge the Commission to prevent producers from importing ingredients to evade costs.12
Why — Expanding the scope prevents competitors from bypassing carbon costs using cheap imported ingredients.3
Impact — Importers of raw fertilizer materials would face new taxes and regulatory requirements.4
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Ragn-Sells urges EU to allow recycled phosphorus in animal feed

23 Jul 2025
Topic — Commission listing products and waste streams with high critical raw materials recovery potential.
Message — Ragn-Sells calls for reviewing legislation prioritizing material origin over quality. They urge the Commission to lift the ban on recycled phosphorus for feed.12
Why — The company could sell its recycled phosphorus within Europe instead of exporting it.34
Impact — Non-EU exporters like Russia would lose market share in the European phosphorus industry.5
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Ragn-Sells urges fair waste sector inclusion in EU ETS

7 Jul 2025
Topic — This consultation evaluates the EU carbon market rules for a 2026 legislative review.
Message — The group requests that waste inclusion does not penalize actors managing toxic substances. They suggest using free allowances and satellite monitoring to ensure accurate measurement and innovation.123
Why — These changes would lower compliance costs and make recycled products more competitive against virgin resources.45
Impact — Manufacturers of non-recyclable goods would lose the benefit of shifting environmental costs onto others.67
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Ragn-Sells calls for circular solutions in industrial decarbonisation act

4 Jul 2025
Topic — The initiative aims to accelerate industrial decarbonisation while supporting European competitiveness and productivity.
Message — The organization argues that the EU should target future support programs toward circular solutions rather than linear processes. They call for legislative reforms to recognize waste as a potential source of sustainable raw materials.123
Why — Prioritizing circularity would unlock significant market incentives for their specific material recovery technologies.45
Impact — Companies relying on traditional mining and linear production methods would lose financial support.67
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Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

20 Jun 2025

Every year, about 100 billion tonnes of raw material is used in the world. In only five years, the extraction of virgin materials has increased by 10 billion tonnes. Since the turn of the millennium, this extraction has increased by 70%, and since 1970 it has tripled. At the same time, only 7.2% of the global economy is circular, meaning that it consists of materials that have already been used rather than relying on virgin materials. In 2018, this number was 9.1%. Despite increased recycling, the world has become less circular at a rapid pace, as the extraction of virgin materials has increased significantly faster than recycling efforts. This development has devastating consequences. Accord¬ing to the UN, the extraction and processing of natural resources account for about 50% of climate change, 90% of biodiversity loss, and 90% of the threat to access to water. As traditional sources of raw materials become increasingly depleted, it takes more and more energy to extract the same amount. Similarly, many other forms of pressure on the planet also increase, such as land use and pollution. Additionally, the production of many crucial raw materials is concentrated in a select few countries. This gives them a disproportionate amount of power and causes problematic dependency on imports for the rest of the world. The EU currently classifies 34 raw materials as critical to its economy. These materials are essential to the EU economy and are often irreplaceable. However, the risk of supply issues is high, for example, due to geopolitical challenges to import. The list has grown rapidly, from 14 materials in 2011 to 34 in 2023. The good news is that relatively small changes to our sourcing of raw materials could have a profound impact. The pledges already made under the Paris Agreement are not enough to keep the world from heating up too much. But just doubling the circular share of the global economy from todays small numbers would limit global warming to well under two degrees Celsius, according to the UN-backed Circularity Gap Reporting Initiative. Consequently, the transition to a circular economy is com¬pletely crucial for humanity. If the world fails to do this, it will be impossible to manage the fight against climate change and several other imminent threats to the planet. Many nations and blocs, including the EU, have committed to transferring to a circular economy and have action plans in place to make it happen. However, the traditional linear economy includes several obstacles to such a transfer. The flawed pricing of raw materials and emissions is one such barrier. When recycling companies are forced to deal with polluted waste streams, the recycled material also becomes more expensive, leading the industry to opt for virgin materials and slowing or halting the transition to a circular economy. Virgin materials do not fully bear the cost they cause through extraction and processing. There is simply no cost to producers associated with the continued extrac¬tion of new materials, even though this practice is respon¬sible for half of the worlds climate emissions. Neither does the price increase as we approach the depletion of the worlds easily accessible resources. The impact of the raw material on issues more challenging to measure, such as local pollution and threatened biodiversity, is, to an even lesser extent, reflected in the pricing of the raw material. Todays outdated view on waste effectively hinders the transition to circular models by imposing legislative or economic penalties on the use of raw materials derived from sources classified as waste. Changing this harmful paradigm and removing unnecessary obstacles to a circular society would be one of the most critical efforts enabling the transition to a sustainable future. Please see the attached document for more information about these barriers and innovative solutions to increase circularity in Europe.
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Meeting with Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall), Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

30 Apr 2025 · Circularity, water resilience

Ragn-Sells urges transforming wastewater plants into resource recovery centres

27 Feb 2025
Topic — The consultation seeks a plan for a water resilient Europe through circular economy approaches.
Message — Ragn-Sells recommends redefining wastewater treatment plants as resource recovery centres that produce raw materials. They advocate for market regulations based on product quality rather than origin. The company also proposes producer responsibility schemes to manage upstream chemical contamination.123
Why — Adjusting market conditions would help the company’s recycled materials compete with cheaper alternatives.4
Impact — Producers of lower-quality virgin goods would lose their market protection over recycled materials.5
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Ragn-Sells urges EU to allow recycled phosphorus in feed

16 Feb 2025
Topic — The consultation seeks a holistic approach to ocean policies and blue economy.
Message — The company calls for updating feed regulations to allow phosphorus recovered from sludge. They advocate for mandatory sludge collection at new aquaculture sites and a focus on product quality over origin.123
Why — This would enable the company to scale its proprietary technology and secure massive European investments.45
Impact — Foreign exporters like Russia and Morocco would lose market share and political leverage over Europe.67
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Ragn-Sells urges EU to recognize carbon stored in products

16 Jul 2024
Topic — Rules for determining when carbon emissions are permanently chemically bound in products.
Message — The organization requests that storage of fossil and biogenic carbon in products be considered permanent under a circular certification framework. They also urge the Commission to clarify which product categories fall under the regulation and their annual production volumes.12
Why — This would resolve business uncertainty and support the commercial viability of their patented carbon-negative technology.34
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Ragn-Sells pushes EU to broaden nitrogen recovery standards

17 May 2024
Topic — European authorities are updating the Nitrates Directive to regulate recovered fertilizer use.
Message — Ragn-Sells wants nitrogen recovered from municipal and industrial wastewater included in the directive. They claim the current focus on only three products limits innovative nutrient recycling.12
Why — Expanding the directive allows the firm to commercialize its proprietary wastewater recovery technology.3
Impact — Traditional chemical fertilizer producers using the Haber-Bosch method face increased competition from recycled alternatives.4
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Ragn-Sells calls for mandatory nutrient recycling from wastewater

6 Mar 2024
Topic — Evaluation of EU rules protecting water quality from agricultural nitrate pollution.
Message — Ragn-Sells wants the Nitrates Directive to promote nutrient recycling from wastewater. They demand legal requirements for nitrogen recovery and incentives for green technology.12
Why — This would increase market demand for Ragn-Sells' circular nutrient recovery technologies.34
Impact — Traditional fertilizer manufacturers using high-emission methods face competition from recycled alternatives.5
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

17 Nov 2023

Summary of Ragn-Sells view on the Commissions proposed revision of directive 2008/98/EC on waste Transitioning to a circular economy is crucial to our ability to mitigate climate change, the depletion of our natural resources, and the risk of overshooting planetary boundaries. According to the UN, the extraction and processing of natural resources account for about 50% of climate change, 90% of biodiversity loss, and 90% of the threat to access to water. If we are serious about creating a sustainable society, we must use the materials we already have, over and over again. Ragn-Sells welcomes the current revision of the Waste Framework Directive but does, however, consider the scope too limited. We believe that a general ambition to reduce the amount of waste does not lead to a circular economy. Instead, the ambition must be the long-term reduction of the unsustainable extraction of natural resources. The waste hierarchy, or any principle aimed at reducing waste in general, needs to be abandoned and replaced with a fundamental strategy for a sustainable supply of raw materials. All production of materials needs to be given the same conditions, regardless of whether it originates from waste or virgin production. Making society circular requires a whole new attitude towards waste, where waste is treated as a source of sustainable resources. Current waste legislation in Europe and other developed countries does not address the correct issues, and thereby counteracting efforts to establish large-scale circular flows. A new definition of waste must therefore be established, allowing more waste flows to be used as sources of raw materials. This requires extensive reforms of legislation and taxes. Virgin materials do not fully bear the cost of their extraction and emissions, which gives them a competitive advantage compared to recycled materials. This skewed market condition needs to be adjusted. The lawful and lucrative use of harmful substances in goods makes many potential material loops impossible. The polluter, who benefits from introducing harmful substances into the system, must pay for them to be taken out of the system. A broader revision of the Waste Framework Directive is needed, which includes a new approach to waste. To enable a circular economy, waste needs to be treated as a valuable source of sustainable resources. We believe that such a review should cover the following three key points: 1. Abandon the waste hierarchy and replace it with a principle based on the society's need for raw materials. Then let the new principle guide a complete review of all relevant policy instruments. 2. Abandon other special waste regulations. Ensure that the same requirements and market conditions apply to all extraction of raw materials, regardless of source, and make it possible to store waste for future extraction. 3. Stimulate the demand for recycled material. Make it profitable for companies to use recycled materials.
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Meeting with Emma Wiesner (Member of the European Parliament)

15 Nov 2023 · Möte: Om hur Sverige kan gå före i en cirkulär framtid

Ragn-Sells urges EU to prioritize nutrient recycling in soil law

2 Nov 2023
Topic — This consultation concerns a new EU law for monitoring, managing, and restoring soil health.
Message — Ragn-Sells calls for a holistic approach that prioritizes nutrient recycling to close nutrient cycles. They advocate for better coordination between overlapping environmental laws to reduce administrative burdens. The organization also demands uniform high standards for all substances applied to fields.123
Why — Stronger polluter-pays rules would make Ragn-Sells' recycled materials more competitive against cheaper virgin resources.4
Impact — Polluters and virgin material producers lose when forced to pay for the waste they generate.5
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Ragn-Sells urges EU to support carbon capture from waste

31 Aug 2023
Topic — The EU is developing a strategy for industrial carbon management and storage infrastructure.
Message — They want to facilitate cross-border transport of waste and include fossil carbon dioxide. The company proposes a labelling scheme for recovered carbon dioxide to boost circularity.123
Why — Classification as permanent storage would improve the business case for their carbon management projects.4
Impact — Mining companies lose market share as recycled ash replaces virgin materials in construction.5
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Response to European Critical Raw Materials Act

6 Jun 2023

The Swedish environmental company Ragn-Sells, active in waste management, environmental services and recycling, converts waste into raw materials that can be used over and over again. Ragn-Sells drives the transition to a circular economy through solutions that reduce the companys own and other actors' environmental and climate impact. Ragn-Sells wants to be living proof that caring for the earth and business go hand in hand. For the EU and its member states to reach the set environmental goals and ambitions, all actors in the society need to move towards increased sustainability and circularity. Some companies, including Ragn-Sells, have taken the lead in the circular transition by investing in and upgrading infrastructure to meet the environmental and sustainability requirements of the future. The transition to a resilient, resource-efficient, climate-neutral and bio-based circular economy requires that existing resources are used over and over again. Ragn-Sells underlines that the Commissions proposed Critical Raw Materials Act is timely and highly important. In general, the proposal contains many relevant and important initiatives. The Commission has, however, chosen to narrow the scope of the proposal, and fails to sufficiently problematise how linear material flows should be replaced by circular ones. It is also worrying that the number of critical raw materials is increasing. The proposals focus on recycling is therefore positive, even though the obstacles to the increased recycling of materials need to be handled much more in depth. General comments A limited proposal. Ragn-Sells considers the scope of the proposal, focusing on technologies important for the green and digital transitions needed to produce modern batteries, limited. The exclusion of other sectors, for example the EU's food sector and materials such as phosphorus, an important but scarce plant nutrient, is a missed opportunity to strengthen the EU's independence and resilience. Phosphorus is today listed as a critical, but not strategic, raw material for the food value chain, meaning it is not covered by the fast-track permitting process or any other benefits that come with being listed as a strategic material. Recycling of raw materials. The list of critical raw materials of particular importance to society and the economy has, although some materials have been removed (indium and natural rubber have been removed from the list of critical raw materials), grown rapidly since it was introduced in 2011 from 14 materials to 34 in the Commission's current proposal. The EU is largely dependent on the import of these materials, as for example most phosphorus mines are located outside of Europe. According to the UN, the extraction and treatment of raw materials are liable for half of the world's climate emissions, 90% of the water shortage and 90% of the threat to biodiversity. Ragn-Sells considers it unfortunate that Europe's need for raw material has to be dependent on the opening of new mines, which affects the climate negatively. Many of the critical and strategic raw materials in the Commissions proposal exist in our waste. Today's outdated view of waste does, however, prevents the extraction of critical raw materials from the waste and thereby securing Europe's self-sufficiency. Only with a new approach to waste, where it is fully seen as a source of sustainable raw materials, can we tackle both problems at the same time. Europe and the rest of the world have to close the cycles of critical raw materials needed for the green and digital transitions, as well as the agri-food sectors. By closing the cycles, we can contribute to a more resilient agriculture and a safer supply of food and biomaterials and reduce the extraction of virgin finite resources.
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Ragn-Sells warns taxonomy rules could block circular economy transition

3 May 2023
Topic — This initiative creates a classification system for sustainable investments in the circular economy.
Message — Ragn-Sells calls for including energy recovery in the taxonomy to avoid financing barriers for waste management. They request removing recycling mandates for old building materials to prevent the spread of hazardous pollutants. The group also advocates for including phosphorus and nitrogen recovery from wastewater.123
Why — Including these activities allows the company to secure green financing for its recycling operations.4
Impact — Public health and environment lose if rigid recycling rules spread toxins from old structures.5
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Ragn-Sells urges EU to certify fossil carbon storage

27 Feb 2023
Topic — The European Commission is proposing a regulatory framework for certifying carbon removals.
Message — Ragn-Sells requests that the EU allow certification of fossil carbon removals. They argue CCUS projects should be eligible for funding regardless of carbon origin. This should occur at least during a transitional phase to foster innovation.12
Why — Access to fossil carbon would provide the resources needed to develop their technology.34
Impact — Environmental efforts are harmed when strict rules block innovations that reduce emissions.5
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Ragn-Sells urges mandatory nutrient recovery from wastewater plants

22 Dec 2022
Topic — The European Commission is revising rules for urban wastewater treatment and disposal.
Message — The organization proposes mandatory recovery rates of 60% for phosphorus and 15% for nitrogen from wastewater. They demand strict rules to remove hazardous contaminants during recycling rather than just diluting them. They also call for removing legal barriers that prevent the expansion and modernization of treatment facilities.123
Why — These rules would allow their recycled products to compete fairly with raw materials.4
Impact — Producers of mined and imported fertilizers may lose market share to recycled alternatives.5
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

The current global economy uses more than 100 billion ton of materials each year. Only 8,6 % of these 100 billion tons is recycled resources the rest is consisting of virgin natural resources. The combined effect and result of current material management are increased concentration of greenhouse gases in the atmosphere, extinction of species and disruption of our biogeochemical systems. There are a number of reasons why recycled materials find it difficult to compete with virgin materials, resulting in the desired cycles not occurring. But the mechanism that then, in practical terms, tilts the playing field in favour of the virgin materials is the same: The incorrect pricing of raw materials and external effects caused by the extraction and processing of the raw materials. Virgin raw materials do not bear the costs they give rise to through their extraction and further handling. Nor does the price reflect the long-term scarcity. Even less does the price of the commodity reflect impacts that are harder to measure, such as local pollution, species extinction and reduced biodiversity. Another clear effect of the dysfunctional pricing is that producers can profitably manufacture and sell products that cannot be recycled, or - even worse - cause pollution further down the chain. They therefore pass the bill on to someone else, completely legally and sanctioned by today's system. This must change by giving full effect to the principle known as the polluter pays: PPP. The principle has not had an effect. Instead of the costs being borne by the producer who uses a dangerous substance, the substances follow along the value chain. In the end, if lucky they end up in waste management system with a responsible recycler, but the majority ends up in the environment in a global perspective. Most of the time, it is therefore the general public that is forced to pay for greatly increased waste management, or cleanup when the levels of unwanted substances locally become high. When recycling companies are forced to deal with polluted waste streams, the recycled material also becomes more expensive, which again leads to the industry choosing virgin materials and the transition to the circular society is stopped. Whoever makes money by selling a product that contains dangerous substances and thus creates a problem for society must bear the costs caused by the problem. It would lead to a change at the producer level, which can save money by ensuring that their products are free of hazardous substances and can be disposed of circularly when they have served their purpose. In a circular system, traditional waste actors are instead raw material producers. Their competence and technology for capturing and phasing out unwanted substances from the cycle is needed to be able to make available raw materials that are mixed up in waste streams. But the costs of that work, of course, end up in the price of the raw material. Therefore, actors who produce virgin raw materials also have to take the costs of keeping society toxic-free and climate-neutral, and charge them to customers who buy the raw materials. The higher the value of a material, the greater the chance that it will be recycled and circulated when the product it is in has served its purpose. Many metals are recycled to a large extent because they have a high value in the next stage. However, it is not possible to push forward circularity by regulating waste alone. As long as no one wants the materials that are sorted out, with the costs of recycling in the price, the cycles do not arise. It is therefore important to understand that all measures to promote increased circularity in the short term must aim to create an increased demand for recycled raw materials. Greater demand leads to higher prices, faster innovation and increased profitability, which makes it attractive to invest in recycling. It also provides incentives for producers to develop products that can be disposed of circularly.
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Response to European Critical Raw Materials Act

23 Nov 2022

The environmental company Ragn-Sells converts waste into raw materials that can be used over and over again. Ragn-Sells drives the transition to a circular economy through solutions that reduce its own and other actors' environmental and climate impact. Ragn-Sells wants to be living proof that caring for the earth and business go hand in hand. Please find our response to this consultation attached. To summarise, Ragn-Sells welcomes the Commission's timely initiative of a European Critical Raw Materials Act and agrees with the objectives stated in its call for evidence, to support the green and digital transition and strengthen EU resilience by securing a sustainable supply of critical raw materials. We especially agree with the identified need for a definition of priorities and objectives for EU actions (objective number one) and strengthening the EUs critical raw materials value chain (objective number three). It is positive that the Commission highlights the need for future EU legislation on the recovery of critical raw materials from waste. We do, however, consider the focus of materials that are essential for components of green technologies, used in digital application, and are crucial to the defence, aerospace, and health industries, too limited. If the Commission is serious about putting forward new legislation on critical raw materials, we find it important that it takes all the benefits that come with extracting resources from waste into consideration. The current fertiliser supply crisis is a result of the shortage of raw materials, such as phosphorus, potassium, and nitrogen. We are facing a shortage in nitrogen fertilisers due to the current energy crisis (natural gas price and supply crisis), as well as phosphate and potassium due to disruptions in international supply chains that impact the EUs access. This leads to high food prices and reduces the unions food security. By including the food and fertiliser sector, as well as adding nitrogen and potassium to the list of critical raw materials, the EU could strengthen its value chains of key fertilisers. We request a recycling-first approach. Ragn-Sells technology could produce 30 % of the EUs annual targeted production of magnesium, minimising the need for new mining of critical raw materials and strengthening the EUs autonomy. Recycling raw materials from waste streams are, however, not sufficiently facilitated or incentivised in current EU legislation. Materials originating from waste are met with market barriers or other administrative obstacles. This results in a lack of investments at a time when these investments are more crucial than ever. We strongly believe that our innovative technology could help the EU strengthen its supply of critical raw materials and, by doing so, ease the dependency on raw materials from third countries. Future actions in the critical raw material action plan should therefore aim at the recovery and recycling of nutrients with high-quality and efficient recovery processes, to increase the EUs autonomy regarding critical raw materials.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Miltton Europe and Ragn Sells AS

10 Oct 2022 · Preparatory meeting for a broader exchange with interested Cabinets on Ragn-Sells OSA project for circular economy

Meeting with Frans Timmermans (Executive Vice-President) and Ragn Sells AS

19 May 2022 · Presentation of circular OSA project on the recovery of resources from oil shale ash waste deposits

Meeting with Asger Christensen (Member of the European Parliament)

31 May 2021 · pure nutrients from sewage sludge