Sieć Badawcza Łukasiewicz - Instytut Metali Niezelaznych
IMN
Łukasiewicz Research Network - Institute of Non-Ferrous Metals (IMN) is a research centre of the Polish non-ferrous industry.
ID: 493457617613-34
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
Łukasiewicz Research Network Institute of Non-Ferrous Metals (IMN), a leading European R&D Institution, specializing in the processing and recycling of non-ferrous metals, welcomes the European Commissions proposal for a Circular Economy Act. We recognize its potential to strengthen the availability of secondary raw materials, improve the stability of supply chains, and enhance the competitiveness of European industry. However, we would like to point out, that the planned framework must create conditions under which recycling becomes economically viable which is an often problem for a currently working recycling companies. Our position reflects the technological and scientific expertise of our Institute within a key challenges faced by the recycling sector. First and foremost, IMN believes that the recycling industry should not fall under the EU Emissions Trading System (ETS). Imposing carbon-trading costs on recyclers leads to a paradox in which the production of primary materials outside the EU, often in accordance to significantly lower environmental standards, becomes cheaper than material recovery within the EU. This results in the displacement of production processes from the European market and contributes to the outsourcing of emissions to third countries. If Europe aims to secure a competitive and sustainable supply of secondary raw materials, the recycling sector must be supported rather than burdened with additional regulatory costs. Equally important is the strengthening of ecodesign requirements. The Circular Economy Act should introduce more robust and binding rules that oblige manufacturers to design products with their end-of-life phase in mind. This includes ensuring easy disassembly, standardization of components, availability of spare parts, and the possibility of repair and upgrade. Moreover, products should be constructed in a way that facilitates high-quality recycling and avoids the use of combinations of materials that are difficult or impossible to separate. Decisions made at the design stage ultimately determine whether a product can be reused, repaired, or efficiently recycled. This is one of the most important instruments for reducing waste and increase the ratio of recycled materials. In our opinion, the design of the system must also ensure that responsibility for circularity is not shifted onto consumers. End users should not be laden with additional administrative tasks or costs arising from inefficient product design. Instead, companies should be encouraged to adopt reusable packaging, reduce unnecessary plastics, and enable easy self-repairable products. Raising environmental awareness among consumers is another crucial component of a functioning Circular Economy. Many customers still lack reliable information about the origin of raw materials, the environmental impact of manufacturing and disposal, or the realities of the energy and transmission systems that power seemingly clean technologies. Properly implemented Life Cycle Assessment (LCA) should serve as a transparent and practical tool for informing consumers about the real environmental benefits and drawbacks of products over their entire life cycle. Last but not least, we believe that the Circular Economy Act should support the development of European recycling infrastructure and limit the export of waste outside the EU, ensuring that valuable resources and related environmental impacts remain within the European regulatory system. Market and regulatory mechanisms should reward technologies capable of delivering high recovery rates of critical raw materials, and harmonized rules for classifying waste and secondary materials should reduce administrative barriers and improve market efficiency. The Circular Economy Act has the potential to become an important legislative instrument, supporting Europes green transition. However, to be effective, it must truly strengthen the recycling sector and require responsible product design.
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