OpenLobby.EU
Explore

Waste Management and Recycling Cluster

WMRC

Cluster as a collection of modern, diverse links between enterprises, scientific world, self-regulatory organisation, administration and business support institutions has been recognized in the EU and the world as one of the proven ways to implement the policy of innovation and is described as one of the most effective instruments of development policy at the level of countries and regions.

Lobbying Activity

Response to Advanced Materials Act

12 Jan 2026

This document presents the position of the Circular Economy and Recycling Cluster a National Key Cluster in response to the European Commissions consu as part of the inception impact assessment for the forthcoming Advanced Materials Act. While expressing overall support for the initiative, the Cluster emphasises that the effectiveness of the Act will depend on its ability to address the entire life cycle of advanced materials, including the systematic and operational integration of industrial recycling capacities. The paper identifies key legal, regulatory and investment-related risks, particularly for small and medium-sized enterprises (SMEs), such as the absence of design-for-recycling principles, legal uncertainty regarding end-of-waste status, administrative burdens and insufficient alignment between technological development and financial frameworks. It concludes with a set of targeted recommendations aimed at ensuring that the Act effectively embeds circular economy principles, supports investment in recycling infrastructure (including first-of-a-kind installations), stimulates demand for secondary raw materials and strengthens the role of SMEs within the European advanced materials value chain.
Read full response