The EU aims to reduce its dependence on imports of critical raw materials and secure supply for the green transition. However, according to a new report from the European Court of Auditors, it is far from certain that these targets can be achieved with the current initiatives.
Batteries, wind turbines and solar energy are among the technologies the EU considers essential for both the energy transition and increased strategic autonomy.
Critical raw materials such as lithium, cobalt, nickel, copper and rare earth elements are key components in many of these technologies, and demand is therefore expected to increase significantly in the coming years.
In the short term, this will lead to increased mining and extraction of virgin materials. However, a substantial share of the raw materials the EU is seeking is already present in products currently in use – or in waste streams such as electronic waste.
“If Europe is to reduce its dependence on imports of critical raw materials, it is also necessary to look at the resources already embedded in products on the market,” says Morten Harboe-Jepsen, CEO of Retur, of which Elretur is a part.
Recycling rates remain low
The report from the European Court of Auditors, published on 2 February 2026, shows that recycling rates for many critical raw materials remain well below the EU’s own ambitions.
The EU’s Critical Raw Materials Regulation sets a target for at least 25% of the consumption of strategic raw materials to come from recycled sources by 2030.
The EU has identified 34 critical raw materials, of which 17 are classified as strategic due to their importance for, among other things, the energy transition, digital infrastructure and supply security.
However, the report shows that recycling rates in practice remain far below this level for many materials.
According to the report, seven of the raw materials that are central to the energy transition are currently recycled at rates of only 1–5%, while ten are not recycled at all.
At the same time, the European Court of Auditors points out that the EU’s recycling targets are largely input-based. This means that the targets primarily focus on the total volume of waste collected or treated for recycling. As a result, a system can meet recycling targets without necessarily recovering the critical raw materials themselves.
In addition, the report highlights a lack of economic incentives to extract materials that are technically difficult or costly to recover from waste streams.
“There is therefore significant potential in the products already placed on the market. However, current European systems are largely designed to handle waste volumes – not necessarily to ensure that critical materials are actually recovered,” says Morten Harboe-Jepsen.
Electronic waste holds a key part of the solution
Electronic waste contains significant amounts of critical raw materials.
However, collection rates for waste electrical and electronic equipment (WEEE) remain below the targets set out in the WEEE Directive.
As a result, valuable materials are effectively lost.
At the same time, the WEEE Directive does not necessarily ensure that critical raw materials in electronic products are actually recovered. The directive primarily focuses on the collection and treatment of waste as a whole, rather than the recovery of specific materials.
The European Commission has therefore issued recommendations to Member States and initiated infringement procedures against several countries that fail to meet the collection targets.
“This is an example of how regulation sometimes measures the wrong things. We are good at measuring how much waste we collect, but not necessarily how much of the critical raw materials we actually bring back into the economy,” says Morten Harboe-Jepsen.
Reuse can extend the value of materials
Electronic waste does not only contain materials, but also products that in many cases are still functional.
In the waste hierarchy, reuse ranks above recycling. When products can be tested, repaired and returned to use, both their functionality and materials are retained in the economy for longer.
In Denmark, Elretur is working with this approach through the country’s first reuse facility for electronics, Electronic Reuse and Recycling, which we established in collaboration with HJHansen in 2025.
At the facility, products are extracted from the waste stream, repaired, and prepared for reintroduction to the market with a warranty.
Experience shows that far more products than previously assumed can be reused – not only traditional products such as smartphones and computers, but also vacuum cleaners, toys, sports watches and small household appliances. The facility is expected to recover around 100,000 electronic products from the waste stream annually.
“When we extend the lifetime of a product, we not only preserve the materials. We also preserve the energy and resources already used to produce it,” says Morten Harboe-Jepsen.
Market challenges for recycling
The EU is seeking to address the challenge of securing resources by diversifying imports, increasing European production and strengthening the recycling of materials.
However, according to the report from the European Court of Auditors, progress is hindered by a number of structural challenges – including a struggling European recycling industry.
A lack of economies of scale and global market conditions make it difficult for European recycling companies to compete with players in, among others, China, where companies are often vertically integrated and operate at a larger scale.
At the same time, rules governing the transport of waste mean that around 90% of waste in the EU is treated in the country where it is generated. This can limit the development of more efficient and specialised treatment structures.
A stronger focus on circularity
The EU has already introduced a range of initiatives aimed at strengthening circularity in the economy.
This includes, among other things, requirements for improved information on product material composition through ecodesign regulations. The objective is to make it easier to repair, dismantle and recycle products.
However, according to the European Court of Auditors, significantly stronger efforts are still needed if the EU is to secure sufficient access to the raw materials required for the green transition.
The EU’s ambition is to reduce Europe’s dependence on imports of critical raw materials.
But the report from the European Court of Auditors points out that this will require more than new targets and strategies. It will also require better utilisation of the resources already embedded in products and waste streams across Europe.
Because critical raw materials are not only found in mines – they are also found in products already placed on the market.
