EU Critical Raw Materials Act: too ambitious or not ambitious enough?
A case study on the implications of the three Critical Raw Material Act proposals on satisfying demand for neodymium in wind turbines more sustainably through recycling in Germany
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Abstract
The mitigation of climate change and the transition to a more sustainable and circular use of resources are two of the largest challenges of our time. To this end, the European Commission proposed the Net Zero Industry Act (NZIA) and Critical Raw Materials Act (CRMA) in March 2023 as further pillars to its Green Deal. While the NZIA focuses on establishing supply chains for net-zero technologies, the CRMA aims to maintain access to the necessary materials. However, these so-called Critical Raw Materials (CRMs), are not only required for net-zero technologies but also for numerous other applications. To ensure their growing demand can be met more sustainably, the European Commission CRMA proposal states that 15% of total CRM consumption in the EU must be satisfied through recycled materials by 2030. In response to the Commission’s proposal and as part of the legislative process, the European Council proposed a more ambitious target of 20% of demand to be satisfied through secondary materials. The European Parliament’s proposal takes a slightly different approach in that it suggests a 45% target for recycling all waste streams, rather than focusing on a set share of consumption.
Given the current dynamic nature of the legislative process, no publicly available literature exploring the extent to which the three proposals can contribute to meeting CRM demand more sustainably could be identified. Hence, the objective of this thesis is to quantify and analyze the implications of each recycling target, leading to the following research question: “How do the Critical Raw Materials Act recycling targets proposed by the European Commission, Council and Parliament compare in their contribution to meeting future demand more sustainably?”. To address this question, a case study on closed-loop neodymium recycling of NdFeB magnets in onshore and offshore wind turbines in Germany between 1989 and 2045 is performed. To map past and expected future neodymium stocks and flows, a dynamic material flow analysis (dMFA) is used. Building on a business-as-usual model without any recycling, explorative scenarios are developed reflecting each of the three CRMA proposals for recycling.
The results reveal that under the expected flow dynamics, the achievement and effectiveness of the targets depends on the time period considered. Because neodymium demand is expected to increase significantly over the upcoming decade, the Parliament’s targets are the most realistic until 2030, given that they are defined relative to actual waste streams. In contrast, achieving the Commission’s and Council’s consumption-based targets is comparably unrealistic, due to the fact that not enough waste streams will be available to satisfy 15 or even 20% of the rapidly growing demand. Extrapolating the targets of the Commission and Council beyond 2030, shows that they are achievable from around mid-2030 onwards. Regardless of the scenario, recycling rates need to increase significantly and rapidly. To meet the Commission’s and Council’s targets in particular, recycling rates of up to 100% until 2035 must be realized. Compared to current recycling rates of below 1%, this appears highly ambitious.
Policy makers are advised to establish targets beyond 2030 and to support relevant stakeholders in creating a recycling infrastructure, both financially and through favorable framework conditions. Future research should explore whether the specific trends observed in this case study also apply to other strategic applications and materials. Moreover, research on how product-life extensions could contribute to decreasing demand for primary materials in the short- to medium-run should be conducted.