The European Electronics Recyclers Association (EERA) has urged EU policymakers to give a more prominent role to waste electrical and electronic equipment (WEEE) recyclers and secondary raw materials in the proposed Industrial Accelerator Act (IAA), arguing that the legislation does not fully reflect their contribution to industrial decarbonisation and supply chain resilience.
In a position paper released this month, EERA welcomed the objectives and ambition of the proposal, which aims to strengthen European industrial competitiveness while accelerating decarbonisation. However, the association also highlighted a number of gaps, which it characterised as "structural rather than incidental". According to EERA, the IAA's overall framing leans heavily toward primary production without giving equal weight to approaches such as recycling that avoid emissions.
The association noted that recycling contributed to supply chain security and stressed the "distinct position within the circular economy" occupied by WEEE recycling given its role in recovering critical raw materials. According to EERA, neither these contributions nor the emissions avoided through the use of secondary raw materials are adequately reflected in the Commission's proposal.
EERA also argued that recycling facilities face many of the same obstacles as other industrial projects. "The investment gap for building new recycling capacity is significant and permitting delays remain a structural constraint," the association said.
Among its recommendations for targeted adjustments to the proposal, EERA is urging policymakers to explicitly recognise WEEE recyclers as part of Europe's industrial base. It also wants recycling facilities to be eligible for industrial acceleration areas, funding mechanisms and simplified permitting procedures under the proposed legislation. The association further called for lifecycle-based carbon accounting to ensure a level playing field between production routes based on secondary raw materials and those relying on primary inputs. In addition, EERA urged lawmakers to ensure the IAA is aligned with existing and forthcoming circular economy legislation.
The association also pointed to what it described as a contradiction in EU policy, arguing that valuable secondary raw materials recovered from WEEE streams continue to leave Europe despite efforts to strengthen supply chain resilience. EERA said the issue could be addressed through measures supporting investment in EU recycling capacity, the purchase of secondary raw materials recovered in the EU and protection against dumped or subsidised imports.
Although the proposed IAA acknowledges the role of the circular economy and secondary raw materials, this is reflected only in a limited number of provisions. For example, the Commission would be required to consider the use of recycled materials when setting criteria for low-carbon products, and circular business practices are among the many factors member states should take into account when designating industrial manufacturing acceleration areas. EERA argues "circularity must be treated as a core industrial strategy not as a secondary consideration".
Several of EERA's concerns echo recommendations previously put forward by Recycling Europe. The recycling umbrella organisation has likewise argued that recycling should be included among the strategic sectors eligible for streamlined permitting under industrial acceleration areas and has called for stronger recognition of circular materials within the Act's low-carbon and "Made in Europe" provisions.
The Commission presented the Industrial Accelerator Act in March as part of its Clean Industrial Deal agenda. The proposal seeks to increase manufacturing's share of EU gross domestic product to 20 per cent by 2035 through measures including faster permitting procedures, industrial acceleration areas and low-carbon and Union-origin requirements for selected industrial products.
