EU and Recycling of Critical Raw Materials: Stuck in Legal Limbo?
Topi Turunen, Johanna Suikkanen (Finnish Environment Institute, SYKE)
Many policy documents have called for a higher degree of circularity in the use of critical raw materials (CRMs). This paper examines how this objective has been translated from EU policy to legislation. The analysis presents three regulatory strategies used in the current framework to promote the recovery of CRMs: indirect methods, direct regulation of single CRMs, and collective regulation of all CRMs. The indirect approach has struggled to effectively target CRMs. Direct regulation of single CRMs provides an alternative, but other than the new Batteries Regulation no legislation has introduced strong obligations requiring recovery of single CRMs. The proposed CRM Regulation would codify the main concepts relevant for governing and regulating CRMs collectively. While the legislation would create a solid foundation for these processes, its failure to put forward immediate or long-term solutions to CRM recovery remains a serious shortcoming. The present research indicates that the current legal obligations lack a focus on the recovery of CRMs, with concrete obligations to this end limited.
European Energy and Environmental Law Review
Volume 33, Issue 3 (2024) pp. 139 – 149
Building scenarios of urban sustainability for critical raw materials
Katri Valkokari (VTT) and Anna Aminoff (Hanken)
The paper aims to build scenarios for increased circulation of critical raw materials (CRMs) in the context of urban sustainability transformations, using the Dator’s Manoa School Four Futures framework and a participatory workshop. As a result, he configured four scenarios illustrate the diverse trajectories and associated challenges and opportunities for CRM circularity and urban sustainability. The limitations of the scenario analysis, such as the need for further validation and action planning with relevant stakeholders, and the potential bias of the workshop participants are acknowledged. The paper aims to contribute to the literature and understanding of urban sustainability transition and circularity of CRMs, and to inspire new research openings by demonstrating the interconnections and related dynamics of transition.
16th NESS – Nordic Environmental Social Science Conference
Circularity of critical raw materials – a case study of supply chains in the e-bike industry
Anna Aminoff (Hanken) and Katri Valkokari (VTT)
This study aims to address the gap between recognized importance of critical raw materials and limited number of empirically grounded analyses by focusing on the e-bike supply chains, a sector less mature than electric vehicles but influenced by upcoming EU regulations. The paper examines how organizations within the e-bike supply chains align with CE practices concerning CRMs and the tensions they face. The findings reveal the nascent adoption of circular strategies in e-bike supply chains. The collection of batteries, organized under extended producer responsibility, emerges as a key strategy. However, the study also brings to light inherent tensions between circular strategies and among different actors
36th Annual NOFOMA Conference of the Nordic Logistics Research Network
“Something like this the industry has been waiting for” A plot handover as a tool for market formation for circular building
Tommi Halonen (Tampere University) & Erkki-Jussi Nylén (Finnish Environment Institute, SYKE)
Initiating circularity to the building industry has been one of key subjects in the circular economy (CE) transition. In our case study, we have analyzed a plot handover as a particular policy instrument that can accelerate transition to circular building. In Finland, municipalities have zoning monopoly, and through plot handover procedure municipalities can assign plots for building companies mostly based on their considerations (e.g., local policy goals, price, market situation). The study was done in collaboration with City of Tampere (225 000 inhabitants). In summer 2022, Tampere decided to utilize a plot handover procedure in a form of competition to get construction companies to design circular building concepts in an attractive plot for the companies.
Our findings show that 1) competition call defined and operationalized the CE in a clear enough manner which guided partner and building material acquisitions but left plenty of room for innovation. In relation, 2) the city’s choice to utilize competitive evaluation criteria over pre-defined requirements made companies explore more broadly the possibilities of circular building and partners for the project. 3) Building companies understand sustainability demands are increasing change pressure for the industry, but still the sector is driven by profit margins. The plot handover competition of valuable piece of land provided companies a change test their value chains and cost-benefit analyses in a new and temporary setup. Finally, the competition was not organized in an immature setup. Instead, circular solutions have been contemplated in the sector and companies felt confident enough to draft and submit their concepts to the competition. This indicates that 4) timing was right for this type of coordinative measure. In conclusion, a single well-timed policy intervention can accelerate transition process even in a case of single building in a single city. Whether the transition occurs depends on what happens next, but the case analyzed here has the potential to act as an important acceleration event.
15th International Sustainability Transitions Conference, Oslo, Norway, 17—19th of June
Conference paper:
Navigating tensions in circular ecosystem development: a case study of slow-the-loop and close-the-loop strategies in the Finnish e-bike ecosystem
Authors: Bruno Garcia de Oliveira and Anna Aminoff, Hanken School of Economics
Abstract: This paper investigates tensions both within and between slow-the-loop (StL) or close-the-loop (CtL) strategies in the early stages of a circular ecosystem. The study applies an embedded case design and investigates the e-bike ecosystem in Finland. We interviewed the main actors of this ecosystem and performed a qualitative data analysis. First, we identified tensions within both StL and CtL strategies. We aggregated tensions into three categories: e-bike design, operation logic, and e-bike users. Second, we propose that alternative circular strategies can become oppositional poles in the early the stages of ecosystem. Based on paradox literature and a polarity map, we discuss how the emerging ecosystem needs to shift from either/or to both/and thinking to develop circular strategies.
Poster presented at Critical Materials in Circular Economy of Cities (Romulus) seminar 2024 (10.4.2024):
The European Union and Recycling Critical Raw Materials: Stuck in Legal Limbo?
Author: Topi Turunen SYKE
Link to poster [PDF]
Master Thesis:
Circular Business Models for increasing critical raw materials circularity in urban environment – Case E-Bikes
Timo Kaivonen, LUT
Abstract: Having secured access to Critical Raw Materials is extremely important to the economy and security of Europe since those materials are needed in a variety of goods and key technologies which are used every day. To address this issue, EU´s Critical Raw Materials Act aims to ensure the EU’s access to a secure, diversified, affordable and sustainable supply of CRM. This thesis is done for VTT as part of a research project which focuses on creating sustainable pathways for cities by increasing the circularity of Critical Raw Materials. The case product for the study is E-bike, with a focus on the entire lifespan of the bike and the life cycle of components containing Critical Raw Materials, namely battery and motor. The theoretical part focuses on exploring the Circular Strategies (10R) and Circular Business Models at the organizational and ecosystem level. By qualitative research with semi-structured interviews total of 13 organizations within the E-bike ecosystem are studied. The research identifies the current Circular Strategies and the opportunities and challenges prevailing in the ecosystem. Cities can play a significant role in increasing material circularity through their procurement, such as when purchasing urban e-bike systems. Increasing material circularity requires extensive collaboration among ecosystem actors, which, in turn, requires the sharing of data, knowledge, and expertise across organizational boundaries. Cities should proactively initiate collaboration. According to the results, many actors simultaneously implement Circular Business models to both slowing and closing material loops. The 10R framework is considered a useful tool for identifying and analyzing interdependencies prevailing in the ecosystem.
Link to Master Thesis [PDF]
Conference paper:
From policies to circular innovation – critical raw materials in cities
Ensuring secure and sustainable supply of critical raw materials (CRMs) is at the core of EU’s political priorities for the twin transition. This requires innovations in enhancing circularity of these materials. The cities could have an important role supporting transition on a variety of business ecosystems. In this study, we explore the means cities have identified to boost circularity of critical raw materials. Supported by a conversational AI tool (Bard), we first analysed how CRMs are considered in the circularity agendas of cities. The results showed that the current focus lies at end-of-life phase of products and recycling. The second phase was an interview based deep dive into the innovation potential and drivers and barriers related to circularity of CRMs. At the landscape of CRMs, the cities have both direct and indirect influence on circularity. Circular procurement and Public-private-partnership (PPP) can directly affect circularity while training and education can be efficient indirect actions.
Authors: Arnold M., Petänen P. and Valkokari K.
Presented at: ISPIM Connects Salzburg – The Sound of Innovation. Lappeenranta University of Technology, LUT Scientific and Expertise Publications: Reports, ISPIM Connects Salzburg, Salzburg, Austria, 11/12/23.
https://cris.vtt.fi/en/publications/from-policies-to-circular-innovation-critical-raw-materials-in-ci
Conference presentation:
Urban symbiosis concepts for sustainable circular loops of CRMs containing products
In response to the pressing need for resource conservation, especially critical materials in high-tech products, this paper addresses the challenges hindering the transition to a circular economy. This paper explores new sustainable value co-creation models between multiple actors in cities for increasing the circularity of selected high technology products, containing critical raw materials (CRMs). Focusing on e-bikes as a case study, which heavily relies on critical raw materials (CRMs) for components like batteries and motors, the research explores innovative value co-creation models among various city actors to increase circularity. The study emphasizes the potential of networked business models, examining their optimization and operationalization for closer loops of CRMs. By aligning with the 9R framework, the paper identifies emerging business opportunities and the role of public actors, particularly cities, in supporting environmentally and socially sustainable circularity. The findings unveil diverse circular supply chain configurations that promote urban symbiosis, contingent on contextual conditions for effective implementation.
Authors: Arnold M. and Valkokari K.
Presented at: Rethinking Value – Resources For Planetary Wellbeing – World Resource Forum ‘23, Geneva 4-6.9.2024
Urban symbiosis concepts for sustainable circular loops of CRMs containing products — VTT’s Research Information Portal
Kriittisten raaka-aineiden kiertotalous EU:n politiikkatavoitteena
Suikkanen, Johanna & Turunen, Topi (2023), Suomen ympäristökeskus
Kriittisten raaka-aineiden kiertotalous EU:n politiikkatavoitteena (helsinki.fi)
The circular economy of critical raw materials as an EU policy objective
To make headway in the green transition, the European Union has drawn attention to the availability of critical raw materials, both virgin and recycled ones. Circular economy has been proposed as a solution for improving the availability of raw materials needed for the green transition. This report discusses the extent to which EU policy objectives and actions encourage the circular economy of critical raw materials. The report is based on a document analysis of European Commission communications (COM) and related staff working documents (SWD). The documents illustrate the policy objectives, outlined actions and legislative proposals as well as the challenges associated with critical raw materials.
Since the EU Raw Materials Initiative was published in 2008, critical raw materials management policy has evolved in different policy areas, including raw materials policy, circular economy, industrial and economic strategies and strategic action plans on mobility and batteries. During the period under review, numerous communications outlining objectives and measures have been published which look to the circular economy for improving access to critical raw materials. In particular, the lists of critical raw materials (2011, 2014, 2017, 2020, 2023) and the communication and legislative proposal on critical raw materials published on 16 March 2023 point the direction for objectives set out in other documents. Three legislative processes of particular importance are currently ongoing in the EU: the proposals for an Ecodesign Regulation, Battery Regulation and Critical Raw Materials Regulation. Each of the proposed regulations contains new policy instruments that can promote the recycling of critical raw materials in the future.
Promoting the circular economy is one of the objectives in managing critical raw materials that comes up consistently in different policy areas. The main goal is to promote the recycling of critical raw materials in the internal European market and the availability of recycled materials. The proposed regulations mainly focus on recycling certain critical raw materials found in batteries and, under the Critical Raw Materials Regulation, also in permanent magnets. Additional requirements may be expected in the future as the Ecodesign Regulation and the Critical Raw Materials Regulation are implemented. Proposed non-legislative policy instruments include standards for recycling, RDI funding and pilot projects, competence development, and exploring and exploiting the resources contained in waste. Together these measures lay the foundation for promoting the circular economy of critical raw materials in the EU.
Oikeudelliset käsitteet, sääntelyobjektit ja ympäristösääntely
Turunen Topi, Ympäristöjuridiikka 1/2023, s. 34–51.
Kuvaelma artikkelista: Ympäristö- ja terveydensuojelua käsittelevä sääntely kohtaa jatkuvan haasteen vastata uuteen tieteelliseen tietoon. Tunnistetut ympäristöongelmat ovat entistä monimutkaisempia, ja tämä asettaa haasteita sääntelylle. Jotta sääntelyllä voitaisiin suoraan puuttua eri ongelmiin, on ongelmat ensin pystyttävä kääntämään sääntelyn kielelle. Esimerkiksi mikromuovien säänteleminen on ollut hankalaa, koska ei ole yhtenäistä käsitystä tai määritelmää sille, mitä mikromuoveilla tarkoitetaan. Voidaankin katsoa, että oikeudellisilla määritelmillä ja käsitteillä on olennainen asema ympäristöongelmien hallinnassa: Ne voivat muuttaa alun perin ei-oikeudelliset ilmiöt hallittaviksi sääntelyobjekteiksi. Sääntelyobjekti on ensisijaisesti – institutionaalista tai reaalista – ilmiötä kuvaava edustus, ei itse ilmiö. Oikeudellisen hermeneutiikan käsitteistön näkökulmasta sääntelyobjektilla tarkoitetaan normipremissin kannalta merkityksellistä faktapremissiä, jolle voidaan antaa lainopillisen metodin kautta oikeudellinen merkityssisältö. Kuitenkin sääntelyobjektin normiulottuvuus itsessään määrittää linssin, jonka kautta arvioidaan, onko jokin seikka oikeudellisesti merkityksellinen vai ei. Oikeudellinen merkitys voi syntyä kun ilmiö käännetään oikeudelliselle kielellä antamalla lainsäädännössä uusi määritelmä, joka luo perustan sääntelyobjektin syntymiselle, tai kun jonkin olemassa olevan määritelmän katsotaan soveltuvan kyseiseen ilmiöön ja sille voidaan antaa merkitys sitä koskevien normien kautta. Joka tapauksessa oikeudellinen merkityksellisyys rakentuu aina muiden merkitysten kautta. Tämä kirjoitus tarkastelee sääntelyobjektien asemaa sekä niihin liitettäviä merkityssisältöjä ympäristöoikeudellisessa sääntelyssä ja ympäristöongelmien hallinnassa.
Conference paper: Towards Urban Symbiosis of critical raw materials – a conceptual paper
Regions and national economies are facing several challenges regarding raw materials. As cities and metropolitan areas are increasingly becoming hubs of economic activity, they may also play a role in addressing raw material challenges. Many eco-industrial parks are not only found in industrial areas but also in urbanised areas the concept of urban symbiosis may offer viable solutions to those challenges. Urban symbiosis builds on urban and regional metabolism and industrial symbiosis, providing a concept and analytical toolkit that can serve to develop strategies to create the more efficient use and circulation of critical raw materials (CRM), enabled by the integration of different and complex systems. In advancing urban symbiosis it is important to understand what kind of roles cities can have in the urban symbiosis as well exploring concrete models of collaboration and new ways of joint value creation in urban symbiosis ecosystems.
Authors: Maria Antikainen (VTT), Mona Arnold (VTT), Päivi Kivikytö-Reponen (VTT), David Lazarevic (SYKE)
The paper was presented at KES-SDM conference in Split, Croatia, September 2022
The full paper is available here.
Conference paper: Increasing circularity of high-tech products by multi-stakeholder value optimisation
The work explores new sustainable value creation models in cities for increasing the circularity of selected high technology products containing CRMs. The focus was on CRMs in smart buildings and their renewable energy solutions.
In the short-term perspective, enabling increased recycling of batteries and solar panels can have the largest impacts on circularity. To ensure increased circularity in the future, other options, such as leasing combined with takeback systems, reuse, maintenance, repair and refurbishment, other sharing models should be considered for optimal resource use, and lifespan extension for critical materials. Cities can take a considerable stronger role in promoting such strategies, notably by, firstly, applying them on public buildings and construction and generally incorporating circularity criteria more strongly in their procurement.
Authors: Mona Arnold (VTT), Päivi Kivikytö-Reponen (VTT), Maria Antikainen (VTT)
The paper was presented at ISPIM Connects-conference in Athens, Greece, November 2022.
The full paper is available here.
Webinar: Project presentation
In this video, Maria Antikainen (VTT) gives a presentation of the Urban Symbiosis project, and presents the first project results.
Webinar: What are the main tensions in the Circular Supply Chain?
In this video, Bruno Oliveira (Hanken) presents the results of a literature review discussing “What are the main tensions in the Circular Supply Chain?”.
Based on a Paradox lens, Bruno presents four clusters of tensions in the Circular Supply Chain: Product and Business Model; Knowledge and Skills; Stakeholder Collaboration; and lack of Policy and Standards. The results can help practitioners concentrate on finding alternative pathways for a more circular future.