On 18 November 2024, the International Energy Agency (“IEA”) published a detailed 163-page Report titled “Recycling of Critical Minerals: Strategies to Scale Up Recycling and Urban Mining” (the “Report”). The Report emphasizes the importance of recycling in securing the supply of essential minerals – such as copper, lithium, cobalt, and rare earths – which are needed for the so-called clean energy transition.

The Report underscores the need for robust recycling practices that create secondary supply sources that reduce reliance on mining. The IEA calls for greater clarity on policies and regulations to support the uptake of recycling – particularly of electric vehicle (“EV”) batteries – and sets out nine high-level policy recommendations.

The Report covers the following topics:

  • Current Recycling Landscape: discussing recycling performance indicators, historical trends, and region-specific data for critical minerals;
  • Future Outlook: discussing the potential for secondary supply, focusing on sectors like EV batteries, e-waste, and mining waste;
  • Cross-Cutting Challenges: examining economic, technological, and regulatory hurdles; and
  • Policy Frameworks: outlining strategies to scale up recycling, including regulatory harmonization, financial incentives, and workforce training.

The IEA’s nine policy recommendations set out in the Report are as follows:

  1. Develop comprehensive, long-term policy roadmaps with clear goals;
  2. Harmonize global waste management and recycling regulations;
  3. Strengthen domestic recycling infrastructure through mandates and incentives;
  4. Promote traceability and certifications to increase trust in recycled materials;
  5. Provide financial support for innovation, R&D, and workforce development;
  6. Enhance recycling systems in developing economies with technical and financial aid;
  7. Address data gaps to improve decision-making and investment;
  8. Encourage circular economy practices beyond recycling, such as reuse and refurbishment; and
  9. Mitigate environmental, social, and governance (“ESG”) risks in recycling processes.

For each of these policy recommendations, the Report describes existing policies that address some aspects of the recommendation – such as the EU’s Critical Raw Materials Act (“CRMA”), outlined in our prior blog.

The IEA produced this Report in response to the request by the Ministry of Foreign Affairs of Italy as part of its G7 agenda. The Report calls on policymakers at the national, regional, and global level to take coordinated action to integrate recycling into mineral supply chains for a clean energy transition.

* Created in 1974, the IEA is an intergovernmental organization whose 31 member countries and 13 association countries account for 75% of global energy demand. The core role of the IEA is providing policy advice to its member and association countries to enhance the reliability, affordability, and sustainability of energy.

Photo of Carole Maczkovics Carole Maczkovics

Carole Maczkovics is a market leader in State aid law, with a robust background in the economic regulation of network industries (energy and transport) and in public contracting (EU subsidies, public procurement, concessions).

Carole has a proven track record of advising public and…

Carole Maczkovics is a market leader in State aid law, with a robust background in the economic regulation of network industries (energy and transport) and in public contracting (EU subsidies, public procurement, concessions).

Carole has a proven track record of advising public and private entities in administrative and judicial proceedings on complex State aid and regulatory matters before the European Commission as well as before the Belgian and European courts. She also advises clients on the application of the EU Foreign Subsidy Regulation (FSR) and UK subsidy control regime.

Carole has published many articles on State aid law and on the FSR, and contributes to conferences and seminars on a regular basis. She is a visiting lecturer at King’s College London on the FSR and at the Brussels School of Competition on the application of regulation and competition law (including State aid) in the railway sector. Carole gives trainings on State aid law at EFE, in Paris. She also acts as Academic Director of the European State aid Law Institute (EStALI).

Photo of Sam Jungyun Choi Sam Jungyun Choi

Recognized by Law.com International as a Rising Star (2023), Sam Jungyun Choi is an associate in the technology regulatory group in Brussels. She advises leading multinationals on European and UK data protection law and new regulations and policy relating to innovative technologies, such…

Recognized by Law.com International as a Rising Star (2023), Sam Jungyun Choi is an associate in the technology regulatory group in Brussels. She advises leading multinationals on European and UK data protection law and new regulations and policy relating to innovative technologies, such as AI, digital health, and autonomous vehicles.

Sam is an expert on the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act, having advised on these laws since they started to apply. In recent years, her work has evolved to include advising companies on new data and digital laws in the EU, including the AI Act, Data Act and the Digital Services Act.

Sam’s practice includes advising on regulatory, compliance and policy issues that affect leading companies in the technology, life sciences and gaming companies on laws relating to privacy and data protection, digital services and AI. She advises clients on designing of new products and services, preparing privacy documentation, and developing data and AI governance programs. She also advises clients on matters relating to children’s privacy and policy initiatives relating to online safety.

Photo of Matthieu Coget Matthieu Coget

Matthieu Coget advises multinational companies and governments on EU public policy, trade, and energy matters. With a strong background in general EU law and procedure, he provides strategic advice to clients in a changing regulatory environment.

Matthieu’s practice encompasses all aspects of EU…

Matthieu Coget advises multinational companies and governments on EU public policy, trade, and energy matters. With a strong background in general EU law and procedure, he provides strategic advice to clients in a changing regulatory environment.

Matthieu’s practice encompasses all aspects of EU policymaking and legislative advocacy, particularly in regulating the food and beverage, technology, and industrial sectors, along with EU trade, energy, and economic security policies.