Deposits, design, and EPR are the three keys to better material recovery in Europe. A new report by the Coordination and Support Office of the Circular Cities and Regions Initiative (CCRI-CSO) sets out policy recommendations for the upcoming EU Circular Economy Act (CEA).
A recurring concern throughout the report is the persistently poor collection performance (from electronic waste to construction materials and textiles), and the question of how policy, financing, and product design can be better aligned to keep more materials in the loop.
Structural bottlenecks
Europe’s circular transition is increasingly shaped by local and regional implementation. Cities and regions manage critical levers such as public procurement, waste management, and innovation ecosystems, yet face three systemic bottlenecks. First, a lack of regulatory coherence: overlapping EU legislation and diverging national interpretations increase administrative burden and create legal uncertainty. Second, a structural investment gap hampers the scaling of circular infrastructure. Third, reliable data and digital systems for monitoring and traceability remain largely absent. Together, these three barriers determine whether circular solutions can be successfully scaled and embedded in the European economy.
Europe’s collection problem
Despite an extensive European regulatory framework, collection systems consistently underperform. The starkest example is electronic waste (WEEE): in 2022, only 40.6% of generated WEEE was formally collected, well below the EU target of 65%. Nearly half of all electronic waste disappears through informal channels, is hoarded by end users, or is illegally exported outside the EU. A similar pattern is visible for construction waste, textiles, and small electronics: the materials exist, but the systems to recover them are failing.
The report identifies three structural causes. First, financial incentives for consumers are insufficient, as long as discarding is free and easy, returning items requires a deliberate extra effort. Second, responsibilities between municipalities, Producer Responsibility Organizations (PROs), and collectors are poorly defined, resulting in gaps in coverage and quality. Third, harmonized safety standards are lacking, which is particularly urgent as lithium-ion batteries are appearing in an increasing number of devices, rapidly increasing fire risks at collection points and sorting facilities.
Deposits as a key instrument
One of the most concrete recommendations is the introduction of deposit-return schemes (DRS) for small electronics such as smartphones, tablets, and laptops. These are precisely the devices most likely to be stored away or disposed of through the wrong channels, despite containing critical raw materials including lithium, cobalt, and rare earth elements.
Under a DRS, consumers pay a refundable deposit at the point of purchase, reimbursed upon return through an authorized collection point. The report stresses that such a system must be carefully designed: with clear interfaces to municipal collection infrastructure, adequate geographic coverage across both urban and rural areas, and mandatory data sharing with local authorities for planning purposes.
EPR as the funding base for safe collection
The report makes a strong case for EPR contributions to go beyond recycling and explicitly cover the costs of safe collection, storage, and pre-treatment. This is urgent: current practice leaves municipalities carrying safety risks and infrastructure costs for which no dedicated funding exists. The revised WEEE Directive should establish minimum standards for risk assessment, staff training, segregation of hazardous components, and fire prevention, and require PROs to finance these costs accordingly.
Design as a precondition for effective collection
Better collection alone is not enough if recovered materials are nearly impossible to separate once collected. The report, therefore, calls for mandatory design-for-disassembly requirements for all electrical and electronic equipment, starting with product groups containing the highest concentrations of critical raw materials. Producers meeting these design standards would qualify for lower EPR contributions. This is a direct financial incentive to build recoverability into the product from the outset.
The report makes it clear that better collection will not automatically follow from more ambitious targets. What is needed is a coherent package: financial incentives that motivate consumers, clear responsibilities that relieve pressure on municipalities, safety standards that manage risk, and product design rules that make material recovery economically viable. Without this combination, Europe’s recycling ambitions will remain little more than words on paper.
Walther Ploos van Amstel.