Ragn-Sells: The EU Circular Economy Act could pave the way for a more circular Europe 

In February 2025, the European Commission adopted the Clean Industrial Deal, a roadmap designed to enhance competitiveness and speed up decarbonisation. One of the six pillars of the Deal is the transition to a circular society, with the aim of doubling the circular share of the economy. To achieve this ambition and accelerate the circular transition, the Commission has committed to introducing a Circular Economy Act, expected to be published in 2026.  
 
As part of the process of shaping the Circular Economy Act, the Commission invited Ragn-Sells Group CEO Lars Lindén and Head of Public Affairs & Government Relations EU Tobias Eriksson to join other circular experts at the Clean Industrial Dialogue on Circularity on 2 July.  
 
This is a longer version of the statement given by Lars Lindén at the meeting, outlining the main barriers to the circular transition and presenting solutions for overcoming them. Ragn-Sells looks forward to continuing to contribute to the development of this important legislation.

Statement by Lars Lindén on the EU Circular Economy Act 
 
Dear Vice Presidents, Commissioner, and Circular Friends,  
 
First, I want to congratulate the EU Commission and President von der Leyen for announcing a commissioner responsible for a “competitive circular economy”. 
 
Today, the majority of circular initiatives focus on waste reduction and recycling. However, this will not lead us to a circular economy. Based on our discussions with the European Commission last year, I believe that upcoming policies will increase the demand for recycled materials in the production of new products. Nevertheless, we still need guiding tools that focus on the efficient overall use of resources, material quality, and detoxification. 
 
I represent Ragn-Sells, a family-owned Swedish waste management company that is transitioning to become a resource producer and detoxifier in a future circular economy. In 2015, we began shifting our business away from waste management. To guide this development, we established three fundamental principles to underpin our future business.  
 
These principles are: 

• Reducing the use of virgin resources by providing high-quality materials from urban waste streams. 

• Decontamination of material flows – regardless of their final use. 

• Ensuring a liveable planet, where future generations can thrive. 

We believe that these pillars are essential for the transition to a circular economy, where virgin resources are replaced by recycled materials. The principles are based on the scientific understanding of the planetary boundaries and the flow of materials through society. By creating a circular loop that incorporates proper detoxification, we can counteract violations of any of the nine planetary boundaries that define the safe operating space for human activity on our planet. Today, humanity is transgressing six out of these nine boundaries, with increasing pressure on all boundaries but one – ozone depletion. 
 
To accelerate the shift to a circular society, efficient material use should be made a top priority for policy development at all levels of government. Furthermore, all decisions should be analysed from an Earth system perspective to ensure they are ambitious enough. 
 
The three pillars of a successful circular transition 
 
Reducing the use of virgin resources. 
Every year, approximately 100 billion tonnes of virgin raw materials are used globally. In just five years, the yearly extraction of virgin materials is expected to increase by 10 billion tonnes.  
 
This development has had devastating consequences for both people and the planet. At the same time, outdated regulations and a lack of information about material value chains are preventing us from increasing circularity. In order to curb global warming and stay within the planetary boundaries, we must use our resources as efficiently and as many times as possible. 
 
The KPI announced for the Circular Economy Act, aimed at doubling the share of recycled materials in the economy from today's 12% to 24% by 2030, will contribute to this. 
 
To support the circular transition, Ragn-Sells is investing in new solutions to recover resources from waste streams and deliver high-quality materials that can be reintroduced into the production cycle. 
 
Decontamination of circular flows 
The transition to a circular economy requires both preventing the contamination of future secondary resources with long-lived contaminants such as PFAS and ensuring an extended period of waste detoxification.  
 
At Ragn-Sells, we are committed to protecting our ecosystems and promoting truly sustainable circular practices. We cannot allow hazardous waste to remain in circulation. Therefore, landfills must serve as the detoxifiers and resource banks of society. Over time, we expect the need for recycling and detoxifying contaminated materials to gradually decrease. 
 
Ensuring a liveable planet, where future generations can thrive 
Detoxification is not only vital for us today – it is also our responsibility to future generations to ensure that we do not pass on hazardous substances. Today’s focus on waste minimisation has contributed to persistent contaminants spreading across our lands, our rivers, and our oceans. This must stop.  
 
We also have a duty to safeguard our finite resources so that future generations can continue to produce the food and products they need. Let us not waste our resources through subpar recycling solutions. 
 
What are the main barriers to the circular transition? 
 
Quality versus origin 
Today, the EU is almost entirely dependent on imports to supply its agriculture with phosphorus – one of the key ingredients in fertiliser and animal feed. Relying on an aggressive Russia for input critical to European food security is perhaps the perfect illustration of harmful dependency.  
 
With circular solutions, all the phosphorus currently imported by the EU for animal feed could be replaced by better products sourced from our sewers, provided that the ban on phosphorus recovered from wastewater is addressed. This would significantly reduce climate emissions from agriculture while driving innovation and creating jobs in Europe. 
 
However, today’s non-circular legislation prioritises the origin of materials over their quality. As a result, we are prevented from using high-quality phosphorus recovered from incinerated sewage sludge ash in animal feed, simply because it originates from waste. In fact, we are not even allowed to apply for a testing permit in Europe.  
 
This forces us to turn to other markets. We are now preparing to export our clean product to Canada, the US, or Brazil. At the same time, Europe continues to import phosphorus from countries such as Russia and Morocco – phosphorus that comes with both health and environmental impacts, as well as political risks.  
 
Despite these market barriers, we are now building two phosphorus recycling plants in Europe. My open question to you is: where do you think the next 50 plants will be built? 
 
The waste hierarchy addresses the wrong issue 
The waste hierarchy, which currently underpins all waste regulation in Europe and other developed countries, does not address the right issues. By treating waste as a problem to be minimised rather than a potential source of high-quality resources, the waste hierarchy counteracts efforts to establish large-scale circular flows. 
 
In a circular economy, the priority is not to minimise waste, but to separate valuable resources from hazardous substances, ensuring that only high-quality materials re-enter the production cycle. In line with this, we need to shift from a waste-based logic to a resource-based logic, promoting detoxification and resource recovery instead of waste reduction. 
 
Legal barriers to carbon circular solutions 
We welcome the Commission’s strong commitment to phasing out fossil fuel activities within the EU. We also recognise the Commission’s efforts to create necessary carbon sinks by locking away carbon dioxide through carbon capture and storage technologies. 
 
However, we would also encourage a stronger, parallel focus on supporting innovations that utilise carbon dioxide in the production of materials. Current regulatory and financial frameworks could be reshaped to incentivise such innovations, expanding Europe’s options for creating carbon sinks. 
 
With the right legal conditions, Europe holds great potential to extract key materials, such as silica, aluminium, and magnesium, from waste streams – resources that are all classified as strategic raw materials under the Critical Raw Materials Act.  
 
Today, existing legislation, along with the absence of common carbon management rules, standards, and a sufficient carbon dioxide transportation network, hinders the development of circular innovations that use carbon dioxide as a raw material. With a more supportive legal framework, Europe could even become an exporter of critical materials, such as magnesium, in the future. 
 
How can these barriers be addressed?  
 
Judge materials based on quality rather than origin  
The production of materials may require different conditions and safety verifications depending on whether they originate from waste or virgin sources. However, once quality and safety have been proven, regulations governing the market placement of raw materials should no longer discriminate against products based on origin, as is currently the case. It is unreasonable to allow lower-grade products while banning or restricting higher-grade alternatives simply because they are derived from sources classified as waste.  
 
FEFAC, the EU organisation representing the animal feed industry, and ESPP, representing the European nutrient recovery sector, together with six other organisations, have produced a report highlighting the current barriers and proposing practical solutions.  
 
Replace the waste hierarchy with a strategy for a sustainable supply of raw materials  
A general ambition to reduce waste does not necessarily lead to a resource-efficient, circular economy. Instead, the focus must shift toward reducing the unsustainable extraction of increasingly depleted natural resources by detoxifying and reusing the materials we already have. 
 
Building a truly circular society demands a whole new attitude towards waste, where waste is treated as a valuable source of sustainable resources. This shift requires extensive reforms of legislation and taxes. To enable a successful circular transition in Europe, the waste hierarchy must be replaced with a strategy for a sustainable supply of raw materials that incorporates waste as its primary resource base. 
 
The International Chamber of Commerce has produced a report proposing a new model to facilitate the transition from a waste-based logic to a resource-based logic.  
 
Ensure an equal assessment of the climate benefits of CCUS projects 
To accelerate innovation in carbon capture, utilisation, and storage (CCUS) technologies, all types of carbon dioxide, regardless of their source, should initially be permitted with a clear plan for the gradual phase-out of fossil-based sources. Such a transitional period is necessary to incentivise investments and enable the development and scaling of CCUS solutions. 
 
In addition, the Commission should address the current lack of adequate carbon dioxide transport infrastructure by proposing a legislative package that ensures an open, non-discriminatory, multimodal, and cross-border transport and storage network.