Beyond Recycling: A Circularity Approach for a Truly Resilient Electronics Supply Chain

Estimated reading time: 4 minutes

Dr. Diana Radovan, director of sustainability policy and sustainability advocacy lead at the Global Electronics Association, has been at the center of some of the electronics industry's most consequential policy discussions, from the European Parliament in Brussels to sustainability summits in Germany and circularity conferences across Europe.

With the European Union's landmark Circular Economy Act moving closer to reality and updates to PFAS regulations, she has been ensuring that the voice of the electronics industry is heard. In this interview, she discusses what's coming, why it matters, why true circularity extends far beyond recycling, and what policymakers still need to do to enable it.

Marcy LaRont: Diana, what are the basic objectives of the European Circular Economy Act?

Diana Radovan: The Circular Economy Act (CEA) is an important focus right now. It aims to transform Europe into a resource-efficient and climate-neutral circular economy. Key objectives include:

• Reducing resource consumption and promoting systematic recycling and reuse of materials
• Minimizing environmental burdens, particularly through waste and CO₂ emissions
• Enhancing the strategic independence of Europe from resource imports and fostering innovative business models within the EU
• Strengthening sustainability by integrating it more closely with competitiveness and innovation
• Fostering resource efficiency and addressing the growing consumption trend

LaRont: Where are you at in the process?

Radovan: We are currently reviewing our position from last year, which was submitted as part of the European Commission “Have Your Say” CEA consultation, to strengthen some of the key messages and address gaps that we see in other discussions with policymakers.

The CEA still risks being overly focused on reducing electronic waste, particularly battery recycling for phones, tablets, and other consumer electronics, while ignoring the needs and realities of a more holistic, supply-chain circularity approach. As the Global Electronics Association, we are uniquely positioned to help de-risk this approach and ensure that all actors in the complex electronics value chain are involved and heard as the CEA develops, from design to end-of-life.

There are several ways, i.e., R-strategies, to achieve supply chain circularity. All these Rs (Table 1) need to be re-emphasized, and the structural barriers in reaching them require careful consideration. Of those, recycling is one of the last resorts. Recycling and other R-strategies are also not possible without design features built in to enable them from the start.

Additionally, although metal recovery can be done without much technical effort and urban mining is quite promising, what we can recover from consumer electronics and batteries (the current topic of focus in e-waste discussions related to the upcoming CEA) is quite limited in terms of economic value. More focus is needed on discussions around PCB(A) recycling.

Moreover, there has to be a market demand for secondary raw materials to encourage their recovery, as well as standards that ensure that technical requirements that high-reliability electronics depend on are met. At the Association, we continue to develop standards that support sustainability and circularity, developed by the industry for the industry, such as those for the repair and modification of PCBAs.

Currently, with a few exceptions, primary (virgin) materials are still cheaper. Moreover, legal definitions of what represents waste and what counts as resource vary broadly across the EU.

Table 1: The 10 Rs of E-waste circularity

LaRont: From your perspective, how is the Circular Economy Act portrayed to industry and society?

Radovan: Some of our members are already achieving impressive results with circular manufacturing, including recovering nearly 100% of certain metals where there is sufficient market demand. The challenge is scaling those successes across the electronics value chain. That requires stronger business incentives and long-term investment.

As we explain in our recent position paper,¹ many circular economy projects struggle to attract financing because they have longer payback periods than traditional linear business models. We also highlight how uneven investment across Europe and fragmented funding programs make it difficult for companies to commercialize new circular solutions. Policymakers can help by supporting the infrastructure needed to automate remanufacturing, repair, and recycling.

Design is equally important. If products aren't designed for disassembly from the beginning, many circular strategies simply aren't practical at end of life. In complex electronics, redesigning products for circularity can take seven to 15 years, making stable, long-term investment essential.

LaRont: It seems quite a task to educate policymakers so they fully understand circularity and how to apply it to electronics and manufacturing. Is that where the Association is making the most significant contribution to the process?

Radovan: Indeed, this is one key element. The Association is uniquely positioned with deep insight into the entire global value chain, including from a design perspective. I believe this is where we can make the biggest difference.

Policymakers seem open to dialogue and aware of some of the challenges, but there is more to be done in terms of advocacy, as well as time pressure, politically speaking, to get this Act out as soon as possible. The real lesson will be the conversations we continue to have with policymakers and all supply chain actors once the Act is out. Last year, the European Commission conducted a detailed survey to help define the pillars, but there’s still uncertainty on what the Act will include.

We need electronics companies that represent the full value chain on board with us as part of that conversation. Because those companies are also still learning what circularity means for them, we have created a circularity resource hub as part of our Evolve program.

References

1.        “Steps Toward a Circular Economy Act for a Resilient Electronics Ecosystem,” Global Electronics Association, July 21, 2026.