Secondary materials – such as recycled waste and industrial by-products – can and will replace more and more virgin resources in a circular, resource-efficient, sustainable, future-proof EU-economy.

Due for adoption later in 2026, the EU Circular Economy Act has the potential to boost the EU economy, the material independence of its important supply chains, decarbonisation of industrial products and protection of natural resources through a functioning internal market for secondary raw material.

“A real circular economy will give Europe a sustainable competitive advantage,” said Anita Gianelli, Industry and Process Manager for at Eurima, the representative association of all major European mineral wool insulation producers. “Europe is well placed to become the global leader in recycling and circularity but still a lot needs to be done to address remaining bottlenecks and ensure the right policy-framework conditions. Therefore, the Circular Economy proposal will come at a pivotal moment.”

“Removing barriers – of an economic, regulatory and technical nature – to a real European single market for secondary raw materials needs to be the first step to enable increased recycling of construction products such as mineral wool insulation at scale”.

Accounting for more than 10% of the EU’s GDP and nearly one-third of industrial employment, the construction sector is vital to Europe’s economy, to the Green Deal, the Clean Industrial Deal, and to emerging circular economy ambitions.

As Eurima explains in a new position paper, the recovery of construction materials from deconstruction and renovation is a first essential step to creating a strong European market for secondary raw materials. Yet, it remains a huge challenge for stakeholders in the EU: including the construction sector.

Without a functioning internal market for secondary raw materials, there is today too little incentive to use these valuable resources. At the same time, the lack of data makes it very difficult to obtain a clear picture of the actual situation we have across the EU.

• Harmonised thinking

Alongside high quality data to access high quality waste, Eurima’s members see the need to align thinking in the interface of chemicals and waste policies within the single market, among other key EU initiatives. “This is the missing link,” said Silvia Herranz, Sustainability and Technical Manager at by Etex.

“Instead of allowing key EU legislative initiatives to work against each other, Europe should be harmonising rules and stimulating investment, including through predictable market signals,” she continues.

Caterina Rocca, Rockwool Group Regulatory Affairs Director and Vice President of Eurima agrees that “to fully enable a functioning European market for secondary materials, harmonised definitions are essential. Only with clear and consistent terminology can companies and policymakers align efforts to close material loops and develop robust circular value chains. Circularity can only succeed if a coherent and consistent EU regulatory framework is aligned with local ecosystems of coordination and cooperation”.

“It is undeniable that there is a need aligning local, regional, national and EU level work. The EU needs to “support and promote” the development of a circular economy, including through the exchange of knowledge between Member States and local authorities, according to Anita Gianelli. But at the same time “there needs to be room for tailor-made solutions adapted to the situation of each country and region to choose the best measures,”

An important step is to make a clear distinction between recyclable waste and non-recyclable waste to ensure high quality and manageable sorting. Inspiration can be found in work-ongoing at Member-State level.

Austria offers one existing example within a specific regulatory context. Its granular waste code classification system identifies wastes such as mineral wool insulation by type and disposability characteristics. This approach reflects national conditions and offers valuable lessons that can inform developments also in other contexts.

Other pilot projects, such as the first local Extended Producer Responsibility (EPR) system for construction products in France, provide additional context-specific insights – particular on waste collection, sorting, cleaning, and related logistics. These initiatives are still evolving and should be understood as exploratory rather than definitive models.

At regional level, Flanders is also moving towards requiring more granular categories for the separation of construction and demolition waste with implementation expected from 2027 onwards.

Although these developments must be considered in their country-specific frameworks, they collectively signal a broader move towards increased granularity in the material-specific management of construction and demolition waste.

• Clear thinking

A strong European market for secondary raw materials must build on an updated mindset, supported by the use of targeted public awareness raising and behavioural campaigns, as alongside the needed policy and industry developments.

This means removing regulatory barriers to recycling, at the same time as maintaining the high environmental and health standards for which Europe is famous.

For the mineral wool insulation sector, putting together a coherent, cross-cutting legislative framework across the EU would scale-up recycling and the development of robust markets for secondary raw material, in a true circular economy.

Recycling has for a long time been central to the best practice of enabling industries such as ours but “the facilitation and integration of circular economy practices as fundamental building block of our EU business-models and economy has for too long not been enough at the centre of EU thinking. The EU Circular Economy Act will be a game-changer, hopefully… ” as Anita puts it.

“It’s time to close the loop in a true circular economy.”