APPG Critical Minerals UK Circular Economy Meeting – 2 July 2025

On 2 July 2025, the All-Party Parliamentary Group (APPG) for Critical Minerals convened to explore the essential role of the circular economy in securing the UK’s critical mineral supply chains. With the government’s new Critical Minerals Strategy expected imminently, the session brought together industry leaders, policymakers, academics, and regulators to examine how circularity can enhance national resilience by conserving resources, protecting the environment, and reducing reliance on opaque and volatile international markets. 

Chair of the APPG, Noah Law MP, opened the session by highlighting the extensive cross-departmental collaboration underway, particularly the work led by the Department for Environment, Food & Rural Affairs (DEFRA) on a forthcoming Circular Economy Strategy. Noah emphasised that while international trade partnerships remain important, especially with the EU, the strategic value of advancing domestic circularity for national resilience should not be overlooked. Key gaps identified included reducing barriers around waste certification, adopting a more robust tailings processing, and modularising key products and applications of critical minerals, an area which, if optimised, could “really tip the balance of our ability to deliver a truly circular approach.” 

Industry Insights 

Iain Gulland, CEO of Zero Waste Scotland (ZWS), underscored the growing environmental and economic imperative of circular approaches in “solving the supply challenge” of critical minerals. ZWS, a public body supported by the Scottish Government, works across resource-heavy industries vital to the green transition, delivering circular economy programmes and policy guidance to over 300 businesses, communities, and devolved governments.  

Initially inspired by the potential to redeploy materials from decommissioned oil and gas infrastructure to onshore and offshore wind farms, ZWS are exploring how to rewire the current economic model to build renewable supply chains. Iain emphasised the need for further data gathering and materials mapping beyond wind farms to expand UK-wide infrastructure, “mainstream circularity for businesses”, and ultimately reduce demand for virgin materials. He also called for coordinated and focussed innovation by universities and research institutions to enable product design that supports repair, restoration, and refurbishment. He noted that while waste is a devolved matter, key legislative action will likely occur at the UK-wide level.  

Academic Perspectives  

Frances Wall (Camborne School of Mines) discussed two circular economy roadmaps recently launched by the Circular Economy Centre for Technology Metals (Met4Tech) in partnership with the British Geological Survey, several universities, and a wide range of stakeholders. Part of a £30 million United Kingdom Research and Innovation (UKRI) initiative, the roadmaps focus on lithium-ion batteries and rare earth magnets — critical components in driving the UK’s industrial and net-zero ambitions. Frances stressed that circular economy thinking must encompass the entire value chain.  

While end-of-life recycling is significantly valuable for material retention and in need of immediate support, she described it as a “loop of last resource” and warned that relying on it alone will fail to “hold materials at the highest value.” She underscored the urgent need for better data, comprehensive lifecycle assessments, and the development of product passports to trace and track materials through use, reuse, and recycling. Frances also highlighted the importance of increased investment in research and development (R&D), particularly in remanufacturing and disassembly, and pointed to product-as-a-service business models as effective levers for advancing circularity. 

European Experience  

During the open discussion, Julie-Ann Adams, CEO of the European Electronics Recycling Association (EERA) and Secretary General of the European Battery Recycling Association (EBRA), provided an industry perspective on regulatory hurdles facing recyclers. One of the most pressing issues, she said, is the long lead time — often 3 to 5 years — to obtain a recycling permit in the EU and the UK, which threatens global competitiveness. Julie-Ann advocated for reframing “waste” as “secondary raw materials” to reflect their recovery potential and value and, in many cases, their superior quality due to lower contamination levels.  

“Technical feasibility and economic viability” remain major challenges despite being essential for success, with EU operations often 1,500% more expensive than those in China or on the global market. This is due to the higher energy costs, higher compliance obligations for health and safety, environmental protection etc. and higher wages. Product passports, she noted, are of limited use to recyclers due to the limitations of QR codes and the sheer volume of material processed. Complementary infrastructure is needed to identify the Critical Raw Material (CRM) content of recycled material. She recommended incentivising greater knowledge sharing between recyclers, who are often commercially centred; increasing investment in data gathering to anticipate future material demand amid emerging battery chemistries; and prioritising the recycling of commercial and industrial equipment such as MRIs.  

Strengthening Domestic Resilience 

Julian Hetherington, Director of Automotive Transformation at the not-for-profit Advanced Propulsion Centre (APC) UK, is dedicated to facilitating funding to domestic R&D projects developing net-zero technologies. He highlighted that most recoverable material currently derives from manufacturing process scrap rather than end-of-life products, making domestic retention a priority. Without “speculative support measures to bring metallurgical processes to the UK,” long-term export contracts — likely ultimately circling back to China — for black mass (processed batteries for recycling) will prevail, undermining efforts to build domestic recycling capacity.

Global Outlook 

The conversation then turned to geopolitical considerations. Libby Peake (Green Alliance) voiced concern over the global trend toward resource nationalism and stockpiling of critical minerals — practices that only wealthy nations can afford and which risk leaving others undersupplied. While she acknowledged this as an “understandable tendency,” she warned it’s a “dangerous road to go down” given the zero-sum dynamics that could hinder global decarbonisation efforts. Libby endorsed the government’s narrative of “fighting climate change together” and advocated for equitable access to critical materials and a more balanced distribution of supply, potentially through a global clean power alliance. Julian (APC UK) expressed that, in some cases, strategic stockpiling may be necessary to appropriately manage geopolitical risk rather than for managing price volatility which interferes with market operation, illustrating the delicate balance required between national resilience and international cooperation. 

Left to right: Simon Tillotson (ERM), Frances Wall (Camborne School of Mines), Perran Moon MP, Iain Gulland (ZWS) 

UK Challenges and Opportunities  

Additional challenges were raised around gaining access to mine tailings which remain a significant opportunity in the recovery of CRMs and support the proper management in mitigating risks such as chemical contamination and long-term environmental impact. Cultural heritage protections also remain a barrier to further exploration at certain sites. Providing a regulatory perspective, Graham Winter (Environment Agency) reiterated that regulations exist to protect people and the environment, not to obstruct progress, and reflected a growing appetite for better alignment with broader objectives in the UK’s critical minerals strategy.  

Thomas Kelly (Ionic Technologies) pointed to the difficulty of competing with Chinese suppliers, arguing that market forces alone will not resolve supply constraints. He called for stronger government measures to stimulate domestic demand and diversify supply, easing the pressure of volatile prices on manufacturers.  

Julie-Ann (EERA & EBRA) echoed this, endorsing a “carrot and stick” approach, such as mandating recycled content in sectors that produce/manufacture products thus incentivising a circular approach and use of the materials being recovered from waste. She stressed that material “needs to return to the industry it came from.” She also highlighted that the UK’s hazardous waste incurs costs and creates an international disadvantage. In response, Jeff Townsend (Critical Minerals Association (UK)) questioned what steps industry must take to help government fundamentally rethink the definition of “waste.”  

Mark Richards (Rio Tinto) proposed that in addition to new mines, the UK should consider leveraging existing ores, infrastructure, and permits. He cited one of their facilities in Sorel-Tracy, Quebec, which could be capable of supplying 20% of the world’s scandium as a byproduct of titanium dioxide production. Sarah Gordon (Satarla), highlighted the UK’s exemplary performance in recycling platinum group metals (PGMs), showcasing the outcome of well supported circularity. A notable example is Johnson Matthey, the world’s largest refiner of secondary (recycled) PGMs, which extracts and recovers PGMs from complex products and refines them to commercial grade-purity.   

Closing Reflections 

The meeting concluded with reflections from Simon Tillotson and Nick Hilton of Environmental Resources Management (ERM), who summarised the circular economy as a core design principle, not merely an afterthought. They urged stakeholders to look beyond material recovery and embrace a broader vision of regeneration that prioritises long-term sustainability, effective resource management, and economic resilience. 

As the UK continues to navigate an increasingly complex and competitive global environment for critical minerals, circularity represents both a strategic opportunity and a responsibility. Given its multi-faceted nature, it warrants continued discussion and offers numerous topics for exploration in future sessions. This meeting made clear that coordinated action across industry, academia, and government will be essential, supported by innovative policy, sustained investment, and a willingness to rethink how we value the materials that power our modern world.  

Policy Recommendations

1. Reassess current definitions of waste and develop strategies to enable 'waste' materials to be recognised and utilised as valuable resources. 

2. Support and streamline permitting processes to accelerate recycling infrastructure development. 

3. Encourage circularity within businesses by expanding economic incentives and access to public and private funding opportunities. 

4. Collaborate with manufacturers and fund R&D to encourage business models based on modular design and ease of disassembly.  

   
   

If you’d like to know more about the Critical Minerals APPG or attend future events, please contact jeff@criticalmineral.org or eileen@criticalmineral.org. 

This article was written by Elliott Trickey, Political Analyst at CMA (UK), and Gaia Rogers, Communications, Events & Public Affairs Intern at CMA (UK).