Legnica, 4th November 2025

ZPPM / 27S / XI / 2025

Position of the Polish Copper Employers’ Association on the legislative initiative on the Circular Economy Act (Ref. Ares(2025)6250342) – DG ENV B3 („From Waste to Resources”) and DG GROW I4 („Sustainable Products”) – draft EU regulation on the circular economy

European Commission

Directorate-General for Environment (DG ENV)
Breydel 2, Avenue d’Auderghem 19 / Oudergemselaan 19
From Waste to Resources (ENV-B-3)

Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW)
Breydel, Avenue d’Auderghem 45 / Oudergemselaan 45
Sustainable Products’ (I4)

1040 B – 1049 Brussels
Belgium

Position of the Polish Copper Employers’ Association on Circular Economy Act (Ref. Ares(2025)6250342.

Title of the initiative: Circular Economy Act – Ref. Ares(2025)6250342; Type of act: Proposal for a regulation; Legislative proposal supported by an impact assessment (Call for evidence – Ares(2025) 6250342)

The Polish Copper Employers’ Association would like to input our feedback in legislative initiative on Circular Economy Act – our point of view is presented to Call for evidence – Ares(2025) 6250342.

In connection with the European Commissions commencement of work on the assumptions for the new Circular Economy Act, Polish Copper Employers Association presents its position below.

The main objective of the new regulations should be to support and develop existing waste management models, increasing the availability of secondary raw materials and removing barriers that limit the competitiveness of enterprises during the transition to a circular economy. In the field of circular economy, member entities of Polish Copper Employers Association focuses on copper recovery from scrap (inc. KGHM), being a national leader and one of the leading companies in Europe.

All copper-bearing materials generated by the KGHM company are processed in its own installations. The smelters in Legnica and Głogów carry out intensive recycling using modern technologies, while the Group develops infrastructure for preparing high-quality copper feedstock. The largest waste stream about 28 million tonnes of flotation tailings annually is managed at the Żelazny Most Tailings Disposal Facility, where it serves as a construction material. KGHM also develops recovery processes enabling the reuse of post-production waste as construction and reclamation materials or abrasives.

A key group of materials includes smelter slags such as shaft slag from Legnica and poured or granulated slags from Głogów. These are used in construction, mining, and industry.

Over the past decade, KGHM Metraco has managed around 10 million tonnes of slag, reducing the need for natural aggregates and preventing landfilling. Slag-based materials have been used in major Polish infrastructure projects such as the S3, S5, S6, and S11 expressways. This practice confirms that smelter slags are valuable materials, not typical waste. However, under current law, the producer must prove that a material is not waste but a by-product or has lost its waste status. This procedure is costly, time-consuming, and unclear, creating barriers to circular solutions.

Polish Copper Employers Association therefore calls for clear and harmonized end-of-waste criteria, especially for metallurgical slags and dusts containing recoverable metals. Such criteria should be defined by regulation, ensuring uniform and practical application. This would help fully utilize the potential of these materials, reduce bureaucracy, and encourage investment in recycling technologies. Facilitating the recognition of end-of-waste status for slags directly supports the European Green Deal, increasing the use of secondary raw materials, reducing landfilled industrial waste, conserving primary resources, and lowering CO emissions. Regarding construction debris and excavated soil.

Polish Copper Employers Association supports introducing into european law a procedure for their reuse, with criteria for loss of waste status established by regulation rather than individual national administrative decisions. This would align with circular economy principles and help achieve the EU goal of 25% secondary material use by 2030. Similar systems already exist in other EU countries. In Germany, under the BGRB guidelines and BBodSchV regulations, recycled construction materials can be classified as products if they meet environmental and technical standards. In the Netherlands, under the Besluit bodemkwaliteit (Soil Quality Decree), rubble and soil can be reused in construction or land reclamation once specific parameters are met, without additional waste permits.

Polish Copper Employers Association recommends adopt comparable, transparent solutions to strengthen the circular economy and promote the sustainable use of industrial by-products.

Yours faithfully

Jarosław Dudkowiak
CEO & President of the Management Board of the Polish Copper Employers’ Association

This position is based on expert opinions and reports from member entities of the Polish Copper Employers’ Association.

The Polish Copper Employers’ Association is the employers’ organization, independent in its operations from state and local government authorities and administration, as well as other organizations. Our organization brings together over 120 employers, employing nearly 38,000 employees. The Association was founded by KGHM Polska Miedź S.A., and our members also include private entities, particularly those in the small and medium-sized enterprise sector, as well as local government companies with no financial ties to the KGHM Group. For nearly 30 years, the Association has been monitoring and reviewing draft legislation relevant to the economy, protecting the rights and representing the interests of employers and entrepreneurs.

Polish Copper Employers’ Association: Transparency register: TR ID 308627025380-23