REACH Metals Gateway

Practical example

Circular economy and Climate considerations in an I-RMOa: A Cobalt Metal RMOa


This is a short summary of some aspects of an RMOA in anticipation of potential EU regulatory action on cobalt metal, classified as carcinogen 1B.

The complete example in pdf format is available here.

10 different risk management options were analysed to check if they could address possible risks, whilst enabling the benefits of continued use, recycling and re-use of cobalt metal.
A key parameter in the analysis was that the EU had listed cobalt as a Critical Raw Material, considering the role cobalt substances play in the EU economy and in its transition to a Green Economy.

This example focuses on the Circular Economy and Climate dimensions of this RMOa:



Mass Material Flow


The mass material flow describes where the cobalt comes from and where it is used, as well as its end-of-life situation (such as what is recycled or what may be lost to the environment).

This assessment is essential for the discussion of the circular economy (Pillar II) and climate (Pillar III) dimensions! Indeed, the information provided in the material flow allowed us to understand and determine:

  • Which uses of cobalt contribute to addressing climate change and their relative importance in terms of volume of the cobalt metal placed on the EU market and related exposures,
  • The necessity to make the uses of cobalt metal circular in the EU (end-of-life); in particular, vis-à-vis the fact that 93% of the raw materials from which cobalt is refined are sourced outside the EU.


Circular Economy (Pillar II of the I-RMOA)

An objective requires to look at both the possible assets and drawbacks of cobalt in terms of circular economy, also considering that this metal is on the Critical Raw Materials list of the EU and that as such the EU will in no way be able to survive on local sources of cobalt ever.


  • Infinite recyclability of non-ferrous metals (as thus cobalt)
  • Cobalt is recovered from end-of-life scraps that arise from turbine blades, cutting tools, rechargeable batteries, magnets and spent catalysts.


  • Recycling relies on costly infrastructure
  • Need for more efforts to design products to ensure recyclability
  • Loss of cobalt as an impurity (too low %) in flows of other metals and metal scrap cycles 

Climate (Pillar III of the I-RMOa)

The use of cobalt is crucial for the EU to transform its transportation system, as laid out in the Green Deal. Without cobalt, the ambitions of the green agenda in increasing the usage and production of electric cars will be difficult to achieve. With inadequate or disproportionate risk management of cobalt, a fundamental portion of the Green Transition desired by the EU would be at stake.


By 2050, batteries will be Europe’s major use for cobalt under all the study’s scenarios, with new demand reaching up to 350% of cobalt. From the KULeuven Report




The following proportionality attributes of each of the 10 RMO have been assessed:

  • Effectiveness
  • Practicality
  • Consistency
  • Economic impact
  • Human health and the environment

In this RMO, the human health and environment attribute takes a more holistic view on whether the RMO will lead to an overall improvement in human health and the environment considering, among others, impacts on the climate (e.g., energy consumption and emissions) and on the circular economy (e.g., on recycling and resource consumption).




The 10 RMOs were given a score.  The scoring was then assessed by comparing it with the baseline scenario which reflects the evolution of the situation in the absence of further regulatory action (also called a business-as-usual scenario):


The conclusion was that, compared to the baseline scenario, RMOs 2, 9 and 10 would provide the most benefits, especially when the circular economy and climate dimensions were taken into consideration.



Last page update: 28 November 2023