GSMA和Connect Europe：关于《循环经济法案》的立场文件

CirculareconomyintheTelecommunicationssector November2025 The GSMA and Connect Europe welcome the European Commission’s efforts tosupport thetelecommunicationssector’s transition towards a more circular economy, notably through thepublication ofthe strategy of the Clean Industrial Dealand its reference to the New Circular EconomyAct, the revision of theWEEEDirective and the Green VAT initiative.Increasing the circularity of theICT sector benefits consumersandcompanies,the environment, and theregion’s competitivenessand strategicautonomy. Theamount of electrical and electronic equipment put on the market in the EU rose from 7.6 milliontons in 2012 to 14.4 million tons in 20221.At the same time, thevolume of electronicwastegeneratedhasgrownby 2% each year, while less than 40% of electronic waste iscollectedin the EU2. For most Europeantelecom operators, themajority of their total carbon emissions–across theiroperations andvaluechains–come fromthe manufacturing and the supply chain of electronic andelectrical equipment (such as smartphonesandnetwork equipment)3.Increasing the circularity ofnetwork equipment and devices can play a key role in reducing emissionsand environmentalimpactsacross the value chain4. GSMA research showsthat consumersincreasinglywant–and benefit from–circular devices andservices5.Companies providingmorecircular products and services are also seeing many businessbenefits, including revenue growth, supply chain resilience, andgreater customer loyalty. At the same time, the current linear economycontinues toincrease demand forstrategically importantmaterials and minerals such as copper, lithium, cobalt,rare earth elements,and other critical minerals.These minerals are essentialcomponents ofclean energy technologiesand ICT hardwaresuch aselectric vehicles,batteries, wind turbines, data centres, and networking equipment. In a world marked by increasing geopolitical tensions and growing competition overthe supply,processing,andaccess to critical raw materials, theEU isincreasingly looking at how to ensure mineraland energysecurity through diversifying supply and securing domestic resources. This iswhythecircular economyisessential: itserves as a keyleverfor telecom operatorstotacklevalue chainemissions,while alsooffering asolution tothe growinge-wasteproblemandstrengtheningthe EU’s mineral security.Moving away froma“take-make-use-dispose” model and transitioning to amore circularmodel is essential to keep resource consumption within planetary boundaries. In acircular economy, the value of products, materials and resources is maintained in the economy for aslong as possible, and the generation of waste isminimised.Usingand consuming in a more circularway can substantially reduce the impacts ofdigital technologies onthe environment, whilealsoenhancing theEU’scompetitiveness andsecurity. Simplifying rules and obligations, alongside advancing digitalisation, is the right path forward—especially as many existing barriers stem from overlapping or conflicting requirements. For these reasons, GSMA and Connect Europe welcome the New Circular Economy Act, the review ofthe WEEE directiveandwould welcomethe Green VAT initiativewhich canserve as an effectiveincentive system. I-The revision of the WEEE directive The telecoms industrysupportsthe primary goals of the existing Directive on Waste from Electricaland Electronic Equipment(WEEE)from 2012.Preventing the generation of WEEE, promoting resourceefficiency, and enhancing the environmental performance of all parties involved in the EEE life cycle.However,telecom operatorsconsider thatseveralelementscould be improved to facilitate betterfunctioning and promote easier exchanges in the circular economy, such as: A-Harmonisethe WEEE collection systems within the EU In the WEEE management chain, the waste holder (i.e.telecomoperator) is supposed to collect thewaste from the different sites and customers,andthentransportit to the Producer ResponsibilityOrganisations (PRO)responsible forits treatment (sorting, dismantling and recovery). After thetreatment, the PRO is supposed to report to thetelecomoperatordetailsof the treatment results:tonnage received from the telco operator, type and outputs of the recovery operations (energy/rawmaterials, reuse). However, in some countries,there is a gap in the information required. The main consequence is thatin some casesPROs provide telecom operators with less accurate information on the treatment of thecollected waste.Reports provided by Producer Responsibility Organisations (PROs) frequently lackessential data required for Corporate Sustainability Reporting Directive (CSRD) compliance at theGroup level—particularly regarding recovery types (e.g. energy or raw materials), disposal information,recycling rates, and component reuse.This information gap poses a significant challenge to accurateand comprehensive sustainability reporting. Recommendation1:Changethe WEEE directive into a regulation, to ensure f