Critical blind spots: unpacking corporate reporting on critical minerals recycling
The electronics industry is booming — and it’s not slowing down anytime soon. The consumer electronics market alone is projected to surpass $1 trillion by 2030, while the push for renewable energy and electric vehicles (EVs) continues to accelerate. Digitalization and the green transition are driving this surge in demand, and it may seem like a step in the right direction. But there’s a catch.
Behind every smartphone, laptop, and electric vehicle battery, there is an often forgotten but essential component: critical minerals like silicon, cobalt, lithium, and rare earth elements (REEs). As demand for electronics and green energy technology soars, so does the need for these minerals. But their extraction comes with significant environmental and social consequences, ranging from habitat destruction, pollution, exploitation, human rights violations, conflicts, and political instability –all of which have already claimed too many lives and livelihoods in countries like the Democratic Republic of the Congo.
The pressure to reduce reliance on newly mined materials has never been greater. Recycling critical minerals should be at the heart of this effort. But are electronics companies truly embracing the circular economy?
We analyzed the sustainability disclosures of 30 major electronics companies to find out how much information they provide about recycled minerals. We looked for publicly available information about the amount of minerals recycled, the companies’ targets for recycling, and the minerals that were mentioned.
Do companies disclose how much they recycle, or are they keeping us in the dark?
What are the reporting requirements for recycled minerals?
Currently, most corporate disclosures related to minerals focus on conflict minerals — such as tin, tungsten, tantalum, and gold (3TG) — rather than recycled materials. The companies we looked at typically reference three regulatory frameworks in their reports:
- The Securities Exchange Act of 1934 (17 CFR 240.13p-1)
- The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
- The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
The EU Conflict Minerals Regulation could also lead to voluntary reporting from companies, although it was not mentioned as the basis for reporting.
These frameworks are designed to prevent minerals from financing armed conflicts and human rights abuses, but they don’t require companies to report on recycled minerals. Instead, companies voluntarily disclose data on recycled minerals, often as a secondary way to limit the use of conflict minerals.
The Corporate Sustainability Reporting Directive (CSRD) and the associated reporting standards ESRS E5 Resources Use and Circular Economy are expected to introduce more standardization in reporting recycling practices. However, at this stage, reporting on recycled minerals remains largely voluntary and inconsistent.
How do companies disclose their mineral recycling practices?
We found that while most companies mention recycling and minerals, their disclosures lack consistency and clarity. Here are two key challenges:
1. No standardized reporting across companies
Each company defines its own metrics, making comparisons difficult. Some indicators appear in the reports of multiple companies, but there is no consistent reporting pattern. For example, companies disclose:
- Tonnes of electronic products, e-waste, or minerals recycled
- Percentage of materials in products coming from recycled sources
- Percentage increase in recycling of specific minerals (e.g., gold)
- Percentage of products sold to customers containing recycled minerals
- Percentage of manufacturing waste upcycled
- Number of components saved from landfills
- Number of devices recycled
- Overall recycling rate
- Tonnes of Post-Industrial Recycled (PIR) metals
The lack of uniformity in reporting poses significant difficulties for anyone trying to compare companies’ recycling practices or understand how sectors, such as electronics, are changing over time.
2. Lack of specific data on critical minerals
Most companies report on recycling in aggregate terms, mentioning categories like “devices,” “e-waste,” or “components” without breaking down the specific minerals being recovered. Figures such as the recycling rate or percentage of products recycled also fail to provide the necessary information. This lack of detail obscures the reality of their recycling efforts.
For example, one company may report that 14 million hardware components were recycled — but if that only includes plastic casings and steel screws, it tells us nothing about whether critical minerals like lithium or cobalt are being reused. Only a few companies provided specific figures on recycled minerals like tantalum or gold.
This lack of transparency makes it nearly impossible for stakeholders to assess whether companies are truly “closing the loop” on critical raw materials.
Why we need stricter reporting requirements
The gaps in disclosure leave civil society, investors, and policymakers without a clear picture of corporate recycling practices. Without reliable data, it is impossible to differentiate between companies making real efforts and those engaging in greenwashing rather than genuine action. The lack of standardized reporting makes it easy for companies to overstate their commitment to circularity.
Given the environmental destruction caused by mining and the finite supply of critical minerals, recycling should be a top priority for industries like electronics and renewable energy. Public oversight is essential to drive meaningful change.
The CSRD’s reporting requirements include indicators on resource use and circularity (ESRS 5), which, if companies choose to report on recycling minerals specifically, could lead to more transparency on minerals recycling practices. However, the recent Omnibus proposal threatens to discard some of those requirements, which would mean maintaining the status quo. And the truth is that without mandatory, granular reporting on recycled minerals, many companies will continue operating in obscurity.
Stronger global reporting standards on critical mineral recycling are urgently needed. In the end, it is about stopping the human suffering and environmental damage that comes with the world’s growing appetite for technology. We urge companies to implement the ESRS 5 reporting standards when preparing disclosures in relation to resource use, and on minerals in particular, no matter whether the relevant ESRS standards are maintained in CSRD.
Do you want to join us in calling for more transparency on minerals recycling? Share this article and get in touch with Aureliane at aureliane@wikirate.org. We welcome partnerships with civil society, academia, journalists, and businesses.
This article was co-written by Wikirate contributor Nabilla Khansa Naura, Business and Human Rights Practitioner, and Aureliane Frohlich, Program manager at Wikirate.
