Secondary Feedstock Supplier Evidence Toolkit: origination due diligence protocol and readiness score for Brazil–EU sourcing

Secondary Feedstock Supplier Evidence Toolkit

Document type
Recipient profiles
Country
Italy
Target audience
Language for original content
Start/End date
to

The Critical Raw Materials Act sets a 2030 benchmark for recycling, and producers of products containing permanent magnets will have to disclose recycled content. Those claims need documented feedstock. In Brazil, formal e-waste collection is documented for about 3% of generation, and the domestic certificate of final destination does not cover exported material.

This part of the EU-Mercosur Secondary Raw Materials Evidence Series is a question protocol for European recyclers, traders and corporate buyers before they contract a Brazilian supplier of e-waste, printed circuit boards or magnet bearing components. It aims to identify potential red flags that buyers may encounter and to list the evidence that they will need.

The toolkit contains:

  1. Origination protocol: 41 questions in six blocks (counterparty identity and standing; provenance and recycled status; material and classification; data and liability; legal transfer capability; disclosure fit for the buyer's own obligations). Each question states the evidence expected and the red flag it tests.
  2. BSF-ERI readiness score: six weighted domains, four gating conditions (registration, classification and consent under the Basel Convention and Regulation (EU) 2024/1157, data destruction, recycled-status claim) and four decision bands. An example uses fictitious data.
  3. A simple expected-evidence-cost formula for pricing missing evidence before contracting.

Buyers need to send the questions to the supplier, collect the evidence, check the shipment consent chain, then score the file. The gates stop a weak file regardless of the total score.

This is intended to be a methodology, not legal advice or certification.

See also Evidence gap.