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Many policy documents have called for a higher degree of circularity in the use of critical raw materials (CRMs). This paper examines how this objective has been translated from EU policy to legislation. The analysis presents three regulatory strategies used in the current framework to promote the recovery of CRMs: indirect methods, direct regulation of single CRMs, and collective regulation of all CRMs. The indirect approach has struggled to effectively target CRMs. Direct regulation of single CRMs provides an alternative, but other than the new Batteries Regulation no legislation has introduced strong obligations requiring recovery of single CRMs. The proposed CRM Regulation would codify the main concepts relevant for governing and regulating CRMs collectively. While the legislation would create a solid foundation for these processes, its failure to put forward immediate or long-term solutions to CRM recovery remains a serious shortcoming. The present research indicates that the current legal obligations lack a focus on the recovery of CRMs, with concrete obligations to this end limited. [ABSTRACT FROM AUTHOR]