Commission Implementing Regulation on the list for the purposes of Article 26 of Regulation (EU) 2024/1252

For the CRM Phosphate Rock (P), the European Sustainable Phosphorus Platform ESPP notes that the following materials, potentially significant for phosphorus recovery and recycling, are missing in the list proposed in the draft regulation annex: - Animal manures and slurry these contain in total a similar quantity of P to that used in mineral fertilisers. - Agricultural run-off water, e.g.

EFPRA, the European Fat Processors and Renderers Association, represents the European animal by-products industry. Fats and protein derived from animal by-products have applications in many markets from animal feed, pet food and fertiliser to biofuels and oleochemical products (soaps and detergents).

Opigeo, a spin-off of the University of Padova, welcomes the opportunity to contribute to the public consultation on the Critical Raw Materials Act implementing regulation laying down the list of products, components and waste streams considered as having potential to recover critical raw materials.

Article 26 of the Critical Raw Materials Act - Regulation (EU) 2024/1252 - empowers the Commission to specify in a list such items with a high potential for critical raw material recovery. This aims to help Member States create national circularity programmes containing measures to address various circularity dimensions, e.g. reuse, recycling and waste prevention & collection.

The two main goals of Ørsteds use of circularity in our (offshore) wind projects are to ensure availability of critical raw materials, and to help minimise the adverse environmental impacts that are related to extraction and processing of virgin resources. Today we estimate that 90-95% of all materials in our windfarms are recyclable.

Bergfald Environmental Consultants (BMC) was established in 1993 as Norway's first consultancy company to work exclusively with environmental issues and has in recent years worked extensively with value chains that supply critical raw materials and published several reports on this increasingly important topic.

FNADE, the French federation for waste management and environmental services, is the professional organisation representing the private resource and waste management industry. As a major player in the circular economy, the waste industry produces recycled materials, fertilisers and green energy, substituting natural resources and fossil fuels. It provides solutions to major environmental and climate challenges.

FEFAC represents the European compound feed & premix manufacturing sector. Our sector is closely linked to the livestock sector. A waste stream that is currently missing is manure, which is a source of organic phosphorous (CRM). We would recommend to place this on the list.

TEAM2 is a competitiveness cluster based in Lens, specialising in the implementation of the circular economy at the heart of industrial activities. In our view, this list of products, components and waste streams lacks clear definitions, leaving room for interpretation by each reader.

ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy (WtE) plants in operation in Europe. It seeks to promote the technologies which recover both energy and materials from non-recyclable waste that would otherwise end up in landfills.

Cefic, the European Chemical Industry Council, welcomes the opportunity to contribute to the public consultation on the Critical Raw Materials Act implementing regulation laying down the list of products, components and waste streams considered as having potential to recover critical raw materials.

FEAD, the European Waste Management Association, welcomes the Commission's draft Delegated Act regarding the list of waste streams with high critical raw material recovery potential under Article 26 of the Critical Raw Materials Act (CRMA).

As a manufacturer of cars and batteries, we believe that sector-specific regulations such as the Batteries Regulation and the proposed End-of-Life Vehicles (ELV) Regulation should remain the primary legal instruments driving circularity in our industries. Any circularity measures targeting batteries or motor vehicles, including those related to critical raw materials, must be anchored in these two regulations.

We identify a risk of double regulation between national measures on circularity and the WEEE Directive, which will soon be revised and is expected to include provisions on critical raw materials. We recommend that, when publishing the list of products, components and waste streams that shall at least be considered as having a relevant critical raw materials recovery potential, the European Commission also specifies…

General feedback: Article 26 of the Critical Raw Materials Act (CRMA) stipulates that Member States must establish a national programme within two years. It clearly states that these programmes should only address products and waste streams that are not already subject to specific obligations under EU law regarding collection, recycling, and reuse.

EHI members cover more than 90% of the European market for heat and hot water appliances, including heat pumps and hydrogen-compatible boilers, which are in the scope of the Critical Raw Materials Act. As such, we support the objective of the Critical Raw Materials Act to decrease the Unions dependency on third countries for the import of the critical raw materials that will be necessary for the digital and green…

Fedeback on behalf of Elval, aluminium rolling division of ElvalHalcor: 1. Our position is that the initiative should further prioritize aluminium scrap from all streams, with special emphasis on packaging. UBC collecting and recycling should be recognized as a critical target for all member states, supported with relevant schemes like DRS. 2.

POSITION PAPER regarding critical raw materials in waste streams Commission Implementing Regulation listing the products, compo-nents and waste streams considered as having a relevant critical raw materials recovery potential under Regulation (EU) 2024/1252 The proposed implementing regulation with its goal of recovery more critical raw materials in the Union is in principle to be supported and welcomed by the…

We would like to propose the inclusion of "source-separated human urine and excreta" in the Annex of the draft Commission Implementing Regulation, specifically within the list of "waste streams that are considered as having a relevant critical raw materials recovery potential". Human urine and, more generally, excreta, represent valuable resources for nutrient recovery.

The EPMF welcomes the Commissions initiative to lay down a Critical Raw Materials Act (CRMA) Implementing Regulation listing components, products and waste streams with high critical raw material (CRM) recovery potential.

Representing the vast majority of critical raw materials (CRMs) and e-waste recycling facilities in Europe through its members, the European Recycling Industries Confederation (EuRIC) has a strong interest in supporting the identification of waste streams with high potential for CRM recovery to increase the volume of processed materials.

EUREFAS, the European Refurbishment Association, welcomes the Commissions initiative and strongly supports the objectives of the Critical Raw material Act Regulation 2024/1252. EUREFAS particularly endorses the recognition of the materials listed in Annex I as having high strategic potential in contributing to the EU's critical raw material (hereafter CRM) policies as outlined in Article 1 of the Regulation.

Grupa Kapitałowa Grupa Azoty as capital group supports the principles of sustainable development, including the idea of circular economy as a tool for building a strong, competitive and independent economy within the European Union.

The European Power Tool Association (EPTA) welcomes the opportunity to provide feedback on the draft Implementing Regulation listing the products, components and waste streams considered as having a relevant critical raw materials recovery potential under Regulation (EU) 2024/1252. Please find our comments in the enclosed position paper.

SolarPower Europe and its Battery Storage Europe Platform welcome the opportunity to provide feedback on the additional draft legislation for Article 26 of the Critical Raw Materials Act (CRMA) and its accompanying Annex.

ACEA welcomes the objectives of the Critical Raw Materials Act (CRMA) to reinforce the resilience and sustainability of European supply chains. To ensure regulatory efficiency and avoid unnecessary complexity, the CRMA must be closely aligned with existing sectoral legislation, most notably the Batteries Regulation and the proposed End-of-Life Vehicles (ELV) Regulation.

Please find our feedback in the attached document. The German Association of the Automotive Industry (VDA) consolidates around 620 manufacturers and suppliers under one roof. The members develop and produce cars and trucks, software, trailers, superstructures, buses, parts and accessories as well as new mobility offers.

Lassociation amorce responds to this consultation as a representative of the public authorities managing waste treatment facilities and urban depuration stations in France (installations of which several by-products are included in this new list).

Filed in French · English published by the European Commission

EDP appreciates the European Commission (EC) opportunity to provide feedback on the products, components and waste streams with a high potential to recover critical raw materials (CRM): -Sectors with high Critical Raw Material (CRM) intensity should be prioritized in the identification of specific waste streams and end-of-life products.

RÉCYF is a French SME specialising in the recovery of mixed non-ferrous metals from incineration bottom ashes. RÉCYF supports the European Commission's policy on critical raw materials and this consultation on material flows of interest, including incineration bottom ashes as a source of raw materials. Which is in line with our credo: « to turn our waste into resources ».

The European ferro-alloys and silicon association, Euroalliages, welcomes the European Commissions initiative to enhance the recovery of critical raw materials (CRMs) from secondary sources such as slags. Slags, a by-product of the ferro-alloys and silicon industrial processes, offer significant potential for circular useparticularly in construction and, in some cases, CRM recovery.

Confartigianato Imprese is the most representative Italian organisation of crafts and micro and SMEs and one of the most important social partners in Italy. At national level, it has 104 local associations, 21 regional federations, 1.206 offices and 10.700 employees, offering different types of services to over 1.5 million craftsmen and small entrepreneurs and almost 700.000 businesses.

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LG Energy Solution Wrocław sp. z o.o. presents the position as regards the draft of the Commission Implementing Regulation listing the products, components and waste streams considered as having a relevant cricital raw materials recovery potential under the Regulation (EU) 2024/125 and the Annex thereto. Please see enclosed the file.

Thanks for the opportunity to contribute. You will find here attached our position paper. Our main requests are the following: For battery-grade graphite: Domestic content rules for recycled graphite in EU batteries Funding for certification of recycled anode materials Standardisation of graphite concentrate composition Battery passport data to drive sustainable demand For carbon fibres, we ask the Commission to add…

Response of the European Battery Recyclers Association (EBRA) Regarding Article 26 of the Critical Raw Materials Act List of Products, Components and Waste Streams with a High Potential to Recover Critical Raw Materials Introduction EBRA welcome the opportunity to respond to the European Commissions consultation on the implementation of Article 26 of the Critical Raw Materials Act (CRMA), which provides for the…

As the International Platinum Group Metals Association (IPA), representing over 80% of the global platinum group metals (PGMs) industry, we support the European Commissions objective to improve circularity for Critical Raw Materials (CRMs), including PGMs. These metals are vital for the EUs green transition, digital infrastructure, and strategic resilience.

To the European Commission Initiative of Critical raw materials products, components and waste streams with a high potential to recover critical raw materials Dear European Commissions representatives, On behalf of ELVALHALCOR S.A.

Europacable, the voice of Europes cable system manufacturers, welcomes the opportunity to contribute to the public consultation on the implementing regulation of Article 26 of the Critical Raw Materials Act, focusing on national measures on circularity.

The draft implementing regulation includes digestate and compost from separately collected biowaste in the list of products, components and waste streams considered as having a relevant critical raw materials recovery potential within the meaning of Article 26(1), points (b) and (c), of Regulation (EU) 2024/1252.

As Eurometaux, the European non-ferrous metals industry association, we support the goal to improve circularity for metals and Critical Raw Materials (CRM) in particular. Our sector provides many of the critical raw materials that enable the EU green and digital transitions and are also important for strengthening its security and defence.

EERA welcome the opportunity to respond to the European Commissions consultation on the implementation of Article 26 of the Critical Raw Materials Act (CRMA), which provides for the establishment of a list of products, components and waste streams with high potential for the recovery of critical raw materials (CRMs).

We as BDE agree with the list of priority waste streams for CRM recovery that the Commission has presented in the draft. However in our view, in order to guarantee an efficient implementation in Member States legislation, we think that the Implementing Regulation should have a binding effect on Member States and not only should serve as a reference for the scope of the national measures as stated in Recital 2.

Biorepack, a producer responsibilities organization (PRO), is the national consortium for the organic recycling of biodegradable and compostable plastic packaging. Biorepack promotes the recycle of biodegradable and compostable plastic packaging into compost, a soil improver as source of nutrients to restore soil fertility, facing the issue of desertification, a growing threat in the EU.

The list is deemed sufficiently detailed for the classification of key products and components relevant to the supply of critical raw materials. To enhance clarity and ensure consistency with existing collection frameworks, it is recommended to structure the product categories according to the specific EU WEEE classification system, as adopted in EU legislation for EPR schemes.

The RESiLEX consortium is hereby contributing to the present public consultation by presenting the highlights of two workshops organized in 2024 and 2025, which saw the participation of more than 100 experts and stakeholders in the field of Critical Raw Materials, Photovoltaics, and Batteries. The document attached provides all the details, with the main identified issues and proposed solutions.

The National Institute for Circular Economy (INEC) is working to make the pressure on resources essential to decarbonisation objective. The Country Strategy Netherlands Carbone study under resource constraints makes it possible to quantify, for each of the resources studied, the risks to supplies and the potential for applying circular economy levers.

Filed in French · English published by the European Commission

Derichebourg Environnement is one of the global and European leaders of circular economy, specialized in metal waste recycling, working with local authorities, industries and Extended Producers Responsibility (EPR) systems.

Ragn-Sells welcomes the Commissions proposed products, components and waste streams listed in the annexe. We want to emphasise the strategic importance of utilising the phosphorus recovery potential in sewage sludge. Today, the EU is almost entirely dependent on imports to supply its agriculture with phosphorus, one of the key ingredients in fertiliser and animal feed.

Titanium is identified by the Critical Raw Materials Act (CRM) of 2023 as a strategic material for which a safe and sustainable supply must be guaranteed. The EUs Critical Raw Materials Act, passed in 2023, sets clear 2030 benchmarks for strategic materialsincluding titanium. The advantages of titanium are its weight, mechanical properties (fatigue, ductility), corrosion resistance.

The International Copper Association Europe welcomes the possibility to provide feedback on the European Commissions draft implementing Regulation under Article 26(7) of the Critical Raw Materials Act (CRMA). The implementing act is important as it will define the products, components and waste streams that should be in the scope of measures to be taken by Member States to increase waste prevention and the…

Posting feedback on behalf of Danijel Rodić : [email removed] , DOMEL is partner of REMHub project focusing on rare earth metals and permanent magnets which I am coordinating> In Europe, the bulk of potential reserves of HREE-s, such as dysprosium (Dy) and terbium (Tb) are presently available in secondary resources (products).

CEWEP, the Confederation of European Waste-to-Energy Plants, welcomes the inclusion of sludges from mono-incineration and incinerator bottom ashes (IBA) originating from municipal, industrial, or commercial waste incineration in the list of waste streams considered to have high potential for the recovery of critical raw materials (CRMs). These residues represent a valuable secondary source of raw materials.

Many historic European Mining regions have a lot of abandoned mining and processing wastes. In some cases, these waste come from metallic mining and contain potential concentrations of CRMs. So, I propose to include in the list not only construction and demolition wastes but Metallic Mining and Processing Waste coming from abandoned deposit sites.

The European Compost Network (ECN), the European umbrella organisation representing the biowaste recycling sector, welcomes that digestate or compost from separately collected biowaste are considered by the Commission as having a relevant critical raw materials recovery potential within the meaning of the Critical Raw Materials Act (Regulation 2024/1252).

The Norwegian Environment Agency welcomes the European Commissions initiative to identify products, components, and waste streams with significant potential for the recovery of critical raw materials (CRMs). Need for Clear and Harmonised Definitions: To ensure that the list can serve as a practical and effective reference for national-level implementation, we believe that further clarification is needed.

The European Biogas Association (EBA) welcomes the European Commissions initiative to enhance the EUs strategic autonomy and circularity by identifying waste streams with potential for the recovery of critical raw materials (CRMs), as outlined in Regulation (EU) 2024/1252.

Umicore welcomes the proposed implementing act as a solid foundation but highlights several key areas for improvement to ensure effective and harmonised CRM recovery across the EU. 1. Need for Coordinated Implementation CRM use is highly dispersed across sectors. Without EU-wide coordination, national initiatives risk fragmentation and inefficiency. Economies of scale are essential for viable CRM recycling. 2.

Dear Committee As a member of CEWEP and speaking on behalf of Indaver, a pioneer in advanced materials recovery and sustainable waste management, we applaud the European Commission's initiatives to improve the EU's resilience and circularity by identifying waste streams with the potential to recover critical raw materials (CRM), as specified in Regulation (EU) 2024/1252.

Novelis is pleased to contribute to the consultation launched by the Commission on Article 26 of the Critical Raw Material Act (Regulation 2024/1252), regarding the identification of products and waste streams with high potential for critical raw material recovery. Novelis welcomes the proposed Annex I as a strong starting point.

The Swedish Environmental Protection Agency (SEPA) appreciates the Commissions efforts to identify products, components, and waste streams with significant potential for critical raw material (CRM) recovery. However, to effectively serve as a reference for the scope of national measures, the list requires greater clarity.

It is important and fundamental to create waste stream categories so that both the legislator and companies can channel their activities. I would ask to add another category for the recovery, from the end of life, of individual and collective protection devices, used for protection from inonizing X radiation.

The list provides a useful taxonomy of products and components, yet it is not sufficiently linked to the specific classifications as used in EU legislation which determines specific systems, such as under Extended Producer Responsibility of the WEEE Directive.

Public infrastructure is not just built its excavated. And what we extract, we rarely trace. Benefit every road, tunnel, or sustainable megaproject funded by EU taxpayers, a hidden flow of value disappears: Earth is removed, often containing rich pozzolanic materials, VOLCANIC aggregates, and other valuable components. These materials are not inventoried, not classified, not declared as assets, and not taxed.

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