Framework for ensuring a secure and sustainable supply of critical raw materials

The consortium of the H2020 project "FlashPhos" (see below) suggest to include White Phosphorus (P4) and its derivatives on the list of strategic raw materials in the CRM act. Due to its high-temperature production process, white phosphorus and its products have a much lower contaminant level than the wet or green P-acid, produced by wet-chemical digestion of phosphate rock, and products from it.

Please see attached file, which is a translation to English of SSNC's official referral response to the Swedish Government on the CRMA. SSNC also largely supports EEB's and other European NGO:s upcoming position paper on the subject. Kind regards, [name removed] Forest and Mining Specialist Swedish Society for Nature Conservation (SSNC)

-Include a 2030 reduction target for critical raw materials in Article 1. Reducing EU demand and consumption of primary raw materials will increase its resilience to potential future shocks, reduce risks for human rights violations and social and environmental impacts in Europe and resource-rich third countries and help achieve EU climate goals under the Paris Agreement.

currENT welcomes the Critical Raw Materials Act proposed by the European Commission on 16 March 2023. It is vital that the EU identifies and secures delivery of all the raw materials that will be necessary for the transition to a fully decarbonised economy.

The DGB refers to its ‘trade union requirements for a modern supply of raw materials’ (see Annex). A strategic raw materials policy must meet the demands of sustainability, security of supply and good work. In the DGB’s view, four objectives should be pursued: Promote circular economy and, where possible, reduce the consumption of raw materials and reduce good work and high environmental standards along the raw…

Filed in German · English published by the European Commission

Radical climate action is needed, but increasing mining and raw materials consumption is not the way to lower our GHG emissions, as today mining and metallurgy already represent 20% of all health impacts from air pollution and more than a quarter of global carbon emissions (1). The EU population is 6% of the global population, yet we consume 25 - 30% of the global resources.

In the context of the REPowerEU plan and the need for Europe to increase resilience in its energy transition value chains, RECHARGE the leading voice of the European advanced rechargeable and lithium batteries value chain in Europe welcomes the Critical Raw Materials Act (CRMA).

EGGA welcomes the Commissions initiatives to propose a comprehensive approach to scale up and accelerate the supply of primary and secondary raw materials in the EU and to address strategic dependencies through the proposed Critical Raw Materials Act.

Position on the Critical Raw Materials Act Executive summary EPEE welcomes the proposal from the Commission of a Critical Raw Materials Act and the focus on strengthening the critical raw materials supply. As the voice of the Refrigeration, Air Conditioning and Heat Pumps industry (RACHP), EPEE supports the goal of increasing the circularity of critical and strategic raw materials.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CNV Internationaal welcomes an assertive European strategy for critical raw materials, to support ambitious climate and energy objectives. The Commission proposal offers a strong basis for a strategy to combine more resilient supply chains, circular economy, research and innovation and robust and enforceable human rights and labour rights standards worldwide.

BASF welcomes the publication of the Critical Raw Materials Act (CRMA) as it introduces a necessary set of measures to secure the sustainable implementation of the Twin Transition, as well as the resilience of many European frontrunning industries, including the chemical industry.

The CRMA should include measures to reduce the demand for critical raw materials, ensure that projects operate in a transparent manner, and ensure the participation of local civil society, communities and indigenous peoples, prioritise circularity and enforce due diligence norms and standards and international human rights and environmental laws.

Filed in Spanish · English published by the European Commission

SuperNode welcomes the Critical Raw Materials Act proposed by the European Commission on 16 March 2023. It is vital that the EU identifies and secures delivery of all the raw materials that will be necessary for the transition to a fully decarbonised economy.

SUEZ welcomes the European Commissions proposal on the Critical Raw Material Act. Indeed, elements in this proposition would contribute to the strategic independency of the European Union while maintaining with regards to the circular economy, a particular reduced environmental footprint through increased recycling.

The International Platinum Group Metals Association (IPA) appreciates the European Commissions proposal for a Critical Raw Materials Act (CRMA). IPAs comments are primarily concerned with proposed benchmarks, joint purchasing mechanism, as well as the one-size-fits-all approach applied by the European Commission which currently doesnt fully reflect the fact that critical raw materials have very different features…

The Confederation of Norwegian Enterprise feedback on Critical Raw Materials Act The Confederation of Norwegian Enterprise (NHO) is Norways largest organisation for employers, and the leading voice of business and industry in Norway. Norway and the EU enjoy a strong relationship, and the cornerstone of this relationship is the EEA agreement.

SGL Battery Solutions GmbH • P.O. box 1193 • 86400 Meitingen SGL Battery Solutions GmbH Dr. Peter Roschger Head of Battery Solutions Meitingen, June 22, 2023 To the European Commission Feedback to EUC Proposal on a European Critical Raw Materials Act -- This feedback letter is a follow-up to Response to Public Consultation (reference number F3361518) filed by SGL Carbon on November 25, 2022.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EU and global industrial transformation needs to ensure that societies companies, governments and their services, citizens are designed to live in harmony with nature and well within planetary boundaries. This means climate, biodiversity (also through resources and materials), and pollution objectives need to be addressed together, not as separate silos or issues.

Contact: Dr [name removed] Director European Affairs International Zinc Association 168 Avenue de Tervuren Brussels 1150, Belgium Tel. : [phone removed] Mob: [phone removed] Email : [email removed] EU Transparency Register No. 017018214013-57 The International Zinc Association (IZA) is pleased to add our voice to the 2 amendments related to Zinc: 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German Environmental Aid (DUH) considers that the Critical Raw Materials Act (CRMA) must enable a reliable supply of raw materials with the materials needed for decarbonisation and green transformation. The CRMA aims to ensure that resource needs are minimised as much as possible and that raw material extraction and processing are carried out in the least environmentally and socially burdensome way.

Filed in German · English published by the European Commission

The VCI supports the European Commissions proposal establishing a framework for ensuring a secure and sustainable supply of critical raw materials (Critical Raw Materials Act, CRM Act; COM(2023) 160). We highly appreciate inclusion of strategic raw materials into a regulatory framework. Quantifiable objectives on Union extraction, processing, and recycling capacities offer planning and investment security.

IUCN NL response to the consultation of the CRMA The mining undertaken to meet the vastly increased demand for raw materials such as nickel, copper and bauxite/aluminum is resulting in widespread biodiversity loss, ever-increasing deforestation and the destruction of other ecosystems such as wetlands, which in turn are crucial to addressing the climate, water and biodiversity crisis.

The Federation of European Risk Management Associations (FERMA) shares the European Commissions aim to better equip the EU with the tools to ensure our access to a secure and sustainable supply of critical raw materials. We are therefore supportive of the European Commissions policy intervention in the form of the proposed Critical Raw Materials Act (the CRMA) on the premise it will help to fulfil that aim.

Position Paper on the Critical Raw Materials Act (CRMA) The European Portable Battery Association (EPBA)1 is the leading organisation representing the interests of primary and rechargeable portable manufacturers, industries using portable batteries in their products and distributors of portable batteries active within the European Union and beyond.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UNESID is the trade association of the Spanish steel Industry and the first tier of downstream activities. It gathers 46 companies that employ 50,000 people, in addition to more than 20,000 related to scrap recovery. Every tonne of steel produced in Spain carries out 7 in environmental investments. The Spanish steel industry is the recycling champion, as every year 11 m tonnes of ferrous scrap become new steel.

RUD, June 30th 2023 Critical Raw Materials Act (CRMA) – feedback from Franzefoss Minerals AS Franzefoss Minerals AS is a family-owned mineral company that has mining, processing and sales of limestone and dolomite as its core business. We are in Norway and was established in 1919. Currently we mine some 2 million tons of dolomite and limestone annually.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Critical Raw Materials Act (CRMA) proposal is a vital first step towards boosting the EUs critical raw materials capacities, increasing the resilience of raw materials supply chains, and promoting supply chain sustainability and circularity. It sets high ambitions and a conducive framework for a secure and sustainable supply of critical raw materials for the European economy.

LEVA-EU is the only trade association in Europe to work exclusively for businesses in the sector of light electric vehicles (LEVs). We currently have over 80 members, a large majority of which are SMEs. Their activities are focussed on the production, import and/or distribution of a variety of light, electric vehicles and LEV-components, including motors that include permanent magnets.

With reference to our attachment, we will, on behalf of Northern Norway, give the following input to the hearing on CRMA: - A strong framework and streamlining permitting processes will be important to provide both mineral actors and local communities more predictability and continuity.

The reference, in section 15 of the preamble of the proposed regulation, to the rights of indigenous peoples does not sufficiently align with international legal standards. In particular, the proposed regulation says that projects should ensure engagement in good faith as well as comprehensive and meaningful consultations with local communities, including with indigenous peoples.

RREUSE calls for a Critical Raw Materials Regulation that is based on circular principles and promotes both sufficiency and resource efficiency. This can be achieved by adopting the following circular strategies, in order of importance: - Rethink and reduce: lower the demand for CRMs by promoting systemic change; - Circular design, repair, and re-use: extend the life of products to keep CRMs in use for longer; -…

To promote raw materials resilience and safeguard a just transition, the CRMA must include measures to reduce raw material demand, ensure that strategic projects operate transparently and guarantee complete participation of local civil society, communities and indigenous peoples, prioritise circularity, and mandate compliance with existing due diligence standards and international human rights and environmental…

1 av-430/06/2023 Ref. Ares(2023)4555847 Date 30.06.2023 Faculty of Engineering NTNU Raw Material Forum input to the Critical Raw Materials Act of 16 th March 2023 The Norwegian University of Science and Technology (NTNU), Norway’s largest university, conducts research and education across the entire value chain for raw materials production, encompassing exploration, mining, mineral processing, metallurgy…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EUROBAT, the leading association of European automotive and industrial battery ‎manufacturers,‎ supports the EU Commission's Critical Raw Materials Act in their urgency of action to address the 2030 risk of raw materials bottlenecks for clean energy technologies.

ECOS calls for a Critical Raw Materials Regulation that is based on circular principles and promotes both sufficiency and resource efficiency. This can be achieved by adopting the following circular strategies, in order of importance: - Rethink and reduce: lower the demand for CRMs by promoting systemic change; - Circular design, repair, and reuse: extend the life of products to keep CRMs in use for longer; -…

Orano welcomes this proposal for regulation that will support the EU security of supply, reinforces circular economy, and reduces EUs dependency toward third countries. Indeed, access to critical raw materials (CRM) is crucial to attain the EUs climate and digital objectives. Orano has several projects related to strategic raw materials as listed in the EC proposal.

With the EU Critical Raw Materials Act, the European Commission is sending an important signal to strengthen European sovereignty in the raw materials sector. However, central instruments for implementation are missing.

30 June 2023 BDE Federation of the German Waste, Water and Circular Economy Management Industry Statement on the European Commission's proposal for a Critical Raw Materials Act (COM (2023) 160 final) BDE Brussels Office Rue de la Science 41 1040 Brussels Tel: [phone removed] [email removed] The BDE Federation of the German Waste, Water and Circular Economy Management Industry was founded in 1961 and is the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Minera Sabina SLU. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to resources.

The European Commission has adopted a proposal for European Critical Raw Materials Act which aims at ensuring secure and sustainable supply chains for EU's green and digital future. To achieve the green and digital transitions, the EU must significantly increase and diversify its critical raw materials supply, strengthen circularity and support research and innovation The northernmost regions of Norway, Finland and…

Please find attached detailed comments for the CRMA as well as associated NZIA. In general, Spanish automotive industry welcomes the activities to facilitate and simplify procedures but is aware of the subsidiarity and lack of EU competencies in that area - member states will be key to deliver. Streamlined and enhanced financial instruments are missing as well, especially for NZIA.

The matter of the European Critical Raw Materials Act was addressed in Viken County Councils meeting June 29th, 2023, case 173/2023. Please see the attachment for the County Councils statement. The County Council's resolution points: 1. Viken County Council believes it is very positive if the EU wishes to strengthen sustainable mineral production and build robust supply chains for mineral raw materials. 2.

INFORMATION Europäisches Rohstoffgesetz: Auswirkungen auf die deutsche NE-Metallindustrie Hintergrund Am 16.03.2023 hat die Europäische Kommission (KOM) ein Gesetzespaket zu Rohstoffen, den so genannten EU (Europäische Union) „Critical Raw Materials Act“ (CRMA), vorgestellt.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CAN Europes response to the public consultation on the CRMA is provided in the context of the importance of EU policy addressing climate and resources/materials issues together, in an integrated and systemic manner.

TEDAE is the Spanish National Association for the Aerospace, Defence, Security and Space Industries, representing directly or indirectly more than 100 companies with a turnover of 11,594 million euros, exporting 47% of its products and services and contributing 1.4% to Spain's Gross Domestic Product. TEDAE is also a member of ASD, the Aerospace, Security and Defence Industries Association of Europe (ASD).

To ensure a just transition, the following changes must be made to the Critical Raw Materials Act (CRMA)*: Certification schemes: The CRMA must remove the reliance on certification schemes to demonstrate Strategic Project compliance with project requirements. These schemes vary significantly in their transparency, requirements and frequency and quality of assessments.

With the EU Critical Raw Materials Act, the European Commission aims to strengthen European sovereignty in the raw materials value chain. The TÜV Association welcomes this objective and considers the proposed policy measures suitable to achieve this goal, in particular the aim to improve the sustainability and circularity of critical raw materials.

The Critical Raw Material (CRM) Act can be gathered as a new framework to reduce the dependency of the European Union on non-EU countries for the supply of critical, as well as raw materials in general. Exploration in each of the EU territories and countries is urgently needed to achieve this goal.

The Critical Raw Materials Act (CRMA) to secure CRM access for the Green and Digital transition is structured around supply risk reduction and diversification of sources. Other important components such as waste management or circularity are still not strong enough.

***********For publication and more details use the attached pdf*************** The proposed European Critical Raw Materials (CRM) Act aims to ensure a sustainable and secure supply of critical materials for high-tech industries. However, mining's historical association with conflict and exploitation raises concerns.

CCOO del Hábitat welcome the European Commissions timely initiative to address the paramount issue of securing the necessary raw materials supply for a green and digital transition. Furthermore, we support the intention of the European Commission to pay attention on critical and strategic raw materials.

The transition to clean energy as part of the implementation of the European Green Deal will bring new challenges related to safeguarding the supply of raw materials needed for an effective energy transition. SUCH raw materials including Phosphorus and Phosphate Rock.

Filed in Polish · English published by the European Commission

The steel industry welcomes the European Commissions initiative to secure the sustainable access to critical raw materials. This is necessary to support the EU ambition to be the first climate neutral continent, to lead the digital decade and to be sure that the future of industry is made in Europe.

Danish Shippings three most important issues regarding the Critical Raw Materials Act are: Upscaling of renewable energy Availability of sustainable maritime fuels Continued global, open trade Danish Shipping is positive about the security of raw materials e.g., to support the production of renewable energy in the EU, and that EU in this regard considers the uncertainty and dependency that Europes in-dustry will…

The German Potash and Salt Association (VKS) welcomes the Critical Raw Materials Act (CRMA) to strengthen the European raw materials supply security. Potash and salt are key mineral raw materials for food security, extracted from underground deposits by conventional and solution mining techniques.

The European Data Centre Association (EUDCA) represents the European data centre operator community. EUDCA is happy to submit a commentary on this consultation, and wants to draw attention to the following key points: Availability of key strategic and critical raw materials: EUDCA fully supports the European Commissions measures to ensure the supply of key critical and strategic raw materials.

30.6.2023 Suomen luonnonsuojeluliiton lausunto asiassa European Critical Raw Materials Act Komission esitys edistäisi kiertotaloutta ja erityisesti kierrätystä. Kannatamme asetusehdotuksen tavoitteita lisätä kansallisia kiertotaloustoimia ja kaivannaisjätteiden sisältämien kriittisten raaka-aineiden hyödyntämistä. Siinä on kuitenkin monia ongelmia, joista monia on otettu huomioon ehostuksen jatkovalmistelussa.

Filed in Finnish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Polish Chamber of Industrial Energetics and Energy Customers (POL: Izba Energetyki Przemysłowej i Odbiorców Energii) is an organization of economic self-government that brings together entities related to the generation, transmission, trade and receipt of electricity and heat.

Comments by the Government of Korea on the proposal for a Critical Raw Materials Act The Government of the Republic of Korea (the “Government of Korea”) welcomes the opportunity to submit its comments on the European Commission’s (the “Commission”) proposal for a Regulation establishing a framework for ensuring a secure and sustainable supply of critical raw materials and amending Regulations (EU) 168/2013, (EU)…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ATEDY, the Technical and Business Association of Gypsum, a national organization representing suppliers and manufacturers of plasters, plasters and their derivatives, is committed to the objective of supplying essential raw materials to European societies in the most sustainable way and contributing substantially to the objectives of the European Green Deal.

Talga Group, a European producer of natural graphite anode material for lithium-ion batteries, welcomes the European Commission's proposal for a Critical Raw Materials Act as part of the Green Deal Industrial Plan.

It is of utmost importance that we reach a massive global reduction of greenhouse gases (-45%) by 2030, and a carbon neutral society in the EU until 2050 the latest. We need to create a living and economic model that is socially acceptable and that respects planetary boundaries.

Generation Climate Europe (GCE) expresses its concerns regarding the European Commissions Proposal for a Regulation establishing a framework for ensuring a secure and sustainable supply of critical raw materials published on the 16th of March 2023. In addition, we suggest potential elements for the improvement of the Regulation in the attached position paper drafted by our Digitalisation Project.

Galp welcomes the pioneer and important proposal for a Regulation establishing a framework for ensuring a secure and sustainable supply of critical raw materials, namely by developing the EU internal capacity while reducing and diversifying external dependencies.

The Spanish Group of Strategic and Critical Raw Materials (GEMPE/c) , established by the Spanish Institute of Engineering and the Association for Energy Transition in 2021, promotes initiatives to generate an informed and constructive debate among stakeholders public administration, academia, civil society, parliamentary groups, private companies, and media primarily regarding the risk implications for the supply of…

The CRMA must ensure full respect of the rights of affected communities and Indigenous peoples, including their participation rights, in compliance with human rights and environmental due diligence standards, international human rights and environmental laws.

East and North Finland would like to highlight the following messages: Involvement of local communities and dialogue: The regions would like to emphasize the importance of early dialogue with the local communities. Planned operations impact on the local peoples lives must be addressed with due consideration and meaningful dialogue that respects local communities and livelihoods.

May 2023 Ref. Ares(2023)4520763 - 29/06/2023 CONEBI feedback on the proposal for Critical Raw Materials Act CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its national industry members. In the EU there are about 1000 companies, the majority of them being small and medium-sized enterprises (SMEs), providing more than 170,000 direct/indirect jobs.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Nobian welcomes the European Commissions legislative proposal for a Regulation aimed at securing the supply of critical and strategic raw materials. Nobian also appreciates the opportunity to provide feedback on the proposal. The proposal is an important step towards reducing strategic dependencies of the EU.

JSW SA. welcomes the initiative of the European Commission to create a legal framework that guarantees favorable conditions for the development of the critical raw materials value chain in the European Union. Ensuring safe and sustainable access to raw materials of our domestic production is crucial for the success of EUs green and digital transition and the achievement of climate goals.

CECIMO welcomes the announced legislative proposal, the European Critical Raw Material Act (CRMA) as an important initial step towards developing competitive and resilient digital future and green transition of industries.

Securing Indigenous Rights in the Green Economy Coalition (SIRGE) feedback on the European Commission Proposal for an EU Critical Raw Materials Act June 2023 To operationalize its twin digital and green transition, the European Union requires a high supply of Critical Raw Materials (CRMs).

European Aluminium, the industry association representing the whole aluminium value chain in Europe, welcomes the Critical Raw Materials Act (CRMA), as a long-overdue first step towards acknowledging the need for a full value chain approach in realising Europes strategic resilience and sustainable growth. Securing a sustainable and robust access to raw materials in support of the twin transition is key.

Registered Office (UK) Fourth floor, 43 Berkeley Square, London, W1J 5FJ, United Kingdom E [email removed] T [phone removed] Ares(2023)4515777 - 29/06/2023 Norway Ref. Office Norge Mineraler, Langholmveien 6, 4373 Egersund, Norway E [email removed] T [phone removed] Norge Mineraler AS - Feedback on the EU CRM Act proposal Norge Mineraler AS welcomes the Critical Raw Materials Act (CRMA) proposal and appreciates the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SMEunited welcomes the initiative to increase the supply of raw materials that are too often scarce and furthermore needed for future-oriented technologies. Creating an assisting environment for raw materials projects, and binding procedural deadlines for Member States are a necessary start to make raw materials projects deliverable for SMEs. However, the proposal has a number of weaknesses, namely: 1.

The CEA welcomes the draft European regulation on critical materials, aimed at improving the Union’s security of supply through combined action on domestic supply of primary and secondary materials, as well as on the diversification of external supplies. However, it is a serious blind spot to propose action on the demand for materials by means of an effective and sobriety approach.

Filed in French · English published by the European Commission

The Sámi Parliaments in Finland, Norway and Sweden cooperate through the Sámi Parliamentary Council (SPC). SPC was established in year 2000. The traditional Sámi territories are known collectively as Sápmi. We would like to express our views about the proposal on The Critical Raw Materials Act.

AMINER, the association of research, extraction, mining- metallurgy processing, auxiliary and service companies of Andalusia (Spain) welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition.

Critical Raw Materials Act: Metals industry improvement areas to Commission proposal Europe’s Critical Raw Materials Act is an important first step forward for Europe’s raw materials and industrial policy. It recognizes that the EU must act urgently to avoid unhealthy dependencies or supply bottlenecks for the metals and minerals required in its energy and digital transitions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As requested by NGOs in the initial consultation, deep-sea mining (DSM) should be explicitly excluded from the scope of the Critical Raw Materials Act (CRMA), including explicit exclusion from the criteria of Strategic Projects. In the Commissions proposal, whether DSM is included in the scope of the Regulation or whether DSM operation could be given priority status as Strategic Projects is concerningly unclear.

The European Recycling Industry welcomes the European Commissions (EC) proposal for a Regulation on Critical Raw Materials and acknowledges the Commissions commitment to set ambitious measures to boost the circularity of CRMs, which are often indispensable inputs for a wide set of strategic sectors including renewable energy. EuRIC represents the European recycling industry at an EU level.

- T&E supports Strategic Projects across the critical metals value chain, notably in processing, recycling & mining from waste. T&E analysis shows there can be sufficient processing capacity in lithium, cobalt and (with a push) nickel to meet Europes 2030 goals. - Environmental & social safeguards cannot be compromised, and should be strengthened in the area of indigenous peoples rights and waste management.

The European Precious Metals Federation (EPMF) position on the European Critical Raw Materials Act 28 June 2023 The EPMF welcomes and strongly supports the European Commission’s Critical Raw Materials Act (CRMA). The CRMA is of paramount importance for the EU’s greening and digital progressions, especially in the scopes of other EU initiatives, e.g.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We refer to the invitation to provide input on the European Commission's proposal for a new regulation on the framework for critical raw materials, the Critical Raw Materials Act, as well as the meeting on 15 May 2023. We appreciate the opportunity to submit our proposed amendments in writing on the regulation.

The Commission's proposal for a Regulation establishing a framework for ensuring a secure and sustainable supply of critical raw materials (the CRMR) aims to ensure that the European Union has access to a secure and sustainable supply of Critical Raw Materials (CRMs) and Strategic Raw Materials (SRMs) for its digital and green transitions while ensuring a high level of environmental protection, circularity, and…

FEAD welcomes the Commissions proposal for a Critical Raw Materials Regulation (CRM) as an important step towards clearly acknowledging the role of circularity, recycling and recovering of materials in the diversification of supply sources and in reducing the EUs dependencies. In addition, by recycling CRMs, the EU can conserve natural resources, and minimise the environmental impacts of mining and extraction.

Oslo, June 29, 2023 Critical Raw Materials Act (CRMA) – feedback from Norwegian Mineral Industry Introduction Norwegian Mineral Industry (NMI) is an industry organization for companies that explore, extract, manage or refine mineral resources in Norway, or companies that otherwise have a particular connection to the mining industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Critical Raw Materials Act (CRMA) is of great relevance for suppliers of raw materials, such as Latin American and Caribbean (LAC) countries, since this policy will imply new extractive processes in the region that could jeopardize rights to a healthy environment, to participation and access to information; to prior consultation and free, prior and informed consent, and to other related rights such as the right…

Návrh nařízení Evropského parlamentu a Rady, kterým se stanoví rámec pro zajištění bezpečných a udržitelných dodávek kritických surovin a kterým se mění nařízení (EU) č. 168/2013, (EU) 2018/858, 2018/1724 a (EU) 2019/102 (Akt o kritických surovinách / CRMA) Hospodářská komora České republiky (HK ČR) vítá návrh Aktu o kritických surovinách (nařízení) Evropské komise, který nastiňuje způsob, jakým chce EU zajistit a…

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To promote raw materials resilience, secure strategic autonomy, and safeguard a just transition, the CRMA must: include measures to reduce raw material demand; ensure that strategic projects operate transparently and guarantee complete participation of local civil society and of communities and indigenous peoples; prioritise circularity by moving higher up waste hierarchy framework; and mandate compliance with…

AMG Lithium welcomes the European Commissions proposal for a regulation to establish a Framework to ensure and secure the sustainable supply of Critical Raw Materials (CRMA) for Europe. As the first Lithium refinery in Europe, we consider the CRMA an essential piece of legislation for the twin climate and digital transitions and would like to highlight some key priorities below (and in the document attached).

The EUSKAL ARIDO ASSOCIATION OF INDUSTRIAS AND FABRICANTS OF ARIDES OF THE COUNTRY VASCO Welcomes the European Commission’s initiative to address the oversight issue of leaving the supply of Raw Materials required for a green and digital transition.

Filed in Spanish · English published by the European Commission

My Name is Ilia Tsilov and I'm the Sales and Marketing Director at Dead Sea magnesium which is an ICL (NYSE: ICL) company producing Magnesium Metal in the Dead Sea in Israel. ICL Group Ltd. is a multi-national manufacturing concern that develops, produces and markets fertilizers, metals and other special-purpose chemical products. ICL serves primarily three markets: agriculture, food and engineered materials.

We are referring to the proposed Regulation on the European Critical Raw Materials Act We agree that critical raw materials (CRMs) are essential inputs for various strategic sectors, amongst which there is also the health sector, and the suppliers of these imports are often concentrated in a small number of third countries during the extraction and processing stages.

THE Critical Raw Materials ACT: ACTION MODE ON The European association for ferro-alloys and silicon industries, Euroalliages, welcomes the European Commission’s proposal on Critical Raw Materials. It is a key starting point to prevent shifting our industrial base outside Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

While the CRMA references mutually beneficial partnerships and value addition in third countries, it is grounded primarily on the EUs supply security, lacking a global justice approach. The way strategic partnerships and projects are currently conceptualized bears the risk of exacerbating human rights and environmental risks, circumventing democratic participation, and undermining development in resource-rich…

Eramet, a European mining and metallurgical group, is a key player in the extraction and refining of base metals necessary for the overall growth of our economy (manganese, mineral sands) and those critical for the transition to a climate neutral economy (nickel, lithium, cobalt).

The Deep Sea Mining Campaign respectfully but strongly recommends that the CRMR explicitly exclude deep-sea mining and instead establish binding EU material-footprint reduction targets particularly for metals as an important step towards downscaling the EUs resource consumption. The precedents and rationale for this recommendation are outlined below.

The GENERAL DE HORMIGONES, S.A. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to…

The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining.

As an environmental and human rights organisation PowerShift, we see 3 key challenges in the Critical Raw Materials Act: Enshrine reduction targets in Articles 1 and 25! The European Commission has recognised that, on the one hand, we are highly dependent on imports and, on the other hand, the global extraction of raw materials contributes to significant environmental damage and human and labour rights violations.

Filed in German · English published by the European Commission

The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining.

Anglo American broadly welcomes the Critical Raw Materials Act (CRMA) and its underlying goal of reducing strategic dependencies by improving resilience of critical raw materials (CRM) supply chains, an essential enabler of the EUs twin green and digital transitions. The global human population almost nine-billion people cannot be supported without mining.

European Commission Reykjavík, June 27th 2023 Sent via the Have your say Portal Subject: Review on the Critical Raw Materials Act The Confederation of Icelandic Enterprise (SA) and The Federation of Icelandic Industries (SI), hereinafter referred to as "the organizations," have review the matter mentioned above which was presented on the 20th of March 2023.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Critical Raw Materials Act IRMAs recommendations on the European Commissions draft proposal Enhancing Environmental and Social Responsibility in Mining Through Due Diligence The role of certification schemes as outlined in Article 29 and Annexes III and IV in the CRMA should be clarified, both in terms of how they should be used as well as their limitations.

The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining.

Airbus welcomes the Critical Raw Materials Act package proposed by the European Commission, aimed at strengthening the EU CRMs security of supply from within and with the support of like-minded partners. Airbus and its suppliers depend almost exclusively on raw material imports and any EU attempt to build more resilience in CRM supply is more than welcome.

Hydrogen Europe welcomes the European Commissions aim to strengthen the European value chain for the extraction, processing and recycling of the critical raw materials that are key for clean techs and, more broadly, the overall transformation of the energy system.

Region Norrbotten och Region Västerbottens positions in brief: (for more information see attached file) It is important that the regulation contributes to a mining industry with high sustainability goals that consider the specific local and regional conditions in the areas where mining operations take place.

We welcome that the EU Commission has recognised the strategic importance of raw materials and is acting. However, in particular articles 27 and 28 on the recycling of permanent magnets should be considered for closer analysis and for changes. VDMA represents 3,600 German and European machinery and equipment manufacturing companies. The industry stands for innovation, export orientation and SMEs.

Korea Business Association Europe (KBA Europe), representing over 390 Korean companies in Europe, and Korea International Trade Association(KITA), representing about 70,000 international trading companies in Korea, appreciate the feedback opportunity regarding the Critical Raw Materials Act(CRMA).

This document sets out AEGIS Europes views on the Commissions Proposal on a European Critical Raw Materials Act (CRMA) published on 16 March 2023. The EU will need massive amounts of strategic raw materials in the coming years to meet the requirements of the twin transition while preserving Europes strategic autonomy.

The extraction and processing of critical raw materials is often associated with serious impacts on humans and nature. The CRMA is therefore an important opportunity to create rules to make raw materials supply chains more sustainable.

Filed in German · English published by the European Commission

CEN and CENELEC welcome the European Commissions proposal for the Critical Raw Materials Act, published 16 March 2023 and the aim to reinforce EU monitoring capacities and strengthen both the EU value chain (through the identification of mineral resources and raw materials projects in the EU's strategic interest, with strong environmental protection) and the EU external policies on CRMs.

The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining.

Orgalim represents Europes technology industries, comprised of 770,000 innovative companies spanning the mechanical engineering, electrical engineering and electronics, ICT and metal technology branches. Together they represent the EUs largest manufacturing sector, generating annual turnover of 2,906 billion, manufacturing one-third of all European exports and providing 11.19 million direct jobs.

The Critical Raw Materials Act aims to ensure EU access to a secure and sustainable supply of critical raw materials, enabling Europe to meet its 2030 climate and digital objectives. Statkraft underlines the critical need to ensure sufficient and diversified access to Critical Raw Materials to succeed with the energy transition to renewables.

Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europes industrial workforce at European Level. Trade unions have long been calling for a stronger EU strategy on raw materials to move towards greater independence through the sustainable exploitation of their own resources, as well as security of supply through a joint and fair…

Renault Group welcomes the CRMA as a first step to secure a sustainable EU value chain by 2030.We call for a clear ambition and adequate EU Industrial Plan to be among the world leaders on green technologies.We ask for a level playing field among competitors by refusing unfair trading practices, as OEM are investing billions of euros exploring new areas of know-how. I.

The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining.

The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining.

In addition to the EuChemS' response to the Public consultation on this topic at the end of last year, the European Chemical Society wants to add the following feedback on the European Critical Raw Materials Act: We recommend adding Phosphorus (P4) and Purified Phosphoric Acid to the Strategic Raw Materials (sub)List, as both are supply-critical and are essential for the designated Strategic industry sectors…

LANXESS welcomes the opportunity to contribute to the European Commission's proposal to establish a framework for ensuring a secure and sustainable supply of critical raw materials. LANXESS acknowledge that phosphorus and phosphate rock have been included in the Critical Raw Materials list in the EU Commissions proposal for a European Critical Raw Materials Act.

Vanitec’s response to the public consultation on the EU’s Critical Raw Materials Act 26 June 2023 Vanitec, the international organization representing vanadium companies and organisations involved in the mining, processing, manufacturing, research and use of vanadium and vanadium-containing products, welcomes the Commission’s proposal on Critical Raw Materials Act (CRM Act).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

maki Consulting considers a Critical Raw Material (CRM) Regulation (including for Strategic Raw Materials (SRM)) to be a suitable way to address supply risk to societys demand for critical and strategic materials. In fact, it is arguably both more relevant and more meaningful than current indicators on Resource depletion overall that look into extraction speed vs. (global) stock.

Ana María Alonso Zarza, Director of the Geological and Mining Institute of Spain, CSIC To: European Commission The Geological and Mining Institute of Spain (CN IGME CSIC) is a public research Institute of CSIC, Spanish Science and Innovation Ministry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Bosch highly welcomes that the EU is taking action to secure the supply of critical raw materials for industry. Copper should not be classified as a SRM. It is a base metal that is widely available from different sources and traded on functioning, transparent international markets. Treating Copper as a SRM would lead to a wrong focus of efforts (e.g., for recycling, supply chain stress tests).

KGHM Polska Miedź S.A. comments and remarks to the Proposal for a Regulation of the European Parliament and of the Council establishing a framework for ensuring a secure and sustainable supply of critical raw materials Lp. 1. 2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Minviro welcomes the life cycle approach of the Critical Raw Materials Act. We firmly support the implementation of a level playing field for raw materials, requiring environmental footprint declarations, in line with the EU battery regulation. Additionally, we appreciate the inclusion of impact categories beyond carbon footprint and the thorough evaluation thereof.

We attacked our comments to this draft regulation in a separated document. In particular, we want to remark that we are pro-rata to remote copy and nickel battery grade from the list of critical raw material and strategic raw materials. There have been a market failure of these raw materials in the European Union.

Filed in Spanish · English published by the European Commission

Naturvernforbundet | Mariboes gate 8 |0183 Oslo [email removed] Telefon [phone removed] Org nr.: 938 418 837 Bank: 7874.05.56001 European Commission Oslo, 23.06.2023 Input to the public consultation on the European Commission proposal for the Critical Raw Materials act. We refer to the European Commission’s consultation on the Critical Raw Materials Act (CRMA) and appreciate the opportunity to give our comments.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EuroGeoSurveys welcomes the proposed CRM Act as a positive action toward supporting and boosting the EU exploration and mining industry and increasing the resilience of EU raw materials supply chains, necessary to achieve the Green Deal. Specifically, we note the recognition of the important roles that the National Geological Survey Organisations and, collectively, EuroGeoSurveys will play in its implementation.

The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining.

Today, Europe sources more than 95 % of its rare earth elements from outside. To guarantee its own supply and the strategic autonomy of European manufacturers, MagREEsource has developed an innovative and clean technology for recycling end-of life magnets with Hungary, in order to recover a magnet powder that can be directly used for the manufacture of new magnets.

Filed in French · English published by the European Commission

The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association, pinfa, www.pinfa.eu regrets that Phosphorus (meaning elemental phosphorus, P4 and derivates) is not listed in the proposed Critical Raw Materials Act as a Strategic Raw Material, as the substance/component is crucial for fire safety in batteries, renewable energy, electrical systems, circuit boards, electronic, power and data cables…

The Critical Raw Materials Act (CRMA) represents an important milestone for the European supply of raw materials and for strengthening the resilience of the European economic area. The German Steel Federation welcomes this regulation. Steel is the most important construction material. Due to its multi-recyclability, steel is a prime example of the circular economy.

Terre des Hommes Netherlands welcomes and supports the European Commissions proposal to establish a comprehensive framework for ensuring a secure and sustainable supply of critical raw materials with the proposed European Critical Raw Materials Act.

Our feedback: The EU Critical Raw Materials Act (CRMA) June 2023 Today, the EU sources more than 95% of its rare earth elements (REE) from China. REEs are, among other, important for the production of permanent magnets, which are crucial components in wind turbines, EV motors, and other technologies needed to reach the EU climate targets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Energy Research Alliance (EERA) is an association of European public research centres and universities with the mission to catalyse European energy research for a climate-neutral society by 2050. Bringing together more than 250 organisations from 32 countries, it is Europe's largest energy research community.

The International Council on Mining and Metals (ICMM) welcomes the European Commissions clear recognition and commitment to responsible mineral supplies in the Critical Raw Materials Act, and we welcome the opportunity to take part in this second public consultation on the proposed regulation.

The Pan-European Resources and Reserves Reporting Committee (PERC) is a not-for-profit association of six professional organisations whose membership includes a significant proportion of currently active European mining professionals involved in the extractive minerals industry in Europe and around the world.

The German Association of the Automotive Industry (VDA) consolidates about 650 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. We represent the interests of the automotive industry and stand for modern, future-oriented multimodal mobility on the way to climate neutrality.

Corbion welcomes the Commissions initiative to ensure Europes secure and sustainable access to critical raw materials. The proposal is an essential step towards reducing strategic dependencies on third countries imports and improving the resilience of the EU. We, at Corbion, notably appreciate the introduction of the concept of material substitution within the text.

The European Ceramic Industry Association welcomes the Commissions initiative aimed at ensuring a secure and sustainable supply of critical raw materials. As a highly heterogeneous sector, the ceramic industry includes multiple sub-sectors ranging from construction products to refractory ceramics, from technical components to commodities like tableware.

PKEE welcomes the draft proposal that aims at reducing dependency and diversifying imported strategic raw materials. We believe that this proposal strengthens the autonomy in the supply of key raw materials in the EU for net-zero technologies. If done right, it can boost domestic production in the EU away from other countries including China.

ASD welcomes the European Commissions legislative proposal for a Regulation aimed at securing the supply of critical and strategic raw materials. Given the EUs aerospace and defence sectors almost exclusive reliance on raw materials imports, we strongly support attempts by EU decision-makers to build more resilience in the supply of CRMs.

The European automotive supply industry (CLEPA) appreciates the European Commissions proposal for a Critical Raw Materials Act (CRMA). Material dependencies could undercut our industrys transformation. The EU should deliver trade and raw material partnerships with third countries, a higher recovery rate of materials, improved sourcing conditions, and a strengthening of EU raw material supply chains.

RISE believes that the commissions proposal to a large extent address relevant topics such as benchmark and goals, strategic projects and definitions, circularity and environmental assessment. RISE's views and comments on the present proposal mainly concern the parts that relate to definitions on strategic and critical materials, strategic projects and the proposal on stress test, permitting processes, value chain…

Elemental Phosphorus P4 and Purified Phosphoric Acid should be on the EU Strategic Raw Materials List. Both are essential for all identified Strategic industries: batteries, renewable energy, electronics-data, aerospace. All these sectors need phosphorus flame retardants to meet fire safety requirements. The EU is import-dependent for P4 on China, Vietnam and Kazakhstan.

The company CEMENTOS TUDELA VEGUÍN, S.A.U. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of…

Please find attached detailed comments for the CRMA as well as associated NZIA. In general the industry welcomes the activities to facilitate and simplify procedures, but is aware of the subsidiarity and lack of EU competencies in that area - member states will be key to deliver. Streamlined and enhanced financial instruments are missing as well, especially for NZIA.

VTT, the Technical Research Centre of Finland, recognises the tremendous significance of critical raw materials in the electronics, defense, aerospace, mobility, chemicals, and health industries, amongst others, and especially for digital applications and the energy sector and we welcome EU pulling together to act on the topic.

The Mercedes-Benz Group AG would like to give the attached feedback to the European Critical Raw Materials Act. Mercedes-Benz is committed to a fully electric future of mobility. A core element of our sustainable business strategy is Ambition 2039.

The European Federation of Geologists (EFG) is a not‐for‐profit organisation instituted to ensure competent and ethical practice among geoscientists in Europe while representing the profession across the continent. As such, we have identified three themes within the pending legislation that we believe should be revised. These themes are addressed in the attachment, in priority order for EFG.

The Spanish Association of Producers of Industrial Minerals (AINDEX) welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition.

The Swedish environmental company Ragn-Sells, active in waste management, environmental services and recycling, converts waste into raw materials that can be used over and over again. Ragn-Sells drives the transition to a circular economy through solutions that reduce the companys own and other actors' environmental and climate impact.

Encompassing all sectors our economy, providing tangible benefits for our citizens and businesses, while providing the means to ensure the strategic autonomy and the resilience of Europe, space has an essential dimension to the functioning of our society that cannot be jeopardised. In this regard, Eurospace welcomes the European Commissions legislative proposal for a Critical Raw Materials Act.

HEIDELBERG MATERIALS HISPANIA welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to…

Warsaw, 18th May 2023 PKN ORLEN POSITION ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ESTABLISHING A FRAMEWORK FOR ENSURING A SECURE AND SUSTAINABLE SUPPLY OF CRITICAL RAW MATERIALS [COM(2023) 160 FINAL]. We welcome the proposal for a Critical Raw Materials Act.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurogypsum, the association representing the interests of the European gypsum supply and gypsum product manufacturing industry, is committed to the objective of supplying essential raw materials to European societies in the most sustainable way and substantially contributing to the objectives of the European Green Deal.

Access to and supply of Critical Raw Materials (CRMs) is crucial to the European energy transition and to the EUs broader industrial and strategic goals. For the EUs battery industry, domestic supplies of relevant CRMs remain insufficient to meet expected demand and challenges to cost-competitive access to these materials both in Europe and in third countries endure for European industrial players.

Exploitation of Rocas Industriales y Minerales S.A. welcomes the European Commission’s initiative to address the overriding issue of leaving the supply of Raw Materials necessary for a green and digital transition.

Filed in Spanish · English published by the European Commission

Feedback to Commission on CRMA from Open Society Foundations Climate Initiative Open Society Foundations supports the Commission’s intentions to expand the availability of renewable energy in Europe and recognises the need to increase the EUs access and processing capacity of critical raw materials.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Spanish Confederation of Mineral Raw Materials Industries-PRIMIGEA, welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition.

The National Association of Aggregate Manufacturers-ANEFA, in defense of the legitimate collective interests of its members, welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition.

The Spanish Confederation of Extractive Industries of Industrial Rocks and Minerals-COMINROC welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition.

The Federation of Aggregates (FdA), which represents the interests of companies producing aggregates in Spain, both nationally and internationally, welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition.

The Company PAVASAL EMPRESA CONSTRUSCTORA S.A. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of…

The Agrupacion Empresarial Minera Navarra (AEMINA) welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition.

The Federation of Norwegian Industries welcome the new proposal for a Critical Raw Materials Act. Reaching the targets of the European Green Deal and the accelerated ambitions of REPowerEU will require a significant increase in the use of minerals and metals. Going forward, improving Europes access to critical minerals and metals will be decisive for securing strategic autonomy and delivering the green transition.

Fraunhofer expresses its explicit support for the CRMA and its overarching goal to ensure the EUs access to a secure and sustainable supply of critical raw materials. Particularly the provisions for developing the circularity of critical raw materials markets and lowering the environmental footprint of critical raw materials are commendable.

With the Critical Raw Materials Act (CRMA), the European Commission is presenting a regulation aimed at strengthening Europe's sovereignty with regard to the supply of raw materials. BV Glas welcomes this initiative, because strategic and critical raw materials are also used to manufacture glass products, especially in the special glass industry.

POSITION PAPER European Commission Proposed Critical Raw Materials Act Nickel Institute Position Introduction The Nickel Institute1 welcomes the European Commission’s proposal for a Critical Raw Materials Act, published on 16th March 2023. Nickel producers are at the beginning and at the end of important value chains for the EU´s future.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The GALICIAN AGGREGATES ASSOCIATION (ARIGAL) welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of…

The Spanish Association of Manufacturers of Magnesia (MAGES) welcoming the European Commission’s initiative to address the oversight issue of the supply of Raw Materials required for a green and digital transition.

Filed in Spanish · English published by the European Commission

The Spanish Cement Association (Oficemen) welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access…

The AIZKIBEL, S.A. COMPANY welcoming the European Commission’s initiative to address the oversight issue of the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaching an insurmountable legislative barrier for MPS and is in line with the fundamental principles of access to resources.

Filed in Spanish · English published by the European Commission

CANTERAS ACHA, S.A. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to resources.

The COMPANY MAGNESITAS DE Rubian, S.A. welcoming the European Commission’s initiative to address the oversight issue of the supply of Raw Materials required for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaching an insurmountable legislative barrier for MPS and is in line with the fundamental principles of access to…

Filed in Spanish · English published by the European Commission

ANCADE welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to resources.

The company Cementos Lemona S.A.(a CRH company) welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition.

ARIDOS CAMARERO S.L. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to resources.

The Company HORMISORIA S.L. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to resources.

The Catalan Cement Association welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to…

Magnesitas Refractarios, S.L. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to…

Magnesitas y Dolomías de Borobia, S.L. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to…

Magnesitas Sorianas, S.L. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to resources.

Magnesitas Navarras, S.A. welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to resources.

DEAR Ladies and Gentlemen, with my feedback, I would like to support ESPP’s “Phosphorus Inititive (P4)” and highlight the need for a sustainable sourcing of P4 derivatives within the EU from the point of view of a processing company (Chemische Fabrik Budenheim – subsidiary of the sibling Oetker Participation Company).

Filed in German · English published by the European Commission

To support the EUs industrial competitiveness through the green and digital transitions, the European Commissions proposal for the Critical Raw Materials (CRM) Act must be made workable for industry and respect Single Market principles.

EARTO welcomes the European Commissions proposal for a regulation to establish a Framework for ensuring a secure and sustainable supply of Critical Raw Materials and the accompanying Communication. EARTO members are ready to contribute to the definition and subsequent implementation of the Critical Raw Materials Act (CRMA), and hereby put forward the following key messages.

CRITICAL RAW MATERIALS ACT CONSULTATION POSITION PAPER Brussels, April 2022 European Aluminium, the voice of the entire aluminium value chain in Europe, welcomes the Critical Raw Materials Act (CRMA) as a long-overdue first step towards acknowledging the need for a full value chain approach in realising Europe’s strategic resilience and sustainable grow.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Confederation of Swedish Enterprise welcomes the European Commission's initiative to improve access to critical and strategic raw materials for business in the EU. It notes that this is both through the intention to promote opportunities for exploration, mining, processing and recycling as well as the ambition to strengthen trade relations with like-minded countries.

A3M, which represents French metals mining, processing, and recycling industry, wishes to express its strong support for the draft European Union (EU) Regulation on Critical Raw Materials, aimed at ensuring EU's strategic autonomy. Please find attached A3Ms position on the draft regulation on Critical Raw Material ACT.

Cobalt Institute response to Critical Raw Materials Act consultation 2nd May 2023 1. Recommendations and summary We support the intentions of the Act, which represent an important first step towards supporting resilient raw materials sourcing and production, globally and in the EU. There remain opportunities to go further, which we outline these in this paper.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Commissions proposed Critical Raw Materials Act is a much-needed initiative in today's world. Demand for critical raw materials (CRMs) will continue to increase, in order to underpin a sustainable transport system in the near future.

Brussels, 19 April 2023 CRM Alliance Position Paper on the Critical Raw Materials Act Introduction The Critical Raw Materials Act is an important step for Europe’s ambition to secure a competitive domestic value chain for critical and strategic raw materials. The CRM Alliance welcomes the proposal, and the ambition Europe has for the raw materials industry sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Brussels, 21 March 2023 BeST Position Paper on the European Critical Raw Materials Act With the present paper, the Beryllium Science and Technology Association (BeST) encourages co-legislators to carefully assess the impact of the provisions included in the recently published Critical Raw Materials Act (CRM Act) on EU industry and its supply chains.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I'm an Italian Mining Consultant, with more than 35 years experience in more than 60 world countries. I'm mining and exploration geologist member ot the Italian Council of National Geologists (CNG), Competent Person for Dimension Stone (DS) and Construction Materials (CM), EU PERC and EFG member and Head of PERC Construction Materials and Industrial Minerals (IM) subcommittee.

European Public Consultation on Critical Raw Materials Act Technical contribution by the Ministries of the Flemish region This contribution is a selection of views, not a full answer to all possible parts of a CRM-act 1) Challenges for securing sustainable supply of critical raw materials General challenges To fulfil the societal needs in the coming decades towards a greener and more digital future (‘twin…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Geological Survey of Italy, department of ISPRA, the Italian Institute for Environmental Protection and Research, welcome the initiative to produce a new European CRM ACT with great interest and satisfaction. Italy has a long history of mining extending back to Pre-Roman times. It is our intention to identify all the ancient mining sites.

In the context of the overarching objectives of the European Green Deal and the REPowerEU, Li-Cycle supports the European Commissions proposal for a Critical Raw Materials Act to secure a sustainable supply of critical raw materials. Secure and sustainable supplies of battery materials such as nickel, cobalt, lithium, and graphite will be critical for ensuring rapid energy and mobility transitions.

The proposed Act plans to dramatically maximise mining, in the middle of intertwined social, ecological and climate crises. The harmful effects will be felt especially in third countries, again, mainly in the Global South as well the EU neighbourhood. Serbia, an EU candidate country, is experiencing a boom in exploration, and ramping-up of existing production, with detrimental socio-ecological impacts.

Technology development and knowledge transfer for a secure supply of raw materials worldwide is working to reduce the use of fossil fuels in industry and daily life. In order to be able to make more and more efficient use of renewable energies, the use of future-oriented technologies is necessary.

Filed in German · English published by the European Commission

The Energy Storage Systems Association, BVES, is representing energy storage companies from across the EU. It is welcoming the consultation on critical raw materials. This is an important step to develop a sufficient EU raw material strategy which will lay the basis for a net-zero economy in the EU.

We support the European Commissions initiative on Critical Raw Materials Act (CRMA) and would like to take the opportunity to welcome the announcement of the Green Alliance and the intention of establishing a Strategic Partnership on Raw Materials and Batteries with Norway. The need and demand for minerals is increasing and minerals are becoming an crucial part of the regional, national and global geopolitical game.

A global coalition, coordinated by the Yes to Life No to Mining Europe working group, gathered 180+ community platforms, human rights and environmental organisations, and academics from 36 nations, in June 2021 called on the EU to abandon its plans to massively expand dirty mining as part of EU Green Deal and Green Recovery plans.

MagREEsource is a young Magnet producer whose ambition is to structure a sovereign industrial sector, anchored in the circular economy, and wants to open the first European MagFactory with a capacity of 500 tons by 2027.

A RESPONSIBLE EUROPEAN CRITICAL RAW MATERIALS ACT The European Union is facing a key political and social moment that will shape the future of Europe's identity and quality of life standards. However, now more than ever we are also aware of the negative consequences of uneven economic and technological development.

Value chain should start with the identification of potential mineral deposits in Europe. The knowledge of the subsoil potential is a basic information for the raw materials strategy. A state-of-the-art data set would be a key element to help the decision making process

The pan-European network of research funding organisations on non-fuel, non-food raw materials for the sustainable development and the circular economy (ERA-MIN3) supports the Commissions initiative. ERA-MIN3 network is represented by Foundation for Science and Technology (FCT), Portugal, at the High-level Steering Group of the EIP on Raw Materials for the period 2021-2024.

1 (2) 25.11.2022 European Critical Raw Materials Act Feedback from Finnish Mining Association Finnish Mining Association welcomes the European Commission’s planned adoption of a European Critical Raw Materials Act (henceforth ECRMA). We underline the importance of the Commission’s clear commitment to ensuring that high environmental and social performance standards are met.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

REIAs Input for the EU Raw Materials Act Date: November 25th, 2022 To: DG GROW, EU Commission A. Policy Proposals: Just Transition Fund: With the opportunity of the EU's Midterm Review of the Multi-year Financial Framework, the EU should amend the Just Transition Fund's maximum eligible grant amount per single projects and per single NACE code. Currently caped at 18.7 Million, it should be expanded to 80 Million.

While the EU is on a long-standing path for its raw material policy, including criticality aspect, we highly welcome the increase emphasis put on this matter and the announced intention to increase efforts besides the Raw material strategy that is already in place (COM (2020)474).

AEPSA (Association of Portuguese Companies for the Environment Sector) welcoming the European Commission proposal for a Critical Raw Materials Act. Please find below AEPSAs contribution to the call for evidence on critical raw materials (in Portuguese).

Filed in Portuguese · English published by the European Commission

The Danish Agriculture and Food Council welcomes this initiative from the Commission. It is important to point out that much more should be done to secure and reuse the valuable resource in organic waste and in biomass in general. We support the ECN's considerations and proposals for this consultation, which were submitted on 10 October.

LKABs views on the Critical Raw Materials Act (full details + urgent requests in the attachment) LKAB welcomes the Commissions initiative to address the obvious and urgent need to secure supply of raw materials required to develop digitalization and advanced technologies, to reach the objectives of the Green Deal.

Gas Distributors For Sustainabilty (GD4S) welcomes the EC initiative on critical raw material. Availability and affordability of natural resources will drive sustainable economic models and energy transition. Decision-makers need information and data to manage uncertainty and adverse conditions.

The International Platinum Group Metals Association (IPA) is a non-profit association that represents the worldwide leading mining, production and fabrication companies in the global platinum group metals (PGMs) industry, comprising platinum, palladium, iridium, rhodium, osmium and ruthenium. The IPA welcomes and fully supports the European Commissions intention to put forward the Critical Raw Materials Act.

The Critical Raw Materials Act offers Europe the opportunity to secure access to the minerals and other raw materials required for green technology, and to promote its vision of responsible mining. In fact, these two opportunities are inextricably linked. Without responsible mining, there will be major challenges and disruptions for access to these critical raw materials.

Circulating our economy brings social and environmental co-benefits. In addition to its contribution to the decarbonisation of our industry, it is a strategic lever to safeguard our sovereignty in supplying critical raw materials, offering the recovery of waste from our European electronic and electricity park.

Filed in French · English published by the European Commission

Form Energy welcomes the European Commissions Critical Raw Materials (CRM) initiative, which comes at a key interval as the EU takes action to advance the energy transition, strengthen its strategic autonomy and ensure reliable, affordable energy supply.

The Association of Municipalities Jämtland Härjedalen inspel in the consultation on the EU Critical Raw Materials Act consists of 21 counties and 21 regions. The county is the name of the state administrative division and the region is the name of the political regional level. The local political level is made up of primary municipalities. There are 290 primary municipalities in Sweden.

Filed in Swedish · English published by the European Commission

This response is provided on behalf of the Pan-European Resources and Reserves Reporting Committee (PERC), which is a not-for-profit organisation whose members are professional organisations representing many mining industry professionals working in Europe.

Genanvend Biomasse welcomes this initiative from the Commission. It is important to point out that much more should be done to secure and reuse the valuable resource in organic waste and in biomass in general. We support the ECN's considerations and proposals for this consultation, which were submitted on 10 October. With regard to CRM and organic waste, the focus will be on the recycling of phosphorus.

With about 50,000 members in over 100 countries, the Royal Society of Chemistry is the UKs professional body for chemical scientists. The chemical sciences community already makes substantial contributions to the green economy, including developing new battery chemistries, and will continue to bring vast and varied knowledge and skills to a diversity of economic sectors which will contribute to, and undergo…

The European Chemical Industry supports the objective to secure a sustainable supply of critical raw materials to support the green and digital transitions and strengthen EU resilience. Access to raw materials, feedstock and energy at economically sustainable prices will remain an important element of the EUs chemical industry competitiveness, next to enabling its green and digital transition.

Russia's war of aggression against Ukraine, which violates international law, has highlighted Europe's dependence and vulnerability on Russian energy sources. But not only here: In the case of strategic minerals such as rare earths, the dependence, especially on China, is already much greater. Raw materials are being used as a weapon by Russia in particular. Europe can be blackmailed.

Europes technology industries are committed to providing high-tech solutions to enable the EUs twin digital and green transitions. However, in recent years they have experienced huge challenges in accessing raw materials at competitive prices, which in the long term could impair their ability to continue to innovate and drive Europes transition towards a more sustainable economy.

FEFAC represents the EU Compound feed and Premixtures industry for food-producing farmed animals and aquaculture. FEFAC welcomes the action plan of the EU Commission regarding critical raw materials. We would like to stress that the food & feed chains are also highly dependent on a number of substances being essential nutrients for animals, especially minerals (rock phosphate, magnesium sources) and feed additives…

AFEP, the association of large French companies would like first to thank the European Commission for giving the opportunity to submit comments at the occasion of the public consultation for the impact assessment of a legislative proposal regarding the adoption of a Critical Raw Material Act.

AFAÏA is the French Federation representing companies specialized in the manufacture of innovative and sustainable fertilising products: growing media, organic soil improvers, organic and organo-mineral fertilizers and biostimulants. Today, we represent more than one hundred companies involved at least one of these fields.

Position Paper for the Critical Raw Materials Act Recycled CO2 as a climate-positive raw material November 24, 2022 Paebbl is a young, pan-European SME, whose aim is to develop and commercialise scalable mineralisation technology that can help the EU in its transition to climate neutrality.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Considering its long-standing involvement in this domain and the critical role of strategic minerals for the Energy Transition, BRGM welcomes the EU initiative of establishing a Critical Raw Materials Act. As a Research and Technology Organisation, the BRGM has the relevant skills to support the European commission and Europes raw materials industry to identify, characterize, produce and recycle raw materials using…

The Zero Emissions Platform (ZEP) welcomes the upcoming initiative aimed at safeguarding the supply of critical raw materials through a package on Critical Raw Materials. ZEP would further like to note that bottlenecks and supply chain dependences and vulnerabilities may well pose a risk for the future deployment of Carbon Capture and Storage (CCS) and Carbon Capture and Utilisation (CCU) technologies in the EU…

25 November 2025 BDE Feedback: Announcement of a Proposal for a CRMA The BDE welcomes the Commission's initiative for a Critical Raw Materials Act as ground-breaking. The problem regarding Europe's increased dependence on raw material exports from third countries with autocratic and undemocratic structures was already expounded about 20 years ago on German national level.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SGL CARBON GmbH • P.O. box 1193 • 86400 Meitingen Graphite Solutions Business Line Battery Solutions Dr. Peter Roschger Head of Battery Solutions Meitingen, November 24, 2022 To the European Commission Response to Public Consultation for the European Critical Raw Materials Act -- About SGL Carbon SGL Carbon is a global leader in the development and manufacture of carbon and graphite-based solutions serving a wide…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CALL FOR EVIDENCE European Critical Raw Materials Act EFG Expert Panel on Minerals and their Sustainable Use – 10 November 2022 Introduction Over the past decade, the European Commission and Parliament have addressed the security of supply of critical raw materials through various Communications, studies, reports and resolutions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Schneider Electric welcomes the European Commission proposal for a Critical Raw Materials (CRMs) Act. It is a great opportunity to strengthen EU resilience and security of supply of CRMs. The most important aspect will be getting the scope right. We wish to highlight copper, nickel, high-purity manganese, light rare earth elements, cobalt, graphite, silicon, and silver, as strategic materials.

2022-11-25 Ref. Ares(2022)8175325 - 25/11/2022 Point of Contact: [name removed] Director EU Single Market and Trade Policy The Association of Swedish Engineering Industries Email: [email removed] Phone: [phone removed] The Association of Swedish Engineering Industries (Teknikföretagen) input to the European Critical Raw Materials Act Responding to the Call for Evidence for an Impact Assessment published by the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We support the aims of the proposed EU Critical Raw Materials act to ensure the secure and sustainable future supply of CRMs. We recognise the importance of critical materials to the transition to NetZero and our future prosperity and security. In particular CRMs are required for strategically important sectors such as aerospace and defence.

EU businesses are progressively witnessing a significant increase in demand of strategic materials and components that is not being met by existing production capabilities. At the same time, the EU is facing threats of losing production due to decreasing global competitiveness, especially in the area of energy intensive basic products.

The European Ventilation Industry Association (EVIA) welcomes the Commission proposal for a CRMA and appreciates the opportunity to provide feedback. EVIAs main message is that the CRMA should not set prescriptive requirements in the legislation itself. The CRMA should be a framework legislation that sets objectives that are implemented more granularly in the appropriate Internal Market legislation.

The Danish Institute for Human Rights (the Institute) welcomes that the EU identifies adverse social and environmental impacts as one of the six key problems in the supply of critical raw materials. Indeed, the production of critical and processing of raw materials can have significant adverse impacts on the human rights of workers and communities.

A3M reimburents the French metal mining, processing, and recycling industry. We strengthen support for the initiative of an EU CRM Regulation aimed at ensuring strategic value of EU through a supply of strategic raw materials to achieve EU key objectives (energy and digital transitions, sustainable mobility, operations of strategic value chains including EU defence).

Filed in French · English published by the European Commission

Quebec welcomes the European Commission’s initiative to adopt a European regulation on critical raw materials and welcomes the opportunity to contribute to this public consultation. Quebec shares a vision and objectives aligned with those of the European Union and is keen to deepen the already well-established collaboration to help create more sustainable, resilient supply chains based on respect for common…

Filed in French · English published by the European Commission

Disclaimer: This response has been submitted by Hydrogen Europe on behalf of the Electrolyser Partnership, an initiative jointly organized by the European Commission and Hydrogen Europe under the auspices of the European Clean Hydrogen Alliance.

ECOS welcomes the initiative to establish a European Critical Raw Materials (CRMs) Act. However, this must be based on circular principles and promote both sufficiency and resource-efficiency. This can be achieved by adopting the following circular strategies and measures: 1. Rethink and reduce demand through systemic change, promote access over ownership: o Set an EU-wide material footprint reduction target (incl.

The coronavirus pandemic and its economic aftermath along with the current energy crisis resulting from EUs dependency on Russian fossil fuels have only increased the urgency to ensure the security of supply of raw materials to the EU and its strategical independence, as well as to reduce the impacts on the environment due to increased use of CRM in the global economy.

Réponse de RTE à l’appel à contributions au sujet des matières premières critiques L’économie circulaire sera une condition de réussite majeure, à la fois de la transition numérique et de la transition écologique, pour plusieurs raisons convergentes : • La maîtrise des risques géopolitiques et industriels sur l’approvisionnement en matières nécessaires pour les matériels numériques et pour les infrastructures…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)