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

The importance for the EU to secure a supply of critical raw materials to transition away from fossil fuels and toward energy independence is well understood. But future needs must be a) carefully assessed and influenced through demand-side management, b) not met principally through the continued extraction of raw materials, often with negative impacts on biodiversity and people and c) that sourcing is subject to…

The Norwegian University of Science and Technology (NTNU), Norways largest university, conducts research and education across the entire value chain for raw materials production, encompassing exploration, mining, mineral processing, metallurgy, materials science and downstream application of raw materials.

Positioning on a European Strategic Raw Materials Act Contents I. Summary II. Introduction III. Preliminary remarks on the scope and name of the Act IV. Challenges V. Solutions a. Strengthening domestic mining and refining (pillar 1) b. Securing access to raw materials from abroad (pillar 2) c. Expanding recycling and the circular economy (pillar 3) d.

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

25 November 2022 ETRMAs response to the Call for Evidence on the Critical Raw Materials Act Introduction The European Tyre and Rubber Industry welcomes the Roadmap published by the European Commission on a European Raw Materials’ Act.

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

Hydrogen Europe is the European association representing the interest of the hydrogen industry and its stakeholders and promoting hydrogen as an enabler of a zero-emission society. With more than 400+ members, including 25+ EU regions and 30+ national associations, we encompass the entire value chain of the European hydrogen and fuel cell ecosystem.

ESPP welcomes the proposal to reinforce EU Critical Raw Materials policy. We particularly support the two Roadmap objectives: 1. Define priorities, and 3. Strengthen the EU value chain including recycling. We suggest that, beyond the Roadmap proposals, it is necessary to address the links between energy security, food security and CRM policy.

Akku Minerals Oy is a newly formed junior mineral exploration company focused on a sustainable answer to Europes critical raw minerals supply shortage. We are passionate about securing the local raw minerals the EU will need to decarbonise our industries and transition us to a green economy. Importantly, we want to do that responsibly and respectfully.

For the production of glass-ceramic panels for electric cooktops (induction / radiant) several raw materials that are listed as Critical Raw Materials by the EU (notably Lithium) are needed. Lithium is a critical component of glass-ceramics and cannot be substituted. For the year 2025 we expect around 15 million glass-ceramic cooktops to be sold in the EU, containing an estimated 4,350,000 kg of lithium carbonate.

The Covid-19 pandemic caused significant disruptions to global supply chains, with several contractors experiencing delays in the delivery of products. The ongoing war in Ukraine has further strained the supply of certain construction materials in Europe and price increases for construction materials are being observed across all EU Member States.

The German Environment Agency welcomes the initiative for a Critical Raw Materials Act. As an environmental agency, we value the importance of a sustainable supply of critical raw materials, in particular, for many products and components of the green transition such as rare earth magnets (e.g. wind turbines, electric vehicles), lithium and cobalt (e.g.

The path taken by the EU to increase the resilience of the European supply and value chain points in the right direction. In particular, the fact that the planned legislation contains a very broad package of measures which influence each other and are as mutually supportive as possible is to be welcomed.

With reference to the public consultation, Fiven AS, a Norwegian SiC producer, welcomes the opportunity to give feedback to the European Critical Raw Materials Act (CRMA). Fiven has 4 remarks/suggestions: 1. Silicon carbide (SiC) has strategic functions such as application in power electronics and electric vehicle efficiency, advanced ceramics etc. but tends to be forgotten in critical raw material assessments. 2.

The German Automotive Industry fully supports the goals of the European Critical Raw Materials Act. However, the identified challenges and proposed fields of action of the European Critical Raw Material Act need to be adapted.

Johnson Matthey is a 205-year-old British company with operations in Europe and worldwide that is a global leader in sustainable technologies, catalysing the net zero transition for our customers and wider society. JM has committed to reach net zero by 2040, and strongly supports the EUs aim to be climate-neutral by 2050.

European Movement International welcomes the Commissions European Critical Raw Material Act initiative. While digitalisation helps many sectors to become more efficient, it also carries a significant environmental impact of its own that must be mitigated. Digital technology comes with a continually increasing demand of critical raw materials.

The European Electronics Recyclers Association (EERA) notes that this initiative will create new jobs and industry growth and provide security for Europe. We recognise that action must be undertaken at the EU level to ensure the supply of key CRMs as it will be impossible to implement and negotiate at Member State level given the lack of harmonisation in regulations and single market initiatives.

Dear Sir or Madam, On behalf of FERROGLOBE a global leader in advanced metallurgical products, we appreciate and welcome the initiatives on measures to secure more sustainable and resilient raw materials supply critical for the green transition. Europe will require huge amounts of strategic raw materials by 2050 to meet the requirements of the twin transition.

Critical Raw Materials Act – Input from the Swedish Recycling Industries The Swedish Recycling Industries welcoming the Commissions initiative on Critical Raw Materials (CRMS). Supply of critical raw materials is instrumental for the EU’s green and digital transition and to tackle climate change. It can also address the implementation of the Green Deal and the Circular Economy Action Plan.

Filed in Swedish · English published by the European Commission

Technology Industries of Finland (TIF) warmly welcomes the European Commissions planned adoption of a European Critical Raw Materials Act. Raw materials are indispensable to ensuring that the transition towards a green and digital European economy is successful. At the same time, they are also commodities that are at high risk of supply disruption.

This consultation process shows the intrinsic failure of the EU, since, although mainly targeted at European actors, they do not take into account the voices of states, communities, people outside the European Union, who will particularly feel the impacts of these decisions.

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There are limited amount of critical raw materials. The mining of such non-renewable materials have several sustainability issues. It is clear that such materials are needed. However, Europe should find and develop renewable alternatives to scarce critical raw materials. For example, by-products of pulp production (e.g. lignin) can provide promising materials to materials used in batteries.

A summary response from EIT RawMaterials and the European Raw Materials Alliance (ERMA) The European raw materials sector views the European Critical Raw Materials Act as the single, most vital action needed to reform the industry, strengthen the technological advantage, and allow Europe to compete globally on a level playing field.

FNADE, the French association for waste management and environmental services supports the willingness of the European Commission to secure the supply of critical raw materials. European self-sufficiency and autonomy are more than ever needed and dependence on third countries must be drastically reduced.

Response to the European Commission's call for evidence on the forthcoming European Critical Raw Materials Act. GCE Ocean Technology would like to draw the Commissions attention to the potential of deep-sea mineral extraction both in national water, including Norway, as well as in international waters manage by the International Seabed Authority, where several European countries/companies have exploration licenses.

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.

Comments for Public Consultation From: Volkswagen AG To: EU Commission Dear Sir or Madam With this message Volkswagen AG would like to give a feedback on the public consultation regarding the European Critical Raw Materials Act (ECRMA). https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13597-European-CriticalRaw-Materials-Act_en.

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

The Federation of European Publishers (FEP) is an independent, non-commercial umbrella association of European book publishers associations. FEP represents 29 national associations of publishers of books, learned journals and educational materials from 28 European countries. FEP is thus the voice of the great majority of publishers in Europe.

Comments to the public consultation on the legislative initiative for European Union critical raw materials The Andalusian Marble Industry Association - (AEMA) is a business association which works as a key instrument in the empowerment of the Marble Region and serves as a catalyst and mediator of everything related to the activity of natural stone in Andalusia.

Filed in Spanish · English published by the European Commission

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

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

Veolia is the global leader in optimised resource management. The Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries.

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

Input from Worldwide Fund for Nature (WWF) Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

The European Recycling Industries Confederation (EuRIC) welcomes the European Commissions initiative on Critical Raw Materials (CRMs) and is pleased to share the view of European Recyclers about what is needed at an EU level to achieve the very goals of it. EuRIC is the authoritative voice of the recycling industry at a European level.

@ nernoxAvrTA,s Ref. Ares(2022)8167267 - 25/11/2022 avilas.no EnhelsregistererForelaks.egisterel Org. no. 913 009 843 Main Address: Stokkahegen 23. 4022 StevarEer Norway Oslo Address: Presader( Harbitz gate 15c, 0259 Oslo, NoMay Stavanger, 25.17.2022 EU Critical Raw Material Act (CRMA) - Call for Evidence Dear Madam/Sir, Thank you for issuing your Call for evidence for an Impact Assessment on an EU Critical Raw…

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

DGEG General Directorate for Energy and Geology, Portugal Mining Authority, expresses the opinion on the new Critical Raw Materials Act: 1. We welcome this European Commission initiative, considering it very relevant to reinforce the development of the entire value chain of raw materials, promoting internal security of supply in the EU for industrialization, namely in the renewable energy sector, essential to…

Feedback on the European Critical Raw Materials Act With reference to the public consultation, Battery Norway welcomes the opportunity to give feedback to the European Critical Raw Materials Act (CRMA). Battery Norway proposes the following: 1. Battery Norway acknowledges that the main aim of the CRMA is to reduce supply risk for critical raw materials in Europe.

K+S Group is an internationally oriented raw materials company based in Germany with production sites in Europe and North America that supplies the strategic minerals POTASH and SALT to European agriculture (potash fertilizers), industry, the pharmaceutical sector and consumers.

Bonn/Düsseldorf/Berlin, 25. November 2022 Stellungnahme zu “Europäischem Gesetz über kritische Rohstoffe“ Sehr geehrte Damen und Herren, wir bedanken uns für die Möglichkeit, zu der Initiative der Europäischen Kommission zu kritischen Rohstoffen Stellung nehmen zu können: I. Allgemeines Der bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V.

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)

Based on our extensive experience in different decarbonization projects, we would like to recommend in the CRM Act not only to consider rare earths and other metals, but also to define early enough other liquid and gaseous resources (in particular methane [CH4], hydrogen [H2], carbon dioxide [CO2] and solid carbon [C]) as critical raw materials and thus to derive and implement measures for their future supply.

Normalización Española European Critical Raw Materials Act Comments from the Spanish Association for Standardisation Comments from UNE. 2022/11/25 1/2 Normalización Española Standardisation as a key player in this challenge Europe faces economic and environmental challenges related with the supply of Critical Raw Materials, including the location of resources and the strategies of different actors.

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

Lapland Chamber of Commerce strongly supports the initiative of European Critical Raw Materials Act and we thank for the opportunity to state our support for it. In Finland, the mining industry is largely located in the north of Finland, Lapland. The turnover of mining and quarrying in Lapland in 2021 was 0,9 billion euros and direct employment was 2,100 person-years.

Fraunhofer expresses its support for the establishment of the Critical Raw Materials Act. To deliver on its ambitious goals, we would like to reinforce the European Commissions efforts with expertise and innovative solutions for a broad range of sectors, which stand to be impacted by the roll out of the initiative. Our key messages are: 1.

RISE Research Institutes of Sweden welcomes the initiative on measures to secure more sustainable and resilient raw materials supply critical for the green transition and would like to give the following input to the development of the EU CRM Act.

The ETIP PV welcomes the opportunity to contribute to the European Commission public consultation on the upcoming European Critical Raw materials act. The European Union needs to have a raw material strategy that is consistent with the imperatives of its energy and climate policies, notably with regards to energy independence and for the success of the European Green Deals in terms of jobs and social impacts.

EurEau wishes to comment on this initiative as follows: Political context: The inclusion of resilience and security in the analysis of the criticality of raw materials is welcome. We strongly believe that public health protection should be added. All sectors covered by the forthcoming Critical Entities Resilience Directive, including drinking water and waste water services, should be covered by the Act.

Digitalisation is not green! We call on the EU to abide by existing EU law in the so-called digital transformation and to reduce the environmental footprint. Protecting all lives and a natural environment takes precedence over economic interests, profits and economic growth.

Filed in German · English published by the European Commission

VKS (German Association of the Potash and Salt Industry) welcomes the initiative of the European Commission to secure raw materials supply for Europe. The Russian war against Ukraine, critical dependencies on raw materials supply from outside the EU and disrupted supply chains during the corona pandemic have highlighted the vulnerability of the European economy.

1) About Cosentino We are a spanish and global family business, dedicated to the design and commercialisation of innovative high-value surfaces for the world of design and architecture. To this end, we create premium brands and products that provide sustainable, innovative and functional solutions for both the home and public spaces such as Silestone®, Dekton® and Sensa by Cosentino®, innovative surfaces that allow…

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

The Korea Business Association Europe (KBA Europe), representing over 380 Korean companies in Europe, appreciates the feedback opportunity regarding the European Critical Raw Materials Act. We welcome the Commissions initiative to increase security of critical raw materials in the EU.

The vital transition away from fossil fuels towards cleaner technologies for transport will drive, depending on the technology, the demand for raw materials like lithium, nickel. Whilst some CRMs are available in the EU, Europe is largely dependent on third countries for mining, processing, refining and recycling, even more so in the case of batteries needed for EVs and considering the current geostrategic tensions.

This reply is made on behalf of the Fair Trade Advocacy Office which is an advocacy organisation of the Fair Trade Movement for Fair Trade and Trade Justice with the aim to improve the livelihoods of marginalised producers and workers in the Gobal South. We would like to emphasize that the most affected groups, especially rights holders throughout the entire value chain of CRM, are consulted.

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. Via the CONEBIs national industry members, more than 600 small, medium and large companies are represented in CONEBI.

SEMI Europe, the global industry association representing more than 2,500 companies and 1,3 million professionals from across the global electronics manufacturing and design supply chain welcomes the opportunity to comment on the European Commissions upcoming initiative on critical raw materials.

As the voice of the cycling industry in Europe with 100 corporate members, Cycling Industries Europe (CIE) welcomes the European Commissions intention to publish a European Critical Raw Materials Act and subscribes to the objectives set out in the Inception Impact Assessment document.

EuroGeoSurveys - the Geological Surveys of Europe - welcomes the initiative of establishing a Critical Raw Materials 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.

Norge Mineraler AS welcomes the opportunity to provide feedback to the European Commission's initiative on a Critical Raw Materials Act. Norge Mineraler AS is an independent, privately-owned Norwegian mineral exploration company. It owns 61 exploration licences, covering more than 521 km2 near Stavanger in southwest Norway.

Reduced demand and increased circularity should be the first priorities in covering the need for critical raw materials. Policies to reduce demand can include setting binding material footprint reduction targets, as described in the consultation response from the EEB. There is also a strong need to increase circularity for many CRMs.

Internal Ref. Ares(2022)8160516 - 25/11/2022 25 November 2022 ACEA views on the Critical Raw Materials Act initiative Internal ACEA VIEWS ON THE CRITICAL RAW MATERIALS ACT GENERAL REMARKS ACEA welcomes the announced initiative of the European Commission for a European Critical Raw Materials Act (CRMA).

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

Summary It is the position of the Swedish Construction Federation that to promote resilience and competitiveness, the Commission must: - widen the scope of the Act to include strategic raw materials, - enhance the opportunities for exploration, extraction and refining of metals and minerals in general, - identify inconsistencies in EU legislation that may conflict with EU objectives, especially climate target…

Based on proposal announced by EU President Ursula von der Leyen, Geological Survey of Finland (GTK) expresses strong support to EUs concern related to raw materials, especially critical raw materials and their sustainable use and management. GTK sees the initiative is very much spot on and necessary.

The European automotive and industrial battery industry supports the proposal for a Critical Raw Materials Act to ensure a sustainable supply of raw materials in the EU. Europe relies heavily on batteries to decarbonise mobility, energy systems and other sectors.

Please find attached the feedback by the National Board of Trade Sweden. Summary It is the opinion of the National Board of Trade Sweden that: Open and rules based international trade is an important instrument for securing access to Critical Raw Materials. Secondary sources of Critical Raw Materials, such as repurpose, reuse and recycling, are central to secure access to Critical Raw Materials.

Hydrogen Europe Research welcomes the consultation opened ahead of the publication of the European Critical Raw Materials Act proposal. Indeed, materials research is an important research field for fuel cells and hydrogen. Reducing the use of critical raw materials and improving the performances of technologies whilst reducing their overall costs are key challenges across the hydrogen value chain.

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.

(Please see the attachment for the full statement) CEPE welcomes the initiative for a European Critical Raw Materials Act. Chemicals are key for the well- functioning of various strategic supply chains and should therefore be considered in the act1. CEPE reminds of the severe raw material shortages that started in 20212 and the continued high prices impacting the sector in its ability to supply.

Offshore Norway welcomes the EU Commissions proposal to establish a Critical Raw Materials Act and its aim to increase and diversify the EU's supply of critical raw materials. In this regard, when identifying strategic projects in the EU that have the potential to help secure the EUs diversified access to raw materials and have strong environmental and social performance, Offshore Norway would like to draw the…

As the EU finds itself on an exciting transition to a new energy and mobility system, it needs to create a contingency plan to secure the continuous supply of important materials required for the clean energy transition, such as Cobalt, Nickel, Lithium, or Silicon.

J.No. GEUS Ref. November 25 2022 Feedback on European Critical Raw Materials Act Addressed by GEUS (The Geological Survey of Denmark and Greenland) GEUS welcomes the European Critical Raw Materials Act (ECRMA), which we find both timely and necessary.

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

The Australian Government welcomes the opportunity to contribute to the call for evidence to inform development of the European Critical Raw Materials Act (the Act). European Commission President Ursula von der Leyens recent State of the Union address highlighted many of the key challenges facing the global community in transitioning to carbon neutrality and in achieving energy security.

CONSEJERÍA DE POLÍTICA INDUSTRIAL Y ENERGÍA Secretaría General de Industria y Minas Dirección General de Minas. PROPUESTAS DE LA JUNTA DE ANDALUCÍA ACERCA DE LA INICIATIVA LEGISLATIVA SOBRE MATERIAS PRIMAS CRÍTICAS Esta Administración comparte el interés y la importancia de abordar una acción regulatoria conjunta a nivel europeo que permita el desarrollo necesario de la industria extractiva para conseguir los retos…

Filed in Spanish · English published by the European Commission

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

November 24, 2022 SUBMITTED ELECTRONICALLY RE: EU Commission Request for Feedback comments Regarding European Critical Raw Materials Act; Feedback comments from the Korea Battery Industry Association ("KBIA"). Ⅰ. Introduction and Background We are established in 2011 to support the Korea battery industry, which has been continuously growing since 1999.

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

The model of energy transition that dominates the climate agenda from the Paris Agreements reproduces, in regions such as Europe, a model of living concentrated on the consumption of goods and energy, while in countries such as Chile, Argentina and Bolivia, the extra-activist exporting model exacerbates conditions of socio-environmental vulnerability, as is the case with the Salares in the Atacama Puna where a large…

Filed in Spanish · English published by the European Commission

Firstly, we advocate actively for sufficiency next to efficiency. The CRMA needs not just focus on reacting to changes in the supply side but also actively influence the demand side. The CRMA should prioritise demand reduction, sufficiency and circularity over primary resource extraction. Reducing material consumption is at the same time vital to achieving the EUs objectives to live well within planetary boundaries.

Please find attached our position. Erratum in ‘Feedback reference F3353541’: As you can see by this and other submitted contributions from CSOs and national and regional associations (e.g. F3358992, F3354958), the F3353541 contribution is far from representing “all Portuguese associations related to mineral raw materials”, as mentioned.

Filed in Portuguese · English published by the European Commission

Recent international events, including the coronavirus pandemic and Russias invasion of Ukraine, have illustrated clearly that supply chains for critical goods are highly connected and carefully organized on a global scale. These supply chains count on cooperation on a broad scale, from sourcing raw materials to transporting them to final assembly or refinement.

EU Critical Raw Materials Act Feedback from Suhanko Oy (Finland) As one of the largest undeveloped resources of critical metals in the EU, the Suhanko project in Northern Finland, offers the basket of critical raw materials we see as essential for European Green Energy Transition.

Our contribution is focused on the following three topics: 1. Include social/political indicators in your impact assessments to avoid supply risks 2. Expand focus from recycling to other CE strategies such as reduce 3. Invest in existing recycling and recovering infrastructures outside EU The entire feedback can be found in the attachment.

The world’s major economic powers, including the European Union, are causing unsustainable demand for exploration and exploitation of raw materials. The European Union accounts for only 6 % of the world’s population, but it alone consumes 2530 % of the world’s metals. In this context, the question of fairness in global resource consumption needs to be raised.

Filed in French · English published by the European Commission

Magneti Ljubljana d.d. is European producer of permanent magnets from 1951 year. We support CRM act and we want to indicate what should be done to increase competitiveness of production of permanent magnets in EU. Regarding: "4.

Iridium is a critical raw material for the PEM electrolysis. Thus, the new act needs to include specific and suitable measures referring to iridium supply. 40% of the announced electrolyzer capacities are supposed to be PEM. This sums up to about 67 GW (cumulative) until 2030.

Critical raw materials (CRMs) are essential to the twin transition. Studies show the CRM demand for 5G network equipment, photonics, edge computing applications and quantum technologies would grow 15-fold in a fast-rollout scenario. The EU can spur public and private initiatives to promote responsible, environmentally friendly and socially sustainable CRM production, processing and recycling.

The Business and Human Rights Resource Centre is an international human rights organisation dedicated to advancing human rights in business and eradicating corporate abuse. Our research on the human rights impacts of mining can be found here: https://www.business-humanrights.org/en/from-us/transition-minerals-tracker/. Our comprehensive response is attached.

Xcalibur Multiphysics is a world leader in airborne geophysical solutions, including value-adding data acquisition, data processing, data interpretation, data management, and specialized software. We offer natural resource mapping (rare earth , battery materials, underground water , geothermal ...) to, sustainably, unlock the hidden wealth of the Earth and facilitate the energy transition from fossil fuels.

Position Paper Revision of Critical Raw Materials (CRM) Act Publication date: 25 November 2022 The steel industry welcomes the European Commission’s 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.

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

In instances where there is no alternative option than to mine critical raw materials, mining operation should be subjected to highest environmental and social standards including meaningful consultations with affected communities. It is important that human rights and environmental impacts are given equal importance under the Commissions proposal.

Orano thanks the European Commission (EC) for giving the opportunity to contribute to the elaboration of the European Critical Raw Materials (CRM) Act. Orano, as a European company, boasts unique, internationally recognized expertise in the nuclear fuel cycle. Our group has more than 40 years experience spanning the entire fuel cycle, including in chemistry, hydrometallurgy and process industrialization.

Albemarle is an industry leader in battery, industrial, and specialty grade, high-quality lithium production. We operate across a diverse range of hard rock and brine lithium resources and conversion facilities in Europe, North and South America, Asia, and Australia, to develop and manufacture a broad range of lithium compounds, including lithium carbonate, lithium hydroxide, lithium chloride, and value-added…

Hi, We have reviewed the critical raw material list, and based on our need being a battery manufacturer we will list following raw materials as critical: Lithium (1) Copper (2) Iron (3) Aluminium (4) Silicon (5). Vanadium (5) Posphorus (5) Sulfur (5) Natural graphite (5) Items are listed in a critical manner (1-5). Those listed as (5) are all equal when it comes to criticality.

Rare Earths Norway strongly supports the European Commissions announcement to propose a European Critical Raw Materials Act (CRM Act). Today, approximately 98% of Europes demand for Rare Earth Elements (REE) is supplied by non-EU/EEA countries, and we would like to highlight that there is significant potential for REE mining in Europe today.

SINTEF https://www.sintef.no/en/ one of Scandinavia's largest independent research organizations, welcomes the European Commission's initiative on Critical Raw Materials Act. We support the CRMA main objectives as given in the Call for evidence for the CRMA. As a research organization, we especially emphasize the importance of research and innovation (objective 6).

Carester is a french company working on rare Earths with two main activities: — Support rare mining companies by developing ecologically and economical reference processes – Developing a project to build an industrial manufacturing unit unit to recycle 2000Tons of magnets from 2024: this unit aiming at is a reference from ecologically and economically point of view.

Filed in French · English published by the European Commission

I specialise in the geology of European sources of critical raw materials and the challenges facing the extraction of critical resources. I am commenting on sources for rare earths, niobium and tantalum used in many green technologies and access to which is implicit in any zero-carbon future. I make these comments: 1.

The citizens’ association Elektrosmog and Health does not consider the digital transition to be green and far from being a solution to climate issues. On the contrary, with the digital switchover and 5G, the evironmental burden will increase. Producers must give priority to protecting the environment over profit. Products shall have built-in recyclability and reparability.

Filed in Slovak · English published by the European Commission

Europe`s imports of raw material will increase Most raw materials are imported from countries in the gobal South. Increasing mining activities are leadi to environmental destruction and human rights violations. Mining over-boom under the wing of energy transition continues colonialism For three decades, our organisation Rettet den Regenwald has been accompanying and informing about the resistance of communities in…

Jastrzębska Spółka Węglowa (JSW) would like to express its support for the EU CRM initiative and hope that the Commission will propose measures which will help rebuilt EU's raw materials industry. JSW is a major producer of coking coal - a key steel-making ingredient and one of the CRMs.

The Critical Raw Materials Act is Europes unmissable opportunity to catch-up in the global race for metals and minerals supply. Europes energy and mobility systems will completely transform over the next decade, supercharged by the REPowerEU plan and 2035 internal combustion engine ban.

Vulcan Energy Resources welcomes the European Commissions initiative to strengthen the European Unions critical raw materials value chain enabling a more resilient and more sustainable supply. We would like to thank the Commission for the opportunity to contribute to the public consultation. Please see attached file.

Upholding high-level multi-stakeholder governed environmental and social standards for the mining sector, like those in the Initiative for Responsible Mining Assurance (IRMA) Standard for Responsible Mining, is essential to the EUs objectives of ensuring security of critical raw materials (CRMs) supply and a just and green energy transition.

The Medical Nutrition Industry International (MNI) welcomes this consultation as an opportunity to highlight the importance of planning for medical nutrition, an essential part of treatment and care. The consultation mentions the health industries in its introduction, which should not be limited to medical devices or in-vitro diagnostics, but all components of healthcare.

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

Mawson Oy is developing the Rajapalot gold-cobalt Project in Finland. If in production today, Rajapalot would be the EU's 3rd largest cobalt mine. Mawson strongly support this initiative, in particular in its aims to harmonise Member states approaches to critical minerals development. Finland has significant mineral endowment to support European self sufficiency.

The Mining Secretary of Argentina takes this opportunity to send its views and comments on the initiative for a Raw Materials Act of the European Union. Argentina shares the objective of securing a reliable value chain related to critical raw materials that is economically, socially and environmentally sustainable for the European Union as well as for its supplier partner third countries.

EJF is an international non-governmental organisation working to protect the natural environment and human rights. EJF has offices in Brussels, Germany and the UK as well as on the African and Asian continents. The security of supply of critical raw materials is of paramount importance to any state or state-like entity.

Key message Enhance the opportunities for exploration and extraction in general in the EU. Critical Raw Materials are often extracted as a by-product of base metal and iron. Access to many of these metals will become scarcer in the future.

The Horizon Europe FutuRaM project (Future Availability of Secondary Raw Materials) will play a key role in ensuring a secure supply of secondary and critical raw materials from within the European Union. It contributes to a mapping of the potential supply of secondary CRMs from EU stocks and wastes.

REC Solar Norway appreciates the opportunity to provide feedback on the European Commissions public consultation on the European Raw Materials Act. We strongly support policies focused on promoting European autonomy and sustainable raw materials. Yet, we also would like to take the opportunity to explain the importance of covering solar grade silicon in the forthcoming work.

We fully support this initiative to introduce ambitious regulation for more resilient supply chains. Permanent magnets composed of rare earths must pay particular attention as they are heavily used in priority sectors of our economies (mobility, electricity production, energy efficiency).

Filed in French · English published by the European Commission

Seas At Risk comments: On deep-sea mining: Deep-sea mining (DSM) should be explicitly excluded from the scope of the proposed Critical Raw Materials Act (CRMA), including explicit exclusion from the definition of strategic projects.

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

TNO welcomes the initiative of the European Commission to create a legislative package on the Critical Raw Materials (CRM). TNO is a research and technology organization in the Netherlands with the Material Transition as an important area of activities.

3 Europa-Kommissionen Paul Bergsøes Vej 6 2600 Glostrup Billedskærervej 17 5230 Odense M Telefon [phone removed] [email removed] www.tekniq.dk Dato: 24. november 2022 Høringssvar vedrørende Kommissionens forslag til forordning om en europæisk lov om råstoffer af kritisk betydning Indledning Kommissionen har med sit forslag til forordning, dateret den 30.

Filed in Danish · English published by the European Commission

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

CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT This document aims to inform the public and stakeholders on the Commission's future legislative work so they can provide feedback on the Commission's understanding of the problem and possible solutions, and give us any relevant information that they may have, including on possible impacts of the different options.

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

ECI welcomes the initiative of the EU Commission for a Critical Raw Materials package with legislative and non-legislative measures. This paper wants to summarise our views about which essential elements the package should address and to give the rationale of and expand on our responses to the open public consultation questionnaire.

The Spanish Federation of Recovery and Recycling (FER) is the leader association in which representative companies invaded in the collection, trade, processing, and recycling of different waste streams such as metals, plastics, pallets, ELV, WEEE, tyres, textiles. ERF represents, between member companies and member associations, over 435 companies.

Filed in Spanish · English published by the European Commission

Secondary materials, especially materials such as rare earth elements, gallium and indium, that are needed in renewable energy technologies or high-tech applications, make a marginal contribution to meeting materials demand.

A local and competitive critical raw materials supply chain will enable Europe to build the greenest batteries in the world. However, this opportunity will only be realised if the EU actively supports the mining of its own unique mineral deposits.

Brussels, 22 November 2022 CRM Alliance Position Paper on the Critical Raw Materials Act The CRM Alliance (CRM-A) welcomes the European Commission’s proposal of a legislative action for critical raw materials (CRMs) – the European Critical Raw Materials Act (CRM Act) – and would like to make the following comments: • Expediting permitting processes Permitting is one of the main obstacles companies face when…

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

Europeans for Safe Connections request the EU to abide by EU law in the digital transition, which in too many ways is not a green development. Far from being a solution to climate change, the ecological footprint of the digital economy would reach its peak with the digital transition and 5G. This environmental footprint must be reduced.

The Raw Materials Group of Scientists for Future (S4F) wishes to give feedback on the following three topics: Primary raw material extraction To promote sustainable and responsible mining, the development and implementation of a global, broad-based and effective certification program for the extraction of raw materials is called for.

Check and evaluate existing financing instruments to support the necessary investments in projects for the production of raw materials and critical metals (mines, refineries, and recycling capacities) within the Union and outside it.

European Critical Raw Material Act Call for evidence for an impact assessment November 2022 Introduction We are Bluejay Mining plc a mineral exploration and development company and a founder member of the European Raw Materials Alliance, whose own licence assets are in both Greenland and Finland. We are a publicly listed company whose shares trade on stock exchanges in the London, Frankfurt and the USA.

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

November 2022 EUROPEN response to the call for evidence and public consultation on a European Critical Raw Materials Act EUROPEN, the European Organization for Packaging and the Environment, is supportive of the European Commission’s initiative to develop a European Critical Raw Materials (CRMs) Act in order to secure a sustainable and diversified supply of critical raw materials in Europe, while addressing existing…

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

The Finnish Chemical Industry and its Battery Group represent the Finnish key actors in the Battery Value Chain. We strongly support this initiative to address the need to secure sustainable European raw materials for the green and digital transition. Europe has the potential to produce a majority of the CRMs for its own industry and consumer demand.

IMA-Europe position on the IA of Critical Raw Material (CRM) Act FINAL Industrial Minerals Association Europe (IMA-Europe) representing the interest of Industrial minerals producers in Europe, welcomes, the Call for evidence the European Critical raw Material Act presented by the Commission (30 September 2022).

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

EARSC Statement European Critical Raw Materials Act The European Association of Remote Sensing Companies (EARSC) is a trade association based in Brussels, representing the European downstream services sector. EARSC counts more than 135 members across 25 countries in Europe.

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

Novelis welcomes the European Commissions announcement to propose a European Critical Raw Materials Act and the intention to include policy measures specifically focused on boosting the EUs circularity of critical and strategic materials alike. In building EU strategic autonomy, we call on the Commission to recognise the strategic value of aluminium and the untapped potential of circularity to boost its supply.

Northvolt is a European supplier of sustainable, high-quality battery cells and systems. Our mission is to build the greenest battery in the world with a minimal carbon footprint and the highest ambitions for recycling to enable the European transition to renewable energy.

The Eydecluster is a Process Industry Cluster (https://www.eydecluster.com/en/ ) located in the South of Norway. We are dedicated to making the circular transition happen. The European Critical Raw Materials Act for the future, in our opinion, needs to provide a holistic outlook and significant step forwards for our societal materials management.

The environmental company Ragn-Sells 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 its own and other actors' environmental and climate impact. Ragn-Sells wants to be living proof that caring for the earth and business go hand in hand. Please find our response to this consultation attached.

The circularity of textile fibre, needs to be addressed separately and differently from other material flows because of the different nature of textile industry (very manual-work heavy, low market entry barriers, very fragmented market, very complex global supply chains, etc).

IndustriAll European Trade Union’s response to the call for evidence on the forthcoming EU Critical Raw Materials Act Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europe’s industrial workforce at European Level.

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

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

The Covid pandemic and Russia’s invasion of Ukraine have highlighted some vulnerabilities of the European Union associated with the supply of raw materials and the strategic value chains that depend on them. The CEA supports the Commission’s desire to improve European anticipation capacities on these issues, as well as the reduction of the risks associated with supplies.

Filed in French · English published by the European Commission

Hydro is a global industrial company with operations in 40 countries and 30,000 employees. Hydro is the largest European aluminium company in addition to being a significant renewable power producer in Norway. Hydro is also developing battery materials and hydrogen businesses. Hydro is an active shareholder in: (1) Hydrovolt. A joint venture with Northvolt recycling EV batteries; (2) Vianode.

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). We are working towards becoming a major contributor to fulfil the European demand in base metals by 2030.

Firstly, the CRMA needs not to just focus on reacting to changes in the supply side but also influencing the demand side: prioritising demand reduction, sufficiency and Circularity over primary resource extraction. The CRMA should be signed politically that the Commission must act on setting this overall materiality reduction target in its next mandate.

Filed in Spanish · English published by the European Commission

With this position paper Infinity Lithium Corporation Limited (ASX:INF) and its wholly owned subsidiary, Extremadura New Energies SL, share our comments to the Call for Evidence in support of our response to the public consultation questionnaire on the upcoming European Critical Raw Materials Act (EU CRM Act).

Solvay welcomes the Commission's Critical Raw Materials (CRMs) initiative, including a legislative proposal, which will aim to strengthen the EUs resilience and security of supply as regards CRMs. The supply of CRMs, such as Nickel, Cobalt, Lithium, Magnesium, Palladium, etc. are essential for the chemical industry to sustain Europes economic and environmental ambitions.

The International Raw Materials Observatory (INTRAW) supports the Commissions initiative and wishes to make the following observations and recommendations under the following headings: 1. Policy and Strategy. 2. Governance. 3. Permitting. 4. Substantive Support. 5. Research and Innovation. 1.

In the last years, the European Commission undertook multiple initiatives to boost the European industry and make it more competitive globally, such as The New Industry Strategy or The EU Chemical Strategy for Sustainability Towards a Toxic-free Environment. All these actions are supposed to lead us to the green and digital transformation of the European industry and enhance Europes strategic autonomy.

Please see attached the Cobalt Institute's response to this consultation. In summary, cobalt demand is likely to grow significantly as Europe transitions to a green economy. It is a critical mineral in this context and likely to be strategically important in the future.

The Geological and Mining Institute of Spain (CN IGME CSIC) is a public research Institute of CSIC, Spanish Science and Innovation Ministry. IGME provides expert knowledge on all aspects of geoscience, and is the responsible for advising the Spanish government and its Autonomous Community governments on the sustainable development of its territory and resource management.

[transcript of an email sent to DGGROW I.1 - 22/11/2022 11:23 UTC] Dear DG GROW Unit I.1, dear Mr Handley, Mr Grohol, and colleagues, With interest we have been following the proposal for a regulation "European Critical Raw Materials Act" - Ares(2022)6746256.

Finnish Minerals Group, FMG, strongly support this initiative to address the need to secure sustainable European raw materials for the green and digital transition. FMG is a special-purpose company wholly owned by the State of Finland and established to develop the sustainable mining and battery industry in Finland.

European Aluminium, the industry association of the full aluminium value chain in Europe, welcomes the Critical Raw Materials Act as an opportunity to deliver a European industrial agenda that will support sustainable growth and strategic autonomy in raw materials while ensuring their production and transformation at the highest environmental and social standards.

The Beryllium Science and Technology Association (BeST) represents the manufacturers, suppliers and users of beryllium metal, beryllium containing alloys and beryllium oxide ceramics in the EU market. BeST has the objective of promoting sound policies, regulations, science and actions related to the safe use of beryllium and to serve as an expert resource for the international community on the benefits and…

Erion Erion is the largest Italian non-profit Producer Responsibility Organization for WEEE and Waste Batteries management, representing 2.500 producers. In 2021, Erion managed more than 290.000 tons of WEEE. How to make the WEEE urban mine strategy effective in the EU To increase CRMs recovery from WEEE it is key to act on 3 dimensions: re-imagine collection models, re-think the legislative framework, and…

Water Europe (WE) is the voice and promoter of water-related innovation and RTD in Europe. WE is a multi-stakeholder association representing over 250 members from academia, industry, technology providers, water users, water service providers, civil society, and public authorities. WE activities and positions are guided by its Water Vision The Value of Water: Towards a Future-Proof European Water-Smart Society.

The European Energy Research Alliance 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 30 countries, EERA is Europe's largest energy research community.

Stora Enso is a renewable materials company that employs more than 18 000 people in the EU. We deliver renewable and circular products that store carbon and provide low-carbon alternatives to non-renewable materials. We are one of the largest private forest owners in the world and are working to replace fossil-based materials with sustainable, renewable alternatives based on wood.

The Geological Survey of Slovenia (GeoZS) is a public research institute, providing information about the geological setting and natural resources of Slovenia. In a role of Mining Public Service, GeoZS supports the Ministry responsible for mining. GeoZS supports the preparation of the CRM Act as announced by the President of the EC.

1. We all know that there is and will be a risk of supply of critical metals. 2. These metals have already been proven to be essential for the transition to the Green Deal 3. Europe needs metals but does not want to mine and process them indoors for social and environmental reasons 4. So far, there have been no initiatives to support raw material producers and explorers 5.

The European Critical Raw Materials Act (ECRMA) is another step to achieve the self reliance and the supplying of the European Union. ECRMA should take into account several problems we are facing nowadays. Critical raw materials (CRMs) supply are indispensable not only to carry out all the plans about digital transition, renewable energies or eco-mobility but to build and develop the technology and the industry in…

The ECRMA is a vital part of a coherent European industrial strategy that takes into account the full value chain for key technologies such as permanent magnets, batteries, solar panels and microchips. Reducing dependency from unreliable foreign sources, specially those with opposing geopolitical interests such as China, is vital to secure the overall supply and ensure European strategic autonomy.

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

Los Objectives to augment la capacidad en las different steps de la cadena of deben value favour la materias auxiliarias sobre las primarias, la minería solo debería be una opción después that if Hayan agotado all the optiones of supply of secondary metales, sustitución de materiales, demand for rare tierras de la EU puede completely satisfied with el reprocesamiento of deposits of abandoned mineral-waste.

Filed in Portuguese · English published by the European Commission

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

Please include Tin (Sn) as a critical raw material for Europe to secure. Europes does not (yet) have a domestic EU supply of tin as a raw material. The tin market (360,000t/yr) is <2% of the copper market and completely dominated by the following countries: China, Indonesia, Peru, Bolivia, Brazil, DRC - leaving the rest of the world (inc. EU) highly susceptible to supply disruptions.

First Ammonia believes that a similar principle as the energy efficiency first principle should be applied to critical raw materials: A CRM efficiency first principle. It is at least as important to minimise our consumption needs for CRMs as it is to secure sustainable sourcing of the CRMs we do really need. First Ammonia proposes that this principle is considered for the European Critical Raw Material Act.

Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency, and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.

We support the intention of the proposed Act but recommend two critical modifications to its scoping. The proposed Act conceptualizes raw materials as mining and lightly processed minerals, but the just transition requires materials that are often highly processed into alloyed ingots before any manufacturing or fabrication can be done.

We urge the EU to not only diversify its supply of raw materials but to see what strategies it can take to have a resource light economy and society. Reducing the demand in raw materials is urgent as the extraction of minerals causes more and more stress to water and land for local communities and as already lead to severe human rights violations all over the world.

Norwegian trade unions and employers joint response to the European Commissions call for evidence on the forthcoming European Critical Raw Materials Act: Referring to the call for evidence on the European Critical Raw Materials Act (CRMA), we submit a joint response on behalf of Norways main confederations of trade unions and businesses (LO and NHO) and the organisations representing workers and companies in Norways…

In the context of the European Regulation on Critical Raw Materials, we consider several points to be important: 1. clearly identify strategic raw materials (care should not be taken to amalgam) 2. Develop a regulatory and financial framework favourable to activities and projects: the projects are highly capitalised. Companies alone will not be able to carry out these investments (R &amp; D, industrial, etc.).

Filed in French · English published by the European Commission

Thank you for the opportunity to give a feedback. 1.) The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target. It should prioritise demand reduction, sufficiency and circularity over primary resource extraction.So CRMA should not just focus on reacting to changes in the supply side but also actively influence the demand side.

See attached paper for comprehensive consultation response. Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction.

See attached paper for comprehensive consultation response. Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction.

The economic recession of the last two years due to the pandemic of Covid-19, followed by the Ukrainian/Russia war, highlights the vulnerability of the western countries economy and our total dependency on the supply of raw materials in the fields of energy supply, food oil, automotive electronic part, etc.

Supply chain diversification and investment in mining and recycling are all welcome. Most importantly, supply chain transparency should be enforced via strict regulations, to ensure that the critical raw materials used are environmentally and socially sustainable. The creation of a "FAIR RAW MATERIALS" certification system, similar to the "fair trade" one, might be implemented.

In order to successfully move forward on the current energy transformation lithium is a crucial material, and today almost al of this comes from unsustainable mining in South America, Australia or China. However, multiple European countries have large ressources of lithium below the surface.

General comments on deep-sea mining Deep-sea mining (DSM) should be explicitly excluded from the scope of the proposed Critical Raw Materials Act (CRMA), including explicit exclusion from the definition of strategic projects.

In view of the upcoming Critical Raw Materials Act, PIMEC´s recommendations are: The EU should continue with its Open Strategic Autonomy taking into account the crucial role of MSMEs as active actors in European supply and value chains. Signing FTA with reliable commercial partners is of paramount importance as well as finalise trade agreements that are in the pipeline (i.e. Mercosur).

In the impact assessment of the Critical Raw Materials Act (CRMA), at least the following three points must be taken into account: 1. Prioritise sectors of the green transition with low possibilities to decrease resource demand: Before prioritising strategic critical raw materials for regulatory and non-regulatory measures like planned, potentials for reducing resource demand should be scrutinised per sector.

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)

Position paper 10.11.2022 Our reference To: European Commission Kaj Lax, Head of Department, Mineral Resources EU Critical Raw Materials Act The Geological Survey of Sweden, SGU, welcomes this initiative and would like to give following input to the development of the EU CRM Act, aiming to achieve access to raw materials needed for the green transition.

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

The EU’s CRM Act Comments and suggestions • An overall framework for 2030 EU strategic autonomy Introduction Europe’s accelerated REPowerEU clean energy goals but also some its other policies (such as agraculture, construction and renovation, health care) require a considerable increase of strategic metals and minerals for new technologies, and a number of raw materials are central in several strategic areas.

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

November 9, 2022 The European Commission Berlaymont, Rue de la Loi 200, 1049 Bruxelles, Belgium Re: International Council on Mining and Metals (ICMM) comments for the European Commission’s proposed Critical Raw Materials Act Dear Sir/Madam, The International Council on Mining and Metals welcomes the European Commission’s efforts to address the issue of the raw materials required for the transition to a low-carbon…

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

Sustainable Mining in Europe – Sustainable Mining for Europe Euromines policy requests - EU Critical Raw Materials Act – Executive Summary Fostering the license to operate for mining (legal and political) • Lack of investment in mineral exploration and later lengthy, unforeseeable, and complex permitting procedures hinder the uptake of mining projects in the EU.

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

The Portuguese Associations related with Mineral Raw Materials- Cluster Portugal Mineral Resources (APCMR), the National Association of the Extractive and Manufacturing Industry (ANIET), the Portuguese Association of the Mineral Resources Industry (ASSIMAGRA), the Portuguese Association of Ceramics and Domestic Glass Industries (APICER), the Portuguese Association of Geologists (APG) and the Order of Engineers (OE)…

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

Verde Magnesium thinks that EU CRM Act is an excellent initiative in the current economic and geo-politic context and once approved it needs to be implemented considering that the EU and member states should be more pro-active in order to enable the restart of mining and primary metals production in EU. Main action points in our view should target: A. Regulatory frame: A1.

In order to speed up our access to the critical materials that are necessary to succeed in the energy and ecology transitions we need to prioritize actions and 1. invest on green and efficient technologies for all steps of the supply chain from mining to recycling of critical minerals (copper, nickel, lithium, cobalt, tungsten, rare earth...) 2.

1st low diversification of EU supply sources: In part, primary raw materials are distributed among a few countries, where to issues – such as human rights – are critical. For example, > 80 % of tungsten deposits and reserves are distributed among such countries as China, Russia, North Korea. In particular China is trying to get raw materials e.g.

Filed in German · English published by the European Commission

With reference to the public consultation, Vianode welcomes the opportunity to give feedback to the European Critical Raw Materials Act (CRMA). Vianode has 3 proposals: 1. Vianode acknowledges that the main aim of the CRMA is to reduce supply risk for critical raw materials in Europe. This can also be achieved by introducing direct substitutes to the critical raw materials list.

The European Precious Metals Federation (EPMF) welcomes the European Commissions initiative on Critical Raw Materials Act. The EPMF fully supports the European Commissions intention to put forward the Critical Raw Materials Act.

Dear Sirs, Here I am providing some bullet points with my input concerning the Critical Raw Materials Act. 1) The procurement of CRMs from extra-EU suppliers should not be negotiated at the level of single Member State (or even worse, at the level of single company) but by the EU as a whole. 2) Every possible effort must be dedicated to foster the recycling of CRMs, providing suitable incentives.

The fight against climate change is a race against the clock. Transitioning to renewable energy, efficient buildings and electric vehicles rapidly and at unprecedented scale is essential if we are to limit warming to 1.5°C. Beyond climate, our reliance on fossil fuels also undermines our energy security and sovereignty as the Russian invasion of Ukraine has highlighted.

CRM such as magnesium that are produced in Europe with renewable energies such as hydro, wind and photovoltaic and European ESG values need to be supported, financially. Otherwise, the projects end up in China or other countries out of control of EU. Financial support will be a gamechanger for CRM and we will be able to secure supply chains for critical industries.

The Arctic Economic Council (AEC) welcome the European Critical Raw Materials Act and support the idea that EU diversity and increases its supply of CRM. We believe it is important for the EU to source their CRM from responsible mining and trusted allies partner. Those mining destinations are most likely found in the north – in the Arctic region.

Too many of these raw materials are still imported from far and disappear here with our ewaste. Existing regulatory frameworks insufficiently support circularity: recycling and recovery rate of critical raw materials is generally close to zero and the quality of secondary raw materials is low. Recycling companies have no financial nor legal incentive for the development of applied techniques.

Excellent initiative Scarce Raw Materials: Rare earth metals, Vanadium and Cobalt. Strategic Raw Materials: Fast Growing Tree Crops to replace Crude and Natural Gas and this will require Intensive re-forestation. Strategic New Processes: Wood Liquefaction (simultaneous de-polymerization of Lignin and Cellulose's).

The European Compost Network ECN welcomes the opportunity to give its feedback on the Commission’s public consultation on a European Critical Materials Act. Undoubtedly, the EU needs to strengthen circularity of raw materials and foster research and innovation, to better face potential shortcomings and supply deficits provoked by geopolitical instability and growing demand.

As a company with a rich experience in Recycling of Tungsten and Cobalt, we are interested in hearing more from your plans to work with international partners to explore common goals and opportunities to assist European firms in achieving a more secure supply chain while increasing the overall share of recycled materials. Thank you!

There are resources of critical metals known in Europe and there is potential for further discoveries. But no mine exists without exploration, the starting point of the value chain leading to mining, refining, and processing. But within Europe there is great variation in the ease with which one can get exploration licences and the process to acquire them with limited red tape and therefore cost and time.

The recently announced CRM Act is a step in the right direction to reduce the extremely risky policy of the past 20+ years of reliance on external partners for supply. But it is a step which needs action and not long policy discussions where no progress is made.

Existing regulatory frameworks insufficiently support circularity: The recycling and recovery rate of critical raw materials, essential to mitigate supply risks, is often close to zero and the quality of secondary raw materials is often low. Current EU rules do not sufficiently facilitate recycling and recovery of critical raw materials from relevant waste streams and investments in recycling processes are lacking.