Cobalt Institute

Cobalt creates a circular economy. It is highly, and endlessly, recyclable. Every day, Europeans are importing cobalt in the form of cars, phones, laptops and industrial goods, meaning that these could potentially be a strategic future source of diversified and secure raw materials supplies.

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)

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.

This is further feed-back from the Cobalt Institute, providing a non-exhaustive and high-level overview of the applications of cobalt and their contribution to society, and to some key European environmental/industrial policies.

The Cobalt Institute (CI) and the Cobalt REACH Consortium (CoRC) represent the manufacturers, producers, users, traders and recyclers of cobalt in the EU (including for REACH matters) and globally, promoting the sustainable and responsible production and use of cobalt in all its forms.

The Cobalt Institute (CI) supports the Commission's broad objectives in this Regulation. We recognise the need to update existing regulations to keep pace with technological change and ensure the sustainable, long-term growth of the batteries industry in Europe. For further details on our position, please find attached full response.

The Cobalt Institute (CI) supports the update of the current legislation on batteries, promoting the anticipated growth in the battery industry in the EU. This includes the overall benefits to transform the legal instrument into a Regulation, providing further harmonisation and certainty across the EU.

The Cobalt Institute represents over 75% of global cobalt production and processing. It is a non-profit trade association composed of producers, users, recyclers, and traders of cobalt. We promote the sustainable and responsible production and use of cobalt in all its forms.

Please see attached the Cobalt Institute's response to this consultation. We believe the proposed EU CRM Centre should become a strategic pillar of Europe's critical raw materials ecosystem by combining financial, policy and market expertise to strengthen investment, improve regulatory coherence and support evidence-based decision-making.

We support the move to using full equivalent charge-discharge cycles per year (FEqC per year) and vehicle warranty, as this both simplifies the calculation and ensures a fair comparability between batteries. Further, the revised calculation removes unintended consequences such as rewarding inefficient vehicles with a lower carbon footprint.

Cobalt Institute's response includes the following: Support retaining certain aspects and delaying the timelines we are pleased the Commission has decided not to reopen the core due diligence obligations laid out in Chapter VII of the Batteries Regulation, and delay implementation by two years. This provides companies with the certainty and time needed to meet the reporting requirements.

Cobalt is an EU critical and strategic raw material, as well as being classified as a NATO critical mineral given its essential role in defence. Europes political goals security, circular economy, energy transition, and strategic autonomy all necessitate a growing cobalt sector in Europe. This can be done safely. We support a 20 μg Co/m³ (inhalable) Occupational Exposure Limit for cobalt.

The Cobalt Institute (CI) is an international non-profit trade association composed of the major producers, users, recyclers, and traders of cobalt. The CI promotes the sustainable and responsible production and use of cobalt in all its forms.

The Cobalt Institute (CI) represents producers, users, recyclers, and traders of cobalt globally. The European Commission has repeatedly listed cobalt as a critical raw material in the EU for a wide range of key industries and applications, including lithium-ion batteries, medical devices, and industrial catalysts. This is confirmed in the Commission’s 2020 Communication on Critical Raw Materials Resilience.

Due to war and recent geopolitical tensions worldwide, Europes security and defence sector is at the forefront of the EUs political agenda. Raw materials are key to produce European defence applications and therefore stable supply chains are required for the military domain. Cobalt plays a fundamental role for the European defence sector.