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.

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 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.

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.