Eurometaux

The metals ecosystem is pivotal to Europe's industrial base and plays a critical role in enabling the twin green and digital transitions. Non-ferrous metals from the base ones (aluminium, copper, lead, nickel, tin, zinc) through technology metals (e.g. cobalt, lithium, germanium, vanadium, gallium, bismuth) to precious metals (e.g.

As Eurometaux, the non-ferrous metals industry association, we support the EU taxonomy's goal to channel investments towards sustainable economic activities and support economic sectors in their transition. If well designed, the EU Taxonomy Regulation (EU/2020/852) can incentivize financial flows towards activities aligned with climate and environmental objectives, provided that the criteria are fit for purpose and…

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)

1 May 2020 EU CLIMATE NEUTRALITY LAW Eurometaux Response to the European Commission’s Proposal Eurometaux welcomes the possibility to contribute its view on the Commission proposal for a regulation establishing the framework for achieving climate neutrality (European climate law). Climate change is real, the impacts devastating, and we need to find immediate global solutions.

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

This feedback and the position paper attached provide a stocktaking of measures supported by Eurometaux in view of the Commissions preparatory work for the EU ETS review proposal. Eurometaux represents European producers of Non-Ferrous Metals like Aluminium, Copper, Lithium, Nickel, Zinc, Silicon, but also ferro-alloys, among other energy transition metals.

The EU non-ferrous metals industry, delivering materials for many low-carbon applications needed for the green and digital transitions, sees the proposed directive as a tool paving the way for better-informed choices of consumers on the products available on the EU single market.

Eurometaux, the European non-ferrous metals industry, has been actively engaged in the European Commission’s Environmental Footprint (EF) project and has developed, during the EF Pilot Phase, the ‘Product Environmental Footprint Category Rules (PEFCR) for Metal Sheets in Various Applications’. Currently, we are also an active stakeholder in the so called Environmental Footprint Transition Phase (2018 – 2021).

Eurometaux, representing the European non-ferrous metals industry fully supports the transition to a true Circular Economy. Metals are present in various products, including those listed in the Action Plan as key value chains namely, electronics and ICT, batteries and vehicles, packaging, textiles, construction and buildings.

6 October 2021 Carbon Border Adjustment Mechanism (CBAM) Proposal Position Paper of the European Non-Ferrous Metals Sector This paper provides the initial reaction of Eurometaux to the EU’s carbon border adjustment mechanism (CBAM) proposal. Eurometaux represents European non-ferrous metals producers. Amongst non-ferrous, the aluminium sector is included in the list of CBAM sectors for Phase 1.

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

1 April 2020 Inception Impact Assessment: Carbon Border Adjustment Mechanism (CBAM) The Response of Eurometaux – The European Non-Ferrous Metals Industry This document gives the reactions from the non-ferrous metals sector - a very electro-intensive sector – to the European Commission’s inception impact assessment (IIA) on carbon border adjustment mechanisms (CBAM).

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

MARCH 2023 Eurometaux comments: CLP Revision feedback consultation We welcome Commission’s efforts to increase the robustness and the transparency of the CLP, one of the core tools for the implementation of the Chemicals Strategy for Sustainability (CSS).

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

Eurometaux thanks the Commission for the opportunity to comment on the CLP IIA. Please find attached our comments. Please do not hesitate to come back to us if you have any question. Eurometaux is willing to engage in the process to ensure CLP delivers its full potential.

Please find attached our response to the most recent public consultation on the Energy Taxation Directive. Moving ahead, Eurometaux looks forward to the official public consultation and will provide input to the European Commission through this process.

While the European non-ferrous metals (NFM) industry is committed to EUs climate objectives, an ambitious 2040 target will require a massive transformation of energy-intensive industries in just 15 years. Achieving an ambitious target will depend on breakthrough technologies, significant investments and a supportive policy framework, including financial support to create viable business cases for each sector…

See below Eurometaux's key messages, and attached our more detailed position on the carbon price paid in third countries. Eurometaux represents European producers of Non-Ferrous Metals like Aluminium, Copper, Lithium, Nickel, Zinc, Silicon, ferro-alloys, among other energy transition metals. Key points: 1.

23 June 2022 Eurometaux’s Position on the new IED Proposal This paper provides an overview on the main critical issues for the Non-Ferrous Metals (NFM) sector and includes points to be considered in the review of the Industrial Emissions Directive (IED) and Industrial Emissions Portal (IEP).

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

Europe’s non-ferrous-metals industry welcomes the opportunity to provide feedback on the Inception Impact Assessment planning for the Industrial Emissions Directive and would like to share several recommendations on the way forward. Attached you find our considerations regarding the scoping, coherence with other policies as Circular Economy, decarbonisation and water legislation.

Eurometaux, representing the European metals industry, recognises the major work ahead to deliver on EU’s ambition for batteries to help achieve the European Green Deal. Our members, producing and recycling battery metals (e.g.

Eurometaux represents European non-ferrous metals industry. Our sector is the key supplier and recycler of metals for portable, automotive and industrial batteries. The World Bank in 2017 projected that 1000% more metals will be needed for batteries on a global scale.

Eurometaux, representing the European non-ferrous metals industry, supports the objectives of the End-of-Life Vehicles revised proposal to increase availability and improve raw materials quality recycling to enhance EU open strategic autonomy and resilience and facilitate the circular transition of the automotive sector. Metals are present in the car body (e.g. aluminium), car battery (e.g.

The non-ferrous metals industry is one of key suppliers for the automotive sector. Metals are present in the car body (e.g. aluminium), car battery (e.g. lead, lithium, nickel, cobalt, copper), catalytic converter (e.g. platinum, palladium) or motor (e.g. copper) to name just a few applications.

See below Eurometaux's key messages, and attached our detailed position on the CBAM methodology. Eurometaux represents European producers of Non-Ferrous Metals like Aluminium, Copper, Lithium, Nickel, Zinc, Silicon, ferro-alloys, among other energy transition metals. Key points: 1.

Eurometaux welcomes the opportunity to provide feedback on the REACH IIA. Please find attached our comments. Please do not hesitate to contact us if you have any question. Eurometaux stands ready to contribute with the other stakeholders to ensure REACH delivers it full potential.

1. Addressing high and volatile electricity prices and costs As highly electro-intensive, price-taking businesses exposed to fierce global competition, the NFM industry is facing an existential crisis due to soaring electricity prices, still 2-3 times higher in Europe than in the US.

Eurometaux, representing the EU metals producers and recyclers, recognises the publication of the WSR legislative proposal as a very important delivery of the EU Green Deal, connecting to the EU Circular Economy by securing the availability of the secondary raw materials and to the Zero Pollution Action Plan by ensuring that waste are treated in an Environmentally Sound Manner (ESM).

Eurometaux, representing European manufacturers and recyclers of non-ferrous metals, supports efforts towards optimisation of the EU’s waste legislation, in order to secure level playing field for our high-quality recyclers and to remove barriers to intra-EU waste shipments.

Please find below Eurometaux's key messages and attached our position paper on the free allocation adjustment. Eurometaux represents European producers of Non-Ferrous Metals like Aluminium, Copper, Lithium, Nickel, Zinc, Silicon, ferro-alloys, among other energy transition metals.

Recommendations on the New Air Quality Directive The European Non-Ferrous Metal (NFM) sector welcomes the new Proposal for an Air Quality Directive and the opportunities to provide feedback. The NFM sector is strongly committed to continuing lowering emissions of air pollutants for the benefit of human health and the environment.

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

Eurometaux welcomes the opportunity to contribute to the call for evidence in relation to the new European Commission initiative “Chemical safety – better access to chemicals data for safety assessments”. We support such an initiative which is in line with our industry effort to establish a common and robust dataset to be used for risk assessment, promoting the consistent reuse of data across various regulatory…

Eurometaux welcomes the opportunity to provide feedback the proposed Basic Regulation for the European Chemicals Agency (ECHA). We acknowledge the significance of this legislative initiative, considering ECHAs evolving mandate that has expanded well beyond REACH to encompass more broadly chemicals management and areas such as batteries, waste, RoHS, POPs, and cross-border threats.

Dear Madam, Dear Sir, Many thanks for providing the possibility to participate to the Call for Evidence for the proposal for ECHA's basic regulation. Please find attached Eurometaux's contribution. Please do not hesitate to contact us if you need any clarification.

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

We welcome the opportunity to provide feedback on the recent Commission proposal to amend the Water Framework Directive, the Groundwater and the Environmental Quality Standards (EQS) Directives. We noted with great interest that the proposal assigns a central role to ECHA for scientific support in the identification of water pollutants and the derivation of EQS values in the future.

We welcome the opportunity to provide feedback on the Inception Impact Assessment and would like to share some recommendations on the way forward. The Non-ferrous metals industry is committed to continually improve its production performance to prevent, control, reduce and, as far as possible, eliminate its pollution to protect human health and the environment.

We have identified one provision that is problematic for stationary installations the proposed changes to Article 18 thresholds on unreasonable costs of the Implementing Regulation (EU) 2018/2066. The raised thresholds make it harder for stationary installations to show that i) applying a specific monitoring method, or ii) improving an existing one, incurs unreasonable costs.

Europe’s non-ferrous-metals industry is committed to continually improve its production performance to prevent, control, reduce and as far as possible eliminate its pollution to the environment. We welcome the opportunity to provide feedback on the Inception Impact Assessment to the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR) and would like to share several…

Eurometaux, representing European non-ferrous metals producers and recyclers, supports the European Commission’s initiative to improve the sustainability, energy and environmental performance of batteries placed on the EU market. Our sector is actively involved in the EU’s Battery Alliance & Action Plan, sharing the objective to develop globally competitive value chains for batteries in Europe.

This answer provides the position of the non-ferrous metals industry on the draft text of the revised Commission Implementing Regulation (EU) 2019/1842 as regards further arrangements for the adjustments to free allocation of emission allowances due to activity level changes (ALC Regulation) (see pdf attached).