Euromines

Starting in the mine, the whole raw materials value chain is fundamental to boosting EU decarbonization, strategic autonomy, security, resilience, and competitiveness, and it should be achieved while upholding the EUs high environmental and social standards.

Euromines members are committed to facilitating and encouraging the promotion of safe use, recycling and disposal of products through an understanding of their life cycles. Euromines has made significant contributions to the science of Life Cycle Assessment, on which the Environmental Footprint methods are based.

Euromines expresses its support for first a full coverage of downstream goods and introducing an export solution to evaluate and ensure the effectiveness of CBAM as a carbon leakage tool before extending the mechanism to other energy-intensive sectors.

The Commissions proposal to streamline EU environmental legislation, improve coherence across regulatory instruments, and reduce unnecessary administrative burdens, while fully preserving its objectives, is a significant step in the right direction toward achieving a more competitive EU mining industry. Drawing on field observations and experience, we have identified some improvements.

POSITION PAPER – October 2025 Euromines view on Electrification Action Plan Author: Florian Anderhuber Deputy Director General Sustainable Mining in Europe – Sustainable Mining for Europe POSITION PAPER month 2025 Electrification Action Plan Euromines view on the upcoming plan Main key points: Electrification is key – yet mined goods are price takers: mining is to more than 50% electrified, metals mining to more…

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

Euromines would like to use this opportunity to address key challenges if the "Do No Significant Harm" (DNSH) principle is streamlined across the 2028-2034 Multiannual Financial Framework, in particular in terms of applicability and scope and the resulting impact on investment uptake.

Euromines appreciates the initiative by the Commission to create a Critical Raw Materials Centre. Key aspects for the Centre to operate are - a clear mandate and mission statement - adequate staffing - sufficient funding Please refer to attached paper for further information.

The requirement of the draft text to use of the national average energy mix to calculate the battery carbon footprint undercuts the value proposition of EU battery material producers starting from the first step in the value chain: mining.