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.

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)

June 2026 Dr. Florian Anderhuber Deputy Director General Euromines contribution to the consultation on the revised European sustainability reporting standards Need for simplification and proportionality The Commission proposal introduces several simplification tools compared to the initial ESRS framework, such as phase-in provisions, relief mechanisms based on “undue cost and effort”, and a stronger focus on…

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

As the recognized representative of the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 people directly and about four times as many indirectly, Euromines welcomes a Climate Law aiming to assess what would be required to have a more balanced reduction pathway from 2020 to 2050 and to specify what is necessary when increasing the GHG emissions…

Consultation Feedback ETS post 2030 Sustainable Mining in Europe – Sustainable Mining for Europe POSITION PAPER May 2025 ETS post 2030 Euromines, the voice of European mining industry, wants to express its position and its requests on the revision of the ETS Directive.

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

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 members are committed to facilitating and encouraging the promotion of safe use, recycling and disposal of products through an understanding of their life cycles. Primary production of metals and minerals, which remain abundant, will play an important role in delivering the European Green Deal and increased sustainable supply from European sources will be needed to make the sustainable transition: •…

European Association of Mineral raw materials Industries, Metal Ores & Industrial Minerals European Carbon Border Adjustment Mechanism (CBAM) Euromines Position The future carbon border adjustment mechanism should be designed in such a way as to address the risk of carbon leakage while fully complying with World Trade Organization rules, maintaining the competitiveness of the European industry and rewarding…

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

As the recognized representative of the European mineral raw materials industry, covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, the first segment of most strategic value chains and a critical supplier of materials vital for a transition to a low-carbon society, Euromines welcomes a European Green Deal and is prepared to take the necessary…

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.

Sustainable Mining in Europe – Sustainable Mining for Europe Euromines Feedback on Nature Restoration Targets under the EU Biodiversity Strategy Brussels, 22 August 2022 Commission’s draft Nature Restoration Regulation (Com 2022/0195) Biodiversity and mining Raw-material supply makes use of geological anomalies that cannot be moved from where they are found.

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

European Association of Mining Industries, Metal Ores & Industrial Minerals Euromines Position on EU Biodiversity Strategy for 2030, December 2020 Biodiversity and mining Raw-material supply makes use of geological anomalies that cannot be moved from where they are found. Deposits may be situated in remote (and relatively pristine) areas.

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

European Association of Mining Industries, Metal Ores & Industrial Minerals Revision of the Industrial Emissions Directive – Commission proposal to include mining sector - Feedback to “Have your Say” webpage Brussels, 23 June 2022 The European Commission has proposed the inclusion of the (non-energy) mining sector into the scope of the Industrial Emissions Directive (IED) as part of a broader revision of the IED…

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

As the recognized representative of the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures to make it the world's first climate neutral continent.

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)

In general Euromines welcomes the WSR proposal. Some comments we would like to mention are: • Current WSR (1013/2006) contains 25 kg threshold applicable only to waste designed for laboratory analysis. The new text is positive as it increases the threshold to 150 kg and applies it also to shipment waste for experimental treatment tests. However, 150 kg threshold might not be enough for e.g.

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.

As the recognized representative of the European metals and minerals mining industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, Euromines supports the ambition of the Commission to reduce CO2 emissions and to move towards a greener and a more sustainable economy.

This initiative addresses the findings on chemical pollution and the legal obligation to regularly review the lists of priority substances and groundwater pollutants which is regulated under the umbrella of the WFD and which will be further linked to the new Zero Pollution Action Plan.