European Metals

We support the approach of the EC to develop the IAA and to have the EUs first set of local content requirements. This is necessary for sectors such as the European metals industry which is subject to severe global competition. The IAA should provide tangible support to NFMs and CRM & SRM producers. We need much more clarity around the Made in Europe provisions.

European Metals, the European non-ferrous metals industry association, supports the objectives of EU Taxonomy Regulation EU/2020/852 to channel investments into sustainable economic activities, as well as the proposed amendments to the Climate and Environmental delegation acts which aim to improve the usability and implementation of the existing criteria.

European Metals, the European non-ferrous metals association, welcomes the simplification exercise carried out by the European Commission and the European Financial Regulatory Advisory Group (EFRAG) towards the revision of the first set of the European Sustainability Reporting Standards (ESRS).

European Metals represents European producers of non-ferrous metals (NFM), such as aluminium, copper, lithium, nickel, zinc, silicon, as well as ferroalloys and other metals that are essential to the green and digital transitions. Amid high energy and carbon costs, the need for a framework that enables the European industry to survive and continue growing has become even more urgent.

European Metals welcomes the opportunity to provide feedback on the post-2030 renewable energy framework. We bring together the companies and associations shaping Europe's non-ferrous metals ecosystem: from upstream mining and refining to downstream use and high-quality recycling.

European Metals, the European non-ferrous metals industry association, supports the objectives of EU Taxonomy Regulation EU/2020/852 to channel investments into sustainable economic activities, as well as the proposed amendments to the Climate and Environmental delegation acts which aim to improve the usability and implementation of the existing criteria.

European Metals represents European producers of non-ferrous metals (NFM), such as aluminium, copper, lithium, nickel, zinc, silicon, as well as ferroalloys and other metals that are essential to the green and digital transitions. Amid high energy and carbon costs, the need for a framework that enables the European industry to survive and continue growing has become even more urgent.

European Metals welcomes the European Commissions consultation on the Environmental Omnibus and thanks the Commission for the opportunity to contribute. The attached position paper outlines European Metals overall support for the Omnibus as a step toward simplifying and harmonising EU environmental legislation while maintaining high environmental standards.

NON-FERROUS METALS INDUSTRY INPUT TO THE UPCOMING ADVANCED MATERIALS ACT 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 (NFM) - from the base metals (aluminium, copper, lead, nickel, tin, zinc) through technology metals (e.g.

Non-ferrous metals are a key enabler of the twin green and digital transition in the EU. With the demand for these materials expected to grow significantly by 2050, increasing domestic supplies of critical raw materials (CRMs) and other valuable metals must remain a priority of upcoming EU legislation and be facilitated through relevant EU funding instruments covered both within and outside of the 2028-2034…

European Metals, the European non-ferrous metals association, calls for the introduction of a uniform export duty that applies universally towards all countries. As an alternative, and only as a fallback option, we see the possibility of introducing tariff rate quotas (TRQs), which should be based on historical export volumes (i.e. not reflecting the large surge in exports seen in recent years).

European Metals welcomes the opportunity to provide feedback on the update of the governance of the Energy Union and climate action. European Metals brings together the companies and associations shaping Europe's non-ferrous metals ecosystem: from upstream mining and refining to downstream use and high-quality recycling. The Governance Regulation must evolve beyond a narrow focus on decarbonisation policies.

Overall, European Metals welcomes the proposed approach in the draft Delegated Act (DA) and related Annex on the green listing of certain non-hazardous waste, which amends Annexes III, IIIA, IIIB, and IV of the Waste Shipment Regulation (WSR).

As European Metals, the European non-ferrous metals industry association, we fully support the objectives of the Critical Raw Materials Act (CRMA) to improve the resilience and sustainability of Europes raw materials value chains.

While recycled content (ReCo) requirements are not the best tool to boost demand for recycled metals, in the context of the proposed measures, European Metals considers the proposed delegated act and annex on the methodology for the calculation of ReCo in batteries strikes a correct balance between physical plausibility, traceability and practical implementation.

The Agency for the Cooperation of Energy Regulators (ACER) is legally tasked with ensuring a competitive, integrated, and efficient European energy market. While the overarching goal of the European energy regulatory framework is to deliver affordable prices and reliable supply to all end-users, ACERs stakeholder engagement framework has consistently lacked adequate representation for a key market participant…