The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining.
FNM
Fundación Montescola
NGO · Spain
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts — staff, costs, accreditations — are not available for it.
2
positions filed
in the 639 files tracked
1
legislative file
of 639 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 639 consultation files tracked so far (53,766 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Fundación Montescola filed 2 positions between 20 Nov 2022 and 27 Jun 2023, across 1 of the 639 legislative files tracked here, attaching a full position paper 2 times.
2022 · 1 filed2023 · 1 filed
What they argued
Firstly, the CRMA needs to not just focus on reacting to changes in the supply side but also actively influence the demand side. To prioritise demand reduction, sufficiency and circularity over primary resource extraction. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate.
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