Umicore

Key Policy Recommendations for a Circular Economy in non-ferrous Metals & CRMs. To unlock the full potential of non-ferrous metals and critical raw materials in the EUs circular economy, we need smart, targeted policies: 1) Tailor approaches, no one-size-fits-all 2) Use KPIs that reward strategic recovery 3) Build a true single market for waste 4) Focus on quality recycling, not mandatory content quotas 5) Ensure…

Umicore supports the Industrial Accelerator Act (IAA) as a balanced approach combining value-chain priorities with administrative simplicity to support industrial competitiveness in the EU . Our recommendations focus on batteries and electric vehicles across three key areas: 1.

We welcome the amendments to economic activity 2.4 Treatment of hazardous waste, notably the removal of the exclusion for metals and metal compounds and the explicit reference to NACE code C24.4. These changes appropriately recognise the strategic role of metals recycling in achieving EU circular economy objectives and securing the supply of secondary raw materials.

Umicore does not support the separation of battery manufacturing and battery recycling into distinct EU Taxonomy activities. A closed-loop, value chain approach is essential. The EU Battery Regulation is based on a life cycle logic, with binding obligations applying to batteries placed on the EU market as a whole, including recycling and recovery targets.

Europe needs a Critical Raw Materials Centrebut its focus should go beyond joint purchasing and stockpiling. The CRM Centre should primarily strengthen Europe's refining, transformation and recycling capacities, while avoiding unintended distortions of raw material markets.

The draft text for the delegated act on calculating the carbon footprint of batteries requires the use of the national average energy mix. This is not in line with the Product Environmental Footprint method, which the Battery Regulation referred to, and deviates from several European legislation. Further it contains in itself an inconsistency with regards to electricity modelling.

Umicore welcomes the proposed implementing act as a solid foundation but highlights several key areas for improvement to ensure effective and harmonised CRM recovery across the EU. 1. Need for Coordinated Implementation CRM use is highly dispersed across sectors. Without EU-wide coordination, national initiatives risk fragmentation and inefficiency. Economies of scale are essential for viable CRM recycling. 2.

Umicore is a global advanced materials and recycling group. We reduce harmful emissions, power the vehicles and technologies of today and tomorrow and give new life to used metals. Cobalt is a critical and strategic raw material essential to key European industries, including electric vehicles, renewable energy, and aerospace.