Recyclers call for a Critical Raw Materials Regulation that promotes circularity in Europe

European recyclers warn of a plethora of poorly justified proposed amendments found in ITRE’s draft report on the EU COM proposal on Critical Raw Materials (CRMs) published on 26 and 30 May 2023.

While many tabled proposals highlight the need for transparency ‘when the Commission adds or removes a raw material to the list in Annex I & II, Section 1, the Commission shall provide a clear argumentation and a timeline’, others suggest the addition of materials to the aforementioned annexes without the existence of such an argumentation. European recyclers are of the strong opinion that any proposal laid down in EU legislation must be supported by an assessment which is purely based on scientific evidence.

Additionally, EuRIC insists that the Commission should review and, if necessary, update the list of critical raw materials four years after entry into force and every four years thereafter. Reducing the updating frequency would create unprecedented uncertainty in terms of allocations of capital in new investments.

Regarding the proposals proposing an export restriction, EuRIC strongly believes those are at odds with the ‘free trade’ concept and must be disregarded at all costs. Recycled materials meeting industry’s specifications or international standards must have access to international markets. Noteworthy to mention is that such decisions are governed by the EU Waste Shipment Regulation and must not be the focus of this legislative act.

Finally, the proposals that suggest advancing the date of adoption of the Delegated Acts, which will lay down the share of recycled content targets of the materials mentioned in Article 28 of the proposal, are to be strongly welcomed. However, EuRIC believes that not expanding the scope of the Article is a sign of lack of ambition.

“The European Union stands at a crossroads, a defining moment in its existence. The decisions that will be made on a number of crucial legislative proposals – including the proposal on Critical Raw Materials – will define the future of the EU recycling industry and hence its ability to achieve the ambitious targets set in both the EU Green Deal and Circular Economy Action Plan (CEAP)”, warned Emmanuel Katrakis, Secretary, Secretary General of EuRIC.


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