With the publication of the CRM Act and the subsequent public consultation, the CRM Alliance has drafted a common position on the Regulation.
Securing the sustainable access and supply of both critical and strategic raw materials will not be achieved by 2030 within the context of the CRM Act and Communication alone. Following a careful and regular assessment of the CRM Act, the CRM Alliance has proposed the following recommendations that we believe could further support the achievement of the objectives of the regulation:
Early socio-economic impact assessments should automatically be triggered in all legislation aiming to restrict the use of critical and strategic raw materials.
All uses of critical raw materials serving applications and technologies deemed strategic for the EU shall be considered to meet the Essential Use Concept.
The Commission and Member States should provide greater clarity as to how State Aid rules would be used and introduce grant, loan and tax credit mechanisms to support the creation of new facilities in the EU and third countries.
The Commission should provide de-risking mechanisms to support strategic/critical raw materials investments of strategic importance for the EU realised in third countries, in the same way as projects realised within the EU.
The Commission should protect European strategic raw materials’ production from unfair trade practices by maintaining and strengthening trade defense measures, in order to ensure a level playing field.
Future strategic and critical raw materials lists may also be accompanied by an “impact assessment” of existing EU legislation and the impact it has on materials on those lists.
To read more, download the position paper below.