Euromines welcomes that the European Commission embarks on one of the most contentious issues there is when it comes to merging decarbonization with industrial competitiveness. We appreciate the proactive engagement of the Commission but and we take into account the short-term nature of the measures to bridge the current crisis, but we deeply deplore that the proposal as it stands will not help the energy-intensive industry, that the issue of gas prices and the nexus to electricity prices is not considered – and even worse: the risk that the resilience Europe needs gets undermined. The reason for this: is the uncertainty of whether our industry will benefit from redistribution measures while still being exposed to the spot price.

The short-term proposal falls far too short to address the deficiencies of the market design and puts our industry in survival mode as the proposed measures are barely enough to survive. In absence of a re-design that drives prices down, ensure protection for energy-intensive industries such as mining that are key for the Green Deal and for which decarbonization means either direct or indirect electrification our industry requires from the proposed short-term measures to be effective.

On 5 April 2022, the European Commission proposed the inclusion of the (non-energy) mining sector into the scope of the Industrial Emissions Directive (IED) as part of the IED Review. 

The European mining sector is already covered by an ambitious and established permitting system ensuring transparent procedures and stakeholder participation. The mining sector is subject to a dense set of European and national environmental and mining legislation ensuring the highest environmental, climate and safety standards. On the other hand, the IED-system is not suitable for the mining sector and its inclusion would have no environmental benefits. The IED-system of Best Available Techniques will not be functional for the variety of mine types, mine operations and specific mining installations.  It will only hamper and prolong procedures for obtaining mining permits.

Euromines asks the European Parliament and the Council to amend the Commission’s proposal and to exclude the mining sector from the scope of the IED (deletion of Annex I, No. 3.6.). 

It is obvious that two years of COVID-19 and the Russian war against Ukraine have widely disturbed industrial supply chains and set the security of raw materials supply at risk. Against this background, it is not the time to launch a new additional legislative burden for the industry. Under a wider perspective, Euromines would therefore support postponing the further discussion on the IED revision, also because it could hamper the competitiveness of the industry.

Read the Euromines Position - on the Revision of the Industrial Emissions Directive

Overview of the European mining sector contribution to the 7 EU Priorities:

• Ensure a full recovery from the COVID-19 pandemic
• Build the Union of tomorrow
• Global leadership in fighting climate change
• Shape our own digital solutions and establish Europe’s digital sovereignty
• Make our economy more resilient and robust
• Defend our common values and strengthen our democratic model 
• Strengthen the EU's role as a global actor

The most important driving force for increased demand for many metals until 2050 will be the climate transition. The English version of the new Svemin's report 'Climate ambitions and metal needs – opportunities for Sweden and the Swedish mining industry' was launched during the Raw Materials Week 2021. The level of climate policy ambition will therefore be directly related to the availability of raw materials. “The faster we want to switch to a net zero society, the higher the demand for metals,” says Katarina Nilsson, project manager for the study.

The more ambitious climate targets, the more metals and minerals needed for a clean energy transition. European mining companies and mining technology companies are essential for European value chains and thus crucial for overcoming post-pandemic global economic crisis. Read more on sustainable mining best practice cases in the attached publication.

Aiming at identifying the gaps and needs of extractive SMEs and micro enterprises the Project on Occupational Health and Safety covered not only the traditional but also the new and emerging risks to occupational safety and health. The knowledge gathered has been used to develop training material and self-assessment tools to help employees comply with and to raise awareness for occupational health and safety legislation. 

The main deliverables promote the safe and healthy behavior and provide useful information on how to deal with the most common risks present on site. Finally, the project allowed for creating a network of collaboration among the representatives of employers and those of employees in five Member States. 

Please visit https://minesafety.eu/ to learn more about the project and the final deliverables which, we believe, will be useful for the companies in the mining sector.

Within the EU, Member States have sovereign rights over their own natural resources and responsibility for mining and quarrying lies with the Member States within a defined framework of established ownership rights and national, regional, and local regulations – in particular specific mining legislation.

The current review of the Industrial Emissions Directive (IED) considers inter alia to include extractive industries in the Directive. This would mean a far-reaching change of the actual situation. Mining activities (extraction and treatment (i.e. comminution and beneficiation)) have for several reasons until today not been covered by the EU legislation on industrial emissions – neither by the IPPC-Directive nor by the present IED. Euromines rejects the inclusion of mining activities under the scope of the IED as this is not only not justified but would also not lead to an added environmental value and would moreover fail to recognise the specificities of the mining sector and the subsidiarity principle.

“The Briefcase book of daily use minerals” is one of the products of the 3D Briefcase project and a teaching tool at the same time. It is intended to be used for teaching geoscience disciplines in schools as well as informing the public about the importance of mining and minerals in our daily lives. Our current lifestyle also depends on mineral resources. Minerals are everywhere around us. Read more in the newly published book!

To meet future growing global demand of a growing population, Europe must take its responsibility in securing the raw material supply for the EU industry. The European metals and minerals mining sector can secure availability of critical raw materials, other minerals and metal ores needed for existing and future products and technologies enabling a climate neutral, service and welfare orientated, circular and resource-efficient as well a digital society.

Euromines welcomes the Commission Communication “Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability” which confirms the principles of the Raw Materials Initiative (RMI), launched in 2008 with the main objective of assuring a sustainable and safe supply of mineral raw materials to the European industry and society. 

Potential inclusion of additional sectors 

Euromines represents the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly. Its members mine metals and minerals, which will play an important role for a sustainable transition and which make EU´s economy less dependent on raw materials from third countries and thus more resilient to crises. 

Within the EU, Member States have sovereign rights over their own natural resources and responsibility for mining and quarrying lies with the Member States within a defined framework of established ownership rights and national, regional, and local regulations – in particular specific mining legislation. 

The current review of the IED considers inter alia to possibly include extractive industries in the Directive. Nevertheless, such an inclusion would fail to recognise the specificities of the mining sector, the reasons are listed in the Euromines Position Paper.