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

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.

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.

Euromines welcomes a European Green Deal and is prepared to take the necessary measures to make Europe the world's first climate neutral continent. 

The Emission Trading System is one of the most important legal pillars and support systems for the European energy intensive industries. Therefore, any amendment brought to it or any of its subsequent acts in the light of the proposed increased climate ambition for 2030 should be based on a stable, consistent, coherent, socio-economically feasible policy framework, allowing the implementation of the most efficient measures to reduce greenhouse gas emissions while ensuring that long-time goals and the international competitiveness of the industry are not endangered.  

Read more in the Euromines Position on Amendment of the EU Emissions Trading System (ETS).

Euromines is publishing its Position on 'Implementation of the Action Plan on Critical Raw Materials' officially presented yesterday by Euromines President Mr. Mark Rachovides at the hearing of the Consultative Commission on Industrial Change (CCMI) of the European Economic and Social Committee. The main topic of the Hearing of CCMI 177 opinion was the Critical Raw Materials Resilience.

Euromines welcomed the Commission Communication “Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability” (COM(2020)474 final). This document confirms the principles of the Raw Materials Initiative, launched in 2008 with the main objective of assure a sustainable and safe supply of mineral raw materials to the European industry and society, through three balanced pillars.

This communication includes an Action Plan where ten actions to diversify and strengthen Europe’s raw materials supply are proposed. It also states that the Commission “intends to develop and implement these priority objectives and the action plan with the help of Member States and stakeholders, in particular the EIP Raw Materials and the Raw Materials Supply Group.”

The Position Paper is now available.

Europe has its own natural resources, world-class deposits and still major potential. Today, the European mineral raw materials industry occupies no more than a fraction of 1% of the land surface on a temporary basis. Raw-material supply makes use of geological anomalies that cannot be moved from where they are found. Deposits may be situated in remote (and relatively pristine) areas. 

Metals and minerals from the mining and recycling industrial ecosystem are crucial drivers for transition to a sustainable low carbon economy. Safeguarding supply of critical metals/minerals is essential for strategic autonomy of the EU economy (which does not fully depend on providers outside Europe). 
Looking ahead, considering increasing pressures on land use in and around cities, protection of and support for biodiversity is to become increasingly important for all sectors, particularly including the mining industry.

Euromines supports the preparation of EU nature restoration targets in 2021. The different policies like the Biodiversity Strategy 2030 and the Zero Pollution Action Plan, but also other related policies like the Industrial Strategy and the list of Critical Raw Materials, must be coherent. A proactive dialog between our sector and EU decision makers is key to let our sector interact as source for EU businesses within the unique EU framework of nature protection. The European mineral raw materials industry can contribute with its best practices of biodiversity conservation.

Due to its long mining history, Europe has developed unique competence in rehabilitation and eco-system management and the European mining sector actively supports the conservation of biodiversity.

Amendment of the EU Emissions Trading System (ETS) - Euromines Positions the recognized representative of 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, the first segment of most strategic value chains and a critical supplier of materials vital for a transition to a low-carbon society, Euromines welcomes a European Green Deal and is prepared to take the necessary measures to make Europe the world's first climate neutral continent.

The Emission Trading System is one of the most important legal pillars and support systems for the European energy intensive industries. Therefore any amendment brought to it or any of its subsequent acts in the light of the proposed increased climate ambition for 2030 should be based on a stable, consistent, coherent, socio-economically feasible policy framework, allowing the implementation of the most efficient measures to reduce greenhouse gas emissions while ensuring that long-time goals and the international competitiveness of the industry are not endangered. 

The future carbon border adjustment mechanism should be designed in such a way as to address the risk of carbon leakage while fully complying with World Trade Organization rules, maintaining the competitiveness of the European industry and rewarding contributions to a low-carbon Europe.
Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures and bring its value added to making Europe the world's first climate neutral continent.

With regards to the Carbon Border Adjustment Mechanism (CBAM), Euromines agrees that such a new instrument should be designed in a way that addresses the risk of carbon leakage while fully complying with World Trade Organization rules, maintaining the competitiveness of the European industry and rewarding contributions to a low-carbon Europe. In this context, we are ready to bring our value added to the current in depth assessment aimed at identifying the most efficient instrument that will complement the Emissions Trading System and counteract the risk of carbon leakage by putting a carbon price on imports of certain goods from outside the EU.