The European associations Cerame-Unie, Eurogypsum, Euromines, Euroroc, EUSALT, EXCA European Expanded Clay Association, IMA-Europe, UEPG welcome the Commission Communication “Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability”. 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 3 balanced pillars. We also wholeheartedly welcome the launch of the European Raw Materials Alliance (ERMA) which aims to make Europe economically more resilient by diversifying its supply chains, creating jobs, attracting investments to the raw materials value chain, fostering innovation, training young talents and contributing to the best enabling framework for raw materials and the Circular Economy worldwide.

As 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, Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future. We also believe that an updated Strategy for Adaptation to Climate Change should focus both on prioritizing policy areas and actions where EU interventions can be most effective as well as on assessing how to increase ambitions in a manner that best contributes to sustainable growth and enhances economic competitiveness.

In this context Euromines is prepared to take the necessary steps and bring its value added to a climate-resilient society, fully adapted to the unavoidable impacts of climate change, with reinforced adaptive capacity and minimal vulnerability.

The first segment of most value chains, the raw minerals sector is a supplier of critical materials and products to many sectors of the economy. With regards to climate change adaptation, the European minerals sector secures the availability of essential materials needed for a climate neutral, service and welfare orientated, circular and resource efficient economy. For example, the new infrastructure for alternative energies requires an increased use of metals and minerals, in particular steel for pipelines; copper and graphite for electricity cables, generators and electric motors; aluminium, primarily for electricity cables; and a host of other metals and minerals including phosphorous, potassium and nitrogen for biomass production. Also, solar photovoltaic panels and thermal systems use a combination of up to 22 non-ferrous metals, silicon, chemicals (e.g. organic electrolytes) and a specific type of flat glass.

Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future and believes that the EU climate aspiration for 2030 should carefully assess how to increase the ambition in a manner that best contributes to sustainable and inclusive growth and enhances economic competitiveness through accelerating innovation and developing Europe’s industry. It is crucial that in the transition towards becoming climate neutral, the industry maintains and even improves its competitiveness. 

In light of the above, Euromines brought additional comments to its contribution to the public consultation for the EU climate ambition for 2030 and for the design of certain climate and energy policies of the European Green Deal, as per the attached document.

Euromines is publishing its position on the European Commission Brussels, Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions A New Industrial Strategy for Europe (10.3.2020 COM(2020) 102 final). One key element of implementing Europe’s Green Deal successfully must be increasing the resilience of value chains and bringing back value chains to Europe.

To this end industrial value chains need

1. attractive economic, administrative and social conditions,
2. planning security, reliability and consistency throughout the political framework, and
3. a clear strategic focus on maintaining value adding industrial production in Europe.

Raw materials are essential to Europe’s survival as one of the world’s leading economies. The mineral raw materials industry has invested heavily in the EU in recent years and has the potential to contribute further to the recovery strategy through development of new projects and extensions to existing ones.

Euromines would like to highlight that Europe has its own mineral resources, world-class deposits and still major potential. By increasing domestic mineral production, Europe becomes less dependent and improves its sustainable supply chain.

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 to make it the world's first climate neutral continent. At the same time, we believe that policy efforts should be aligned with the fundamental principle of sustainable development, ensure the essential current needs and safeguard the needs of future generations while contributing to economic, social and environmental development. Primary production of metals and minerals, which remain abundant, will play an important role in production processes to 2050 and increased sustainable supply from European sources will be needed in order to make a sustainable transition. The mining sector is well regulated and unavoidably diverse because each operation is developing a unique natural phenomenon. Inclusion of extractive industries in the IED is unlikely to bring additional protection of human health and the environment because the least impacting techniques and technologies are already required by mining and quarrying authorities in the EU Member States.

As the recognized representative of the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 people directly and about four times as many indirectly, Euromines welcomes a Climate Law aiming to assess what would be required to have a more balanced reduction pathway from 2020 to 2050 and to specify what is necessary when increasing the GHG emissions reduction targets by 2030.

As the first segment of most value chains and a critical supplier of materials vital for a transition to a low-carbon society, the mineral raw material industry is prepared to take the necessary actions aimed at turning Europe into the world's first climate neutral continent and contribute to a sustainable and inclusive growth. At the same time, we believe that the Climate Law should form the basis of a stable, coherent, socio-economically feasible policy framework allowing the implementation of most efficient measures to reduce greenhouse gas emissions while ensuring that long-time goals and the international competitiveness of the industry is not endangered. In this context, one of the main purposes of the Climate Law should be to ensure an integrated approach to consistency, stability, and predictability along the whole value chain.

As the recognized representative of the European metals and minerals mining industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, Euromines welcomes the Commission's Sustainable Finance Action Plan for a low carbon, greener economy and agrees that such a socio - economically efficient, sustainable and flexible financial system will contribute to long-term value creation. 

In order to successfully contribute to the common objectives, it is essential that these initiatives on sustainable finance are followed by subsequent proportionate, accurate and fit for purpose documents which include measures and recommendations appropriate to all affected stakeholders.

In light of the above, Euromines would like to make a series of comments regarding the Technical Report on EU Taxonomy published by the Technical Expert Group on Sustainable Finance on 18^th of June 2019. The report is accompanied by a call for feedback as part of the ongoing work carried out by the Commission’s Directorate-general for financial stability, financial services and capital markets union, Directorate-general for environment, public consultation to which Euromines intends to participate and submit its input.

Joint Eurometaux / Euromines Position Paper (submitted to European Commission January 2019)

A. Energy Prices and Costs in Europe (European Commission)

Published every two years, this most recent report underlines the EU's exposure to volatile and growing fossil fuel prices and notes that wholesale prices have started to rise again. Future electricity production costs are expected to increase for fossil fuel-generated electricity (due to import prices and the carbon price) and fall for renewables (linked to the decreasing costs of investment as technologies evolve), with the report suggesting that that electricity market prices could reduce the need for subsidising renewable energy technologies by 2030. 

The EU remains heavily dependent on imports of oil and gas, and the increase in fossil fuel prices (especially crude oil) made the cost of EU energy imports in 2017 rise by 26% to EUR 266 billion. The increase in oil prices could have had a negative impact on EU growth (-0.4% GDP in 2017) and on inflation (+0.6%), the report estimates.

Energy costs for businesses fell from 2008 to 2015 in most of the sectors studied, with the most significant declines appearing in some energy intensive sectors.

The report also considers fossil fuel subsidies (which did not decrease in recent years) in a context of rising energy subsidies to finance the energy transition (€170 billion in 2016). Finally, it contains chapters on the impact of price regulation and the potential benefits of dynamic pricing.

B. Study: Composition and Drivers of Energy Prices and Costs: Case Studies in Selected Energy Intensive Industries – 2018 (Ecofys).

Based on data collected from 189 plants over a 10-year period (2008-2017), the study shows energy prices and costs borne by EU producers operating in 11 energy intensive subsectors: bricks and roof tiles, wall and floor tiles, glass tableware, packaging glass, aluminium primary, aluminium secondary, aluminium downstream, steel (electric arc furnace - EAF), steel (basic oxygen furnace - BOF), nitrogen fertilisers and refineries. Prices for both electricity and natural gas reached a peak between 2011 and 2013 and then decreased. By 2017, recorded prices had returned to pre-crisis levels. Across all sectors, larger consumers are experiencing lower prices and costs. Regulatory components (e.g. network costs, non-recoverable taxes and levies, etc.) have a larger impact on electricity prices than on natural gas prices. Energy costs represent a driver for cost competitiveness, as they account for between 2% and 43% of total production costs in different subsectors. Whereas it is not possible to draw conclusions on the impact of energy costs on margins, a statistically significant negative association between natural gas prices and plant profitability was detected. Finally, the energy costs borne by EU producers appear to be higher than those faced by their international competitors based in Algeria, Egypt, Russia, United Arab Emirates and the US and comparable to those faced by producers in China and Turkey.

Euromines welcomes the Commission’s proposal aiming to promote energy efficiency within the European Union. However, the rules aiming at removing barriers and overcoming market failures should not lead to an overall increase in pressure and economic, social and environmental costs that might subsequently undermine the fundamental principle of sustainable development by making it impossible to serve the essential needs of mankind at present while protecting and ensuring the needs of future generations.