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. 

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.

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.

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.

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.

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.

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.

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

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. 

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.