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.

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.

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.

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 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).

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

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.

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.