Joint Position Paper: EU Critical Raw Material Act – CIDSE

Joint Position Paper: EU Critical Raw Material Act

A Turning Point: The Critical Raw Materials Act’s needs for a Social and Just Green Transition“, Position Paper for the ENVI and INTA Committee Votes – 10 July 2023

As we face escalating environmental and social challenges in the 21st century, a global commitment to comprehensive solutions is required. These solutions should effectively address the over-consumption of resources and socio-economic disparities triggered by unsustainable production and consumption practices. This situation requires both the political will to bolster existing measures like product ecodesign legislation and the readiness to implement new, innovative approaches like establishing energy production limits. All of these steps can contribute to a societal transformation that ensures our activities are in harmony with our planet’s boundaries, promoting a fair and equitable environment.

On 17-18 July 2023, the Environment (ENVI) and International Trade (INTA) Committees of the European Parliament will vote on the EU Critical Raw Materials Regulation (CRMR) Act. Ahead of these two votes, an alliance of over 40 civil society organisations released the Position Paper “A Turning Point: The Critical Raw Material Act’s Needs for a Social and Just Green Transition“. The document delves into the intricacies of the Critical Raw Materials Act within this pressing context and contains the following recommendations to the EU:

  • The EU should actively reduce its dependence on primary raw materials and implement demand-side solutions to decrease critical raw materials consumption by at least 10% by 2030, including phasing out single-use products containing critical raw materials, implementing a material passport system, and adopting national programs to promote material efficiency and the use of alternative materials.
  • The CRMA should not rely solely on certification schemes, as certification alone does not guarantee compliance with mandatory human rights and environmental regulations; instead, a broader assessment of human rights and environmental performance should be conducted. If certification schemes are used as one tool of many, they have to include certain criteria as minimum a multi-stakeholder governance, adherence to comprehensive standards, disclosure rules, accessible grievance mechanisms, and public audit reports.
  • The CRMA’s focus on EU supply security through partnerships lacks a global justice approach. Including concrete measures to ensure sustainability standards, civil society participation, and the protection of human rights and the environment in third countries. Our recommendations include aligning partnerships with international agreements, implementing robust monitoring and remediation mechanisms, defining “value addition,” supporting domestic industrialisation, involving civil society and Indigenous Peoples, ensuring transparency, and avoiding the undermining of commitments through other regulations or trade agreements.
  • The CRMA’s focus on accelerating permitting procedures for Strategic Projects risks bypassing environmental and social safeguards and lacks public buy-in. Streamlined permitting must not come at the cost of environmental protection, meaningful public participation. Incorporating elements like Free, Prior, and Informed Consent (FPIC) and Indigenous rights must be at the center of strategic projects. Additionally, resources to licensing authorities have to be allocated, international agreements referenced, transparency ensured and a subgroup on sustainability and responsible mining within the European Critical Raw Materials Board established. Deep-sea mining due to potential environmental and social impacts has to be prohibited.
  • For the success of the European Green Deal and the EU’s strategic autonomy, it is crucial to prioritise a circular economy approach in the CRMA. This includes implementing an ambitious recycling strategy, enhancing coherence with the waste hierarchy, increasing EU recycling capacity targets, improving collection and separation of critical raw materials (CRM)-containing components, proposing recycled content targets for all CRM-containing products, incorporating measures for public procurement, and ensuring that the recovery of mining waste follows comprehensive regulations and includes plans for remediation of historical pollution.
  • The CRMA should include comprehensive rules for calculating and verifying the environmental footprint of critical raw materials. This requires clear criteria for determining a significant environmental footprint, taking into account the impact on circularity and recycling, international standards, and sustainable practices, conducting prior assessments and consultations with relevant stakeholders, allowing the European Scientific Advisory Board on Climate Change to provide scientific advice, ensuring environmental footprint declarations for all critical raw materials placed on the market, including intermediate and final products, and the adoption of delegated acts to establish environmental footprint performance classes with specific parameters.

CIDSE contact: Kim Claes, Energy & Extractivism Officer (claes(at)

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