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Alliance des Minerais, Minéraux et Métaux

A3M

A3M résulte du rapprochement en janvier 2014 de la FEDEM et de la FFA qui ont décidé d'unir leurs forces pour assurer une meilleure visibilité et représentativité de leurs professions et accroitre l'efficacité de leurs actions communes dans les domaines : compétitivité et développement économique ; développement durable, environnement, santé, hygiène et sécurité.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

Feedback from A3M - Alliance des Minerais Minéraux et Métaux - representing industrial players having operations in France in mining, metallurgy, steel making and metal recycling is given in attached file.
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and Orano and Solvay SA

9 Jul 2025 · Exchange of views on waste codes for permanent magnet waste

Meeting with Thomas Woolfson (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

5 Feb 2025 · Presentation of A3M and discussion about trade, decarbonization and energy.

Response to European Critical Raw Materials Act

25 Nov 2022

A3M represents the French metal mining, processing, and recycling industry. We strongly support the initiative of an EU CRM Regulation aimed at ensuring strategic sovereignty of EU through a supply of strategic raw materials to achieve EU key objectives (energy and digital transitions, sustainable mobility, operations of strategic value chains including EU defense). This act should establish strong ESG requirements for EU and non EU projects related to raw materials based on applicable ambitious standards (eg. IRMA, ICMM, TSM..). A3M has been involved in France with the mission carried out by Ph. Varin that lead to the creation of a French Observatory (OFREMI) dealing with the identification of dependencies on strategic raw materials (RM). The CRM Act should be an opportunity to coordinate a network of national agencies dealing with RM to carry out surveillance and crisis management activities and to direct financial support to priority projects. This regulation must also create a favorable framework for maintenance, creation and development of the entire EU value chain exploration/mining extraction, refining, metallurgical/iron and steel activities and recycling/reincorporation - strengthening the complementarity between primary and secondary raw materials, hence also ensuring the EU circularity targets (ie consistency with WSR, ESPR, Battery regulation). Permitting for strategic RM projects should be streamlined and their operating framework optimized with consistency with other objectives and regulations (due diligence, CSRD, forced labor, taxonomy, environment etc).The CRM regulation should include a mechanism to identify strategic EU projects supported by investments and financing tools, with simplified and dedicated access (eg.via the EIB and an European sovereignty fund, IPCEI), including for extra-EU projects developed by EU operators. A3M favors an ambitious EU policy, strengthening national guidelines for the management and recovery of RM as well as the ESG equivalent expectations for the supply of primary and secondary resources from a non-EU partner country. The diversification of supplies of RM for strategic EU industries also involves a strong policy (including mining diplomacy) for extra-EU extraction within the framework of specifically identified projects involving as much as possible European players. Success of CRM act is also dependent on economic conditions compatible with international business operating costs references (eg. ESG conditions, energy costs). CRM Act should identify strategically important RM based on open criteria as proposed by the Commission (including, but not limit, their importance, concentration of supply, substitution of demand, strategic applications and projected supply shortfalls), without being limited to the current list: must be forward looking and flexible. EU transitions require larger volumes of metals that are not identified on the current list of CRM such as copper, nickel, and high-purity manganese which could face some challenging supply over the next decade and at risk of future criticality. It should be also noted that the steel industry, needed eg. for Energy transition and for defense industries, uses a diversity of metals. Furthermore, given the targets of the Green Deal and the Circular Economy Plan, the list of CRM could also consider the essential contribution of secondary RM. From this point of view, metal scraps, play a major role in the EU production of steel, copper and alloys while largely contributing to drastically reduce CO2 emissions, should be fully recognized as critical secondary materials. The development of RM recycling projects are of paramount relevance, in particular for permanent magnets, batteries, WEEE, etc. The CRM act should also promote actions to improve recycling rates for strategic RM by adopting new legislation for emerging product groups, prioritizing circularity of RM in future revisions of waste legislation (eg. ELV, WEEE).
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

A3M représente les producteurs miniers, industriels métallurgistes, fabricant de batteries et recycleurs français, présents sur l'ensemble de la chaîne de valeur des batteries. Nous supportons largement l'ambition de la Commission Européenne de développer un marché plus durable des batteries. La proposition de règlement reprend un grand nombre des points clés : l'éco-conception, l'approvisionnement responsable, la traçabilité et le recyclage, etc. Nous souhaitons insister dans notre position ci-jointe sur un certain nombre d'enjeux essentiels à la mise en œuvre de cette nouvelle réglementation. Nous exprimons des incertitudes sur les méthodes de calcul qui ne sont pas encore précisées et insistons sur la co-construction de ces méthodologies avec l'ensemble des parties prenantes. Surtout, nous souhaitons que l'ensemble de ces allégations environnementales fassent l'objet de vérification concrètes via des systèmes de contrôle ou de certification afin de garantir une compétition équitable parmi l'ensemble des acteurs économiques. Enfin, la Commission devrait faire preuve de cohérence entre les réglementations en vigueur et notamment sur les substances dangereuses et le transfert des déchets.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

The association of French Steel and Metal industry (A3M) welcomes the legislative proposal to mobilize investment in the EU to achieve sustainable growth in line with the Union’s climate goals and its Paris Agreement commitments. A common EU taxonomy for sustainable finance could play an important role in this process if drafted in a way that takes the specific characteristics of the affected industries into account, based on robust scientific evidence. This should certainly be the case with the steel industry, which has the greatest potential to reduce carbon emissions volumes of any productive industry, and in which environmental performance can only be evaluated by considering its overall production value chain. Unfortunately, the draft Commission delegated act narrowly focuses on only some parts of the steel production’s CO2 emissions, using the methodology of EU ETS benchmarks for setting thresholds, even though these benchmarks have not been designed for this application. This has the potential to hinder, or even prevent, the successful deployment of some of the most promising decarbonisation projects in the pipeline. It is very essential to improve the screening criteria for climate mitigation and adaptation for steel and to correct the proposed delegated act accordingly for a sustainable EU steel industry. The following crucial points should urgently be reflected in the delegated act: - Using the ETS benchmarks does not enable the evaluation of the environmental impact of the activities of the steel industry. A significant portion of the steel industry’s emissions are not taken into account in the ETS benchmarks, as they are transferred to the power sector. An option would be to correct the ETS hotmetal benchmark with the exported waste gas, as explained in the attached document. An alternative would be to use internationally or regionally recognized accounting rules, such as the EN 19694-2 EN standard, to avoid the risk of miscalculating emissions. - Using a more integrated lifecycle approach, taking into account that steel is an enabler for CO2 mitigation in multiple value chains. - Securing the eligibility of EAF steel production without excluding different steel qualities, like stainless steel and high alloy steel, due to the proposed threshold of at least 90% on scrap sourced iron content in final products being set at a technically unachievable level. - Adding Carbon Capture and Usage to the list of low carbon breakthrough technologies and acknowledging alternative sources of hydrogen production.
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Response to A new Circular Economy Action Plan

20 Jan 2020

Our key recommendations for a new Circular Economy Action Plan: Climate 2050 Strategy and Circular Economy Ensure that the Circular Economy contributes fully to Europe’s 2050 climate-neutral strategy, including a focus on increasing metals recycling rates to: - Improve Europe’s domestic supply of raw materials for its low-carbon value chains; - Mitigate and avoid extra greenhouse gas emissions from Europe’s rising metals demand. Support pre-emptive industrial investments into Europe’s recycling capacity for low-carbon technologies, where significant end-of-life volumes will only be available from 2030 onwards (e.g. electric vehicle batteries, solar panels). Global Trade and Circular Economy Ensure a global playing field for European high-quality recyclers, through further actions to better control waste exports (including a robust mechanism for assessing “broadly equivalent conditions” in destination countries). Continue to clamp down on illegal exports, including capacity-building at Member State level. Initiatives focused on tackling the issue of the large export of scrap from the EU by improving their quality and the definition of quality standards. Take stock of global developments including the China waste imports ban, and assess how Europe can act to stimulate the flows of its high-value waste to domestic recyclers. Waste and Circular Economy Use upcoming policy reviews (in 2020) to bring in concrete actions and improvements in Waste Shipment Regulation, Batteries Directive and End-of-Life Vehicles Directive. Include provisions for establishing a mandatory EU certification scheme for e-waste in order to provide the required framework for quality recycling. Lower the administrative burden for intra-EU waste shipments and imports. Encourage Member States to advance and improve their collection and sorting infrastructure (e.g. for e-waste and portable batteries). Product Design and Circular Economy Support the implementation of generic EU regulatory requirements on recyclability in product design, with a flexible approach to implementation for each product group. Focus the EU research agenda on developing new technologies and processes for recovery of less recycled metals. Chemicals Management and Circular Economy Safe production, use and recycling of chemicals should be prioritised to secure a true Circular Economy. Industry and policy makers should set a long-term framework for controlling chemicals exposure, including further collaboration on improving data on chemicals. Today’s thorough chemicals management shouldn’t be hindered by rushed scrutiny under chemicals legislation and only focus on hazard. Europe’s industry needs predictability of investments for battery metals and other materials necessary for the climate transition.
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