Comité Académico Técnico de Asesoramiento a Problemas Ambientales
CATAPA
In haar streven naar een rechtvaardige samenleving waarbij mens en natuur in evenwicht samenleven, focust CATAPA op de negatieve impact van metaalmijnbouw op mens en milieu.
ID: 431904548203-03
Lobbying Activity
Response to European Critical Raw Materials Act
30 Jun 2023
Radical climate action is needed, but increasing mining and raw materials consumption is not the way to lower our GHG emissions, as today mining and metallurgy already represent 20% of all health impacts from air pollution and more than a quarter of global carbon emissions (1). The EU population is 6% of the global population, yet we consume 25 - 30% of the global resources. The CRMA will only make it easier to keep consuming way above our fair share, instead of shifting efforts towards a truly sustainable systemic change that would lead to meaningful resource use reduction. We need to change production and consumption patterns to a circular post-growth economy through implementing strict production rules to avoid single-use products, non-repairable devices and non-recyclable materials from entering our market. Furthermore we need to reduce raw material demand by introducing strong sufficiency policies, increasing recycling rates and the remining of mining waste and urban waste. We are especially concerned about the expansion of strategic partnerships. Mining is the deadliest industry to resist, with 27 environmental defenders murdered last year (2). Indigenous people are most at risk, as their right to free, informed and prior consent (FPIC) as granted by ILO (3), is often ignored. Communities must have the right to say no to mining in their territories, which is why this right to FPIC needs to be granted to all communities affected by mining under strategic partnerships and through supply chains. Mining is connected with serious environmental and social impacts, destroying livelihoods of the people living close by mining and metallurgical sites and polluting surrounding nature for decades. In the strategic partnerships, as well as in mining in the member states, human rights, as well as the rights of communities, must be recognised and protected. Access to justice must be easy and available for everyone, and companies must be held accountable for their actions anywhere. The current due diligence proposal is not strong enough to protect communities from the impacts of mining. A just transition cant leave people behind, the CRMA is leaving many communities behind, in Europe and beyond. The speed-up environmental impact assessments and possible openings of mines in Natura2000 areas are deeply concerning. In times of a severe climate and biodiversity crisis, we cant risk losing more precious biodiversity to polluting industries. Resource extraction and processing together represent 90% of biodiversity loss and water stress in the world (1). We call for -Strong protection of human rights and rights of communities to say no to mining in their territories -Access to justice and transparency in mining projects in the EU and beyond -An EU-wide reduction target for use of resources, with binding sub targets addressing metals -Favour the production, import or use of secondary over primary CRMs -Reduction of raw materials consumption by focusing on mitigation policies, by --Prioritising reaching higher recycling rates as fast as possible raising the targets from 15% to at least 50% and adding a minimum level of recycled CRM content for relevant products --Introducing mandatory product passports, disclosing the amount of CRMs and necessary information for recycling, and mandatory material efficiency regulations --Strong policies to abolish planned obsolescence, strong repairability and ecodesign regulations, as well as increase of product life-spans --Investments in energy saving measures --Investments in public transport, trains, active mobility, and car sharing over privately owned cars; tax benefits must be directed to public transport instead of private cars and planes --Mining waste instead of virgin mining --Promotion of technologies/ innovations that reduce demands of critical raw materials, such as sodium-ion batteries to relieve lithium demands
Read full responseResponse to European Critical Raw Materials Act
25 Nov 2022
Firstly, we advocate actively for sufficiency next to efficiency. The CRMA needs not just focus on reacting to changes in the supply side but also actively influence the demand side. The CRMA should prioritise demand reduction, sufficiency and circularity over primary resource extraction. Reducing material consumption is at the same time vital to achieving the EUs objectives to live well within planetary boundaries. Reducing material consumption can also help the EU to reduce its energy demand and achieve its decarbonisation and biodiversity objectives. It could reduce EUs dependence on imports of critical raw materials would help it to preserve its independence and strengthen EUs resilience to potential future conflicts. The CRMA can signal politically that the Commission must act on setting this overall materials demand reduction target in its next mandate. Within Pillar 1, objectives for increasing capacity at different value chain stages must: 1) have a global social & environmental justice dimension; 2) be underpinned by a commitment to, and enforcement of, high environmental and social legislation and standards; 3) favour secondary over primary raw materials. Within Pillar 2, the mapping and monitoring of strategic mineral resources demand developments is key as well as broader national material flows. The EU needs to actively play a role in influencing demand (beyond mapping). The dedicated operational network mentioned by the Commission should also look into how this can be done, and include civil society. Within Pillar 3, any list of strategic projects that are developed must ensure that: 1) the process and selection are done in a transparent and democratic manner involving all EU institutions and stakeholders; 2) criteria for choosing projects are based on a robust assessment of environmental and social risks, assessment of any company involved and its past performance and a clear community consent; 3) a certain percentage of the strategic projects are secondary raw materials projects. Within Pillar 4, to strengthen resource use, waste and circularity frameworks the CRMA must: 1) signal politically that the Commission must act in its next mandate to develop an EU-wide material footprint reduction target; 2) ensure circularity measures apply to all products containing CRMs including imports; 3) update the EU Extractive Waste Directive to strengthen exploration and documentation of CRMs in secondary deposits and waste streams, including that Member States create an open database reporting data on extractive waste facilities; 4) set binding targets for waste operators of CRMs from different waste streams for material recovery and final recycling levels; 5) set product design requirements, including on product longevity and recycled content; 6) increase support for EU research and innovation funding on recycling, substitution and material recovery technologies for CRMs. Also in Pillar 4, to ensure high environmental, social and governance standards the CRMA must: 1) establish and enforce ambitious environmental, social and human rights legislation and standards, including Water Directive, EIA Directive, Habitats Directive, updating Extractive Waste Directive, and referencing the CS3D; 3) scale up investment and action on low-impact mining, underground mining, bio-mining, geothermal; 4) require suppliers report on carbon emissions, water and material footprint and land use per tonne of material. Lastly in Pillar 4, strategic reserve measures should: 1) include global justice dimension securing reserves in Europe must not reinforce path dependencies of resource-rich countries and must keep open adequate participation for their own economic policy; 2) favour secondary over primary raw materials; 3) comply with the highest possible ecological, human rights and labour standards; 4) be used exclusively for sustainable products and infrastructure. The entire process should be governed by democratic decision-making.
Read full responseMeeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)
16 Nov 2022 · On the side of the EU Raw Materials week High Level Conference, the parties met to discuss current issues related to raw materials and batteries supply