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EUROMETAUX

Eurometaux represents the European non-ferrous metals industry in EU and international legislative matters.

Lobbying Activity

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and Aurubis AG and Viohalco SA

9 Dec 2025 · Discussions on the developments in the European and global copper industry

Eurometaux urges EU to simplify taxonomy for industrial feasibility

5 Dec 2025
Topic — The initiative reviews the EU taxonomy environmental delegated act to update technical criteria.
Message — The group demands achievable criteria based on technical reality and industrial feasibility. They call for simplifying hazardous substance rules and including multi-metallic recycling. They also want to stop applying the DNSH concept to other EU funding programs.123
Why — This would allow metal producers and recyclers to access sustainable finance more easily.45
Impact — Safety advocates lose as the industry pushes to relax restrictions on hazardous substances.6
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Meeting with Dan Nica (Member of the European Parliament, Rapporteur)

3 Dec 2025 · ECF

Eurometaux backs ECHA governance reforms and single budget line

2 Dec 2025
Topic — Regulation modernizing European Chemicals Agency governance and financing structure.
Message — The organization strongly supports introducing a single budget line to allow flexible resource management and reduce administrative overhead. They request broader expert nomination mechanisms, improved transparency in committee decisions through systematic documentation, and better coordination between Commission, Member States, and ECHA on dossier quality.1234
Why — This would reduce their compliance costs and administrative burden while improving regulatory predictability.56
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Meeting with Alexandre Paquot (Director Climate Action) and

25 Nov 2025 · Innovation Fund

Meeting with Eric Mamer (Director-General Environment)

20 Nov 2025 · Developments in environmental policy, in particular REACH, Water Framework Directive, PFAS restriction

Meeting with Andrzej Celinski (Cabinet of Commissioner Piotr Serafin) and Google and

18 Nov 2025 · Presentation on the state of play of the negotiations of the next MFF, with the special focus on communication activities.

Meeting with Paulo Cunha (Member of the European Parliament)

17 Nov 2025 · Electrification Action Plan

Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and

14 Nov 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Kurt Vandenberghe (Director-General Climate Action) and International Copper Association Europe and

14 Nov 2025 · Impact of EU climate policies on non-ferrous metals production

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné)

12 Nov 2025 · General update – CRM – Industrial Accelerator Act – ReSourceEU Action Plan

Eurometaux calls for scrap export curbs and simplified waste rules

6 Nov 2025
Topic — The European Commission is gathering feedback on the proposed Circular Economy Act.
Message — The association requests faster approval for shipping waste between Member States. They oppose mandatory recycled content targets because metals are already infinitely recyclable. The group also wants stricter controls to prevent metal scrap leaving Europe.123
Why — These measures would lower operational costs and protect industries from raw material shortages.45
Impact — Non-EU smelting facilities would lose access to valuable materials if export restrictions are imposed.67
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Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Ditte Juul-Joergensen (Director-General Energy)

17 Oct 2025 · The electrification plan, the Tripartite Contracts plan, the Industrial Accelerator Act

Meeting with Radan Kanev (Member of the European Parliament)

14 Oct 2025 · Waste shipment and Industrial Decarbonisation Accelerator Act

Eurometaux urges lower power prices to save metals sector

9 Oct 2025
Topic — The EU Electrification Action Plan aims to shift energy demand from fossil fuels to electricity.
Message — Support long-term power purchase agreements by subsidizing the costs of matching renewable supply with consumption. Provide upfront capital and carbon cost compensation to ensure electrification remains competitive. Maintain a market-driven approach without mandatory targets or penalizing less flexible sectors.12
Why — Competitive electricity prices would prevent plant closures and secure the industry's future in Europe.3
Impact — National governments and taxpayers would likely fund the proposed subsidies and financial support schemes.4
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Meeting with Sabine Weyand (Director-General Trade)

7 Oct 2025 · EU-US trade relations; availability of aluminum and copper scrap; EU trade defence measures.

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

30 Sept 2025 · Chemicals Management Week of Eurometaux: upcoming environmental omnibus.

Eurometaux urges strict verification of foreign carbon price payments

25 Sept 2025
Topic — Rules for converting carbon prices paid in non-EU countries into CBAM certificates.
Message — Eurometaux calls for clear criteria to assess foreign carbon pricing, particularly regarding subsidies and rebates. They propose regular country reports to document tax regimes and support schemes in exporting nations. Additionally, they argue against recognizing carbon credits until they are allowed under the EU ETS.123
Why — This ensures European producers are not disadvantaged by foreign competitors using hidden government subsidies.45
Impact — Non-EU exporters lose financial advantages from opaque domestic subsidies that currently lower their carbon costs.67
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Eurometaux demands strict carbon border benchmarks to prevent loopholes

25 Sept 2025
Topic — Rules for adjusting carbon border tax obligations to reflect decreasing free emission allowances.
Message — Eurometaux insists carbon border standards must mirror the European system's strict monitoring and climate-friendly benchmarks. They argue benchmarks should be updated regularly and designed to prevent importers from exploiting exemptions or loopholes.12
Why — This would protect European metal producers from unfair competition by carbon-intensive foreign imports.3
Impact — Importers using scrap or specific alloys may lose the ability to avoid carbon costs.4
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Eurometaux urges strict CBAM rules to stop carbon leakage

25 Sept 2025
Topic — This initiative sets methodology for calculating embedded emissions during the CBAM definitive period.
Message — Eurometaux requests a single national default value for aluminium based on primary production to prevent circumvention. They demand grid-average factors be the sole method for reporting indirect emissions.12
Why — These measures prevent foreign competitors from gaining an unfair advantage through resource shuffling.34
Impact — Foreign producers lose the ability to use actual low-carbon values for exports.5
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Meeting with Vicente Hurtado Roa (Head of Unit Taxation and Customs Union) and European Chemical Industry Council and

19 Sept 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Eurometaux urges flexibility and funding for EU 2040 climate target

16 Sept 2025
Topic — The European Commission is proposing a new 2040 greenhouse gas reduction target.
Message — The group seeks to remove the cap on international carbon offsets starting in 2031. They also want more financial support and a mechanism to review industrial competitiveness.12
Why — These measures would lower operational costs and protect European factories from carbon leakage.34
Impact — European clean technology providers may lose investment if funding is diverted to international projects.5
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Meeting with Jessika Roswall (Commissioner) and

16 Sept 2025 · Circular Economy

Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

5 Sept 2025

Key messages of the position paper: - The update of the Guidelines must not compromise the level of compensation provided by the current system to already eligible sectors. - All Member States must make full use of the indirect costs compensation tool, including by applying the supercap (i.e limiting the indirect costs to be paid at undertaking level to 1.5 % of the gross value added of the undertaking concerned) and by going beyond the threshold of 25% of ETS revenues in absolute terms. - The list of eligible sectors should be updated by including sectors proving compliance within the boundaries of the criteria in the 2020 Impact Assessment; mining of non-ferrous (NACE code 0729) is a sector affected by the increase in carbon prices, it is fulfilling the respective 2020 criteria, and it is thus eligible for inclusion in Annex I - The past five years have been characterised by continuous crisis, undermining the robustness and representativity of any data collection regarding the electricity consumption efficiency benchmarks. - Regarding the update of the the geographic areas and CO2 emission factors, we recommend the European Commission to work closely with the Member States authorities to collect the data necessary for these updates. - Despite the massive deployment of renewables, in 2030 fossil fuels will still be setting the price for the majority of hours thus indirect carbon costs will continue to severely impact the final electricity price paid by European consumers beyond 2030. According to the JRC , although electricity generation from renewable sources is expected to increase from 46% in 2022 to 67% in 2030, the number of hours where fossil fuels set the price will remain at 2022 levels. - For the purpose of policy-making coherence, the update should also take into consideration and make reference to the objectives and provisions of the Commissions Steel and Metals Action Plan. - The updated text of the Guidelines must clarify that the updates will enter into force in 2026 and will have legal effects on the compensation level in notified schemes as of 2027 onwards. The compensation for 2025 indirect carbon costs remains unaffected by the updates. - Looking beyond 2030, to ensure carbon leakage protection, indirect cost compensation must be maintained until the EU electricity grid is fully decarbonised and the EU electricity price reaches a level playing field with global competitors.
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Eurometaux urges EU to streamline cross-border metal waste recycling

24 Jul 2025
Topic — This consultation identifies waste streams with high potential for recovering critical raw materials.
Message — The association requests a full life cycle approach and better cross-border coordination. They propose adding heat exchangers and industrial slags to the recovery list. They also oppose mandatory recycled content targets for non-ferrous metals.123
Why — Streamlined cross-border shipping and harmonized rules would reduce administrative costs and delays.45
Impact — National governments lose the ability to mandate that materials stay within borders.6
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Eurometaux backs proposal to delay battery due diligence rules

18 Jul 2025
Topic — The proposal amends battery regulations to postpone specific due diligence obligations.
Message — The organization supports postponing battery due diligence obligations while waiting for official guidelines. They request alignment with other EU sustainability laws to avoid duplicating reporting requirements.12
Why — Delaying these obligations helps companies avoid legal uncertainty and simplifies their compliance structure.34
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Meeting with Andi Cristea (Member of the European Parliament, Shadow rapporteur)

17 Jul 2025 · EU metal industry

Meeting with Ekaterina Zaharieva (Commissioner) and

15 Jul 2025 · Exchange of views on Advanced Materials

Meeting with Radan Kanev (Member of the European Parliament)

15 Jul 2025 · Power Purchase Agreements

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

11 Jul 2025 · REACH and lithium

Eurometaux urges stronger carbon leakage protections for European metal industry

4 Jul 2025
Topic — Review of EU Emissions Trading System elements including carbon leakage safeguards and market stability.
Message — The organization requests maintaining indirect cost compensation beyond 2030, slowing the free allocation phase-out for CBAM sectors, introducing dedicated benchmarks for alumina and secondary aluminium, and earmarking at least 50% of ETS revenues for energy-intensive industries' competitiveness.1234
Why — This would reduce compliance and operational costs while freeing capital for decarbonisation investments.567
Impact — Global climate efforts lose as carbon leakage shifts production to higher-emission regions.89
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Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Meeting with Bruno Tobback (Member of the European Parliament)

30 Jun 2025 · the Critical Raw Materials Act and Strategic Projects

Meeting with Sara Matthieu (Member of the European Parliament)

25 Jun 2025 · How to create an effective single market for waste

Meeting with Pauline Weinzierl (Head of Unit Trade)

19 Jun 2025 · Eurometaux – meeting with the Trade Committee.

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and Metlen Energy & Metals

3 Jun 2025 · Discussion on the competitiveness of the European metal industry.

Meeting with Thomas Le Vaillant (Acting Head of Unit Trade)

26 May 2025 · Minutes meeting Eurometaux on rules of origin 26/05

Meeting with Léon Delvaux (Director Trade) and International Copper Association Europe and

23 May 2025 · Discussion on the availability of copper scrap in the EU market

Meeting with Bruno Tobback (Member of the European Parliament) and European Precious Metals Federation

19 May 2025 · Preparatory meeting - event on chemicals

Response to Communication on the EU Stockpiling Strategy

9 May 2025

As Eurometaux, the European non-ferrous metals industry association, we support the goal to strengthen EU preparedness and resilience to better anticipate and cope with unexpected events. This is even more important in the current tense and uncertain geopolitical context, especially for critical goods, including critical raw materials. Our sector provides many of the critical raw materials that enable our green and digital transitions and are also important for strengthening our security and defence. While an EU Stockpiling Strategy might be beneficial in some cases, we would also like to stress the necessity to consider sector-specificities and material characteristics to ensure that it really delivers on its objectives. The EU non-ferrous metals industry is concerned about the impacts of such an initiative on the market, and in particular market distortions and price fluctuations. As an example, the Platinum Group Metals (PGMs) market is relatively small, highly specialized, and globally integrated. Sudden public-sector interventions, such as the creation of large strategic reserves, would severely distort market dynamics. Historically, even modest shifts in purchasing patterns have caused significant price volatility. In our answer, we will comment on the following aspects: i) Risk and impact assessment and targeted approach; ii) Stockpiling as a part of a broader raw materials strategy; iii) Value chain public and private cooperation. Please find our full answer attached.
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Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

8 May 2025 · Water Resilience Strategy and WFD

Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur)

23 Apr 2025 · Surface water and groundwater pollutants

Meeting with Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra)

11 Apr 2025 · The reform of the CBAM and the potential extension to other sectors beyond the remit of Aluminium and Ferro-Alloys.

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

10 Apr 2025 · Impact of US tariffs

Meeting with Stéphane Séjourné (Executive Vice-President) and

10 Apr 2025 · Impact of US tariffs

Meeting with Benedetta Scuderi (Member of the European Parliament)

7 Apr 2025 · Motion for Resolution on Energy Intensive Industries

Response to Shipments of waste - systems interoperation for electronic submission and exchange of information and documents

2 Apr 2025

Eurometaux, the non-ferrous metals association, represents the full metal value chain from extraction, through transformation to recycling. Facilitating intra-EU shipments of metal-containing waste is of paramount importance for our sector as it shall foster effective and efficient recycling of metals in the EU, allowing to secure their availability for green and digital technologies like wind turbines, solar panels, batteries, EVs, etc. Now, more than ever, clarity is needed on the waste flows, their volumes and destinations, to stop metal scrap leakage from the EU and to achieve full circular economy and resilience. The new Waste Shipments Regulation (2024/1157) brings a number of good measures and one of them is the increased traceability of waste shipments via the DIgital WAste Shipment System (DIWASS). Our sector fully supports that using DIWASS, or an interconnected system or software, will be mandatory as of 21/05/2026 and we are glad that all the preparatory steps are taken to implement it. As the system will serve for a digital exchange of documents and information, we trust that it will significantly reduce the current administrative burden for the waste shipments. See our contribution attached presenting generic and also detailed comments on the draft implementing act.
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Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu)

2 Apr 2025 · The future of the critical metals sector in Europe

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič), Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič)

31 Mar 2025 · Challenges faced by Eurometaux members in particular with respect to copper, antimony and scrap metal internationally

Meeting with Paolo Garzotti (Acting Director Trade)

26 Mar 2025 · The meeting covered the state of EU trade agreements with Latin America.

Eurometaux urges simpler risk-based rules for EU taxonomy

25 Mar 2025
Topic — Proposed amendments to simplify sustainability reporting and reduce costs for European businesses.
Message — Eurometaux requests shifting from a 'hazard-only' to a 'risk-based' approach for chemical criteria. They want to remove headings that currently prevent battery manufacturing from being labeled sustainable. They also recommend deleting requirements to report non-material data to reduce administrative burdens.123
Why — This would lower compliance costs and help metal producers access green finance.4
Impact — Environmental advocates lose stricter chemical safety thresholds that exceed existing EU legislation.5
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Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

25 Mar 2025 · Impact of energy prices on the metal industry

Meeting with Jessika Roswall (Commissioner) and

19 Mar 2025 · Circular economy

Meeting with Dan Jørgensen (Commissioner) and

18 Mar 2025 · Metals

Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and European Chemical Industry Council and

14 Mar 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Bertrand L'Huillier (Cabinet of Executive Vice-President Stéphane Séjourné) and

12 Mar 2025 · Exchange of views on the Steel and Metals Action Plan

Meeting with Paul Speight (Head of Unit Environment)

11 Mar 2025 · EU chemicals regulation/ REACH

Meeting with Radan Kanev (Member of the European Parliament) and CEMBUREAU - The European Cement Association and

6 Mar 2025 · European Energy Forum- Energy intensive industries

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

5 Mar 2025 · Introductory meeting with the new Secretary-General of Eurometaux

Eurometaux urges focus on existing laws over new regulation

4 Mar 2025
Topic — This consultation addresses European water resilience, scarcity, and multi-sectoral management strategies.
Message — The industry requests better enforcement of existing rules rather than introducing new legislation. They favor financial incentives for innovation over penalties and call for regional specificities to be respected.12
Why — Maintaining current rules prevents regulatory burdens that could disrupt domestic raw material supplies.3
Impact — Environmental advocates may see weaker protections if non-deterioration rules are softened through exemptions.4
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Meeting with Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

4 Mar 2025 · Non-Ferrous Metals - Safeguarding the EU industry

Meeting with Valdis Dombrovskis (Commissioner) and

4 Mar 2025 · Competitiveness and Simplification

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

13 Feb 2025 · Omnibus on sustainability

Meeting with Lucie Šestáková (Cabinet of Commissioner Jozef Síkela), Riccardo Rossi (Cabinet of Commissioner Jozef Síkela)

10 Feb 2025 · Critical Raw Material

Meeting with Giorgio Gori (Member of the European Parliament, Rapporteur) and The European Steel Association and

5 Feb 2025 · Exchange of views on resolution on energy intensive industries with the Alliance of energy-intensive industries

Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur) and The European Steel Association

3 Feb 2025 · Surface water and groundwater pollutants

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and European Aluminium AISBL and International Copper Association Europe

29 Jan 2025 · End of life vehicles

Meeting with Ditte Juul-Joergensen (Director-General Energy) and European Chemical Industry Council and

28 Jan 2025 · Competitiveness, Clean Industrial Deal and energy and their impact on European industry.

Meeting with Sara Matthieu (Member of the European Parliament)

21 Jan 2025 · Eurometaux event: Sustainable Raw Materials in the Circular Economy Act and Green Deal

Meeting with Radan Kanev (Member of the European Parliament)

21 Jan 2025 · Eurometaux dinner

Meeting with Eero Heinäluoma (Member of the European Parliament)

21 Jan 2025 · Dinner event

Meeting with Virgil-Daniel Popescu (Member of the European Parliament)

21 Jan 2025 · aluminum production - priorities and issues

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

21 Jan 2025 · General exchange on the Critical Raw Material Act

Meeting with Manuela Ripa (Member of the European Parliament)

21 Jan 2025 · Critical Raw Materials

Meeting with Kathleen Van Brempt (Member of the European Parliament)

21 Jan 2025 · De Europese metaalsector en handelsbeschermende maatregelen

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)

21 Jan 2025 · Clean industrial deal

Meeting with Claudiu-Richard Târziu (Member of the European Parliament)

21 Jan 2025 · Metals Day bilateral meeting

Meeting with Borys Budka (Member of the European Parliament, Committee chair)

21 Jan 2025 · Critical Raw Materials Act high-level MEP dinner

Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and

17 Jan 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Eurometaux urges legal clarity on green tech free allocation

9 Jan 2025
Topic — This consultation updates rules for adjusting free emission allowance allocations based on activity level changes.
Message — Eurometaux requests a provision clarifying that free allocation is not reduced when using clean technologies. They also suggest expanding the list of qualifying carbon-reduction criteria in future guidance documents.12
Why — This ensures companies retain financial support while cutting emissions through new technologies.3
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Meeting with Pietro Fiocchi (Member of the European Parliament)

5 Dec 2024 · Problematiche ambientali

Meeting with Peter Liese (Member of the European Parliament) and BASF SE and

4 Dec 2024 · Austausch

Response to Establishment of the CBAM Registry

26 Nov 2024

Please refer to Eurometaux's position paper attached providing the position and main recommendations of the non-ferrous metals industry on the Commissions draft Implementing Regulation on the CBAM registry. Moreover, you'll also find in the attachment a separate Joint Paper by CBAM sectors discussing the intransparency of the CBAM Registry vs ETS Registry in greater detail. We welcome the Commissions initiative to set up the framework for the establishment of an electronic database to manage a variety of CBAM-related elements, such as CBAM declarations and accredited CBAM verifiers the CBAM registry. The position paper attached identifies certain inconsistencies in the draft text establishing the CBAM registry while providing respective solutions for the issues identified. We have pinpointed various elements of the draft Implementing Regulation that could benefit from refinement and present the relevant recommendations in the position paper attached to enhance its effectiveness and comprehension: 1. Responsibility for communicating decisions on penalties; 2. Legal clarity in Article 10; 3. Defining business continuity plan"; 4. Unclear balance between data confidentiality and data sharing. Please see Eurometaux's paper attached for a full explanation and relevant recommendations to fix the issues identified above.
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Eurometaux demands clearer rules for authorized CBAM declarant status

26 Nov 2024
Topic — Procedures and conditions for authorizing declarants under the Carbon Border Adjustment Mechanism.
Message — Eurometaux calls for precise definitions of expert entities and clearer rules on application deadlines. They recommend establishing a mandatory minimum response time for companies facing authorization rejections.123
Why — Metal importers would gain greater legal certainty and avoid arbitrary response windows during applications.45
Impact — National authorities would lose the discretion to impose extremely short response periods on applicants.6
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Eurometaux urges swift adoption of new battery waste codes

8 Nov 2024
Topic — A revision of the European List of Waste concerning battery chemistries.
Message — The group wants the EU to quickly adopt new codes for batteries and black mass. They request harmonized rules and customs alignment to prevent materials from leaving Europe.12
Why — This ensures valuable strategic materials stay in Europe for domestic recycling.3
Impact — Non-EU processors lose access to critical materials currently leaked from European markets.4
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Eurometaux urges improvements to battery recycling efficiency methodology

18 Oct 2024
Topic — This consultation defines methodologies for calculating and verifying battery recycling efficiency rates.
Message — Eurometaux requests clarifying the 'first recycler' definition and updating reporting templates to include upstream data. They suggest basing reporting on processing cycles rather than calendar years.123
Why — Flexible reporting prevents technical underreporting during complex, multi-year metal refining processes.4
Impact — Non-EU recyclers face stricter regulatory hurdles through mandatory verification of equivalent conditions.5
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Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

16 Oct 2024 · Surface water and groundwater pollutants

Meeting with Christian Ehler (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

4 Oct 2024 · Clean Industrial Deal

Response to Negotiations with Bahrain, Kuwait, Oman, Qatar, Saudi-Arabia and United Arab Emirates

30 Sept 2024

Eurometaux, the non-ferrous metal association, welcomes the opportunity to provide feedback on this Commissions Call for Evidence. Eurometaux supports the objectives of the EU Critical Raw Material Act to diversify supplies of critical raw materials and develop local raw materials supply chains. In light of this, we call on the EU Commission to build on the following points when negotiating new trade agreements with the Gulf countries: 1. Ensure a tailored approach to tariff liberalisation of critical raw materials. It is of high importance to pay careful attention to the EUs existing industrial capacity for critical raw materials when negotiating new partnerships with third countries. Specifically, the EU Commission should distinguish those critical raw materials for which the priority is to preserve the European manufacturing industry (i.e. aluminium, silicon, base metal mining), and those for which there is a lack of industrial capacity in Europe. In the specific case of aluminium, for which there is already an established production in Europe, the EU must avoid unjustified tariff liberalisation on Chapter 76 (aluminium). The aluminium industry has a robust value chain in place in Europe that includes primary production, semi-production, and recycling. In addition, the competitiveness of the European aluminium industry is still suffering from the energy crisis and the overcapacities of some third countries (i.e. China) that dominate the supply chain of critical raw materials. Therefore, the removal of import duties on aluminium (i.e. primary aluminium) would impair the European aluminium industry operations and resilience. Differently, for all those raw materials that the EU does not have an adequate production system, the liberalisation of existing trade tariffs may in a case-by-case approach be necessary to secure a stable and diversified supply chain and reduce EU critical raw materials dependencies (for example, certain battery raw materials). 2. Include clear environmental and human rights standards. The EU Commission should take the EU sustainability standards as the benchmark in the negotiations of future trade agreements with the Gulf Region. The high carbon footprint related to the production of some raw materials (i.e. aluminium) in the region makes it crucial to include clear sustainability provisions and binding clauses on climate, chemicals, and circularity objectives in these bilateral partnerships with the Gulf States. This will safeguard the EUs climate objectives and support EU companies' efforts to decarbonise. The inclusion of these standards should be guided by internationally recognized human rights and environmental standards, including those contained in the OECD MNE Guidelines, the UN Guiding Principles, the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work (Core Labor Standards). 3. Promote fair competition for EU companies. A level playing field should be ensured between the EU and the Gulf region to allow EU businesses to benefit from these potential partnerships. The competitiveness of the EU companies still faces several challenges due to high energy costs worldwide and unfair trade practices such as illegal subsidies and export restrictions. The low energy prices and widespread use of government subsidies in the Gulf region may further jeopardise the EU industry since they give the Gulf countries a competitive advantage. In order to ensure that the EU industry fully benefits from these initiatives, EU authorities should take necessary measures to ensure that EU companies can compete on equal footing with businesses from the Gulf Region. This will allow the EU industry to expand its exports to the Gulf states and increase investment opportunities through strategic projects in critical raw materials. Eurometaux would like to ask for a constructive engagement with the EU Commission during the trade negotiations with the Gulf countries.
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Response to Commission Roadmap to phase out animal testing

27 Sept 2024

We fully support the efforts of the Commission to develop alternatives to animal testing in general and believe that the roadmap will help making the link between the developed assays or methods and their regulatory use and acceptance. Use and acceptance will be crucial to reach the ambition of accelerating chemicals safety assessments and lowering the burden for all actors. To facilitate this, clearly identifying the regulatory relevance of the developed alternative approaches, their scope and applicability, but also ensuring that the results are generated by internationally accepted protocols (e.g. OECD or EU Test Methods) will be key. Metals may have different properties or specificities that may limit the applicability of some tests. We would like to ask to pay attention to the scope and applicability of the alternatives before those are taken up in regulatory schemes, insisting if need so to have further validations for non-organic substances/materials. For metals and inorganics, we have to date, quite some quality animal data, generated for previous regulatory requirements, we would like to continue to use as they form the basis of a reliable assessment, without these existing data being overruled by new assays. For complex endpoints, at this stage, we still see the importance to consider animal data as the non-animal assays available to date offer an incomplete picture of toxicity. However, these assays may help -in association e.g., with exposure considerations -to perform screening and focus testing, understand better the mechanism of action, etc. We are also doing significant efforts on our side to develop and assess alternatives. We have proposed in chemico metal release tests that can support grouping in a weight-of-evidence or better reflect the hazard of complex materials. We are also evaluating the published methods. For example we investigate for now the QICAR as possibility to perform screening. To conclude, we believe that whatever the source of the data, the most important is to ensure their reliability, relevance and robustness to perform good quality regulatory activities. We believe the roadmap can support this ambition.
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Meeting with Hildegard Bentele (Member of the European Parliament)

16 Sept 2024 · Mining Policy

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and The European Steel Association

9 Sept 2024 · Discussion on Transition Pathway for Metals

Meeting with Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

22 Jul 2024 · Meeting with Eurometaux on new State Aid Guidelines for Critical Raw Materials

Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

3 Jul 2024

Eurometaux and EuRIC jointly call upon the European Commission to reconsider its assessment of the alignment of the WSR 1013/2006 with the new e-waste entries under the Basel Convention and to do it only for WSR 2024/1157 where we also suggest to create an intra-EU waste code for non-hazardous waste for which the information procedure (WSR Annex VII) is maintained. From now until May 2026, when the Art. 27 under the WSR 2024/1157 has to be fully implemented, we shall focus on preparing and introducing the EU digitalised system (EDI) for electronic submission of documents and more harmonised and streamlined procedures by notifiers and competent authorities. For more details see the joint paper.
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Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste

3 Jul 2024

Eurometaux and EuRIC jointly call upon the European Commission to reconsider its assessment of the alignment of the WSR 1013/2006 with the new e-waste entries under the Basel Convention and to do it only for WSR 2024/1157 where we also suggest to create an intra-EU waste code for non-hazardous waste for which the information procedure (WSR Annex VII) is maintained. From now until May 2026, when the Art. 27 under the WSR 2024/1157 has to be fully implemented, we shall focus on preparing and introducing the EU digitalised system (EDI) for electronic submission of documents and more harmonised and streamlined procedures by notifiers and competent authorities. For more details see the joint paper attached.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

18 Apr 2024 · Speaker at "2030 resilience: An industrial agenda for achieving Europe's Critical Raw Materials goals"

Meeting with Hildegard Bentele (Member of the European Parliament)

18 Apr 2024 · Panel with MEPs from other groups on "EU Elections debate: Getting Europe back in the global race for clean tech supply chains"

Eurometaux demands strict quality standards for chemical data platform

3 Apr 2024
Topic — The Commission is creating a common platform to share data for chemical safety.
Message — The group calls for transparent standards to verify data quality. They also request clear substance identification guidelines for different metal forms. Finally, they urge a nuanced approach to prevent oversimplifying complex scientific evidence.123
Why — This allows the industry to verify regulatory data against their own specialized metallic databases.4
Impact — Policymakers and users risk taking incorrect actions based on oversimplified early warning indicators.5
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

23 Feb 2024 · Soil Law

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and European Aluminium AISBL

8 Feb 2024 · Physical meeting - Exchange on CBAM

Response to Amendment of the free allocation rules in response to the ETS revision/Fit For 55

20 Dec 2023

Document containing Eurometaux position on Free Allocation Rules regulation attached.
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Eurometaux Advocates REACH Alignment for New Vehicle Regulations

4 Dec 2023
Topic — European initiative to improve vehicle recycling collection and circular car design.
Message — The association requests using REACH for substance assessments to ensure a coherent regulatory approach. They support mandatory component dismantling before shredding to maximize the quantity of metals recovered. Furthermore, they demand that non-EU recycling facilities meet strictly equivalent environmental standards.12
Why — Streamlined regulations and mandatory dismantling would reduce compliance overlaps and secure raw materials.3
Impact — Non-EU recycling operations face stricter market entry barriers if they lack equivalent standards.45
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Meeting with Maroš Šefčovič (Executive Vice-President) and

30 Nov 2023 · Clean Transition Dialogue on Energy Intensive Industries

Response to Drinking water - establishing the European Positive Lists of starting substances

16 Nov 2023

The non-ferrous metals industry recognises the need to protect the drinking water quality and the health of the citizen in the EU. We are committed to continuously improve our materials to prevent, control, reduce and eliminate pollution as far as possible to protect human health and the environment. We support the process regulated under the Drinking Water Directive (2020/2184). As a sector, we are actively engaged at all levels, political, and with the Member States, to improve drinking water quality through improved science and innovation. We welcome the opportunity to provide feedback on the recent Commission implementing decision laying down rules for the application of Directive (EU) 2020/2184 of the European Parliament and of the Council by establishing the European positive lists (EUPL) of starting substances, compositions and constituents authorised for use in the manufacture of materials or products that come into contact with water intended for human. Below are our feedback and recommendations to ensure the science robustness and transparency of this new legislation: Key recommendations: Include all, in use, lead-containing alloys in those eligible for a transitional period, provided that these alloys comply with national regulations and thresholds. The transitional period should be extended to allow industry to adapt. Include the dezincification resistant (DZR) brass materials on the EUPL. Lead content in Galvanized steel should be 0.02 instead of 0.01 to align with maximum limit impurities. The allocation factor for lead leaching from material to water should be increased from 50% to 90%. More detailed information are in the document attached. Overall, Eurometaux continues to emphasise the commitment of the non-ferrous metals industry to ensure good drinking water quality in the EU. Thank you for the attention you will give to our comments, we welcome any opportunity for us to provide additional information.
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EUROMETAUX calls for site-specific standards in Soil Monitoring Law

3 Nov 2023
Topic — The consultation addresses the proposed EU directive for monitoring and restoring soil health.
Message — They request site-specific indicators and reject the 'one-out-all-out' principle for unhealthy soil. The industry asks to exclude mining and installations regulated by the Industrial Emissions Directive. They propose that companies manage risk assessments based solely on current land use.123
Why — This would reduce administrative costs by avoiding overlapping rules and protecting mining operations.4
Impact — Environmental groups lose protections if soil monitoring excludes industrial sites and future land-use risks.5
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

18 Oct 2023 · Discuss Transition Pathway for the metals sectors

Meeting with Pascal Canfin (Member of the European Parliament) and Stellantis and

28 Sept 2023 · Green Deal

Eurometaux urges sub-installation approach for EU climate-neutrality plans

1 Sept 2023
Topic — EU regulation on climate-neutrality plans for granting free emission allowances.
Message — The organization requests three changes: apply climate-neutrality plans at sub-installation level rather than installation level, base targets on measures and investments instead of emissions reduction, and clarify that plans apply only to installations under product benchmarks.123
Why — This would avoid disproportionate penalties for installations where only one sub-installation underperforms.45
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Eurometaux opposes stricter cost thresholds for emissions monitoring

21 Aug 2023
Topic — EU update to rules for monitoring and reporting greenhouse gas emissions under ETS.
Message — The organization requests that cost thresholds in Article 18 remain unchanged. They argue the proposed increases - quadrupling the reference price to EUR 80 per allowance and doubling improvement costs to EUR 4,000 - lack adequate justification and would increase operational burdens while limiting operators' ability to claim unreasonable costs.123
Why — This would preserve their ability to avoid costly monitoring upgrades under current economic pressures.45
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Eurometaux urges clarity on proposed hazardous chemical export ban

31 Jul 2023
Topic — The EU plans to prohibit exporting hazardous chemicals already banned within its borders.
Message — Eurometaux demands a clear distinction between substance bans and restricted uses. They insist that intermediate uses should stay exempt from export prohibitions.12
Why — This ensures European metal producers maintain a competitive level playing field globally.34
Impact — Non-EU nations lose access to materials essential for climate and digital technologies.5
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Eurometaux demands EU formalize environmental footprint methodology

20 Jul 2023
Topic — A proposed directive requiring companies to verify environmental claims using standardized methods.
Message — The organization requests integrating the Product Environmental Footprint methodology directly into the directive. They also argue that hazardous substances shouldn't automatically disqualify products from green claims.12
Why — Using these standards allows the industry to market essential green-transition metals.34
Impact — Environmental groups lose if hazard-based bans on green claims are weakened.5
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Meeting with Dimitri Lorenzani (Cabinet of Vice-President Maroš Šefčovič) and International Copper Association Europe and

7 Jul 2023 · Critical Raw Materials Act

Response to European Critical Raw Materials Act

29 Jun 2023

Please find attached the non-ferrous metals industry improvement areas to the Commission proposal for a Critical Raw Materials Act.
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Meeting with Helmut Geuking (Member of the European Parliament)

7 Jun 2023 · Directive on Corporate Sustainability Due Diligence (CS3D)

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur)

31 May 2023 · Forced Labour

Meeting with Raphaël Glucksmann (Member of the European Parliament, Shadow rapporteur)

31 May 2023 · APA level - Forced labour

Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

The European non-ferrous metals industry, represented by Eurometaux, delivers primary and secondary raw materials for the green and digital transitions. Metals are present in various products, including those listed in the 2020 Circular Economy Action Plan (CEAP) as key value chains namely, electronics and ICT, batteries and vehicles, packaging, textiles, construction and buildings. Our key asks for the ESPR consultations are as follows: Substances of Concern (SoC) The ESPR should avoid overlap with EU chemical legislation. It should not restrict the presence of substances in products for reasons relating to chemical safety and hazard, without exposure and risk considerations. The SoC definition should be coherent with approaches proposed under different legislations and initiatives to protect consumers, e.g. CSS, and should not inhibit recycling. Recycled content This measure should be applied to materials for which the uptake from secondary sources is not mature yet. It should be accompanied by an adequate policy framework to boost collection and sorting of metals-containing products and guaranteeing high-quality recycling, ensuring that enough recycled material is available in Europe. Life cycle assessment The use of life cycle assessment to evaluate the environmental performance of products is key. The end-of-life recycling benefits of metals, their permanent properties and performance during their service lifetime must be properly taken into account. Product design rules The ESPR should bring improvements where needed across different product groups and where specific product-rules are not established or when they dont sufficiently address the sustainability aspects. Coherent EU policy framework The EUs product policy should integrate the different dimensions of sustainability across the full product life cycle, taking advantage of on-going and future legislative processes revising existing or setting new EU rules (e.g. CS3D, REACH, CPR, ELV, PPWD, Critical Raw Materials Act)
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Meeting with Henrike Hahn (Member of the European Parliament, Shadow rapporteur) and Rud Pedersen Public Affairs Brussels and International Copper Association Europe

9 May 2023 · Speaker at a Panel Debate : Critical Raw Materials “Driving European raw materials investment and competitiveness”

Meeting with Christian Ehler (Member of the European Parliament, Rapporteur)

9 May 2023 · NZIA

Meeting with Sara Matthieu (Member of the European Parliament, Shadow rapporteur)

9 May 2023 · Eurometaux event - Sustainable raw materials: from the mine to circularity

Meeting with Anna-Michelle Asimakopoulou (Member of the European Parliament, Rapporteur for opinion)

9 May 2023 · Exchange of Views

Meeting with Susana Solís Pérez (Member of the European Parliament)

9 May 2023 · Future of industrial policy meeting held by parliamentary assistant

Meeting with Nicola Beer (Member of the European Parliament, Rapporteur)

9 May 2023 · Critical Raw Materials Act (Meeting held by parliamentary assistant)

Eurometaux urges inclusion of copper in EU green investment rules

2 May 2023
Topic — This initiative establishes a classification system for environmentally sustainable economic activities for investment purposes.
Message — The group requests adding copper manufacturing criteria as a blueprint for other metals. They also want more flexible rules for chemicals used in electronics and green technologies.12
Why — This would unlock sustainable financing and prevent their products from being disqualified by overly strict regulations.34
Impact — Health and environmental advocates lose if safety restrictions on hazardous substances are loosened to support industrial growth.5
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Eurometaux pushes for copper inclusion in EU green taxonomy

2 May 2023
Topic — The consultation defines environmental criteria for the EU's sustainable investment classification system.
Message — Eurometaux requests the prompt inclusion of copper manufacturing to facilitate investment in strategic raw materials. They also argue for less restrictive rules regarding substances of very high concern in electrical equipment.12
Why — This would unlock sustainable financing for metals and minimize administrative burdens for manufacturers.34
Impact — Environmental groups lose stricter hazard-based protections against toxic substances in electronic products.5
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Meeting with Kadri Simson (Commissioner) and

27 Apr 2023 · Electricity market design.

Eurometaux urges science-based chemical rules and flexible labeling

30 Mar 2023
Topic — The consultation addresses the revision of EU chemical classification and labeling regulations.
Message — The group requests that hazard identification remains based on scientific data and clear guidance. They argue that labeling requirements should remain in guidance rather than strict law.123
Why — This would reduce compliance costs by avoiding the need for new labeling software.4
Impact — Consumers would lose improved label legibility if current formatting rules remain unchanged.5
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Meeting with Dan-Ştefan Motreanu (Member of the European Parliament, Shadow rapporteur) and International Copper Association Europe and International Zinc Association

21 Mar 2023 · Water framework Directive andEnvironmental Quality Standards Directive and Groundwater Directive

Meeting with Milan Brglez (Member of the European Parliament, Rapporteur) and European Precious Metals Federation and International Zinc Association

20 Mar 2023 · Water legislation

Eurometaux urges 2040 delay for new air quality standards

14 Mar 2023
Topic — The Commission is revising air quality standards to align with WHO health recommendations.
Message — The industry wants to delay new limit values until at least 2040. Metal standards should remain non-binding target values to account for natural background levels. They also oppose new health-related compensation schemes for legal reasons.12
Why — Delaying targets avoids disproportionate investment costs for technically difficult emission reductions.34
Impact — Health and environmental groups lose as stricter pollution limits are postponed for decades.5
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Eurometaux urges risk-based standards for EU water pollutant lists

14 Mar 2023
Topic — The European Commission is revising the list of pollutants affecting surface and groundwaters.
Message — Eurometaux recommends a formalised dialogue between regulators and experts and an unambiguously risk-based approach for quality standards. They also call for robust socio-economic impact assessments and maintaining the ordinary legislative procedure for revisions.123
Why — Economic impact assessments and procedural predictability would help the industry minimize new compliance costs.45
Impact — Environmental advocates face a slower and more complex process for restricting dangerous water pollutants.6
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Kurt Vandenberghe (Director-General Climate Action)

22 Feb 2023 · The non-ferrous metals industry

Meeting with Henrike Hahn (Member of the European Parliament) and PowerShift - Verein fuer eine oekologisch-solidarische Energie- Weltwirtschaft e.V.

10 Feb 2023 · Raw Materials & Green Transition

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager)

9 Feb 2023 · Green industrial plan, raw materials

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

26 Jan 2023 · Critical Raw Materials

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

25 Jan 2023 · Corporate Sustainability Due Diligence

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Eurometaux urges harmonised approach for EU forced labour ban

30 Nov 2022
Topic — A proposed regulation to ban products made with forced labour from the market.
Message — Eurometaux calls for a harmonised approach with existing industry standards to avoid bureaucracy. They request clear product categories and time to remedy violations before products are banned.123
Why — This alignment would reduce compliance burdens and protect mining investments in high-risk regions.456
Impact — Vulnerable workers could suffer if responsible companies withdraw and are replaced by lower-standard firms.7
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Response to European Critical Raw Materials Act

24 Nov 2022

The Critical Raw Materials Act is Europes unmissable opportunity to catch-up in the global race for metals and minerals supply. Europes energy and mobility systems will completely transform over the next decade, supercharged by the REPowerEU plan and 2035 internal combustion engine ban. EU demand for base metals, battery materials, rare earths, and more will rise strongly as it builds-up local production of batteries, solar panels, permanent magnets, and other clean tech. But Europe will lose out to China and the US without a decisive plan for securing its own supply. Europes metals industry calls on the European Commission to deliver a truly ambitious Critical Raw Materials Act that kickstarts a rethink of the EUs industrial strategy for its clean energy supply chains: 1. Equal the ambition of Europes international competitors: Europe is now in competition with the US Inflation Reduction Act and its subsidies and tax incentives for local supply chains. The Critical Raw Materials Act must deliver 2030 headline goals and targeted market measures that will offer at least a comparable incentive for new investments building up sustainable European raw materials supply chains. 2. Catalyse European investment through permits, finance, and frameworks: The Critical Raw Materials Act should prioritise actions to push forward EU mining, processing, and recycling projects, to establish a minimum level of strategic autonomy with high environmental and social responsibility. This must be accomplished while avoiding a contraction of Europes electricity-intensive capacity in the wake of the energy crisis. 3. Secure responsible and fair imports from prioritised resource-rich partners: Europe will remain reliant on imports to supply its medium-term growth in the next 15 years, even with a successful domestic investment strategy. The Critical Raw Materials Act must also include a much stronger global strategy for securing responsible imports, which avoids an overdependence on single suppliers and addresses trade distortions. 4.Make Europe the global leader for high-quality metals recycling: Recycling will be Europes key long-term opportunity to establish metals strategic autonomy, especially after 2040 once the first generation of clean energy technologies reach end-of-life in significant volumes. The EU must act now to grow its recycling industry into a leadership position, facing high global competition from other regions. Eurometaux also supports that the Critical Raw Materials Act: 1) Coordinates national agency efforts through an EU Raw Materials Agency or other cooperation 2) Prioritises that the European market is supplied by environmentally & socially responsible metals and minerals, linking coherently to due diligence policies and benchmarking the available global certification schemes without preference for just one
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Meeting with Seán Kelly (Member of the European Parliament) and European Energy Forum

22 Nov 2022 · Dinner Debate: Energy Crisis: causes, consequences & win-win solutions

Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

It is said that for every 1 tonne of e-waste Europe recycles, 2 tonnes are a lost opportunity. Therefore, Eurometaux representing the European non-ferrous metals producers and recyclers is calling for actions to establish a level playing field for high-quality recycling. Our key recommendations: WEEE collection: Encourage Member States to increase separate collection of e-waste supported by actions targeting citizens to properly dispose of WEEE. Level playing field conditions: Make the standard EN 50625 on WEEE collection, logistic and treatment and its Technical Specifications legally binding under the WEEE Directive. Coherence of the EU raw materials, chemicals, product & waste legislation: Ensure coherence between on-going & future EU policies developments to maximise circularity and value of metals extracted from e-waste. For more details, please consult the attached document.
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Eurometaux urges scientific clarity in new endocrine disruptor classifications

18 Oct 2022
Topic — Revision of the CLP Regulation to introduce new hazard classes for endocrine disruptors.
Message — Eurometaux requests removing the suspected category and requires proof of causality for classifications. They urge alignment with international standards and specific assessment frameworks for metals.12
Why — This prevents metals from being restricted due to secondary or non-specific biological reactions.3
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

17 Oct 2022 · Corporate Sustainability Due Diligence

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Eurometaux calls for industry expertise and budget reforms in ECHA

10 Oct 2022
Topic — The Commission is updating the European Chemicals Agency's governance and funding framework.
Message — Eurometaux proposes delaying the regulation until chemical laws are revised to ensure efficiency. They want industry experts included and independent reviews of committee opinions.123
Why — Switching to EU budget funding would provide companies with financial predictability and stability.45
Impact — Free-riding companies would lose their cost-sharing advantage through a registration token system.6
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

6 Sept 2022 · Transition to a circular economy, availability of metals and overview of KU Leuven’s Metals for Clean Energy study findings

Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton), Joan Canton (Cabinet of Commissioner Thierry Breton)

5 Sept 2022 · Energy market situations and decarbonisation plans

Eurometaux backs chemical data sharing while protecting business secrets

16 Aug 2022
Topic — The European Commission is proposing new rules to improve access to and reuse of chemical safety data.
Message — Eurometaux supports consistent data reuse under the 'One Substance One Assessment' principle. They call for simple notification mechanisms that avoid unnecessary delays and protect confidential business information. Industry stresses that data owners' rights must be respected when implementing open data policies.123
Why — Streamlined data sharing would lower administrative costs and prevent redundant testing for metal producers.45
Impact — Regulators and the public may face limited transparency to protect industrial property rights.6
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Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager) and European Association of Mining Industries, Metal Ores & Industrial Minerals and

25 Jul 2022 · Raw materials.

Eurometaux urges flexible emissio n limits to p rotect indus trial resilie nce

23 Jun 2022
Topic — The European Commi ssion is rev ising rules t o reduce ind ustrial pollu tion and was te.
Message — Eurometaux argue s that emiss ion limits mu st remain fle xible to refl ect local con ditions. They oppose manda tory long-ter m transformat ion plans and suggest that innovation c annot be forc ed.12
Why — This approac h would reduc e compliance costs and pro tect sensitiv e company inf ormation from public discl osure.34
Impact — Environme ntal group s and local c ommunities l ose guarantee d access to the most strin gent polluti on protectio n standards.5
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Eurometaux urges alignment of forced labour ban with existing rules

20 Jun 2022
Topic — Commission initiative to prohibit products made with forced labour on the EU market.
Message — Eurometaux requests the new ban be aligned with existing supply chain rules to ensure consistency. They also seek clear guidance for businesses on compliance and enforcement.12
Why — Alignment would reduce regulatory complexity and protect the industry from excessive compliance costs.34
Impact — Conflict-affected regions may lose vital investment if companies flee to avoid regulatory risks.5
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans) and Katholieke Universiteit te Leuven

15 Jun 2022 · Metals and clean energy

Meeting with Alejandro Cainzos (Cabinet of Executive Vice-President Margrethe Vestager), Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager)

14 Jun 2022 · Critical raw materials.

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

9 Jun 2022 · To share five key recommendations from the landmark KU Leuven Metals for Clean Energy study released last week, which quantifies the metals and raw materials needs of Europe's climate-neutrality goal for the first time.

Eurometaux urges more realistic circular economy monitoring framework

3 Jun 2022
Topic — The EU is revising the framework used to assess progress towards circularity.
Message — The industry requests that monitoring relies on official Eurostat data for better comparability. They also argue against mandatory recycled content targets without a robust methodology and impact assessment.123
Why — Focusing on recycling efficiency rather than content targets helps maintain their global competitiveness.45
Impact — Waste exporters and foreign processors face higher costs from mandatory facility certification requirements.6
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

23 May 2022 · ETS

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 May 2022 · Metals for Clean Energy

Eurometaux urges faster permitting and cross-border renewable power support

12 Apr 2022
Topic — EU guidance to speed up renewable energy permitting and facilitate Power Purchase Agreements.
Message — The industry wants uniform permitting rules and priority grid connection for energy-intensive sectors. They also request support for firming costs and multiannual cross-border transmission rights.123
Why — Securing long-term renewable contracts would lower financial risks and prevent industrial smelter closures.45
Impact — Regional authorities and local communities lose their influence over projects due to fast-tracked approvals.67
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

11 Apr 2022

Many thanks for the possibility to provide a contribution to the Call for Evidence on the rationalisation of the use of expertise and resources in view of the OSOA principle. Please find attached Eurometaux's submission.
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Eurometaux calls for specialized metal and inorganic testing rules

7 Apr 2022
Topic — The European Commission is updating internationally agreed test methods for REACH chemical regulations.
Message — The organization proposes including the OECD 29 guidance for testing metal dissolution in water. They argue that metals require specific adaptations to ensure that test results are relevant.12
Why — Adopting these methods allows the industry to use more accurate standards for metal classification.34
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Response to Instrument to deter and counteract coercive actions by third countries

31 Mar 2022

Please find attached Eurometaux's feedback on: Trade – mechanism to deter & counteract coercive action by non-EU countries.
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Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

The non-ferrous metals industry recognises the need to take soil protection, the sustainable functions and use of the soil and restoration of soils to a balanced level within the EU. We are committed to continuously improve our production performance to prevent, control, reduce and eliminate pollution as far as possible to protect human health and the environment. We support the process regulated under the New Soil Strategy. As a sector, we are actively engaged at all levels, political, and with the Member States, to improve soil health through improved science and better monitoring. We welcome the opportunity to comment on the call for evidence for an impact assessment on the Soil Health legislation. Below are our key recommendations to ensure the science robustness and transparency of this exercise. Key recommendations: The EU Soil Health law should: - Ensure healthy and resilient soils capable of providing their crucial ecosystem functions and services; - Be based on sound scientific knowledge and a risk-based approach for sustainable soil use; - Be based on cost-effectiveness and cost-benefit analysis; - Consider the differences in local conditions (soil type, geogenic background concentrations, climate…); - Consider the bioavailability of metals in soil and sediments as it is a key factor to ensure an effective and ecologically relevant approach in risk evaluation and risk management of soil pollution and contamination; - Consider the other legislations in place/coming to tackle other environmental challenges (such as climate change); - Use available data and expertise (e.g. on effects, risks, SEA) gathered in the framework of other European legislations (e.g. REACH, Fertiliser Product Regulation); - Contribute to a better dissemination of the existing knowledge on the state of soils in Europe; - Use publicly available data or anonymise those data that are not, to guarantee transparency in this legislative process; - Ensure stakeholders involvement through expert working groups, workshops, consultations, … Overall, we continue to emphasise the non-ferrous metals industry’s commitment to achieving a good ecological and chemical status of EU soils and to keep on improving the assessment of risk posed by metals in soils through the most updated scientific knowledge and methods.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

Dear Madam, Dear Sir, Please find herewith Eurometaux' s contribution to the call for evidence: RoHS Review/IA Many thanks
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Meeting with Michael Bloss (Member of the European Parliament) and Agora Think Tanks gGmbH and

8 Feb 2022 · ETS

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur for opinion)

25 Jan 2022 · ETS revision

Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur for opinion)

18 Jan 2022 · EU ETS

Eurometaux demands exclusion of indirect emissions from carbon levy

18 Nov 2021
Topic — The EU is designing a mechanism to prevent carbon leakage from imported goods.
Message — Eurometaux requests excluding electricity-related emissions from the carbon border tax until 2030. They also want to maintain the current compensation system for indirect carbon costs. Additionally, the industry demands a solution to protect the competitiveness of European exports.12
Why — This would allow electro-intensive metal producers to avoid high costs and maintain state aid.34
Impact — Global climate goals suffer as foreign producers avoid carbon prices on their electricity use.5
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Eurometaux urges EU to protect metal industry's competitiveness

8 Nov 2021
Topic — Legislative review of the EU Emissions Trading System to reach 2030 climate goals.
Message — Eurometaux requests using a gradual reduction factor as the sole guide for the emissions cap to avoid market shocks. They advocate for maintaining indirect cost compensation and free carbon allowances until global competitors face reciprocal costs.123
Why — This would shield energy-intensive metal producers from high operational costs and safeguard their global market share.45
Impact — Climate targets are threatened if the reserve is used to prevent price spikes instead of cancelling surplus allowances.6
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Meeting with Kadri Simson (Commissioner) and

14 Oct 2021 · High energy prices and how this is affecting the competitiveness of European companies in the energy intensive sectors.

Eurometaux Urges Protection of Trade Secrets in REACH Update

19 Jul 2021
Topic — The Commission aims to clarify chemical registration requirements by amending REACH technical annexes.
Message — Eurometaux requests that joint registration dossiers do not disclose confidential business information to competitors. They also seek to remove testing requirements based on international methods that do not yet exist.12
Why — This would protect sensitive industrial data and prevent potential breaches of competition laws.3
Impact — Regulators and environmental groups might lack specific details about the composition of nanomaterials.4
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Response to Addressing distortions caused by foreign subsidies

14 Jul 2021

Please find attached Eurometaux's feedback.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and The European Steel Association and

7 Jun 2021 · Carbon Border Adjustment Mechanism

Eurometaux warns REACH revision could threaten green energy transition

1 Jun 2021
Topic — The consultation addresses the revision of EU rules for chemical registration and evaluation.
Message — Eurometaux suggests a tiered approach and focusing on what matters regarding exposure and use. They object to a completely hazard-based approach that ignores how metals are used.12
Why — This would lower compliance costs and protect market access for critical green materials.3
Impact — Environmental advocates lose faster bans on hazardous chemicals in consumer and professional products.4
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Eurometaux urges EU to align chemical hazard classes with global standards

1 Jun 2021
Topic — This consultation addresses proposed revisions to the EU’s chemical classification and labelling regulation.
Message — Eurometaux recommends aligning any proposal for new hazard classes with international standards. They suggest addressing endocrine disruptors through existing chemicals safety rules instead of new categories. They also propose establishing a science appeal potential for classification decisions.123
Why — This would prevent international regulatory inconsistencies and reduce compliance costs for metal producers.4
Impact — European regulators face excessive workloads from evaluating unnecessary new hazard categories.5
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Meeting with Florika Fink-Hooijer (Director-General Environment)

18 May 2021 · Waste legislation: future revisions of Waste Shipment Regulation, Waste Framework Directive and ELV Directive

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

5 May 2021 · Implementation of the chemicals strategy for sustainability

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and The European Steel Association and

3 May 2021 · Carbon Borden Adjustment Mechanism

Meeting with Thierry Breton (Commissioner) and

24 Mar 2021 · Commissioner Breton meeting with CEOs from Energy Intensive Industries on Industrial strategy & fit for 55.

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and

19 Mar 2021 · Due diligence

Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders), Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

18 Mar 2021 · EU Due Diligence in Supply Chains” – Importance of the forthcoming EU legislation for the Non-Ferrous Metals Industry

Meeting with Kitti Nyitrai (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

18 Mar 2021 · European metals industry & industrial electrification in new EU Industrial Strategy

Response to Modernising the EU’s batteries legislation

1 Mar 2021

Eurometaux, representing the European metals industry, recognises the major work ahead to deliver on EU’s ambition for batteries to help achieve the European Green Deal. Our members, producing and recycling battery metals (e.g. aluminium, cobalt, copper, lead, lithium, nickel, zinc), are committed to provide its expertise throughout the legislative process to establish conditions for a competitive and sustainable EU battery value chain. Attached paper presents specific recommendations on a number of issues, including: 1) Responsible and ethical sourcing of battery raw materials – Consider a transparent and pragmatic approach that leverages internationally recognised standards building on existing voluntary due-diligence schemes. Avoid loopholes by applying value chain thinking and maintain a level-playing field with third countries, offering a smart mix of minimum requirements and incentives. 2) Carbon footprint – The use of life cycle assessment to assess the environmental performance of products is fully supported. Preparation of the delegated act for the carbon footprint calculation methodology should follow realistic timelines and capitalise on the work done by industry on the initial and currently reworked PEFCR for High Specific Energy Rechargeable Batteries for Mobile Applications. 3) Chemicals management – Promoting and ensuring the safe use of hazardous substances in batteries should not differ from other applications/uses. Any unnecessary legislative overlap should be avoided by the careful execution of a Risk Management Option Analysis (RMOA) to define the most optimal risk management measure. The procedure must follow a risk-based approach, include a socio-economic assessment (SEA) and, if needed, an assessment of alternatives (AoA) considering economic and technical feasibility. 4) Collection and efficient recycling of waste batteries – Introduce realistic collection targets for portable batteries and prevent leakage of waste batteries. Prioritise actions to promote safe and efficient recycling of metals in batteries. 5) Recycled content – Define a robust methodology and ensure a thorough impact assessment before considering the possibility of introducing the mandatory recycled content targets especially until more information on the evolution of the market is available. In the meantime, effectively implement policy framework boosting collection and sorting of metals-containing products and promoting high-quality end-of-life recycling, ensuring that enough recycled materials is available in Europe. 6) Regulatory coherence – Avoid overlaps/inconsistencies between various policy instruments (REACH Regulation, OSH legislation, ELV Directive) regulating use of hazardous substances in batteries to provide industry with a more predictable regulatory framework essential for securing long-term investments and maintaining metals production in the EU. Remove shortcomings in the existing waste legislation for shipment of waste batteries to pre-consented recycling facilities.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

24 Feb 2021 · Industrial strategy; European Green Deal

Meeting with Valdis Dombrovskis (Executive Vice-President)

4 Feb 2021 · Trade Policy Review, Raw Materials, Rules of Origin, CBAM, Transatlantic trade relations, global overcapacities, challenges linked to the green transition, global level playing field

Eurometaux rejects biomass-based reference for EU carbon benchmarks

4 Jan 2021
Topic — The Commission is determining benchmark values for free emission allocations until 2025.
Message — Eurometaux urges the Commission to continue using natural gas as the benchmark reference. They argue biomass targets are unrealistic and distort the internal market. They also call for expert checks of the aluminum sector data.123
Why — Maintaining gas-based benchmarks avoids massive costs and protects the industry's competitiveness.45
Impact — European regions with limited forest resources face economic disadvantages compared to forested nations.6
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Please find our feedback in the document attached.
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Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton), Joan Canton (Cabinet of Commissioner Thierry Breton) and

14 Dec 2020 · Energy, Industrial strategy, Alliances

Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Please find our feedback in the attached document.
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Eurometaux urges stronger carbon leakage protection in ETS revision

26 Nov 2020
Topic — Review of the EU Emissions Trading System to achieve higher greenhouse gas reduction targets.
Message — The organization calls for strengthened carbon leakage protections, including increased free allowances and indirect cost compensation. They oppose one-off cap reductions and suggest releasing set-aside allowances to prevent price spikes.123
Why — These measures would protect the industry's international competitiveness and lower its regulatory compliance costs.45
Impact — Environmental goals may be undermined if increased allowance supply weakens the incentive for emission reductions.6
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Response to EU Strategic Framework on Health and Safety at Work [2021-2027]

26 Nov 2020

The future EU Strategic Framework on Health and Safety Coherence and early assessments for better protection at work Eurometaux, the voice of the collective European non-ferrous metals industry, fully supports having a strong EU framework for Occupational Safety and Health (OSH) that strives for consistent improvements of the health and safety of workers across Europe. As one of the few industry stakeholders involved in the working procedures of the European Chemicals Agency (ECHA), we would like, for the purpose of this Roadmap consultation, to focus on two elements: 1. Clarifying the interface between REACH restrictions and OSH legislation Eurometaux considers the clarification of the REACH-OSH interface essential to the goal of protecting workers while maintaining the competitiveness of EU’s industries. Building on the Chemicals Strategy for Sustainability’s ‘One Substance – One Assessment’ approach, we recommend the following: • Developing clear criteria for Risk Management Option Analyses (RMOAs) that would allow selecting the most appropriate risk management option and would clarify in which cases OELs are preferred to regulatory risk management under REACH. • Setting up an exchange platform involving REACH authorities (DG GROW and DG ENV), OSH authorities (DG EMPL), the relevant Member States Competent Authorities (MSCAs) for REACH and OSH and stakeholders. 2. Assessing socioeconomics earlier in the process Officially, the Service Level Agreement between DG EMPL and ECHA concerns provisions of “scientific evaluations by RAC” on proposals for OELs, biological limit values, health surveillance measure and/or appropriate notations for candidate substances, which are listed under Directive 98/24 on chemical agents at work and/or Directive 2004/37 on carcinogens and mutagens at work. This excludes de facto any non-scientific consideration by ECHA. Furthermore, although DG EMPL does carry out impact assessments a posteriori, we believe that further considerations should be given to socio-economic aspects upstream in the process when changing or introducing new OELs, i.e. before the Advisory Committee for Safety and Health at Work (ACSH) recommends OEL values to DG EMPL, rather than later in the process when decisions on recommended OEL values have already been taken. This would effectively allow to assess feasibility of OEL values in due time. For further information: Violaine Verougstraete Chemicals Management Director verougstraete@eurometaux.be Tel: +32 2 775 63 27 Noam El Mrabet Chemicals Management Manager noam@eurometaux.be Tel: +32 2 775 63 84
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Eurometaux demands scientific approach to water pollution rules

20 Nov 2020
Topic — The EU is reviewing priority substances and pollutants affecting surface and groundwaters.
Message — Eurometaux requests that the Commission uses the best available science and finalizes technical guidance. They advocate for accounting for natural backgrounds and local environmental conditions in assessments.12
Why — This would reduce regulatory pressure by ensuring metal concentrations are assessed more accurately.3
Impact — Environmental groups may see weaker standards as values vary across different regions.4
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Response to Revision of EU legislation on end-of-life vehicles

19 Nov 2020

The non-ferrous metals industry is one of key suppliers for the automotive sector. Metals are present in the car body (e.g. aluminium), car battery (e.g. lead, lithium, nickel, cobalt, copper), catalytic converter (e.g. platinum, palladium) or motor (e.g. copper) to name just a few applications. The growing trend towards clean mobility, which is one of the elements of the EU Green Deal, will require even higher amounts of metals from primary but more desirably secondary sources. Many of those metals are recycled in high yields from the cars collected in Europe. However, the biggest gap to meet the EU Circular Economy objectives is that one third of all vehicles remains undocumented at the end-of-life. This paper responds to the Roadmap on the End-of-Life Vehicles (ELV) Directive revision and addresses key issues from the perspective of the non-ferrous metals industry. OUR RECOMMENDATIONS • Illegal export – Tackle the problem of ELVs deregistered without a certificate of destruction and enforce controls at the borders to prevent their illicit export to non-EU countries. • Recycling aspects – Improve the flow of ELVs and their parts to European recyclers, through improvements to collection, dismantling and sorting and streamline waste shipments rules. Maximise vehicles dismantling before their shredding. • Coherence of EU legislation – Ensure coherence between the ELV Directive and EU waste legislation, e.g. Waste Framework Directive, Batteries Directive and Waste Shipment Regulation.
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Response to Sustainable Products Initiative

16 Nov 2020

Eurometaux, representing the European non-ferrous metals industry fully supports the transition to a true Circular Economy. Metals are present in various products, including those listed in the Action Plan as key value chains namely, electronics and ICT, batteries and vehicles, packaging, textiles, construction and buildings. Our daily operations not only deliver primary but most importantly secondary raw materials for those applications. We believe that a coherent EU product policy framework will be integral to improving product design, manufacturing, use and end-of-life treatment and will meet the objectives of the EU Green Deal. Our input to the public consultation on the Sustainable Products Policy Initiative Roadmap is presented in the attached document and it reflects on specific issues listed in the document. OUR KEY RECOMMENDATIONS: • An integrated approach to sustainability – A high level of protection of consumers and environment is needed while promoting and maintaining a viable European industry. • Life cycle assessment – The use of life cycle assessment to assess the environmental performance of product is fully supported. The methodology used for setting requirements at product level needs to properly reflect the end-of-life recycling benefits of metals, their permanent properties and performance during their service lifetime. • Product design – A consistent approach is needed when applying EU regulatory material efficiency requirements in product design for sustainability, with an adequate approach to implementation for each product group. • A proportionate approach to “substances of concern” – The Sustainable Product Policy shall ensure safe use while enabling sustainable production and recycling of non-ferrous metals in Europe. It needs to focus on targeted measures to control uses where substances of concern cause actual harmful exposure to health and the environment. • Fostering optimal value chains & industrial symbiosis – A proper understanding of value chain particularities is needed to formulate design-efficient solutions to tackle use of resources and the information flow along the full chain. • Green Public Procurement – Minimum EU requirements to be established based on the life cycle approach and considering mainly sustainability, circularity and climate-neutrality aspects.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

While our industry is committed to continually improve its production performance to prevent, control, reduce and as far as possible eliminate its pollution to human health and the environment, the upcoming Zero Pollution Action Plan should remain coherent with other objectives of the EU. This means that the upcoming Zero Pollution Action Plan must: • Pursue a holistic approach (considering all EU objectives of the Green Deal), promoting technically & economically sound & feasible solutions matching its ambitions • Reinforce existing legislation and implementation, rather than going for new legislation • Remain realistic in its ambition, reflecting industry’s technical realities and historical progress, while maintaining a fair level playing field between sectors • Concentrate on what matters by ensuring the focus remains on the main contributors while targeted additional actions do not challenge those who have already progressed intensely to lower emission levels • Control that new monitoring and outlook tools are science-based and appropriately address uncertainty • Promote cross-cutting initiatives that enhance coherence among industrial and environmental pieces of legislation Key recommendations • Environmental policies need to be proportional and based on scientific and factual evidence and efficiently implemented to support the industrial transition and global competitiveness of EU industry • Improve data collection, better understand and assess emissions and identify the main contributing sources to pollution • Ensure a science-based approach to monitoring activities • Ensure that harmonisation efforts do not overrule the suitability of methods and data used for policy making • Ensure that substances needed for the strategic autonomy and sustainable innovations are not regulated according to their inherent toxicity but according to risk and exposure control • Chemical management policy shall ensure the safe use while enabling the sustainable non-ferrous metals production and recycling in Europe • Support the CSS OSOA approach • Need for an integrated approach to risk management that selects the most effective, proportionate and sustainable combined measures for chemicals management, climate and circularity, that would strengthen each other. The specificities of metals impacting risk assessment/ management should also be taken into account • Ensure that attention for new hazard endpoints such as endocrine disruptors and materials (e.g. nanomaterials) considers selective relevant approaches needed to cover the specific nature of these materials (e.g. metals). • Operational permits should be updated and granted based on a technology driven analysis and a transparent and robust methodology to derive emission limits • Secure the IED’s Integrated Approach and BAT conclusions based on technological and economic feasibility • Ensure proportional emission reduction measures to maintain investment conditions in strategic value chains and secure global competitiveness of EU industry • Integrate local environmental conditions and natural backgrounds when defining EQS values and validating Priority Substances • Apply robust criteria and most up-to-date data and scientific knowledge when assessing the risks posed by metals in water • Ensure justified, proportionate and achievable Ambient Air Quality targets • Achieve improvement of air quality in cost efficient manner without entailing disproportionate burden for industry • Improve the flow of end-of-life products and metals containing waste to EU high-quality recyclers, through improvements made to the collection, dismantling and sorting of waste as well as a streamlining of waste shipment rules • Promote risk-management and safe recycling of hazardous substances in a Circular Economy. Ensure coherence between circularity and chemicals’ objectives • Reward synergies in the transition towards a climate-neutral and circular economy that support valorisation of by-products
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

Europe’s non-ferrous-metals industry is committed to continually improve its production performance to prevent, control, reduce and as far as possible eliminate its pollution to the environment. We welcome the opportunity to provide feedback on the Inception Impact Assessment to the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR) and would like to share several recommendations on the way forward (see attached document). We welcome further discussions and are happy to support you throughout the process as best as possible.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Eurometaux, the European non-ferrous metals industry, has been actively engaged in the European Commission’s Environmental Footprint (EF) project and has developed, during the EF Pilot Phase, the ‘Product Environmental Footprint Category Rules (PEFCR) for Metal Sheets in Various Applications’. Currently, we are also an active stakeholder in the so called Environmental Footprint Transition Phase (2018 – 2021). Our response to the consultation includes our sector’s key recommendations on the issue of substantiating green claims and focuses in particular on the four options announced in the Roadmap. OUR KEY RECOMMENDATIONS: • Creation of a coherent product policy framework – The Commission should create a policy framework that supports the circular economy and sustainability, giving full recognition to materials that have a low environmental impact and at the design stage are fit for circularity supporting the objectives of chemicals, products and waste interface. • Further refinement of Environmental Footprint (EF) method – The Commission should work with stakeholders to revise shortcomings defined during the EF Pilot Phase to make sure that the methodology is robust and does not lead to inappropriate results before it is used in the EU policy. • Harmonise methodologies for calculating environmental impacts – The use of the life cycle assessment (LCA) is fully supported whenever the environmental performance of a product needs to be evaluated. The Commission should further promote robust LCA practice and harmonised methodology in order to avoid green claims proliferation to ensure a high level of consistency and to improve comparability. • No standalone EF tool/label – The EF methodology should complement existing tools after essential developments and corrections are made. Benchmarking and comparison of products should remain voluntary and industry led. For a detailed analysis of the 4 policy options see the attached paper.
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Meeting with Virginijus Sinkevičius (Commissioner) and

16 Jul 2020 · To discuss Circular Economy and issues related to the green and digital transitions and the role of metals in a circular economy.

Meeting with Kadri Simson (Commissioner) and

13 Jul 2020 · European Green Deal, decarbonisation of the non-ferrous metals sector, electricity markets and renewables.

Response to Modernising the EU’s batteries legislation

9 Jul 2020

Eurometaux represents European non-ferrous metals industry. Our sector is the key supplier and recycler of metals for portable, automotive and industrial batteries. The World Bank in 2017 projected that 1000% more metals will be needed for batteries on a global scale. Our industry has a capacity to meet those growing demands provided that an international level playing field and coherent EU regulatory framework are complementing our leading sustainability standards and high circularity. The EU is modernising its battery legislation at an important time, after adopting the Strategic Action Plan on Batteries and announcing the success of the EU Battery Alliance. This process will not only need to address the developments of the battery sector since the 2006 Batteries Directive, but it will also need to embrace the ambition of EU Green Deal and Circular Economy Action Plan to support conditions for a competitive, circular and sustainable EU batteries value chain. Our key recommendations on the ‘Modernising the EU’s batteries legislation’ Roadmap cover the following issues: • RESPONSIBLE AND ETHICAL SOURCING OF BATTERY RAW MATERIALS – consider a transparent approach that follows on from OECD guidelines work and evaluates the issue of ethical sourcing across applications and materials. Examples of industry best practice, including voluntary due diligence schemes and value chain platforms should be considered in parallel. • APPROPRIATE CHEMICALS MANAGEMENT – focus on controlling any potential outstanding risks metals in batteries may pose for human health and the environment, without considering only their hazardous intrinsic properties. Avoid disproportionate chemicals management measures (e.g. bans) that can disrupt the EU battery value chain. • IMPROVED COLLECTION AND EFFICIENT RECYCLING OF WASTE BATTERIES – introduce ambitious collection targets for portable batteries and prevent leakage of waste batteries. Prioritise actions to promote safe and efficient recycling of metals in batteries. • ENSURE REGULATORY COHERENCE – avoid overlaps/inconsistencies between various policy instruments (e.g. Batteries & End-of-Life Vehicles Directives and REACH/OSH) regulating use of hazardous substances in batteries to provide industry with a more predictable regulatory framework essential for securing long-term investments and maintaining metals production in the EU. For more details see the attached position paper.
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Meeting with Maroš Šefčovič (Executive Vice-President)

9 Jul 2020 · Maroš Šefčovič holds a videoconference call with CEO’s from Eurometaux.

Meeting with Cecile Billaux (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)

8 Jul 2020 · trade policy issues concerning the metal industry sector

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

29 Jun 2020 · Discussion to debrief on mining activities and priorities in general

Eurometaux urges risk-based approach to EU sustainable chemicals strategy

19 Jun 2020
Topic — The EU is establishing a new strategy to regulate hazardous chemicals for environmental sustainability.
Message — Eurometaux proposes a management approach integrating chemical safety with climate and circularity goals. They request a streamlined assessment process and risk management based on the specific usage of metals.12
Why — The industry maintains its production capacity by avoiding broad bans on hazardous but essential metals.3
Impact — Environmental groups lose if use-specific exemptions allow hazardous metals to remain in the market.4
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Meeting with Thierry Breton (Commissioner) and

18 Jun 2020 · Impacts of COVID-19

Response to Action Plan on the Customs Union

23 Apr 2020

Dear Sir/Madam, Please find attached Eurometaux's feedback on the Commission's roadmap “Taking the Customs Union to the next level”. Should you have any questions, please do not hesitate to contact me, Yours sincerely, Elena Vyboldina Director International Trade and Economy vyboldina@eurometaux.be Tel : +32 2 775 63 15 Eurometaux – European Metals Association Avenue de Tervueren 168, Box 13 – B - 1150 Brussels EU Transparency register No 61650796093-48 www.eurometaux.eu
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Europe’s non-ferrous-metals industry welcomes the opportunity to provide feedback on the Inception Impact Assessment planning for the Industrial Emissions Directive and would like to share several recommendations on the way forward. Attached you find our considerations regarding the scoping, coherence with other policies as Circular Economy, decarbonisation and water legislation. Resulting from these we propose a set of key recommendations. We hope that you find our suggestions useful. Eurometaux remains fully committed to maintaining a fruitful collaboration in the future stages of the revision process.
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Meeting with Frauke Hoss (Cabinet of Vice-President Maroš Šefčovič) and Wirtschaftskammer Österreich and Nickel Institute

17 Apr 2020 · Chemicals strategy for sustainability

Non-ferrous metal industry prioritizes indirect cost compensation over CBAM

1 Apr 2020
Topic — A consultation on a mechanism to price carbon on imported goods into Europe.
Message — Eurometaux argues that improved indirect cost compensation is the best way to prevent leakage. Any border mechanism must cover the whole value chain without replacing existing carbon protections.123
Why — Preserving aid protects these price-takers from unmanageable electricity price increases and global competition.45
Impact — Poorly designed border taxes would force downstream manufacturers to move production outside of Europe.67
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Response to Climate Law

6 Feb 2020

Please find our input in attachment.
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Meeting with Frans Timmermans (Executive Vice-President)

6 Feb 2020 · Climate neutrality and circular economy

Eurometaux urges EU to secure metal supplies for green transition

20 Jan 2020
Topic — The consultation seeks to accelerate the European transition toward a circular economy.
Message — The group requests that the EU streamlines waste rules and implements stricter export controls. They also advocate for mandatory quality certification for electronics recyclers.123
Why — This would secure their raw material supply while reducing administrative expenses and delays.45
Impact — International scrap buyers lose access to European materials due to tighter export restrictions.6
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Eurometaux warns proposed REACH update deadlines are unrealistic

15 Jan 2020
Topic — The Commission is establishing mandatory timelines for companies to update their chemical safety registrations.
Message — Eurometaux wants a clause allowing extra time for complex dossiers and large industrial groups. They argue that current three or six-month deadlines are unrealistic for the metals sector.12
Why — Companies would avoid the financial burden of conducting rushed tests and repetitive dossier submissions.3
Impact — Public health regulators face delays in receiving critical information about chemical safety and risks.4
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

16 Oct 2019 · EU industry in the long term decarbonisation.

Meeting with Daniel Calleja Crespo (Director-General Environment)

8 Oct 2019 · Circular Economy

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

22 Mar 2019 · ETS

Response to Sustainability requirements for batteries

6 Feb 2019

Eurometaux, representing European non-ferrous metals producers and recyclers, supports the European Commission’s initiative to improve the sustainability, energy and environmental performance of batteries placed on the EU market. Our sector is actively involved in the EU’s Battery Alliance & Action Plan, sharing the objective to develop globally competitive value chains for batteries in Europe. Our companies produce and recycle strategic battery metals including cobalt, copper, lead, lithium, nickel and more. Europe has a significant potential to further develop this industrial base. Europe‘s global sustainable leadership can continue to be a differentiating factor to boost Europe’s future battery value chains on a global level. EU regulators and industry must work together to ensure that high sustainability standards are established at the same time as guaranteeing predictability and supportiveness for the required industry investments. In the attached position paper we provide our recommendations on the European Commission’s proposed measures for sustainable batteries, and how to get this environmental and economic balance right for battery raw materials.
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Response to Revision of the ETS State aid Guidelines

17 Jan 2019

Please see the attached document.
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Meeting with Dominique Ristori (Director-General Energy)

8 Jan 2019 · clean and fair energy transition

Eurometaux warns draft carbon allowance rules threaten industrial growth

23 Nov 2018
Topic — The Commission is revising rules for free greenhouse gas emission allowance allocations.
Message — Eurometaux requests heat benchmarks based on natural gas rather than biomass. They want flexibility to use the best production years for historical levels. Rules should reward physical investments even below the fifteen percent threshold.123
Why — This approach secures higher free allowance volumes and reduces the carbon leakage risk.45
Impact — Environmental health and Southern European nations with limited forests face disadvantages under current proposals.67
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Meeting with Dominique Ristori (Director-General Energy) and FuelsEurope and

23 Nov 2018 · clean energy transition and decarbonisation

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and Association of European Automotive and Industrial Battery Manufacturers and RECHARGE aisbl

25 Sept 2018 · Joint meeting with Eurometaux, EUROBAT and RECHARGE to discuss the future of batteries and related chemicals management

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

3 Sept 2018 · Implications on the non-ferrous metals industry of the withdrawal of the UK from the EU

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

12 Jul 2018 · Implementation of the EU Emissions Trading system

Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

The European non-ferrous metals industry is a key materials supplier and recycler of valuable metals from cars, buildings, packaging, e-waste, batteries and other applications. We support fully support the transition to a true circular economy. We believe that a coherent EU Product Policy Framework will be integral to improving product design, manufacturing, use and end-of-life treatment. The attached paper is an input to the public consultation on the Roadmap on EU product Policy Framework and it reflects on specific initiatives listed in the document.
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Response to Revising the rules for free allocation in the EU Emissions Trading System

17 Apr 2018

Key Guiding Principle The EU ETS should be a more dynamic system which safeguards and rewards the growth of sectors identified at risk of carbon leakage. A lower, even more dynamic threshold (i.e. <15%) is need to better reflect industrial requirements for free allocation. Furthermore, under allocation in times of growth can be avoided with a better designed, fairer, more dynamic system. 1. Determination of the historical activity levels According to article 11(1) of the EU ETS Directive, free allocations in phase IV must derive from activity levels based on the 5-years baseline 2014-2018. We recommend to introduce the possibility to omit from the calculation one or more years which may be not representative of the normal production level. For example, the average of the 3 years with the highest production within the baseline period may be used. 2. Adjustments due to production changes We welcome the possibility, introduced in article 10.a paragraph 20, to better align the historical activity levels to the actual production, based on a 2-years rolling average: this approach helps to prevent both under and over-allocation, and helps safeguarding the growth of sectors identified at risk of carbon leakage. However, as the directive doesn’t provide further practical details, we would recommend that: The assessment through the rolling average is started already in 2019, to include from the start of phase IV any relevant production change occurring between 2018 (end of baseline), and 2021. This would honour investments for production growth already in place, and prevent overcompensation if production is reduced The 2-year rolling average is calculated every year of phase IV, to ensure a regular update of the activity levels The actual changes in the allocation, where due, are immediately implemented in the year following the assessment, without time lag 3. Absolute thresholds In addition to the threshold of ±15%, Recital 12 of the EU ETS Directive 12 which states that “The Commission should be able to consider further measures to be put in place, such as the use of absolute thresholds regarding the changes to allocations, or with respect to the deadline that applies to the notification of changes in production” provides the EU Commission the possibility to introduce a more tailored, dynamic system to adjust the amount of free allocation in line with production changes. This possibility should be used to incentivise efficiency improvements and enable growth in those sector’s deemed exposed to carbon leakage. Production facilities should have the possibility to receive additional allocation for this increased production, even if below the threshold of ±15%. Background Creeping projects increase due to productivity and efficiency increases is a general economic fact throughout the non-ferrous metals industry. Indeed, installing new capacity entails significant costs and thus, the most cost-effective and proven way to meet the growing demand is to increase the productivity of existing assets, through continuous improvement and targeted investments. To take the example of aluminium; virtually all aluminium smelters gradually increase over time the intensity of the electricity used in the electrolysis process, hence their production. This technique, referred to as “creeping”, allows them to use the main infrastructures, while upgrading the computer control system, and the electrical and auxiliary equipment. Creeping projects allow a yearly increase of production between 0.5% and 1%, providing a slow but steady increase over a substantial amount of time, additionally improving energy efficiency and overall performance. These production increases would however not be considered by the threshold of ±15%, thus making future creeping projects more unattractive. Such a regulatory system undermines the attractiveness of Europe for our sector as a future investment destination for such projects.
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Response to Carbon Leakage List 2021 - 2030

13 Nov 2017

Eurometaux, represents the European non-ferrous metals (NFM) sector. In the NFM industry, production processes are more electricity-intensive than those used in other sectors. Thus, indirect carbon costs from the EU ETS are often significantly higher than other energy intensive sectors. In addition, we cannot pass-on our additional indirect carbon costs because NF metals are globally traded commodities. Our producers therefore face a very real risk of carbon and investment leakage. We would like to provide the following feedback on the methodological elements to implement the directive: 1) Emissions intensity and emissions factor for electricity The current methodology for defining emission intensity for carbon leakage (CL) list includes direct and indirect emission costs with equal emphasis on the two cost elements. We agree that both direct and indirect should be included - as is the situation today - with equal emphasis when calculating a sector’s exposure to EU carbon costs. The methodology for the CL list for defining indirect emissions is founded on the average emissions for the European electricity market. However, the emission factor for electricity is not set by the European average. Rather, in the European electricity market, prices are decided by the marginal technology in each regional market in Europe. Thus, regional and not average emission factors, based on marginal pricing mechanisms, are the correct methodology. This correct methodology - based on the principles of marginal technology - should be preserved in the State Aid guidelines for indirect compensation in Phase IV. 2) Trade intensity Whilst the calculation of the emissions intensity seems to be appropriate, the trade intensity calculation has methodological shortcomings. Our products are traded on an international exchange at a uniform global price; i.e. the London Metal exchange or similar global pricing mechanisms set a uniform price. We thus cannot pass any unilateral regulatory costs to our customers. Due to lack of data we understand that the more accurate price elasticity of demand approach cannot be used. As long as this is the case, the default value for ‘price-taker’ globally priced commodities should be automatically set at the highest level (100%). o Assessing other countries climate policies Elsewhere, when assessing other countries climate policies, it should be identified what carbon costs their comparable industries actually face. In particular, for indirect carbon costs, there is a need to have a more detailed analysis to assess if their comparable industries face similar carbon costs in their electricity. Looking only at climate policy is insufficient. It should be considered how the systems in each country are designed, how the industry is protected and how electricity prices to industry are affected and compensated. 3) Framework for additional assessments a. Qualitative assessments: Given imperfection of the carbon leakage indicator, the possibility of a qualitative assessment is imperative for the correct detection of carbon leakage risk. As aforementioned, the ‘price-taker’ criterion needs to be integrated into any qualitative assessment. Citing administrative burden should not be a justification for preventing such an assessment. b. Disaggregated assessments: Given the heterogeneous nature of certain NACE 4 codes, it is essential to allow the possibility for sectors to be assessed for carbon leakage risk at a disaggregated level (PRODCOM level), upon request. This is particular relevant for the non-ferrous metals sector where certain large heterogeneous NACE 4 codes do not give an accurate assessment of certain commodities real emissions and trade intensity. Thus, a disaggregated assessment is needed. Limiting legally the use of statistical data to NACE-4 activities in Phase IV - for the sake of reducing the administrative workload – to a limited number of sectors, would be discriminatory
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Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

3 Aug 2017 · Proposal for a new methodology to calculate dumping

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and European Chemical Industry Council and

21 Mar 2017 · Reach evaluation

Meeting with Daniel Calleja Crespo (Director-General Environment)

22 Feb 2017 · REACH, Chemicals, Circular Economy

Meeting with Daniel Calleja Crespo (Director-General Environment)

20 Oct 2015 · Better Regulation and Chemicals Management

Meeting with Bernd Martenczuk (Cabinet of First Vice-President Frans Timmermans) and The European Steel Association and

17 Sept 2015 · Market economy status for China

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and The European Steel Association and

17 Sept 2015 · Presentation of a study

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen) and The European Steel Association and

17 Sept 2015 · EU-China trade relations

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

17 Sept 2015 · AEGIS presenting new study on consequences of granting MES to China

Meeting with Peteris Ustubs (Cabinet of High Representative / Vice-President Federica Mogherini) and Confederazione Generale dell'Industria Italiana and

3 Sept 2015 · AEGIS Europe and MES China

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

2 Jun 2015 · ETS post 2020 reform

Meeting with Carlos Moedas (Commissioner)

30 Mar 2015 · Meeting with the Director of Eurometaux

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

27 Mar 2015 · Eurometaux Position zum Kreislaufwirtschaftspaket

Meeting with Alexander Italianer (Director-General Competition)

12 Mar 2015 · Indirect compensation under EU ETS

Meeting with Jos Delbeke (Director-General Climate Action)

12 Mar 2015 · EU ETS and carbon leakage

Meeting with Miguel Arias Cañete (Commissioner) and

19 Feb 2015 · Competitiviness, Energy Union and ETS review

Meeting with Jyrki Katainen (Vice-President)

9 Jan 2015 · Industrial policy and metals industry

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

15 Dec 2014 · TTIP; Market access; conflict mineral; China; TDI reform