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European Association of Mining Industries, Metal Ores & Industrial Minerals

Euromines

Euromines represents the European metals and minerals mining industry to promote responsible practices.

Lobbying Activity

Meeting with Francois Wakenhut (Head of Unit Environment)

2 Dec 2025 · Courtesy meeting requested to introduce Euromines and establish contact in the context of the preparation of the Circular Economy Act

Meeting with Astrid Van Mierlo (Head of Unit Taxation and Customs Union) and RHI MAGNESITA

21 Nov 2025 · assessment of magnesia for both cement and iron and steel - discussion about the state, procedure and the information the assessment relies on.

Meeting with Maroš Šefčovič (Commissioner) and

14 Nov 2025 · RessourceEU

European mining industry urges no reduction in primary extraction

5 Nov 2025
Topic — New EU Circular Economy Act to enhance sustainable production and recycling.
Message — The industry requests removal of legal obstacles blocking permits, clarification of liabilities for reprocessing extractive waste, and harmonization of EU waste legislation. They oppose additional resource consumption targets and emphasize that primary extraction must continue alongside recycling efforts.1234
Why — This would streamline permitting processes and reduce compliance costs for mining operations.56
Impact — Environmental groups lose stronger restrictions on primary resource extraction and mining permits.78
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Meeting with Paulo Cunha (Member of the European Parliament)

22 Oct 2025 · EU raw materials extraction industry

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

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

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen) and RHI MAGNESITA and

3 Oct 2025 · Tripartite contracts – Affordable Energy Action Plan

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

25 Sept 2025 · Exchange of views on raw materials

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen), Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

18 Sept 2025 · Simplification

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

5 Sept 2025

Euromines, the association of the EU mining industry, welcomes the Commissions initiative to update the EU ETS State Aid Guidelines and extend the list of sectors eligible for indirect CO2 cost compensation. With the increasing electrification of the mining industry, the exposure to indirect costs has substantially increased since the last assessment period (07.29: non-ferrous metals mining indirect emissions intensity indicator rose by 88% since the last assessment and a 6-fold increase in indirect cost exposure; potash-production saw its indirect cost exposure rise nearly 10-fold). You can find a detailed analysis and rationale in the attachment and we would kindly request to be taken into consideration for the detailed assessment by the contractor. To support the Commission's work on updating the guidelines, Euromines can provide the underlying data upon request as it is restricted for public use.
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Mining industry urges full downstream CBAM coverage before upstream expansion

26 Aug 2025
Topic — Extension of carbon border adjustment mechanism to downstream products and anti-circumvention measures.
Message — The organization requests extending CBAM as far down the value chain as possible before adding upstream materials. They want to avoid including mined precursors in Annex I until downstream coverage proves effective against carbon leakage. They also call for robust export solutions and full emissions coverage.1234
Why — This would protect their offtake market from cheap carbon-intensive imports while avoiding higher costs from premature upstream inclusion.56
Impact — Non-CBAM goods producers face higher input costs without carbon leakage protection if precursors are included prematurely.78
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Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

9 Jul 2025 · Exchange on raw materials and energy intensive industries

Euromines Urges Stronger Carbon Leakage Protection and Indirect Compensation

8 Jul 2025
Topic — Review of the EU Emissions Trading System for industry and maritime transport.
Message — Euromines requests a robust carbon leakage framework. They also seek eligibility for indirect cost compensation.123
Why — These measures would reduce operational expenditures and safeguard global competitiveness.4
Impact — Power producers would lose inframarginal profits if carbon costs shift.5
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and Luossavaara Kiirunavaara Aktiebolag

8 Jul 2025 · CRMA and the future Industrial Decarbonization Accelerator Act (IDAA)

Meeting with Jessika Roswall (Commissioner) and

27 Jun 2025 · Competitiveness and Minerals

Meeting with Patrick Child (Acting Director-General Environment)

27 May 2025 · Exchange of views on water legislation

Response to Communication on the EU Stockpiling Strategy

8 May 2025

Position paper EU Stockpiling Strategy While many countries foresee stockpiling for military equipment and defence purposes the question of economic security and resilience has gained traction. Stockpiling can play a strategic and multifaceted role for the European Union (EU) in enhancing economic security, resilience, and strategic autonomy, particularly in an increasingly uncertain and multipolar global landscape. While traditionally linked to military preparedness, stockpiling is now expanding into civilian and economic domains. Stockpiling, when strategically planned and coordinated at the EU level can contribute to economic resilience, strategic independence, and crisis preparedness for many sectors like defence, health and food. For the raw materials sector the risks of distorting markets and prices and the overall costs can be considerable. Before the EU Commission proposes a legislation, we recommend an in-depth impact assessment identifying the advantages and disadvantages of a stockpiling system. Possible advantages of Stockpiling Raw Materials 1. Supply Security Prevents disruptions caused by geopolitical tensions, trade restrictions, natural disasters, or pandemics. Ensures continuous availability of critical materials for industries like energy, defence, and technology. 2. Strategic Autonomy Reduces dependency on non-EU suppliers, especially in sectors where the EU is vulnerable (e.g., rare earths from China). Strengthens bargaining power in global trade relations. 3. Market Stabilisation Stockpiles can cushion price volatility and shortages, especially in high-demand periods. Helps avoid supply panic and overreactions in the market. 4. Crisis Readiness Enables rapid response in emergencies (e.g., natural disasters, wars, industrial breakdowns). Acts as a buffer stock to sustain manufacturing and infrastructure projects during disruptions. 5. Support for Green and Digital Transitions Ensures a steady supply of materials (like lithium, cobalt, or nickel) needed for batteries, solar panels, wind turbines, and semiconductors. Helps the EU pursue its climate goals and digital competitiveness without resource bottlenecks. Possible disadvantages of Stockpiling Raw Materials 1. High Upfront and Ongoing Costs Requires significant financial investment in purchasing, storing, and maintaining stockpiles. Storage of commodities can be technically complex (e.g., moisture-sensitive materials) and costly. 2. Risk of Obsolescence or Devaluation Materials may become obsolete due to technological changes (e.g., shift away from certain battery chemistries). Market prices may drop, making earlier purchases economically inefficient. 3. Inefficiency and Mismanagement Risks Poor planning can lead to overstocking or understocking. Risks of bureaucratic inefficiency, corruption, or misallocation of resources. 5. Market Distortion Artificially inflating demand (when building stockpiles) can distort global commodity markets and be seen as cartels and abuse of market dominant positions. Can lead to international tensions, especially with supplier countries.
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and Boliden Group and

28 Apr 2025 · Soil monitoring law, mining areas

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

15 Apr 2025 · CID Simplification REACH

Meeting with Veronica Manfredi (Director Environment)

10 Apr 2025 · Exchange on the 2025 EU Water Resilience Strategy and the role of the EU mining sector

Meeting with Alexandr Vondra (Member of the European Parliament, Shadow rapporteur)

4 Apr 2025 · CBAM

Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and Boliden Group

28 Mar 2025 · Soil law and mining industry

Euromines calls for voluntary status and higher Taxonomy thresholds

26 Mar 2025
Topic — This consultation seeks to simplify EU Taxonomy reporting rules to reduce administrative costs for businesses.
Message — Euromines proposes raising the materiality threshold to 15% to exempt more operations. They suggest making the Taxonomy voluntary and replacing the current advisory platform.123
Why — This would significantly reduce compliance costs and protect integrated operations from mandatory disclosures.45
Impact — Transparency advocates lose granular data on mining projects failing to meet water-quality standards.6
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Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur) and Verband Kommunaler Unternehmen e.V.

21 Mar 2025 · Surface water and groundwater pollutants

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

14 Mar 2025 · Physical meeting - Exchange of views on CBAM

Meeting with Valdis Dombrovskis (Commissioner) and

4 Mar 2025 · Competitiveness and Simplification

Euromines urges easing water rules to secure raw materials

3 Mar 2025
Topic — The European Water Resilience Strategy aims to manage water scarcity and protect aquatic ecosystems.
Message — Euromines requests amending the Water Framework Directive to remove permitting barriers. They also want to extend compliance deadlines and oppose mandatory EU-level water pricing.123
Why — This would simplify the permitting process for new mines and industrial facilities.45
Impact — Environmental groups and ecosystems lose protection from water degradation if standards are weakened.6
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Meeting with Ion Codescu (Head of Unit Environment)

3 Mar 2025 · Exchange of views on the Soil Monitoring Law and the position of Euromines

Meeting with Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

28 Feb 2025 · Exchange of views on Euromines’ Decarbonisation Roadmap.

Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

27 Feb 2025 · Mining

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

27 Feb 2025 · EU Taxonomy

Meeting with Alexandr Vondra (Member of the European Parliament)

26 Feb 2025 · Omnibus I

Meeting with Andrius Kubilius (Commissioner) and

26 Feb 2025 · Presentation of the association and exchange on synergies with defence and space.

Meeting with Astrid Van Mierlo (Head of Unit Taxation and Customs Union) and Boliden Group and

25 Feb 2025 · Physical meeting - Exchange of views on the policy design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Kurt Vandenberghe (Director-General Climate Action)

25 Feb 2025 · Discuss joint effort to promote Europe’s competitiveness

Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur)

20 Feb 2025 · Soil Monitoring Law

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

11 Feb 2025 · Simplification and Decarbonisation

Meeting with Annalisa Corrado (Member of the European Parliament, Shadow rapporteur)

7 Feb 2025 · Soil monitoring

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

5 Feb 2025 · Omnibus

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Swedish Association of Mines, Mineral and Metal Producers

28 Jan 2025 · Swedish mining sector, mining in Europe

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 Christophe Clergeau (Member of the European Parliament) and WindEurope and

14 Jan 2025 · SEARICA

Meeting with Apostolia Karamali (Cabinet of Commissioner Andrius Kubilius)

10 Jan 2025 · Euromines explained its role, the challenges for the EU mining industry and its approach to green EU mining.

Meeting with Radan Kanev (Member of the European Parliament)

26 Nov 2024 · Decarbonisation of Mining Industry

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

5 Nov 2024 · Surface water and groundwater pollutants

Meeting with Alexandr Vondra (Member of the European Parliament)

9 Oct 2024 · Critical raw materials, energy transition

Meeting with Radan Kanev (Member of the European Parliament)

9 Oct 2024 · Sustainable mining

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

Meeting with Florika Fink-Hooijer (Director-General Environment)

4 Oct 2024 · EU Critical Raw Materials Act, Clean Industrial Deal

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

2 Oct 2024 · European mining industry

Meeting with Hildegard Bentele (Member of the European Parliament)

12 Sept 2024 · Mining Policy

Meeting with Tiemo Wölken (Member of the European Parliament)

12 Sept 2024 · General exchange on critical raw materials policy (staff level)

Euromines urges use of actual energy data for battery footprint

24 May 2024
Topic — Developing a methodology for calculating and verifying the life-cycle carbon footprint of electric vehicle batteries.
Message — Euromines requests that carbon footprint calculations use actual electricity data from specific contracts rather than national averages. They argue that relying on national averages ignores private investments in green energy and contradicts existing EU rules.12
Why — This allows EU mining firms to prove their decarbonization efforts and protect their market value.3
Impact — The green transition suffers as companies lose financial incentives to fund new renewable energy projects.4
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

17 Apr 2024 · Speaker at Euromines event "From Resources to Resilience, Unpacking the Role of Raw Materials for Security, Sustainability and Prosperity"

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

23 Feb 2024 · Energy market

Mining industry urges fairer carbon allowance rules to protect competitiveness

22 Dec 2023
Topic — The European Commission is updating rules for the free allocation of emission allowances.
Message — Euromines requests keeping the process emissions factor at 0.97 while widening iron ore benchmarks. They want to include all agglomerated products regardless of the specific production process. They also suggest excluding crisis years from activity level calculations.1234
Why — The changes would ensure a level playing field and prevent financial losses from unrepresentative data.56
Impact — Carbon-intensive sinter plants and importers would lose market distortions that currently favor them.7
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Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur) and industriAll European Trade Union

7 Dec 2023 · Key Note - Social Aspects of Critical Raw Materials Supply

Euromines calls for mining exemptions in EU soil law

2 Nov 2023
Topic — The consultation concerns a proposed directive to monitor, sustainably manage, and restore EU soils.
Message — The organization recommends that raw material deposits and their extraction be explicitly exempt from the directive's regulations. They want specific provisions in existing industrial and mining laws to take precedence to avoid conflicting requirements. They also advocate for a risk-based approach to assessing soil health rather than a strict one-out-all-out principle.123
Why — The industry would avoid new administrative burdens and maintain control over domestic mining operations.4
Impact — Environmental groups may see weaker ecosystem protections if the directive allows flexible health thresholds.5
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Euromines backs reduced mandatory sustainability reporting requirements

7 Jul 2023
Topic — The Commission is establishing new standards for corporate sustainability reporting across the EU.
Message — Euromines urges the Commission to maintain double materiality to limit reporting. They seek exemptions for trade secrets and qualitative risk assessments.12
Why — Mining companies would see reduced compliance costs and protection for confidential data.34
Impact — Stakeholders lose access to specific data on raw material weights and technical materials.5
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Meeting with Jens Geier (Member of the European Parliament)

5 Jul 2023 · Exchange on the Critical Raw Materials Act

Meeting with Jens Geier (Member of the European Parliament) and WirtschaftsVereinigung Metalle and TRIMET Aluminium SE

10 May 2023 · Exchange on the Critical Raw Materials Act

Euromines Urges EU to Adapt Taxonomy for Mining Operations

3 May 2023
Topic — The initiative classifies environmentally sustainable economic activities to guide investment across the European Union.
Message — The group wants criteria for waste and remediation to be applicable within complex mining operations. They want to remove rules stopping current operators from being recognized for cleaning legacy pollution. They also suggest including the internal repurposing of mining waste as a circular economy practice.123
Why — This change would allow mining companies to access green financing for remediation.4
Impact — Environmental groups lose if current owners cannot fund the remediation of legacy sites.5
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Meeting with Virginijus Sinkevičius (Commissioner) and

24 Apr 2023 · Exchange views on incentives and bottlenecks for the EU mining sector to contribute to security of supply and open strategic autonomy in raw materials

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and

16 Mar 2023 · CMRD6

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and Luossavaara Kiirunavaara Aktiebolag

24 Feb 2023 · Critical Raw Materials Act; EU Taxonomy

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

22 Feb 2023 · Preparation of critical raw materials act

Meeting with Margrethe Vestager (Executive Vice-President) and

10 Feb 2023 · Critical Raw Materials Act

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager) and Boliden Group and Swedish Association of Mines, Mineral and Metal Producers

19 Dec 2022 · Critical raw material

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

11 Nov 2022 · Critical Raw Materials Act and what the European mining industry can contribute

Response to European Critical Raw Materials Act

9 Nov 2022

Please find Euromines feedback to the proposed legislative initiative attached.
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European Mining Industry Warns Nature Restoration Law Threatens Supply

22 Aug 2022
Topic — The EU is proposing legally binding targets to restore degraded ecosystems and biodiversity.
Message — Euromines opposes mandatory targets and prefers a Directive to allow national flexibility. They demand that new mineral deposits remain exploitable inside protected areas and advocate for voluntary "temporary nature" measures.123
Why — This would ensure continued access to mineral deposits and avoid new land-use restrictions.4
Impact — Environmental groups lose because industrial extraction would be permitted within sensitive habitats.5
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Mining industry urges faster permitting for renewable energy raw materials

27 Jul 2022
Topic — The EU is streamlining permit processes for renewable energy projects and power agreements.
Message — Euromines proposes extending simplified permitting and 'go-to-areas' to raw material extraction sites. They argue mining projects supporting renewables should be considered in the public interest.12
Why — Simplified permitting for extraction would lower operational costs and accelerate project development.3
Impact — Member states and renewable energy producers face reduced revenues from pricing changes.4
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Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager) and EUROMETAUX and

25 Jul 2022 · Raw materials.

Response to Regulation on REPowerEU chapters

20 Jul 2022

Euromines welcomes the possibility to provide feedback - please find our response attached. Kind regards
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Euromines opposes including mining in Industrial Emissions Directive

23 Jun 2022
Topic — This consultation explores updating EU industrial emissions rules to ensure sustainable industry practices.
Message — Euromines requests the total exclusion of mining from the revised emissions directive. They recommend postponing the legislative discussion to protect the industry's economic competitiveness.12
Why — The industry avoids higher costs and more complex administrative permitting procedures.3
Impact — The European Green Deal's zero pollution ambition loses if mining avoids these standards.4
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Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur for opinion) and International Road Transport Union Permanent Delegation to the EU

21 Jun 2022 · RED

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

8 Apr 2022 · Industrial emissions directive

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

Euromines acknowledges the main goals and concerns that the initiative “New Soil Strategy” aims to tackle, especially to address potential soil degradation in a comprehensive way. In attachment we give our comments related to the proposed EU Soil Legislation.
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Euromines urges export protections in carbon border adjustment mechanism

9 Nov 2021
Topic — EU proposal to place carbon price on imported products from selected sectors.
Message — The organization requests export rebates or refunds to maintain competitiveness in global markets. They argue the current proposal fragments markets by imposing carbon costs on EU production without addressing exports to third countries. They also call for stronger anti-circumvention measures and extended stakeholder consultations before expanding CBAM to new sectors.123
Why — This would preserve their competitiveness in third country markets where they compete without carbon costs.45
Impact — Third country mining companies lose competitive advantage from operating without equivalent carbon costs.6
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Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

28 Oct 2021 · Impact of rising electricity prices on mining’s competitiveness and ability to meet EU decarbonisation goals.

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Euromines welcomes the European Commission’s Critical Raw Materials Action Plan and its commitment to develop sustainable financing criteria for the mining, extractive and processing sectors in Delegated Acts on Taxonomy by end 2021 together with the Platform on Sustainable Finance. Environmental sustainability of mining in the EU is assured by application of the EU environmental acquis, national mining legislation, international management standards and best practice guidelines. Together, these require that all EU mining operations use superior practices and techniques and achieve a high general level of protection of the environment in each of their unique site-specific contexts. European mineral products also enable – and indeed are essential for – emission reductions and adaptation in other sectors of the economy. The TEG mentions for example, Aluminium for lightweight cars; Copper for electrics and motors in electric vehicles, solar panels and wind turbines; Battery metals (Cobalt, Lead, Lithium, Manganese, and Nickel) for clean mobility and grid storage batteries; Zinc and Cobalt for protecting off-shore wind turbines; Silicon in solar panels; Precious metals for clean mobility and solar panels. A host of other minerals and metals are additionally required for sustainable value chains, including Iron Ore, Tungsten and Magnesite. A sustainability aspect that is frequently overlooked is the need for Phosphorous and Potassium for biomass production, and sustainable agriculture and food supply. Basing the DNSH criteria on the average footprint of the European electricity mix disregards the important differences that exist between the electricity mixes in different Member States. EU Taxonomy DNSH criteria must in all cases reflect the global context. This is absolutely necessary to ensure that European industries are not labelled as doing ‘significant harm’ to the environment despite having a performance that ranks as globally leading. If this issue is not fixed in the first Delegated Act, a precedent will be set whereby European producers are penalised by the EU Taxonomy to the benefit of less sustainable producers in other regions of the world.
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Response to EU Strategic Framework on Health and Safety at Work [2021-2027]

26 Nov 2020

Euromines is the recognised representative of the European metals and minerals mining industry. Euromines actively participates in the Commmissions’ Sectorial Social Dialogue Committee for Extractive Industries and the Standing Working Party on the Extractive Industry. The association also supports voluntary initiatives like NEPSI Agreement and its reporting, clearly demonstrating Euromines’ commitment to continuously reduce exposure to respirable crystalline silica in the workplace. Health & Safety is an absolute priority for the sector as it concerns the well-being of its employees and communities. The sector strives for continuous improvements in this area. Mining companies are making continuous strides in improving working conditions through digitalisation and automation and removing its workforce from dangerous situations and exposure to hazardous substances. The sector welcomes the strategic framework, however, would have a few suggestions for further improvement: • Need for interim assessment of rate and feasibility of implementation of newly adopted lower OELs In the past years number of substances were allocated new, lower binding occupation limit values (BOELs) in Carcinogens and Mutagens Directive and indicative limit values (IOELs) under the Chemical Agents Directive for substances present in the mining industry, for example Cadmium, Lead, Cobalt, Nickel on the one hand and Nitrogen monoxide, Nitrogen dioxide, Carbon Monoxide, Diesel engine exhaust emissions on the other hand. Compliance with occupational exposure limits is of high importance since the health of the workers is the top priority for the sector, however, it must be technically feasible. Companies make continuous improvements in various areas: Mobility technology (installation of modern diesel drive systems, electrical or other alternative drive systems), use of low emission explosives, optimisation of ventilation, change of organisational and workflow processes, alternative extraction processes. All those measures require advancements in technological development, big financial investments and time. For transitional periods, such as for example granted for OELs on NOx and CO, the rate and feasibility of the implementation of such OELs was not assessed adequately and having been granted a transition period it would be desirable if before the end of transition progress and technical advancement would be assessed together with the concerned employers and employees. • Need for a better coordination between EU Agencies, Commission, ACSH and Industry when setting up OELs. - The quality of the scientific reports prepared by ECHA for public consultation, which are also the basis for the recommendation for BOEL values by RAC, should be improved, for example taking into account more up-to-date and epidemiological data provided by for example by industry or respective research institutes; - Employers and employees representing workplaces would like to be more actively involved in the process of developing BOELs providing comprehensive scientific and real-life evidence for a scientific assessment, but also for technical feasibility and required research and/or technical development in order to avoid for example incompatibility of a combination of limit values or other H & S measures at the workplace; - Support for enterprises adapting to stricter BOEL values in the form of facilities for financing research and development works and expenditure incurred on activities aimed at adapting production processes or/and the technologies used by them to new requirements; Further tightening of IOEL value • The Strategic Framework should recognize the importance of social dialogue and reinforce the role of ACSH and SWPEI to ensure the pro-active contribution to identifying OSH policy priorities and encourage the exchange of views and experiences between Member States, Industry and Trade Unions.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

As the recognized representative of the European mineral raw materials industry, covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, the first segment of most strategic value chains and a critical supplier of materials vital for a transition to a low-carbon society, Euromines welcomes a European Green Deal and is prepared to take the necessary measures to make Europe the world's first climate neutral continent. The Emission Trading System is one of the most important legal pillars and support systems for the European energy intensive industries. Therefore any amendment brought to it or any of its subsequent acts in the light of the proposed increased climate ambition for 2030 should be based on a stable, consistent, coherent, socioeconomically feasible policy framework, allowing the implementation of the most efficient measures to reduce greenhouse gas emissions while ensuring that long-time goals and the international competitiveness of the industry are not endangered. Considering the above, Euromines would like to make several comments with regards to the specific objectives and assessed options included in the Inception Impact Assessment as per the attached document.
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Response to Sustainable Products Initiative

15 Nov 2020

Euromines members are committed to facilitating and encouraging the promotion of safe use, recycling and disposal of products through an understanding of their life cycles. Primary production of metals and minerals, which remain abundant, will play an important role in delivering the European Green Deal and increased sustainable supply from European sources will be needed to make the sustainable transition: • products will become more durable, shared more and re-used more, materials will remain in use even longer than today; • even so, the proposed deep transformation of the economy will require significantly more metals and minerals, as more sustainable standards of living are established; • meaning that even with increased recycling, its contribution to raw material supply will continue to vary and there will remain a significant need for primary production. Substantiation of environmental claims using Product and Organisational Environmental Footprint is only possible once the serious flaws revealed by the PEF Pilots are corrected. Euromines strongly supports updating the 2013/179/EU Recommendation establishing PEF/OEF methods to incorporate the necessary improvements identified during and after the 2013-2018 Environmental Footprint Pilot Phase.
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Response to Environmental claims based on environmental footprint methods

28 Aug 2020

Euromines members are committed to facilitating and encouraging the promotion of safe use, recycling and disposal of products through an understanding of their life cycles. Euromines has made significant contributions to the science of Life Cycle Assessment, on which the Environmental Footprint methods are based. Since 2013, Euromines has been actively engaged in the European Commission’s Environmental Footprint (EF) and has helped develop, during the EF Pilot Phase, the ‘Product Environmental Footprint Category Rules (PEFCR) for Metal Sheets in Various Applications’. Not all the defined shortcomings have been resolved to ensure that the EF methodology is sufficiently robust for use in EU policy, and does not lead to inappropriate results.To base the substantiation of green claims mainly on impact categories that may be driving the overall results after normalisation and weighting but have a low overall robustness would not be consistent with the Commission’s stated objectives. In aiming to prevent misleading claims to consumers, the EU must guard against requiring the use of harmonised methods that are themselves poorly defined, explained and understood, or underpinned by non-comparable methods to measure and assess environmental impacts. This would cause the requirements themselves to mislead consumers resulting in higher environmental impacts than would otherwise occur. It is essential that Option 1 be pursued in the short term to align with the most up-to-date versions of the recommended data and methods. Option 2 should be preferred in the longer term. Whichever option is pursued, the Human Toxicity, Ecotoxicity and Resource Use (minerals & metals) impact categories must not be used for public communication purposes such as attempting to substantiate green claims, until their serious flaws revealed by the PEF Pilots are corrected.
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Response to EU Strategy on Adaptation to Climate Change

29 Jun 2020

Euromines is committed to substantially contribute to climate change adaptation! As the recognized representative of the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future. We also believe that an updated Strategy for Adaptation to Climate Change should focus both on prioritizing policy areas and actions where EU interventions can be most effective as well as on assessing how to increase ambitions in a manner that best contributes to sustainable growth and enhances economic competitiveness. In this context Euromines is prepared to take the necessary steps and bring its value added to a climate-resilient society, fully adapted to the unavoidable impacts of climate change, with reinforced adaptive capacity and minimal vulnerability. The first segment of most value chains, the raw minerals sector is a supplier of critical materials and products to many sectors of the economy. With regards to climate change adaptation, the European minerals sector secures the availability of essential materials needed for a climate neutral, service and welfare orientated, circular and resource efficient economy. For example, the new infrastructure for alternative energies requires an increased use of metals and minerals, in particular steel for pipelines; copper and graphite for electricity cables, generators and electric motors; aluminium, primarily for electricity cables; and a host of other metals and minerals including phosphorous, potassium and nitrogen for biomass production. Also, solar photovoltaic panels and thermal systems use a combination of up to 22 non-ferrous metals, silicon, chemicals (e.g. organic electrolytes) and a specific type of flat glass. A continuously changing climate generates a series of risks to mining operations especially because these industries are often located in challenging geographic areas, they rely on fixed assets with very long lifespans, include global integrated supply chains and must deal with environmental and climate sensitive resources. Increased temperatures, changes in precipitation, sea level rise, earthquakes and extreme events have already become stressors with the potential to negatively affect the mining activity. The European metals and minerals industry is already dedicated to identifying and assessing risks so that disruption and damage arising from acute or chronic effects of climate change are minimized. At the same time, we actively contribute and support all stakeholders along the value chain to: • improve knowledge of climate impacts (e.g. through increased awareness and better access to knowledge of individual and collective climate risks); • reinforce planning and climate risk management in the public and private sector (e.g. through risk assessments and helping to close the climate protection gap via risk-transfer mechanisms); • accelerate action with a focus on solutions (in addition to understanding), on deploying innovation (in addition to research), on implementation (in addition to planning), and on prevention (in addition to ex-post). ***
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Response to EU rules on industrial emissions - revision

17 Apr 2020

As the recognized representative of the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures to make it the world's first climate neutral continent. We have attached a letter providing our feedback to the Inception Impact Assessment for Revision of the Industrial Emissions Directive.
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Response to Climate change mitigation and adaptation taxonomy

17 Apr 2020

As the recognized representative of the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures to make it the world's first climate neutral continent. We have attached a letter providing our feedback to the Inception Impact Assessment for a Commission Delegated Regulation on a climate change mitigation and adaptation taxonomy.
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Response to 2030 Climate Target Plan

12 Apr 2020

As the recognized representative of the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures to make it the world's first climate neutral continent. At the same time, we believe that efforts, climate ambitions and targets should be aligned with the fundamental principle of sustainable development, ensure the essential current needs and safeguard the needs of future generations while contributing to the economic, social and environmental development. Therefore, the 2030 Climate Target Plan should carefully assess how to increase the ambition in a manner that best contributes to sustainable and inclusive growth and enhances economic competitiveness through accelerating innovation and developing Europe’s industry. It is crucial that in the transition to become climate neutral, the industry can maintain and even improve competitiveness. It is our strong conviction that when setting the 2030 climate targets, a consistent, stable and predictable value chain approach should also be guaranteed. For more information about Euromines' position concerning the 2030 Climate Target Plan and IIA please see the attached document.
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Response to Revision of the ETS State aid Guidelines

17 Jan 2019

We believe that the main aim of the Guidelines on certain State aid measures in the context of the greenhouse gas emission allowance trading system post-2020 should be to safeguard an integrated approach to consistency, stability and predictability while ensuring a cost-effective decarbonisation of the economy with no competition distortions in the internal market along the whole value chain. 1. The undertakings/sectors eligibility Euromines believes that the best option for determining a sector’s eligibility for indirect carbon costs reimbursement would be to apply the principle of equal treatment and align eligibility for compensation of indirect costs with the eligibility for free allowances, which is determined by the so-called Carbon Leakage List established by the European Commission as a delegated act. Additionally, more targeted additional criteria could be applied to eligible sectors such as their current exposure to international factors and to indirect ETS costs, as well as their competitiveness protection level provided by free allocation and the fact that the electricity cost increases cannot be passed to consumers. 2. The amount of compensation It should be noted that for several sectors exposed to a significant risk of carbon leakage due to indirect ETS costs the overall energy/electricity input will have to rise in order to meet the greenhouse emissions, energy efficiency, automation and digitization targets. Electrification/automation has proven to be the most direct, effective and efficient way of reaching the decarbonization objectives. However, due to various factors the overall electricity consumption will increase and hence rising electricity costs will damage the European industry’s ability to provide at least the baseload demand of EU’s downstream industry. The creation of higher value and refined products to be able to compete on international markets, access to deeper deposits, additional processing of lower-ore grades and by-products, improved recycling of production residues to satisfy Circular Economy objectives will require a higher energy input. Therefore, Euromines believes the compensation of indirect costs should be as high as possible and stable across the entire trading period, without any degressive factor being applied. 3. Incentives of the EU ETS for a cost-effective decarbonisation Euromines agrees that indirect costs compensation should be made conditional upon energy efficiency investments. However, the energy efficiency investments criteria should take into consideration the overall energy efficiency rate along the value chain, the product physical and chemical characteristics, local and regional characteristics as well as the investments in technology aiming at increasing energy efficiency. Reimbursing indirect costs will lead to a proportional if not even higher increase in low-carbon emissions technology investments helping to achieve the necessary standards of environmental protection and climate change targets. 4. The electricity mix Euromines supports keeping the regional CO2 factors reflecting the electricity mix in a given region, as already used by the current Guidelines. Of course a uniform CO2 factor at EU level would be the best option but, given the differences and disparities between member states, we believe that would not be very easily applicable, at least not for the 2021-2030 period. As far as the specific national CO2 factors are concerned, they would be counterproductive because they are not in line with the EU integrated electricity grids and interconnectors. 5. The upper limit on the total compensation which can be granted by a given Member State Euromines supports keeping a Maximum State Aid Level Formula and fully disagrees with introducing an upper limit on the total compensation which can be granted by a given Member State. We believe that such a dynamic, flexible, volatile system should not include any absolute value caps.
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Meeting with Elżbieta Bieńkowska (Commissioner) and

24 Jan 2018 · Exchange of views on Industrial Policy

Meeting with Jyrki Katainen (Vice-President) and

27 Jun 2016 · Investments in Greece

Meeting with Valdis Dombrovskis (Vice-President) and

27 Jun 2016 · joint meeting with VP Katainen to discuss Investments in Greece

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

18 Feb 2016 · Investments in Greece

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion) and The European Steel Association and

2 Dec 2015 · Le statut d’économie de marché de la Chine.

Meeting with Jean-Luc Demarty (Director-General Trade) and The European Steel Association and

10 Nov 2015 · EU industry and China

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

17 Sept 2015 · Presentation of a study

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 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 Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

1 Apr 2015 · Investments in Greece

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

26 Feb 2015 · Industrial Policy