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Finnish Minerals Group

OUR STRATEGIC MISSION is to responsibly maximise the value of Finnish minerals.

Lobbying Activity

Meeting with Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen)

20 Nov 2025 · Critical raw materials

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and Tingvoll

18 Nov 2025 · Discussion on Europe’s EV battery value chain

Response to Circular Economy Act

6 Nov 2025

Dear Sir/Madam, Finnish Minerals Group supports a Circular Economy Act that promotes circularity through innovation, proportionate regulation, and industrial collaboration, while strengthening Europes raw material independence. Recycled content targets should be designed to support responsible and sustainable European primary production. By aligning circular economy principles with Europes industrial and raw material strategies, the EU can build a sustainable, competitive, and resilient foundation for the green transition. Please find a detailed account of our recommendations in the enclosed file.
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Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen) and European Association of Mining Industries, Metal Ores & Industrial Minerals and

3 Oct 2025 · Tripartite contracts – Affordable Energy Action Plan

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

11 Sept 2025 · Exchange of views related to Critical Raw Materials policy and Strategic Projects

Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

26 Aug 2025

Expanding CBAM to Cover Nickel, Cobalt and Lithium Intermediates and Downstream Products Introduction The EUs Carbon Border Adjustment Mechanism (CBAM) is a cornerstone of Europes climate and industrial strategy. Yet, its current scope does not sufficiently cover key raw materials and intermediates critical to the clean energy transition. The Finnish Minerals Group (FMG) urges the inclusion of nickel and cobalt intermediates and refined products (mixed sulfide precipitate MSP , mixed hydroxide precipitate MHP , nickel sulphate and cobalt sulphates ), and lithium intermediates (lithium hydroxide , lithium carbonate ) into the next round of CBAM revision in 2026, including also downstream products using these intermediates such as precursor cathode active materials (pCAM), cathode active materials (CAM), as well as battery cells, modules and packs, motors and engines, electric vehicles and electronics. Without such adjustments, the EU risks creating unintended loopholes, undermining EU climate ambition, and weakening European industrial competitiveness and strategic autonomy. Policy Recommendations 1. Revision of the CBAM in 2026 to include nickel and cobalt intermediates (MSP, MHP, nickel sulphate, cobalt sulphate) and lithium intermediates (lithium hydroxide, lithium carbonate) 2. Include downstream integration in the 2026 CBAM revision cycle, covering pCAM, CAM battery cells, modules and packs, motors and engines, electric vehicles and electronics. 3. Alignment with CRMA and Net-Zero Industry Act, ensuring that CBAM supports the EUs strategic autonomy and secure supply chains. 4. Robust monitoring of global production standards to ensure that CBAM reflects real carbon intensity differences and prevents circumvention. Please refer to the attached file for the rationale of including these items to the CBAM.
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné)

26 Aug 2025 · Overview of Finish Mineral Group’s operations, especially regarding their cathode active material (CAM) project in Kotka, Finland.

Response to Industrial Decarbonisation Accelerator Act

4 Jul 2025

Industrial Decarbonisation Accelerator Act Feedback from Finnish Minerals Group Introduction As the EU moves forward with the implementation of the Clean Industrial Deal and the Critical Raw Materials Act (CRMA), we believe that EU content requirements are the way to go to align climate ambition with industrial resilience. The Industrial Decarbonisation Accelerator Act (IDAA) offers a timely opportunity to translate these policy goals into practice by linking access to EU public funding and procurement rules, to the sourcing of strategic raw materials within Europe. Nickel (Ni), cobalt (Co), lithium (Li), phosphate (P) and rare earth elements (REE) are indispensable to Europes clean and digital transitions, powering technologies such as electric vehicles, batteries, wind turbines, semiconductors and defence systems. While these materials can be produced in the EU either from primary sources or recycling domestic producers face significant structural disadvantages. Global competitors, particularly in China, benefit from state subsidies that depress export prices undercutting EU firms operating under far stricter environmental and social standards. In the case of REE- based permanent magnets, the subsidized cost advantage to Chinese producers is 25 per cent compared to European producers. Without targeted measures, Europe risks losing critical industrial capacity and deepening its dependence on less sustainable supply chains. Binding EU content requirements can correct this imbalance by directing EU support towards projects that source strategic raw materials domestically or commit to future offtake agreements with EU producers. This would unlock much-needed investment in European mining, processing and recycling projects, many of which remain stalled due to uneven global playing field. Consider the lithium battery value chain, where the current EU operating assets on lithium mining and refining will cover only up to 5% of EUs needs by 2030. If known probable projects are in fact built, the degree of self-sufficiency may reach 12% over the same period, and if extended to known possible projects, the EU could reach 40% self-sufficiency in terms of battery-grade lithium production by 2030. This capacity ramp-up is difficult to reach without considerable policy efforts from the EU. By embedding EU content requirements across industrial funding instruments and public procurement in key sectors such as batteries, wind power and defence, the EU can drive upstream development, reduce import dependency, and strengthen its strategic autonomy. To ensure that EU content requirements deliver on their objectives, they must be accompanied by robust traceability and verification mechanisms aligned with the benchmarks set out in the Critical Raw Materials Act. This will guarantee transparency, enforce compliance, and support the development of trustworthy and sustainable supply chains across Europe. Our recommendations 1. Introduce an EU content requirement of 30% across the whole value chain for Ni, Co, Li, P, and REE for low-carbon lead markets, as part of the Industrial Decarbonisation Accelerator Act. 2. Make the use of EU-sourced strategic raw materials a competitive advantage for eligibility under EU funding instruments (e.g. Innovation Fund, InvestEU, Horizon Europe, and the upcoming Competitiveness Fund). 3. Require EU content compliance in public procurement procedures involving clean technologies (e.g. EV batteries, wind power, semiconductors, defence systems) identified in the Net-Zero Industry Act (NZIA) and the low-carbon lead markets to be defined in the Industrial Decarbonisation Accelerator Act. 4. Establish EU-wide traceability and certification systems to verify the origin of strategic raw materials in line with CRMA benchmarks.
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Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

4 Mar 2025 · Exchange on FMG’s activities and recent projects

Meeting with Kurt Vandenberghe (Director-General Climate Action)

4 Mar 2025 · sustainable supply of Critical and Strategic raw materials for Europe

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

10 Dec 2024 · Discussion on the situation of the battery industry and battery raw materials

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

10 Dec 2024 · Discussion on recent developments in the battery value chain and critical raw materials and the importance of this sector in Europe

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

31 May 2024 · Exchange on implementation of the Critical Raw Materials Act