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Industrial Minerals Association - Europe

IMA-Europe

The Industrial Minerals Association - Europe represents the interests of industrial mineral producers in the European Union.

Lobbying Activity

IMA-Europe Urges Inclusion of Minerals in Advanced Materials Act

13 Jan 2026
Topic — The European Commission is consulting on legislation to strengthen advanced materials production capacities.
Message — The association wants industrial minerals recognized as advanced materials in the regulation. They also seek streamlined permitting and unified testing for dual-use technologies.123
Why — Mineral producers would gain access to strategic funding and significantly faster approval times.45
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Industrial mineral producers urge removal of complex Taxonomy rules

5 Dec 2025
Topic — The European Commission is reviewing rules for classifying sustainable economic activities and investments.
Message — The organization proposes simplifying the taxonomy framework and better aligning it with other regulations. They specifically recommend removing complex assessments and increasing industry engagement when developing criteria.123
Why — Reducing administrative requirements would lower compliance costs and improve the sector's overall competitiveness.4
Impact — Environmental groups lose oversight as rigorous verification for avoiding ecological harm is removed.5
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IMA-Europe urges EU to harmonize circular economy waste rules

6 Nov 2025
Topic — The European Commission is consulting on the new Circular Economy Act to boost sustainable production.
Message — IMA-Europe wants the EU to harmonize waste definitions to fix single market fragmentation. They suggest using a flexible directive to avoid adding unnecessary legal layers for businesses.12
Why — Standardized rules would lower cross-border transport costs and simplify permitting for mineral recycling operations.34
Impact — National regulators lose the ability to apply unique local standards for waste classification and transport.5
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Minerals Industry Seeks Recognition as Nature Credit Contributors

29 Sept 2025
Topic — EU roadmap establishing criteria for nature credits to reward biodiversity stewardship.
Message — The association requests recognition of the minerals sector as a key contributor to nature preservation. They emphasize their expertise in land restoration across extraction stages and want the sector included in nature credit schemes. They highlight existing biodiversity work including habitat creation, five million trees planted, and collaborative projects with conservation authorities.123
Why — This would reward their existing biodiversity investments and recognize their contribution toward closing the €48-65 billion annual EU nature funding gap.45
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Industrial Minerals Industry Demands Equal Treatment Across EU Carbon Markets

8 Jul 2025
Topic — Review of EU Emissions Trading System covering maritime, aviation, stationary installations and market reserve.
Message — The association requests equal treatment between ETS 1 and ETS 2 systems to prevent competitive distortions. They demand explicit recognition of specific mineral products like silica sand and ceramic clay on the carbon leakage list. They seek integration of lime-based mineral carbonation as a permanent carbon removal method within ETS compliance.123
Why — This would reduce their carbon compliance costs and protect them from international competition.456
Impact — Climate ambition suffers as the industry seeks to count existing carbonation processes toward emissions reductions.78
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IMA-Europe calls for exemptions to EU deforestation rules

13 May 2025
Topic — Amending the list of products regulated by the EU Deforestation Regulation.
Message — The organization requests that product samples for testing be excluded from the regulation. They want clarification that products only qualify if they use a relevant commodity. Finally, they propose exempting various industrial packing materials and containers.123
Why — These changes would improve operational feasibility and reduce compliance costs for producers.4
Impact — Environmental groups lose oversight regarding the deforestation impact of industrial packaging materials.5
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IMA-Europe backs taxonomy simplifications while seeking more industry input

26 Mar 2025
Topic — This consultation seeks to simplify EU Taxonomy disclosures and reduce corporate reporting costs.
Message — The association supports the 10% de minimis and 25% OpEx thresholds to simplify compliance. They also demand more transparency and direct industry involvement when drafting technical screening criteria.12
Why — These changes would significantly lower administrative costs and simplify complex compliance processes.34
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IMA-Europe highlights minerals’ vital role in water resilience strategy

4 Mar 2025
Topic — The European Commission is developing a multi-annual plan to achieve water resilience.
Message — The association wants quarry rehabilitation included in water management as a nature-based solution. They request recognition for minerals in purification and use of byproducts in conservation.12
Why — Positioning minerals as environmental solutions creates new commercial opportunities and improves the sector's regulatory standing.34
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Calcium carbonate industry urges changes to permanent carbon storage rules

15 Jul 2024
Topic — EU regulation on whether captured CO2 in products counts as permanently stored.
Message — CCA-Europe requests three changes: eliminate double counting by placing emission obligations on industries releasing CO2, not those capturing it; focus end-of-life criteria on recyclability rather than incineration; and expand the Annex to include precipitated calcium carbonate applications in paper and construction products.123
Why — This would prevent double counting of emissions and allow PCC producers to deduct captured CO2.45
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Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

IMA-Europe hereby wishes to raise concerns about the proposed amendment of Article 8 concerning the general requirements on substances, and more particularly on Part 2.(ii) concerning natural multi constituent material where the source is mineral. You will find our feedback in the attached document
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Response to Guidance to facilitate the designation of renewables acceleration areas

22 Feb 2024

Find attached the feedback by IMA-Europe
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Response to Revision of the definition of engineered nanomaterial in food

18 Dec 2023

The European Industrial Minerals Association (IMA-Europe) represents the industrial minerals producers in Europe. Being at the top of the supply chain, minerals are used in a variety of applications including cosmetics, feed additives, food contact materials, and many more. Annually, over hundred thousand tons of minerals are also used as raw material to produce food and food additives in the EU. Considering the importance of the food sector for our industry, we welcome the opportunity to provide comments on the draft amendment of the definition of engineered nanomaterial. IMA-Europe supports the need for regulatory coherence of the nanomaterial definition and the corresponding amendment of the definition of engineered nanomaterial in novel foods. We however identified two key issues in the draft delegated regulation triggering new challenges in the implementation of the definition: (i) the definition of 'manufactured material' and (ii) the solubility criteria. A proposed amendment together with rationale can be found in the attached document.
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Industrial Minerals Association Urges Mandatory Soil Acidity Standards

30 Oct 2023
Topic — The proposed directive aims to monitor and restore health to European soils.
Message — The association wants member states to set specific criteria for soil acidification. They also advocate for mandatory monitoring and liming to improve soil fertility.12
Why — Formal standards for soil acidity would increase demand for industrial liming products.34
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Response to European Critical Raw Materials Act

23 Nov 2022

Please find attached the feedback by IMA-Europe.
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Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

11 Oct 2022 · Industrial Emissions Directive

Minerals Industry Urges Flexible Directive Over Binding Restoration Regulation

22 Aug 2022
Topic — EU proposal setting legally binding targets for restoring degraded ecosystems across Europe.
Message — The association requests the proposal be changed from a regulation to a directive, allowing member states flexibility to adapt restoration goals to local conditions. They want recognition that mining is temporary land use that can enhance biodiversity, and call for economic impact assessment before implementation.123
Why — This would let them continue extracting minerals while avoiding rigid restoration requirements.45
Impact — Degraded ecosystems lose enforceable restoration timelines as flexible directives enable delays and exemptions.6
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Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur)

6 Jul 2022 · Industrial Emissions Directive

Industrial Minerals Association Urges Soil Acidity Monitoring in EU Soil Health Law

16 Mar 2022
Topic — EU directive to protect, sustainably manage and restore soils across Europe.
Message — The association requests that soil acidity be recognized as a threat and included in monitoring requirements. They want pH management promoted as part of sustainable soil management, with advice provided to farmers on the link between acidity and soil fertility.123
Why — This would create demand for their liming materials and soil improvers across Europe.45
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Industrial minerals industry warns against hazard-driven bans in cosmetics

29 Oct 2021
Topic — The European Commission is revising the Cosmetic Products Regulation under its chemicals strategy.
Message — The organization supports a risk management approach based on exposure routes rather than simple hazard properties. They request that product-specific risk assessments remain with specialized committees. They also advocate for exempting naturally occurring minerals from new nanomaterial definitions.123
Why — This would prevent costly product reformulations for chemicals that are safe under specific use conditions.4
Impact — Environmental goals suffer if natural products are hampered by being labeled as nanomaterials.5
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IMA-Europe urges EU to maintain mineralogical energy tax exemptions

20 Oct 2021
Topic — The European Union is currently updating energy taxation rules to meet climate neutrality targets.
Message — The association demands that the European Union reinstate mandatory tax exemptions for mineralogical processes. They call for a transitional phase to help companies switch to low carbon fuels. The group also seeks clearer legal definitions for the processing of extracted minerals.123
Why — This would prevent increased operating costs and preserve the industry's ability to compete globally.45
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Industrial Minerals Association urges recognition of soil acidity management in carbon farming

7 Oct 2021
Topic — EU initiative on carbon removal certification and carbon farming to achieve climate neutrality.
Message — The association requests that soil acidification be officially listed as a soil threat and that correcting soil acidity through liming be included in carbon farming policies. They argue liming improves soil health, increases carbon sequestration, and reduces greenhouse gas emissions.123
Why — Recognition would expand the market for their liming products used to correct soil acidity.45
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

The members of the Industrial Minerals Association Europe (IMA-Europe), representing more than 750 sites employing directly around 42.500 people acknowledge the European Commission’s review of the guidelines on State aid for environmental protection and energy 2014-2020 (EEAG). This new document represents a unique opportunity to improve and update the current regime. In addition to reflecting the latest EU regulatory and policy developments stemming from the low carbon transition affecting the competitiveness of our sector, ranging from EU energy, climate and environmental legislation to global trade and competition law developments over the last decade. For the industrial minerals sector, the state aid rules related to energy and environment are fundamental to ensure that the installations investing in energy efficiency as well as in low-carbon and sustainable manufacturing solutions can benefit from state aids.
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Industrial minerals industry demands recognition of soil acidification threat

9 Dec 2020
Topic — The European Commission is updating its strategy to ensure healthy soils by 2030.
Message — The organization urges the EU to officially recognize soil acidification as a serious threat and include soil pH as a primary monitoring parameter. They recommend promoting sustainable practices like liming to improve soil fertility and carbon sequestration.12
Why — This would boost demand for the industry's liming materials and inorganic soil improvers.34
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Industrial Minerals Association urges legal certainty for mining sites

30 Nov 2020
Topic — The European Commission is proposing legally binding nature restoration targets.
Message — The organization calls for secured access to land and clear criteria for mineral deposits to resolve competing land uses. They emphasize that any 'no deterioration' commitments must be based on scientific considerations and transparent processes.123
Why — The sector would gain investment security and predictable access to critical mineral deposits.45
Impact — Strict conservation efforts may be compromised by prioritizing economic extraction in protected areas.67
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Response to Sustainable Products Initiative

30 Oct 2020

The Industrial Minerals Association, IMA-Europe, and its members welcome the opportunity to share comments on the inception impact assessment of the SPPI. Minerals' unique properties provide specific functions in a myriad of products and processes. The magazines we read, the water we drink, the plastics in our cars and houses, the paints we use and the floor tiles we walk on are just some of the products that minerals "bring to life". As part of the new Circular Economy Action Plan (CEAP) the SPPI is one of the important legislative initiatives to close material loops and boost the circular solutions uptake. In accordance with what the inception IA mentions, we would support to 1. Improve Life Cycle Assessment reliable information on sustainability information flow across the value chains; 2. Focus on functionality rather than the recyclable rates and 3. No one fit all solution for all sectors in Green Public Procurement (GPP). To achieve those goals, we make the following proposals: 1. Life cycle assessment. The lifecycle of a product should be based on more than simply its recyclability rate. The recycling rate alone will not be enough to create a fully functioning circular economy in Europe. All significant stages of the product’s lifecycle need to be considered as there are often trade-offs between these. IMA reiterates its committed to continue to develop qualitative LCI to be used by our value chain stakeholders to conduct qualitative value chain/product assessments. Cooperation with the value chains using the LCI is already a common practice and is working in line with ISO 14040-14044 standard series and the verification process in place. 2. Functionality above recyclability rate. In the CEAP the mineralization is recognized as a path that contributes to climate neutral solution in the building sector. The inception IA mentions measures on the production process. We welcome the fact that the Commission intends to strengthen markets by increasing the availability of secondary raw materials. At the same time, the measures considered should be targeted at application and/or at sector level. Imposing a recycling rate for a product that will not deliver on the functionality (as a result shorter lifetime) should be avoided as it goes against the durability of circular solutions. 3. Green public procurement. The inception IA implies that green public procurement (GPP) has so far not achieved the desired results. While GPP accounts for 14% of EU GDP, there are strong indications that member states often still put most emphasis on the price during a public procurement process rather than on the quality of lifecycle costs of a product or service. To solve this issue, the CEAP suggests the possibility to consider the introduction of mandatory GPP criteria and minimum GPP targets. The Commission should also assess whether instead of EU-wide mandatory criteria, it is not more effective to provide guidance and capacity building to member states to help the market uptake of sustainable public procurement offers. It is too premature to consider minimum GPP targets already before having tested the effectiveness of mandatory criteria on EU-level. The use of more circular procurement thinking should be requested by the highest levels of government, giving procurement managers a clearer mandate to develop and implement such solutions that deliver on societal services and policy objectives. 4. Prior to undertaking any new legislative measures, a thorough ex-ante impact assessment should assess the social, economic, and environmental impacts on the EU industry and its impact on the competitiveness.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

The Industrial Minerals Association Europe (IMA-Europe) welcomes the opportunity to provide its feedback to the European Commission roadmap on the EU Action Plan Towards a Zero Pollution Ambition for air, water and soil. It is a priority for the minerals sector to engage in a constructive dialogue with policymakers to ensure that the EU environmental objectives are achieved together alongside socio-economic development and competitiveness. We would like to share several recommendations on the way forward (see attached document).
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

The Industrial Minerals Association-Europe (IMA-Europe) welcomes the opportunity to provide its feedback to the European Commission on the inception impact assessment, Regulation EC 166/2006. It is only through these assessments that regulations, such as the European Pollutant Release and Transfer Register, can be designed fit-for-purpose. Therefore, it is a priority for the mineral sector to engage in a constructive dialogue with policymakers to ensure its successful review. We would like to share several recommendations on the way forward (see attached document).
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Sept 2020

A framework to facilitate renewable energy IMA-Europe acknowledges the announcement for the revision of the Renewable Energy Directive (RED II) under the EU Green Deal and is willing to contribute to its debate. IMA-Europe acknowledges the European Commission (EC) initiative for a review of the renewable energy rules. The current roadmap, considering a possible upward review of the minimum 32% EU target for renewable energy, aims to be aligned with the impact assessment of the 2030 Climate Target Plan announced for September 2020. The increased political pressure to boost renewable for energy other than electricity could have a notorious impact on the mineral sector. Recognising that, for an industry operating in the EU, energy costs are still much more expensive that in non-EU jurisdictions, under the current socio-economic crisis, the EC shall consider the economic impact of this decision and the potential impact on industrial competitiveness. OUR CALLS • Any revision of RED II must be based on targeted and solid ex-ante impact assessment. The renewable energy target is not a standalone element, but RED II is a comprehensive file with a potential impact on other EU legislations related to climate & energy such as the Energy Efficiency Directive and EU ETS. The current 2030 Climate Target Plan analysis should assess the bottlenecks to meet the existing targets at various MS’s and address these bottlenecks for a common action at EU-27 level. Increasing targets without this prior assessment will result in higher burden for already advanced countries implementing the RED objectives and will result in higher compliance gap for countries lacking behind. • Any revision of RED II and increase of the deployment rate of renewables shall be accompanied of appropriate public funding support. Considering the current economic situation and production shrinkage due to the COVID-19 pandemic, the regulatory compliance cost for EU industry adapting to a potential increased ambition RED shall be considered appropriately by authorities at EU and National level. The mineral industry is working on replacing fossil fuels with renewable energy sources where possible, while adequate public support should remain available. The special case of hard-to-decarbonise industry sectors, shall be recognised by the policy makers. • Coherence in policy making is required. Any revision of RED II must consider on-going evaluations in other legislative initiatives. In a still under construction scenario of the Green Deal, we are concerned about the EC moving in a file, while other legislative files with a direct impact on RED II are still to be defined. A clear example of this concern is the on-going Monitoring and Reporting Regulation (MRR) under the EU ETS. Within the current RED II roadmap is explicitly mentioned the potential impact assessment will look at several options. Option 4 “would result in potentially amending the articles of REDII”, including the sustainability and GHG gas emissions saving criteria (Article 29-31). Considering that the criteria of compliance are designed to define requirements for sectors producing power, heating & cooling; it is not clear if and how these criteria would apply to industrial installations in the scope of ETS. Consequently, a robust assessment and guidance for ‘fit for purpose’ are required to avoid additional burden.
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Minerals industry urges broad definitions for sustainable investment reporting

4 Sept 2020
Topic — The European Commission is defining rules for companies to disclose their taxonomy-aligned activities.
Message — The group demands a broad definition of sustainable activities to ensure continued private investment. They also request that the taxonomy remain voluntary and avoid unnecessary bureaucracy for smaller businesses.12
Why — These proposals would protect the sector's competitive position and lower administrative compliance burdens.34
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Response to Review of the general product safety directive

1 Sept 2020

The European Industrial Minerals Association (IMA-Europe) is pleased to submit the attached comments to the consultation on the review of the General Product Safety Directive.
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Response to Environmental claims based on environmental footprint methods

14 Aug 2020

Inception impact assessment: Legislative proposal on substantiating green claims (14 August 2020) The Industrial Minerals Association, IMA-Europe, and its members welcome the opportunity to comment on the Commission Roadmap on Substantiating Green Claims. Minerals' unique properties provide specific functions in a myriad of products and processes. The magazines we read, the water we drink, the plastics in our cars and houses, the paints we use and the floor tiles we walk on are just some of the products that minerals "bring to life". The Commission back in 2013 published a recommendation (2013/179/EU) for the uptake of the Product/Organisation Environmental Footprint (PEF & OEF) in a voluntary manner, and called for volunteers to test PEF/OEF methods on products and organisations. Due to the use of minerals in multiple applications, IMA was a stakeholder in some of the tested PEF’s (e.g. Intermediate pulp & paper, paints, wine, beers, olive oil, thermal insulation). IMA delivered qualitative Life Cycle Inventories (LCI’s) so the downstream users could develop the PEF’s for their products. The outcome of the methodology testing in various PEF’s indicated that: • The lack of qualitative input data is a shortcoming for reliable PEF statements. • Not all the 16 environmental impacts proposed have the same level of maturity and quality. • These shortcomings are supported by various LCA practitioners. The position of IMA, it is based on its experience in multiple PEF’s, the shortcomings listed above and bottlenecks listed in the inception impact assessment document (Input data quality, Non mature models for all the 16 impacts, Uncertain outcome, Higher costs): 1. IMA is committed to continue to develop qualitative LCI to be used by our value chain stakeholders to allow the assessment along the value chain. Cooperation with the value chain actors using an LCA approach is already a common practice in the minerals sector and is working in line with ISO 14040-14044 standard series and the verification process in place. 2. Focusing only on the PEF will be of limited value for the overall objectives of Green Deal and New circular economy action plan. The new policy initiatives should consider sustainable operations at a larger scale. New policy initiatives should extend the product performance notably with functionality and durability criteria. 3. For any new legislative initiative, a thorough ex-ante impact assessment should assess the impacts (social, economic, and environmental) and how the initiative is impacting the competitiveness of EU industry. 4. Before the above shortcomings are addressed reliably, the IMA position will be to keep the existing status-quo with the baseline scenario: No modification to the 2013 Recommendation and no further action.
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IMA-Europe calls for risk-based chemical assessments and value-chain focus

20 Jun 2020
Topic — The consultation explores a strategy to protect citizens and the environment from hazardous chemicals.
Message — The association supports the 'one substance – one assessment' approach to eliminate duplicate reviews between different agencies. They argue that regulatory focus should remain on risk management rather than hazardous properties. They also propose replacing concepts like 'essential chemicals' with a broader 'value chain' perspective.123
Why — Streamlined assessments and risk-based management would reduce regulatory burdens and protect industrial competitiveness.45
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IMA-Europe seeks delayed timelines and public funding for climate

30 Apr 2020
Topic — This initiative aims to enshrine the European Union's 2050 climate neutrality objective.
Message — The association requests delaying legislative timelines to September 2020 because of the pandemic. They also advocate for using standard democratic procedures rather than simplified executive rules.12
Why — Increased public investment and regulatory clarity would lower the cost of industrial modernization.34
Impact — Environmental groups may see delayed progress if the Commission postpones key legislative initiatives.5
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Response to EU rules on industrial emissions - revision

21 Apr 2020

The Industrial Minerals Association Europe (IMA-Europe) welcomes the opportunity to provide its feedback to the European Commission on the inception impact assessment, Directive 2010/75/EU. It is only through these assessments that directives such as the Industrial Emissions Directive (IED) can be designed fit-for-purpose. Therefore, it is a priority for the minerals sector to engage in a constructive dialogue with policymakers to ensure that the EU environmental objectives will be achieved together in line with the socio-economic developments and sector competitiveness. Please, find attached the Industrial Minerals Association Europe (IMA-Europe) comments on the Inception Impact Assessment for the revision of the Industrial Emission Directive.
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Mineral Industry Urges Fair Treatment in EU Green Taxonomy

20 Apr 2020
Topic — The EU is defining environmentally sustainable activities to direct investments toward climate objectives.
Message — IMA-Europe argues that activities not yet classified by the taxonomy must not be automatically deemed unsustainable. They also call for proportional reporting requirements and industry representation in technical decision-making bodies.123
Why — This protection prevents the mineral sector from losing access to vital investment capital.4
Impact — Workers in traditional industrial sectors may suffer as investment shifts away from their activities.5
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Industrial Minerals Sector Urges Industry Protection in Climate Plan

14 Apr 2020
Topic — The EU proposes increasing greenhouse gas emission reduction targets for 2030.
Message — IMA-Europe demands a robust impact assessment to ensure EU industry remains competitive globally. They call for increased carbon leakage protection and financial support for technological innovation in the mineral sector.123
Why — Strengthened protections and subsidies would lower the financial burden of industrial decarbonization.45
Impact — Environmental groups may find biodiversity and energy efficiency goals sidelined by industrial interests.6
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Industrial minerals sector demands tax exemptions and Council unanimity

31 Mar 2020
Topic — The European Commission is revising energy taxation to align with 2050 climate goals.
Message — IMA-Europe demands that the current mineralogical processes exemption remains for energy-intensive companies. They also insist tax proposals continue to be adopted by unanimity in the Council. The group calls for robust impact assessments before any revision of tax rates.123
Why — This would prevent energy cost increases that could harm competitiveness in international markets.4
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IMA-Europe urges non-binding guidelines for sustainability reporting

27 Feb 2020
Topic — A consultation on revising how companies report their environmental and social performance impacts.
Message — The group supports using non-binding guidelines for sustainability reporting instead of mandatory rules. They argue this approach provides flexibility and prevents new costs for smaller companies.123
Why — Companies would avoid the high costs of complying with strict new reporting standards.4
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Industrial Minerals Association opposes bans on naturally occurring minerals

11 Feb 2020
Topic — The European Commission is establishing a list of prohibited co-formulants for pesticides.
Message — The association requests removing six minerals from the draft list of unacceptable pesticide additives. They argue these substances are safe under current workplace laws and lack formal harmonized classification.12
Why — This would preserve market access and prevent the loss of essential mineral ingredients.3
Impact — Professional users could face higher exposure to substances linked to carcinogenicity and mutagens.4
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IMA-Europe demand s Climate Law protect s industrial competitiveness and predictability

5 Feb 2020
Topic — Establishing a legislative framework to achieve EU climate neutrality by 2050.
Message — IMA-Europe support s the 2050 target but demand s the law preserve global competitiveness. They request that target revision s use robust assessment s and clear calculation methods. They also seek public support to help modernize carbon-intensive industrial processes.123
Why — The sector woul d secure the regulatory predictability and public funding nee d e d for expensive modernization.45
Impact — Environmental advocates lose if requirements for robust impact assessments delay the implementation of stricter targets.6
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Response to A new Circular Economy Action Plan

20 Jan 2020

Industrial Minerals Association Europe (IMA-Europe) represents the industrial Minerals producers in Europe. Industrial minerals are indispensable to society in daily manufactured goods as well as green applications. They are increasingly essential to high-tech as well as environmentally friendly products and technologies such as wind turbines and photovoltaic panels. Wind turbine blades are essentially fibreglass which contains almost 100% minerals (kaolin, borates, alumina, lime, silica sand, soda ash, calcium carbonate). Industrial minerals therefore play a significant role in the transition to a low-carbon economy. We welcome the European Commission’s European Green Deal announcement, Commission’s New Circular Economy Action Plan objective to continue to transition towards a Circular Economy and the link of EU initiatives with the UN Sustainable Development Goals (SDGs) to enhance competitiveness and growth. Following this support and commitment we would like to share with multiple reports illustrating the sector commitment and actions to deliver on these policy objectives: - Industrial Minerals (IM) are a net contributor to Circular economy. We have illustrated with multiple case studies how IM’s are contributing at different life cycle stages of multiple value chains. Link to report: Minerals Contribution to Circular Economy (2018) - Industrial Minerals are 50% recycled thanks to the collection and recycling of end products containing minerals. Examples: Glass 100% minerals and recycled up to 75%. Link to report: IMA Europe Recycling sheets (2018) - Industrial minerals contribution to Sustainable Development Goals (SDG’s) is mapped and reported in: Link to report: IMA contribution to SDG (2018) Aligned with these commitments and actions, IM sector is committed to continue, hoewer we would like to propose few suggestions to the Commission on: On the proposals put forward by the Commission: 1. Considering additional measures for new waste streams, we would like to refer to the Construction and Demolition Waste (CDW). o The CDW mixed flow, needs better conditions for deconstruction and better waste flows to be separated in order to boost their recycling. 2. EU market for secondary raw materials remains to be further developed. Less competitive material due to price, concerns on safety, quality & performance. o The waste legislation sometimes creates legal and practical bottlenecks for a wider uptake and valorisation of secondary raw materials o The definition of the same material and/or product with different names (such as by-product, non-hazardous waste, hazardous waste,) in different countries makes their transport and valorisation not possible o Simplify/clarify the end-of-waste criteria especially linked with the complexity of Waste & REACH legislation New ideas to be considered: 3. The synergies between primary and secondary raw materials should be better integrated into the new circular economy action plan. o The valorisation of the Critical Raw Materials (CRM’s) from historical mining waste streams is a concrete impactful step to be considered as part of the revised action plan on circular economy. o Cross-sectoral cooperation and exchange of multiple flows (raw materials, waste flows, heat, energy, water) between different sectors to deliver on integrated value chains and material flows.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

The members of the Industrial Minerals Association Europe (IMA-Europe), representing more than 750 sites employing directly around 42.500 people, are aware that biodiversity is crucial to the future of humanity and have agreed to work towards its conservation and enhancement actively. OUR KEY MESSAGES 1. Industrial minerals play a significant role in the transition to a low-carbon economy. 2. The extractive activities and the products have a potential impact on biodiversity, at operational sites and within each local community; The sector aims to mitigate these impacts in close cooperation with stakeholders. 3. Biodiversity must be taken into account before, during and after extraction, and its successful management can potentially lead to the creation of new natural areas and habitats. Reconciling Nature and Extraction is possible. Open surface mining often provides perfect conditions for unique habitat creation. 4. Occupying < 0.01% of the EU land area, the sector is highly regulated through land planning and permitting procedures, including environment and biodiversity preservation. Efficiency in the sector can be improved even further through a holistic approach. 5. New procedures and legislation require transparency, certainty, timeline. 6. Criteria defining mineral deposits of local, regional, national or European importance are needed to clarify competing land uses and ensure a level playing field assessment for the mining operations. 7. EU’s ambition for the ‘2030 Biodiversity Strategy’ should be used to underline the need to promote increased investment in the EU’s existing natural assets, with a stronger focus on quality than quantity of ecosystem services. 8. No-go” commitments should only be made if practical issues on definitions, process and management of protected areas are sufficiently scientific and transparent, moreover if issues around the use of protected area boundaries in informing land-use decisions are adequately resolved through an open, transparent, multi-stakeholder process. 9. Natural reserves are essential to offer ecosystems to fauna and flora, but we will need to reconcile these protected areas with other economic and industrial activities. The protected areas shall not be sanctuaries. The industrial minerals industry has proven its capacity to operate in natural reserves with a net benefit for the biodiversity.
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Response to Revision of the Drinking Water Directive (RECAST 2017)

30 Mar 2018

The European Borates Association (EBA), representing the importers and manufacturers of the borate substances welcomes the opportunity to submit comments on the Commission proposal for a recast of the Drinking Water Directive - COM(2017)753 final. Please find enclosed the EBA feedback, outlining the main EBA concerns, which can be summarized as follows: The EBA is disappointed that the Commission has decided to maintain the parameter for boron in Annex I of the Directive at 1 mg/L, despite the fact that the WHO has recommended to raise this value to 2.4 mg/L. The EBA believes that the Commission’s rationale for not increasing the limit is a weak argument, and agrees with the WHO that it disregards the impact of the introduction of desalination costs in Member States that may have limited choices as to new resources of drinking water. According to the WHO report, this also ignores consideration of “running and renewal costs in meeting the existing limit values…”. Moreover, this WHO report states, in the light of current scientific and technical progress, that raising up the value for boron from 1 mg/L to 2.4 mg/L, represents a high level of health protection. Moreover, requests to revise the original, stricter value for boron came from the European Parliament many times from 2012 to 2017 (E-0054582012, E-010109/2014, P-000848-16, E-009146/2016, P-005563-17). European Parliament stresses out the importance to be in line with the WHO’s guidelines (E-010109/2014). The Commission stated that Annex I to the Directive will be reviewed in the light of scientific and technical progress, in the name of the WHO (the Commission answer to P-000848-16). In conclusion, the EBA calls on the European Commission, the European Parliament and the European Council to follow the WHO’s recommendation to raise the limit value for boron from 1 mg/L to 2.4 mg/L. Maintaining the current value is unnecessarily strict and does not provide any additional health benefits, while involving high running and replacement costs for existing installations and higher costs for the introduction of desalination plants.
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Borate industry disputes health risk claims in cosmetic ban

20 Jul 2017
Topic — Proposed ban on borate substances in cosmetic products following chemical classification changes.
Message — The group objects to claims that borates pose a potential risk to human health. They argue that scientific evidence proves these substances are safe within specific limits. They request the ban be justified by existing alternatives rather than safety issues.123
Why — Clarifying that the substances are safe protects the industry's reputation and market standing.4
Impact — Manufacturers and consumers lose specific ingredients despite scientific opinions confirming their safety.5
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Response to EMAS reference document for best environmental management practice in Food and Beverage Manufacturing

14 Nov 2016

• We have not identified any sound justification or data in the JRC background document referenced in the proposal that would support inclusion of BEMP 3.5.1 (Cross-flow rough beer filtration) • We express concern that this BEMP would create commercial interference without a sound scientific basis • The specific section of the JRC document is inconsistent with the Best Available Techniques (BREF) for the Food, Drink and Milk industries, which identified other Best Available Techniques (BAT) including diatomaceous earth (DE or kieselguhr) filtration • Consequently, we respectfully request that the Commission either omit section 3.5.1 from its proposal or replace it with the two BATs identified in the Food Drink and Milk industries BREF Membrane cross-flow filtration is but one technology utilized in the agrofood industry. It cannot be declared to be the best environmental management practice. It is one of the many filtration and separation techniques available to achieve set clarification targets. Decantation, centrifugation and direct flow filtration (with or without filter aid and/or filter media) all are recognized separation techniques used extensively in the beverage industry. Direct flow filtration using DE or kieselguhr as a filter aid is a major microfiltration technology recognized worldwide and used extensively used throughout the agrofood industry, including manufacturing beer. In breweries DE filtration ensures the right quality of beer before bottling. Beer, as a natural product, always will exhibit varying filterability. The ability of brewers to adjust to various filtration requirements therefore is essential. Pre-coat filtration with kieselguhr is versatile, gives excellent filtration results, is easy to implement and is of reasonable cost. A wide range of diatomaceous earth grades of different permeability is readily available on the market from several suppliers. While the EMAS reference document to the BEMP highlights the circular economy in support of membrane filtration, there is no mention of the benefits and success of reusing spent DE filter cake as a soil additive. The reuse of spent DE filter cake is one of the positive attributes inherently recognized in the BREF for the Food, Drink and Milk industries (section 5.2.9). Apart from improving the organic matter content of soil, spent DE filter cake improves soil tilth and water-holding capacity thereby reducing irrigation needs. Similarly, it reduces chemical fertilizer requirements by trapping and holding minerals from fertilizers that otherwise will leach from the soil. Spent DE filter cake, which some have characterized as a waste stream, can best be used as a means to support sustainable agriculture. It should be recognized as a manufacturing product whose reuse should be encouraged as a BEMP. Membrane filtration technologies create waste streams that, by comparison, are more concentrated and more difficult to recycle, such as spent cleaning chemicals (caustic/acid), detergents and spent enzymes. Their chemical oxygen demand should be considered. The membranes themselves, after their useful life, also are difficult to recycle. In addition, the energy and water use of membrane filtration units is much higher per hectolitre of beer than with DE filtration. DE filtration has proven to be a technology that is flexible to accommodate the filtration of different beer types and also that can be optimized to reduce DE, energy and water usage. Moreover, the spent DE filter cake can be a product reused as a soil additive, thus contributing to the circular economy. The Industrial Minerals Association–Europe, IMA-Europe, is an umbrella organisation which brings together a number of European associations specific to individual minerals: Calcium Carbonates (GCC/PCC), Dolomite, Andalusite, Bentonite, Borates, Diatomaceous earth, Feldspar, Kaolin, Lime, Mica, Plastic Clays, Sepiolite, Silica, Talc, Perlite, Vermiculite.
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Meeting with Marianne Thyssen (Commissioner) and

2 May 2016 · Revision of the carcinogens Directive

Meeting with Raquel Lucas (Cabinet of Vice-President Valdis Dombrovskis)

22 Apr 2016 · Exchange of views on the revision of the Carcinogens Directive and the social dialogue agreement on the matter.