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International Copper Association Europe

ICA Europe

The International Copper Association Europe represents companies involved in copper mining, smelting, and recycling.

Lobbying Activity

Meeting with Kurt Vandenberghe (Director-General Climate Action) and EUROMETAUX and

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

Response to Review ecodesign electric motors and variable speed drives.

22 Sept 2025

International Copper Association Europe appreciates the opportunity to provide feedback on the revision of the Ecodesign requirements for electric motors and variable speed drives. Please, find our position attached. ICA Europe main points are as follows: 1) Expanding IE4 as a minimum efficiency level beyond the current 75-200 kW range, to a broader scope, e.g. one between 7.5 kW and 1000 kW, would come with significant annual energy savings. As an illustration, the energy savings in the segment M3-M3v (7.5-75 kW) are estimated in the range of 4 TWh/year of electricity. 2) A life cycle assessment comparing IE3 with IE4 motors in this power range shows that most environmental impacts are lower for the latter efficiency level. 3) When comparing the material use of two energy efficiency levels, it is fundamental to consider not only the bill of materials of the motor itself (which increases for higher energy efficiencies), but also the material need in generation, transmission and distribution assets upstream of the motor (which decreases with lower motor losses). 4) Higher efficiency requirements for motors lead to a net saving of critical raw materials at system level (motor + electricity generation assets), provided the motor technology deployed does not make use of rare earths. 5) Induction motors are made of materials that are highly circular. Recycled content mandates are unnecessary for copper. 6) The tools used for assessing different design options in the framework of Ecodesign / ESPR should reflect accurate and realistic values for the environmental impacts of copper.
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Copper industry urges expanded ETS aid to protect EU production

5 Sept 2025
Topic — Review of state aid for electricity-intensive sectors facing carbon leakage from EU ETS costs.
Message — The organization requests inclusion of copper mining in eligible sectors and an increase in the refining benchmark from 0.31 to at least 0.4 MWh/t. They argue current criteria should remain unchanged for existing sectors but emphasize all Member States must provide compensation to eligible industries.123
Why — This would reduce electricity cost disadvantages versus global competitors and support EU recycling capacity.456
Impact — No specific groups identified as harmed by these proposals in the feedback.
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ICA Europe warns chemical restrictions threaten strategic copper production

11 Aug 2025
Topic — The consultation addresses rules regarding the international trade of certain hazardous chemical substances.
Message — The association opposes restricting coal tar pitch, arguing it is essential for smelting operations. They seek specific exemptions to ensure the copper industry remains stable and productive.12
Why — Maintaining access would prevent factory shutdowns and reduce reliance on foreign copper imports.34
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Copper Industry Urges EU to Expand Critical Materials Recovery List

23 Jul 2025
Topic — EU regulation defining products and waste streams for critical raw materials recovery programmes.
Message — The organization requests adding three copper-rich streams to the EU's recovery list: heat exchangers from heat pumps and air conditioners, solar thermal collectors, and copper tubes from building infrastructure. They argue these additions would capture significant copper stocks currently missing from the regulation.12
Why — This would secure access to tens of thousands of tonnes of recyclable copper annually for their industry.3456
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and Jastrzębska Spółka Węglowa S.A. and

24 Jun 2025 · Implementation of Critical Raw Materials Act

Meeting with Veronica Manfredi (Director Environment)

6 Jun 2025 · The participants discussed the importance of the EU copper industry to the Green transition, environmental protection measures and the Commission’s intention to develop a harmonised environmental quality standard for copper in surface waters.

Meeting with Léon Delvaux (Director Trade) and EUROMETAUX and

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

Meeting with Aurel Ciobanu-Dordea (Director Environment)

13 May 2025 · Exchange of views on the Circular Economy Act

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

9 Apr 2025 · Operations in the EU and decarbonisation challenge, Discussion on Clean industrial Deal and the Steel and Metals Action Plan

Meeting with Petr Bystron (Member of the European Parliament) and Rio Tinto and

9 Apr 2025 · European single market

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

7 Apr 2025 · Clean Industrial Deal, Electrification Action Plan, Affordable Energy Plan, CISAF

Meeting with Dan Jørgensen (Commissioner) and

14 Mar 2025 · Clean Industrial Deal, Affordable Energy Action Plan and new State aid Framework (CISAF), Electrification Action Plan

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

13 Mar 2025 · Omnibus

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Deutsche Bank AG and

12 Mar 2025 · Meeting of the South America Critical Raw Materials (CRM) Coalition of the Willing – Dialogue with private and public sector stakeholders, and financial institutions on sustainable critical raw materials value chains in Latin America.

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

10 Mar 2025 · Exchange of views on proposals on crucial aspects for the competitiveness of the copper industry: energy prices, state aid, decarbonization and circular economy.

Meeting with Radan Kanev (Member of the European Parliament) and EUROMETAUX and

6 Mar 2025 · European Energy Forum- Energy intensive industries

Meeting with Bruno Tobback (Member of the European Parliament)

20 Feb 2025 · Water Directive

Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

10 Feb 2025 · copper

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and EUROMETAUX and European Aluminium AISBL

29 Jan 2025 · End of life vehicles

Meeting with Giorgio Gori (Member of the European Parliament)

21 Jan 2025 · Presentation of priorities and upcoming Clean Industrial Deal

Meeting with Radan Kanev (Member of the European Parliament)

21 Jan 2025 · Policy perspectives European copper industry, 2024-29

Meeting with Bruno Tobback (Member of the European Parliament) and Aurubis AG and Atlantic Copper S.L.U.

21 Jan 2025 · Situatie in de Belgische en Europese Metallurgie

Meeting with Aura Salla (Member of the European Parliament)

20 Jan 2025 · Carbon Border Adjustment Mechanism (CBAM), Competitiveness Compass

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

29 Nov 2024 · Recommendations for an Electrification Action plan in Europe

Meeting with Bruno Tobback (Member of the European Parliament)

24 Oct 2024 · CRMA

Meeting with Lina Gálvez (Member of the European Parliament)

24 Oct 2024 · Copper industry

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

16 Oct 2024 · Surface water and groundwater pollutants

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

16 Oct 2024 · Situation of european copper industry

Meeting with Bruno Tobback (Member of the European Parliament)

23 Sept 2024 · Verwachting voor de nieuwe legislatuur en uitdagingen voor de Europese kopersector

Meeting with Hildegard Bentele (Member of the European Parliament)

10 Sept 2024 · Critical Raw Materials

Meeting with Hildegard Bentele (Member of the European Parliament)

16 Jul 2024 · Critical Raw Materials

Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič) and Aurubis AG and

16 Jan 2024 · Clean air

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and Aurubis AG and

16 Jan 2024 · Clean air

European Copper Industry Seeks Higher Free Emissions Allowances

21 Dec 2023
Topic — EU updating carbon market free allocation rules under Fit for 55.
Message — The industry requests separate benchmarks for sectors unable to use biomass, continued support for chemical energy from raw materials, and maintaining the 0.97 process emissions allocation factor. They argue current proposals penalize efficient copper technologies and threaten decarbonization investments.123
Why — This would preserve free allowances worth hundreds of millions annually for production.45
Impact — Climate goals lose as reduced allocation hampers 600M EUR yearly decarbonization investments.67
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European Copper Institute seeks stronger rules for vehicle recycling

4 Dec 2023
Topic — Revision of EU rules for collecting, recycling, and disposing of end-of-life vehicles.
Message — The group urges prioritizing the dismantling of copper wiring and stronger EU-level export controls. They support excluding copper from recycled content targets and seek exemptions from specific chemical restrictions.123
Why — The industry would recover billions in value by securing more recycled copper.4
Impact — Third-country processing centers lose business as the EU prioritizes automated domestic sorting.5
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European copper industry urges simpler EU sustainability reporting rules

1 Dec 2023
Topic — This consultation seeks to identify and eliminate unnecessary reporting requirements in EU law.
Message — They want EU standards fully aligned with the global reporting framework. They also seek legal clarity and flexibility for future sustainability audits.123
Why — Clearer rules would provide legal certainty and prevent excessive investment in software.45
Impact — Broad stakeholder groups could lose access to specific and granular sustainability data.6
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Meeting with Adam Jarubas (Member of the European Parliament) and European Chemical Industry Council and

15 Nov 2023 · EFSW2023: Taking stock of progress on fire safety – what should the Commission and Parliament do to improve fire safety in Europe?

Meeting with Kadri Simson (Commissioner) and

23 Oct 2023 · Roundtable meeting with 10 Secretary Generals and CEOs of the Electrification Alliance on the revised Renewable Energy Directive (revised REDII), electricity market design, grids and storage.

Meeting with Niels Fuglsang (Member of the European Parliament)

18 Oct 2023 · The Energy Efficiency Directive

Copper industry demands financial support for carbon capture tech

31 Aug 2023
Topic — The initiative evaluates measures to optimize EU-wide carbon capture and storage infrastructure.
Message — The association calls for a legal basis for underground storage in all member states. They advocate for financial compensation for every tonne of CO2 that is captured and stored.12
Why — Financial support would help mitigate high costs that producers cannot pass on to consumers.3
Impact — Public budgets would be strained by providing ongoing financial compensation to industrial firms.4
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ICA Europe urges flexible standards for environmental claims

20 Jul 2023
Topic — Legislation requiring companies to prove environmental claims using standard footprint methods.
Message — ICA Europe requests that multiple assessment methods be accepted. They advocate for harmonized recognition of labelling schemes. They also oppose banning claims on products containing hazardous substances.123
Why — This allows the industry to use existing schemes and avoid costs of new EU methodologies.45
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Meeting with Dimitri Lorenzani (Cabinet of Vice-President Maroš Šefčovič) and EUROMETAUX and

7 Jul 2023 · Critical Raw Materials Act

European Copper Institute calls for mandatory building electrical checks

26 May 2023
Topic — This consultation addresses the EU's action plan to accelerate heat pump market deployment.
Message — The institute suggests making electrical inspections mandatory before heat pump installation to assess building readiness. They advocate for financial incentives to cover the costs of upgrading domestic electrical wiring.12
Why — Compulsory wiring upgrades and manufacturing support would significantly boost industrial copper demand.34
Impact — Households with obsolete wiring may face high costs for mandatory electrical upgrades.56
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European copper industry urges emergency price caps for industry

22 May 2023
Topic — Revising EU electricity market design to improve resilience and reduce energy prices.
Message — The organization calls for including electro-intensive industries in emergency price protections. They propose an automatic mechanism to stop fossil fuel prices from inflating electricity costs. They also seek help managing risks associated with renewable energy contracts.123
Why — Lower electricity prices would ensure global competitiveness and support investments in carbon-neutral production.45
Impact — Fossil fuel power plants would lose revenue as their price-setting power is limited during crises.67
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Meeting with Henrike Hahn (Member of the European Parliament, Shadow rapporteur) and EUROMETAUX and Rud Pedersen Public Affairs Brussels

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

Meeting with Franc Bogovič (Member of the European Parliament, Rapporteur for opinion)

9 May 2023 · Meeting on Critical raw materials

European Copper Institute calls for inclusion in EU climate taxonomy

3 May 2023
Topic — This consultation establishes criteria for economic activities that contribute to EU environmental objectives.
Message — The association argues for the inclusion of copper production as a substantial contributor to climate change mitigation. They request the adoption of technical standards previously developed by the Platform on Sustainable Finance.12
Why — Official recognition would allow copper producers to access new streams of green financing.3
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Aurubis AG

19 Apr 2023 · Sustainable Finance Taxonomy

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Aurubis AG

19 Apr 2023 · Sustainable Finance Taxonomy

Meeting with Michal Wiezik (Member of the European Parliament)

29 Mar 2023 · Wastewater heat recovery

Meeting with Milan Brglez (Member of the European Parliament, Rapporteur)

21 Mar 2023 · Water legislation

Meeting with Dan-Ştefan Motreanu (Member of the European Parliament, Shadow rapporteur) and EUROMETAUX and International Zinc Association

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

Copper Industry Urges Proportionality in New Air Quality Rules

14 Mar 2023
Topic — Revision of EU air quality legislation to align with health recommendations.
Message — The institute requests that the directive includes proportionality principles and target values. They argue further reductions should be avoided for activities where costs are disproportionately high. They insist the Industrial Emissions Directive remain the primary regulatory framework.123
Why — This would lower their long-term compliance costs and preserve their global market competitiveness.4
Impact — Citizens and environmental groups lose if cost-benefit analyses are used to limit pollution reductions.5
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Copper Industry Urges Strategic Inclusion in EU Materials Act

24 Nov 2022
Topic — The European Commission is proposing measures to secure mineral supplies for the green transition.
Message — The association requests copper be designated as strategic to allow for faster project permitting. They also call for waste law reforms to improve the recovery of recycled metals.123
Why — Faster permitting and state aid would reduce investment risks and lower compliance costs for operators.45
Impact — Environmental and health groups could lose protections if chemicals like lead remain unregulated.6
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

The European Copper Institute welcomes the European Commissions (EC) ambition to evaluate the effectiveness of the EU Directive 2012/12/EC (also known as WEEE Directive) about waste from electrical and electronic equipment. WEEE represents the fastest growing source of waste in the European Union (EU). Given that e-waste will reach significantly higher levels in the next decades due to the electrification efforts, the evaluation of the EU rules comes in a very timely manner. To deliver on the ambition to reduce e-waste generation, and to encourage collection, reuse and recycling of electrical and electronic products, as well as recovery of materials embedded therein, ECI wishes to contribute by pinpointing towards some problematic issues and areas for improvement. For this, there are two main considerations that should be made: 1. Significant losses occur at electrical and electronic equipment streams in the EU, when they become waste. They are either not collected or disappear from the EU statistics, leading to lack of sufficient data and unknown whereabouts. 2. Illegal exports and sub-standard treatment affect WEEE recycling, such as: Exports of WEEE to third countries with recycling facilities operating under low environmental performance standards Exports of WEEE as second hand, to circumvent controls (product export instead of waste, disappearing from EU statistics) Copper is required for the transition to climate neutrality due to its excellent electrical and thermal conductivity. It is important for ECI to highlight the challenges and give recommendations to make rules favourable for the minimization of losses. ECI asks the EC to take measures to address the collection challenges, being the main source of WEEE losses in Europe. These should include: Improved design for repair, re-use and recycling of electrical and electronic equipment in facilities with high environmental performance. Better dismantling and removability of certain components (e.g., batteries or printed circuit boards) could facilitate easier disassembly of products at end-of-life. Improved collection, separation, sorting and subsequent treatment of WEEE in the EU by underpinning investments in increasing recycling capacity, and with the use of state-of-the-art technologies operating upon high environmental standards to keep the value of materials within the loop for longer. Optimized arisings detection underpinned by economic incentives and increased enforcement in cooperation with targeted third countries to track illegal WEEE exports, prevent additional emissions from excessive transport, and exchange intelligence on imports of non-functional electronics, the residual effects of which outweigh any benefits from the import. Redesigning Extended Producer Responsibility schemes to incentivize producers to design their product to make it easier for the materials embedded therein, such as copper, to be reused, dismantled, and recycled at end-of-life. Harmonizing e-waste rules across EU legislation (e.g., Waste Shipment Regulation (WSR), Waste Framework Directive (WFD)) to: - Better control exports of WEEE so that they are collected and treated in a safe and sustainable manner, and to digitize the logistics system and facilitate better quality and wider data collection in line with the ongoing revision of WSR (electronic data sheet, electronic data interchange). - Harmonize waste classifications across Member States for more efficient recovery and recycling of metals fractions arising from WEEE, thereby helping in classifying shipments, reducing waiting times, and differentiating between waste shipments and illegal transports under the waste EU legal acquis. Raising consumer awareness and facilitating their increased access to dedicated and safe WEEE collection points at national level, or via additional informative measures (e.g., labelling clearly showing if a value material is embedded) or other incentives.
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Copper industry urges EU consistency with global chemical standards

17 Oct 2022
Topic — This consultation addresses proposed new hazard classes for the CLP Regulation.
Message — The group wants EU chemical labels to match international standards for global trade. They request that endocrine disruptor definitions require evidence of direct causal effects. They also argue against applying new hazard criteria to inorganic metals.123
Why — The industry avoids the high costs of reclassifying products during international trade.4
Impact — Environmental groups lose earlier health protections as the industry prioritizes global consensus.5
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Response to Type approval of motor vehicles regarding access to in-vehicle generated data

1 Aug 2022

On behalf of the European Copper Institute, please find attached our feedback to the call for evidence on the upcoming initiative on access to vehicle data, functions and resources.
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Response to Review of the Construction Products Regulation

11 Jul 2022

The European Copper Institute (ECI), welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR), in particular, ECI welcomes the stronger attention given to Life Cycle Assessments and circularity aspects. Copper is a highly circular material and benefits of recyclability must be considered for metals to better reflect advantages they can bring to the construction sector. Copper by-product iron silicate represents also an opportunity to be used as secondary material in construction to help some construction materials such as cement and concrete to meet recycled content and lower carbon footprint objectives. ECI aims to be part of the discussion with the European Commission, especially when it comes to delegated acts concerned with sustainability aspects (environmental impacts, recyclability indicators, methodologies).
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Copper industry warns against strict EU industrial emission rules

23 Jun 2022
Topic — The European Commission is revising legislation to reduce pollution from large industrial plants.
Message — The industry wants to keep flexible emission ranges rather than meeting the strictest possible limits. They argue that innovation plans should not be a legal requirement for getting an operating permit. Additionally, they oppose expanding these environmental rules to include the mining sector.123
Why — This would protect their economic viability and prevent expensive new reporting burdens.45
Impact — EU citizens lose the health benefits associated with the most ambitious pollution reduction targets.67
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Response to Sustainable Products Initiative

22 Jun 2022

ECI welcomes the European Commission’s ambition for a sustainable product policy framework. The EC proposal on Eco-design for Sustainable Products Regulation (ESPR) has great potential in driving product design towards more sustainability. However, to deliver on the ambition of reducing the negative life-cycle environmental impact of products on the EU market, the following considerations should be made: 1. Definitions - Clarity in the definition of products and physical goods, components, intermediates, and supply/value chains, can guarantee the better implementation of the Regulation. 2. Eco-design performance requirements - In the design of Delegated Acts setting product-specific performance requirements, sectoral specificities shall be considered and the sustainability improvement potential of systems (e.g. buildings) shall be valorised; with the Eco-design Forum’s role being essential for defining performance, selecting parameters and identifying criteria. - Materials’ circular use rate in products must also be underpinned by measures to accelerate industrial by-products’ use in other applications and, thus, mitigate the use of natural resources and avoid useless landfilling. 3. Potentially burdensome requirements - Boundary conditions need to be established about the traceability of actors across the supply chain and when this is deemed essential. - Means of verification for specific eco-design requirements shall be proportionate, and non-compliance allegations must be based on duly substantiated evidence. 4. Hazardous substances - Should not be restricted based on their presence per se in products, but upon the form in which they are found and the adverse impacts caused from the exposure of humans or the environment to these.
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International Copper Association seeks recycling-focused EU circularity indicators

3 Jun 2022
Topic — The European Commission is revising its framework for monitoring progress towards a circular economy.
Message — The industry requests that circularity be measured by recycling rates rather than recycled content. They also want indicators to reflect the climate benefits of copper in green technology.12
Why — Switching to recycling rate metrics better reflects the industry's existing mature recycling value chains.34
Impact — Environmental groups lose a metric that strictly focuses on the footprint of material production.5
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European Copper Institute seeks clearer corporate due diligence rules

23 May 2022
Topic — EU initiative to establish corporate obligations for assessing environmental and social impacts.
Message — The institute requests aligning the directive with UN Guiding Principles and simplifying value chain responsibilities. They also seek less burdensome requirements for tracing secondary raw materials like copper scrap.123
Why — This would prevent high costs and technical difficulties associated with tracing scrap metal.4
Impact — Environmental groups may see weaker enforcement of international treaties if monitoring requirements are reduced.5
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

23 May 2022 · ETS

Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur)

11 May 2022 · EPBD debate series “Road to zero-emission buildings” - online event

Copper industry seeks solar rooftop mandates and stricter electrical standards

12 Apr 2022
Topic — The European Commission is developing a strategy to accelerate solar energy deployment across Europe.
Message — The institute calls for mandatory national solar obligations for new buildings and major renovations. They also advocate for regular electrical inspections and optimized system-wide efficiency standards for cables and inverters.123
Why — Mandatory solar installations and larger cable requirements would drive significant demand for copper products.45
Impact — Building owners may face increased construction costs from mandatory solar and stricter wiring rules.6
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Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur) and European Alliance to Save Energy and

31 Mar 2022 · The Energy Performance of Buildings Directive - Stakeholder Event

Response to Amendment of Regulation 440/2008 (TMR) – 9th ATP / or possibly change to listing of references

16 Mar 2022

We kindly suggest to consider adding OECD 29 Guidance Document on Transformation/Dissolution of Metals and Metal Compounds in Aqueous Media (https://doi.org/10.1787/9789264078451-en). To determine water solubility of metals and inorganic substances, this test method is considered preferable over the OECD 105 water solubility test. This has been agreed with by ECHA. Additionally, the test is useful to determine the ecotoxicological properties of such substances, e.g. it is used to classify metals and metal compounds (see Annex IV to the CLP Guidance) and it can inform about the fate and behaviour in the environment.
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Response to Review of the CO2 emission standards for heavy-duty vehicles

14 Mar 2022

The European Copper Institute (ECI) welcomes the opportunity to comment on the Commission’s inception impact assessment on the Regulation setting CO2 emission standards for HDVs. One of the missions of the association is to promote the sustainable use of copper in electric vehicles. The fast development of battery technologies for passenger cars is enabling an acceleration in the decarbonization of heavy-duty vehicles (HDVs). Given the relatively low margins of HDV fleet operators (around 3% of revenues), the key driver to shift operators to a zero-emission (ZE) technology is the total cost of ownership (TCO). Once a ZE technology has a lower TCO than vehicles fuelled by diesel, demand will pull the transition and OEMs manufacturing HDVs will follow course. For this reason, in our view the ZE HDV uptake will be steeper than the one for cars. Battery technology is ready for this. In most cases, urban and regional HDVs (going back to base everyday) using smart charging have a lower TCO than vehicles using diesel. This is also likely to be the case for long-haul vehicles when they arrive on the market by 2024. To better align the Regulation setting CO2 emission standards for HDVs with this dynamic, ECI suggests the following changes to the current Regulation: 1. Introduce CO2 reduction targets for lorries and tractors of: * 65% by January 2030 compared to 2019 (or 2020 depending when the monitoring started) for those lorries and tractors in categories N2 and N3 of the European classification for vehicle categories that are currently included under the CO2 monitoring and reporting requirements, and * 100% by January 2035 for all new registered lorries and tractors in categories N2 and N3. 2. Include a ZEV mandate for busses and coaches of: * 50% of new registered busses and coaches in categories M2 and M3 of the European classification for vehicle categories to be zero-emission by January 2027, and * 100% of new registered busses and coaches in categories M2 and M3 to be zero-emission by January 2030. 3. Mandate the European Commission to present a legislative proposal by December 2026 to set minimum well-to-wheel energy efficiency thresholds for HDVs. About European Copper Institute The European Copper Institute (ECI) is the leading advocate for the copper industry in Europe and the European arm of the International Copper Association (ICA). Our members mine, smelt, refine and recycle copper for use across the economy, in the electricity system, buildings, transport and industry.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

7 Mar 2022

For a “Fit for 55” EPBD recast The proposed EPBD recast is a steppingstone for buildings’ decarbonisation and European Copper Institute (ECI) recommends considering several improvements to grasp the full potential. - Minimum Energy Performance Standards (MEPS) are welcomed, and their ambition must be “fit for 55”: lock-in effect and sub-optimal choices must be avoided to address the large untapped energy efficiency and decarbonisation potential in the building stock and to secure the contribution of buildings to EU’s carbon neutrality, energy efficiency and renewable energy objectives. - Mainstreaming the Energy Efficiency First principle requires addressing untapped potential: particularly with heat recovery on domestic hot water (potential of 4.5 Mtoe yearly savings by 2030) and efficient design of non-residential electrical installations (potential of 2.4 Mtoe yearly savings by 2050). We call for considering electrical installations as Technical Building Systems, and for including hot water heat recovery into the calculation framework (Annex 1). - Improved templates for National Building Renovation Plans (NBRP) and Energy Performance Certificates (EPC) are an excellent opportunity to capture the multiple benefits of holistic renovation. We recommend safeguarding that electrical installations are considered by ensuring their inspection and by linking information about their safety and readiness into EPCs. - Strengthened e-mobility requirements, with smart charging and right-to-plug are welcomed. Existing residential and small buildings including single family houses are not covered by the proposal it is therefore important to ask all new charging points to be smart and to provide via EPCs information about the readiness of any building to safely install an EV charging point. - The calculation of whole life-cycle greenhouse gas emissions must take into account the recyclability and reusability of materials to ensure products used today will not be the waste of tomorrow. Detailed position of the ECI, including specific recommendations/asks, can be found in the attached file.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

The European Copper Institute (ECI) welcomes the European Commission’s (EC) ambition for proper waste management to protect human health and the environment. The aim of reducing waste generation and landfilling must well remain at the core of the EU waste hierarchy. However, the following approaches and measures should be considered as necessary steps for a fully functioning waste framework. These pertain to: 1. Design-for-Sustainability as essential requirement for proper waste management; 2. Improvement of waste management and treatment along the value chain; 3. Reinforcing consumer awareness to return products after use to collection points; 4. Prioritization of landfilled waste in waste prevention and reduction measures; and 5. Coherent ruling of iron silicate, by-product from copper production, across all EU legislation. We always stress that a full life-cycle management approach, from product design to recycling, is the most viable solution to achieve resource efficiency in a truly function and integrated Circular Economy. In this solution, trade-offs between the objectives of different policy areas (e.g. resource recovery and energy efficiency) are carefully considered and addressed. A concrete support by policy makers is also necessary for appropriate waste management and treatment infrastructure, and for the roll out of best available techniques addressing challenges related to the complexity of products. And the role of consumers in addressing important recycling challenges (e.g. collection) should not be neglected. When looking into waste reduction measures, it is recommended that the Commission prioritizes the amount of landfill waste that leads to value loss, and not the amout which is generated during production processes and finds application either internally or via other uses. More information can be found in the attached European Copper Institute's (ECI) position paper.
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Meeting with Michael Bloss (Member of the European Parliament) and EUROMETAUX and

8 Feb 2022 · ETS

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

2 Feb 2022 · ETS revision

Meeting with Morten Petersen (Member of the European Parliament)

20 Dec 2021 · Energy Performance of Buildings Directive

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards

Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

The European Copper Institute (ECI) supports the EU’s climate ambitions for 2030 and 2050 and welcomes the proposed recast of the Energy Efficiency Directive (EED). Copper is a key material for energy efficiency in all sectors and contributes significantly to the clean energy transition as a sustainable raw material that is essential to decarbonise the economy. The copper industry welcomes the mainstreaming of the Energy Efficiency First principle (via the new Article 3) as a driver for the uptake of energy efficient equipment, appliances, and solutions, while keeping the focus on cost-effectiveness. We underline the importance of targeting untapped energy savings in sectors that are lagging behind, leading to a fairer distribution of efforts. In this regard, ECI welcomes the revised provisions that will help small and medium-sized enterprises (SMEs) to catch up on energy efficiency, and in particular those provisions that widen the scope of energy audits, improve their quality, and incentivize (without obligation) the implementation of cost-effective recommendations stemming from those audits. We support this approach, as we believe that voluntary schemes result in higher willingness to invest on a more continuous time horizon compared to mandatory schemes. Likewise, the obligation for all energy intensive industries to implement energy management is welcome, but needs adjustments. In companies without sufficient organizational capacity, a certification obligation (Article 11(1)) may not be effective in inducing tangible energy efficiency activities beyond the mere formality of compliance with the requirements. We ask for the EED to address this capacity problem and ensure that certification does not become a barrier for the uptake of energy management. We also welcome that the definition of 'energy management systems' (Article 2(14)) was extended with an explicit reference to 'monitoring actual energy consumption', as this shifts the focus of the EED from energy efficiency by design towards energy efficiency in operation. However, we believe that more direct provisions should be included to maintain consistent and real energy performance via metering, control and automation. ECI equally welcomes the stronger requirements on member states to prepare a comprehensive heating and cooling assessment, including local heating and cooling plans (Article 23). This is a first step towards exploiting the huge recovery potential of industrial excess heat via district heating networks. Provisions should also be included to ensure that the Commission monitors the extent to which heat recovery potential is exploited in member states, and if needed, proposes further measures. Considering buildings, our industry strongly welcomes the strengthening of provisions on the exemplary role of public buildings (Article 6) in line with the renovation wave strategy. The scope of buildings covered is extended to all buildings owned by public authorities, not only those owned by central governments. The level of ambition of renovation is rightly increased to achieve the Nearly Zero-Energy Building (NZEB) standard and alternative measures not leading to renovation are removed. We ask to adequately align the EED and the Energy Performance of Buildings Directive (EPBD) to fully exploit the potential of the building sector. The building stock remains the sector with the largest untapped energy efficiency potential and Long-Term Renovation Strategies (LTRS) – required under the EPBD – are key instruments to deliver this potential. The current EPBD requires Member States to show how their LTRS contribute to achieving the 2030 energy efficiency target but a stronger framework is needed to validate the alignment and monitor progress. A specification of the expected contribution from the building sector should be introduced into the EED or the EPBD.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

The European Copper Institute (ECI) is the leading advocate for the copper industry in Europe. ECI supports the EU’s climate ambitions for 2030 and 2050. The Commission has chosen not to include the copper sector in the scope of the proposed CBAM. We welcome this but are concerned about the intention to extend the scope of CBAM in the future to also cover other ETS sectors. ECI believes that CBAM as currently proposed would not constitute an appropriate framework for the copper sector. Because copper is traded on global commodity markets, copper producers cannot pass on the cost increases brought about by regulatory measures to consumers without losing market share to non-EU producers who do not face the same costs. This means that as long as third countries do not have climate policies resulting in equal climate costs for industry in the same timeframe as the EU, it is of crucial importance that the EU legal framework provides robust protection against carbon leakage. The most problematic areas of the Commission proposal in this regard are: 1. Loss of effective protection against carbon leakage. An increased climate ambition of reducing GHG emissions by 55% by 2030 requires stronger carbon leakage protection. For the reasons set out below, CBAM as proposed would not constitute an effective framework to ensure a level playing field and protect the European industry against the risk of carbon leakage. The proposed phase out of free allocation under the ETS for sectors covered under CBAM is therefore of concern. This undermines the measure’s environmental objectives, as the lack of appropriate protection against carbon leakage will lead to an increase in global emissions. 2. Lack of consideration for impact on exports. As proposed, CBAM would put EU exporters to a competitive disadvantage compared with third country exporters. The introduction of CBAM and the consequent phase out of free allocation would raise carbon costs for EU producers of the materials included within its scope both for the share of their output sold in the EU and the share exported. However, third country producers would face a carbon cost for the part of their production exported to the EU, without facing any carbon costs for exports to third countries. 3. Inadequate provisions to avoid circumvention and costs absorption. Article 27 on circumvention has a very limited scope and should be expanded to address resource shuffling whereby exporting countries could use their cleanest industrial plants to export to the EU and keep more polluting installations for the domestic market. The measures the Commission can take in case of circumvention should also be substantially strengthened. The proposed framework would also affect EU and third country producers unequally as CBAM would only apply to the part of the third country operator’s production that is imported to the EU, while EU producers exposed to the full direct- and indirect carbon cost would face a significant increase in their production cost for their total output. 4. Intention to possibly cover indirect emissions in the future. We support the Commission’s proposal not to apply CBAM to indirect emissions. Copper production processes are inherently electro-intensive and the indirect carbon costs of the EU ETS are therefore of significant importance for the competitiveness of copper producers in the EU. Finally, the Commission suggests that the list of sectors that may be added within the scope of a CBAM in the future would be decided under secondary legislation. We do not believe this is appropriate, given the potentially high impact of the inclusion under CBAM for some sectors. The addition of new sectors should be decided through the ordinary legislative procedure to give industry and other stakeholders the opportunity to engage in the decision-making process.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

ECI supports the EU’s climate ambitions for 2030 and 2050 and welcomes the proposed regulations on CO2 emission standards for light-duty vehicles and Alternative Fuels Infrastructure (AFIR) as important steps forward in accelerating the transition to e-mobility. Copper is one of the materials that makes this transition possible. Copper is a key material for electric vehicles and charging infrastructure, but also for numerous other applications that enable the clean energy transition. Copper delivers energy savings and CO2 reductions across the electricity system, in buildings, transport and industry. Reaching carbon neutrality by 2050 means that at least all light duty vehicles should become zero-emission from well to wheel by that time. To get there in time, it is of crucial importance that the proposed regulation on CO2 emission standards and AFIR set an ambitious EU framework. To this effect, we believe the following changes should be made: To the proposed regulation on CO2 emission standards for cars and vans: 1. Introduce an intermediate target for the 2027-2029 period to ensure the successful phase out of non-Zero Emission Vehicles by 1 January 2035. To the AFIR proposal: 2. Apply the Article 3(2) minimum requirements to deploy charging stations every 60 km with a power output of at least 300 kW and at least one power output of at least 150 kW to the whole comprehensive TEN-T network by the end of 2025. 3. Increase the required charging power output to be deployed by member states per every registered battery electric vehicle under article 3(1) to 2.3 kW. 4. Amend article 3(1) to mandate member states to ensure that a sufficient number of publicly accessible recharging stations for light-duty vehicles is deployed in locations where vehicles typically park for extended periods of time. To both proposals: 5. Introduce a reference to the need to consider the Energy Efficiency First Principle in policy, planning and investment decisions in relation to transport, including as regards the well-to-wheel energy efficiency of different zero emission technologies.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

ECI supports the EU’s climate ambitions for 2030 and 2050 and welcomes the proposed revision of the Renewable Energy Directive (RED II) as a step in the right direction to accelerate the deployment of renewables in buildings, heating and cooling, transport and industry. Copper makes a significant net contribution to the clean energy transition as a sustainable raw material that is needed in multiple renewable energy technologies. Copper producers are working hard to further reduce their carbon footprint by improving energy efficiency and reducing emissions. In this regard, ECI welcomes the proposed provisions to facilitate the uptake of long-term renewables power purchase agreements, as well as the recognition under the revised article 23 (paragraphs 4b and 4f) of the use of waste heat in industrial processes as an eligible measure to mainstream renewable energy in heating and cooling. To support copper producers’ efforts to utilise waste heat, Article 23(4) should also cover the conversion of excess heat to electricity for self-consumption. The production of primary copper involves exothermal reactions that generate waste heat. In some cases, such excess heat can be directed to third parties, typically feeding a district heating network. However, in many cases copper production facilities are in locations far from heat sinks such as other industries or district heating networks. In such cases, the best way to valorise excess heat is its conversion to electricity for immediate self-consumption, given the electro-intensive nature of copper production processes. This allows to significantly improve the efficiency of the process, saving primary and final energy. We therefore ask for article 23 paragraph 4b to be reformulated to explicitly include the conversion of excess heat to electricity for self-consumption as an eligible measure. We believe that this is fully in line with the spirit of article 23 paragraph 4 to incentivise the recovery of heat flows that would otherwise be lost without producing a useful effect. Whether heat is used as such or is converted to equivalent forms of energy should not make a difference. This basic principle is also supported by Article 24 paragraph 4 of the recast Energy Efficiency Directive on heating and cooling supply, where the principles for the cost benefit analysis to be carried out to assess the potential to increase efficiency of new and refurbished installations are explained. The principles for carrying out this assessment in Annex X state that “in case of waste heat recovery on-site, at least the use of heat exchangers, heat pumps, and heat to power technologies shall be assessed.” On a different note, the concrete targets for buildings and district heating (articles 15a(1), 15a(2) and 24(4)) should be maintained to deliver on the high improvement potential in these sectors, notably through electrification (heat pumps). Finally, the new article 20a to facilitate system integration of renewable electricity should be maintained. In particular, the provisions mandating access to information of batteries for battery owners and users (article 20a(2)), smart charging functionalities for publicly accessible recharging points (article 20a(3)) and non-discriminatory access to the electricity markets (article 20a(4)) are important to support the fast development of e-mobility at the lowest cost and allow the implementation of an open market for smart charging and grid interaction. Ultimately, this will benefit consumers through lower electricity prices.
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Copper industry urges flexible ETS reform to protect competitiveness

8 Nov 2021
Topic — EU proposal to strengthen emissions trading system to achieve 55% emission reduction by 2030.
Message — The industry requests that the Linear Reduction Factor be the main tool for achieving emissions targets, without rebasing or strengthening the Market Stability Reserve. They want sector-specific fallback benchmarks and consideration of avoided emissions from copper by-products. They also seek MSR flexibility to avoid triggering cross-sectoral correction factors.1234
Why — This would protect their free allowance allocation and reduce carbon costs during the investment-intensive transition decade.56
Impact — Climate ambition suffers if industry receives excessive free allowances and reduced carbon price pressure.7
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Response to Environmental impact of photovoltaic modules, inverters and systems - Energy Labelling

27 Oct 2021

ECI welcomes the initiative relative to the environmental impact of photovoltaic modules, inverters and systems under the Energy Labelling Regulation and the Ecodesign Directive. Photovoltaic power is expected to play a major role in the future energy mix, in accordance with the European Green Deal proposals. Its deployment at residential and small commercial scale needs a minimum set of requirements to ensure transparency for final users in terms of energy yield, environmental performance, lifespan / durability, repairability, and smart readiness. Among the various policy options proposed, ECI supports option 6, consisting on a combination of ecodesign requirements, energy labelling and EU Green Public Procurement criteria, as the most robust way to achieve the above-mentioned objectives. ECI wants stress the importance of implementing electrical installations fully compliant with safety rules, durable and ready for future electrification trends: *** Most of residential and small commercial PV installations are rooftop, where very high temperature levels are reached due to lack of ventilation between the panel and the roof. The electrical installation should comply with this demanding environment to really offer a safe, reliable and durable PV system to the user. An analysis of the relevance of temperature levels reached in PV installations is enclosed and available at https://help.leonardo-energy.org/hc/en-us/articles/4405337249426. *** Equally important is to ensure an adequate and safe downstream/indoor electrical installation. The installation of a PV system should be considered as a trigger point for a complete inspection of the electrical installation. About European Copper Institute The European Copper Institute (ECI) is the leading advocate for the copper industry in Europe. Through a team of policy, industry and scientific experts, ECI uses data-driven research and scientific thinking to support copper’s role in achieving the EU’s policy goals. Copper is a key material in the energy transition: windmills, photovoltaic plants, heat pumps, electric cars, energy storage, transmission and distribution grids, as well as submarine networks require highly electrical conductive materials. Due to its unique properties (strength, corrosion resistance, ductility, alloyability, high electrical and thermal conductivity…) copper is the material of choice for these applications. Copper is equally important for energy efficiency, as electric devices usually require more conductive material to improve their performance.
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Meeting with Seán Kelly (Member of the European Parliament, Rapporteur)

20 Jul 2021 · Implementation of the Energy Performance of Buildings Directive (Assistant on behalf of MEP)

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

3 Jun 2021 · Sustainable batteries

Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

The European Copper Institute, representing the copper industry, would like to express its appreciation for the extensive work that the study team and the Commission has presented with this Preparatory Study and for the opportunity to provide feedback, on which would like to contribute the following: (1) THE NEW WORKING PLAN SHOULD INCLUDE SYSTEM-LEVEL OPPORTUNITIES AS THIS REPRESENTS A QUICK WIN OF SIGNIFICANT ADDITIONAL SAVINGS The energy savings potential at the system's level – how products are combined and operated – is 2 to 10 times higher than at the component level. Optimising systems in Europe could save 3,375 TWh of primary energy and over 541 Mt of CO2 emissions by 2030 (including BACS, industrial motor systems, lighting systems, power cables and circuits). Many political actors have identified the need to thinking beyond products: the MEErP encourages the consideration of different layers up to functional systems, the European Parliament "urges the Commission to include more system-level opportunities in the next Ecodesign work programme" ((2017/2087(INI)), and the policy recommendations in the EPRS Implementation Assessment state that “considering the whole system required for [the product’s] functioning in the Ecodesign process would be another important success towards resource efficiency”. The WP preparatory study doesn’t include systems and therefore misses an opportunity to take steps towards making this political ambition a reality. The attached review by Brocklehurst (2021) identified points in favour of systems, analysed the common issues, and listed suggestions for solutions to explore. (2) LOT 8 POWER CABLES SHOULD BE REVISITED AND BE INCLUDED IN THE WORKING PLAN Power Cables were studied in 2013-2015 (http://erp4cables.net/) but not been subject to a regulation to date, despite a long list of strong arguments in favour: (a) Significant saving potential (7.6 TWh/year by 2025 and 28 TWh/year by 2050) comparable to already regulated products such as fridges & freezers, and washing machines or air conditioners (b) Sales are sufficiently high, about 760-924 kton of copper annually, representing 4-5 billion euro per year (c) Market fails to address this opportunity, as electrical installers are unaware of losses, budgets for investment and for operating expenses are split and tenders do not include the request to perform life cycle cost calculations (d) There is no coverage by other regulations (e) Adequate methodologies are developed by international and EU standards, which could therefore be harmonised to comply with Ecodesign and Energy Labelling regulation. Changing responsibility for compliance from manufacturer/supplier to installer would expectedly be needed to move forward with this product group. (3) ADDRESS ENVIRONMENTAL IMPACTS AND CIRCULARITY ASPECTS OF PRODUCTS VIA A HOLISTIC, LIFE-CYCLE MANAGEMENT APPROACH A systemic thinking via overarching product sustainability principles, backed by robust methodologies, is required to secure the marketing of more sustainable products in the EU. Waste reduction should always remain at the core of sustainability efforts covering the entire product policy spectrum. To this end, producers/importers of products should be able to prove that the design of their products allows firstly for reuse/repair/share, secondly for remanufacture/refurbish/upgrade, and thirdly that the product can be recycled. From a more holistic standpoint, Ecodesign’s initial goal has been to push least efficient equipment out of the market, and so, the new product’s Design-for-Sustainability approach under the SPI should not hamper this objective. Therefore, complementary binding guiding principles can be envisaged per product group. In the case of motor systems, for example, repairing an old motor will never result in the energy savings obtained by replacing it by a new more energy efficient one, while currently used motors are running much longer than their anticipated lifetime.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

The European Copper Institute welcomes the opportunity to participate in the public consultation on the Inception Impact Assessment for the Revision of REACH. Please find our response in the attached file. ECI is the voice of the International Copper Association (ICA) in Europe. The International Copper Association, with its 35 members, represents a majority of the world’s primary copper producers, and some of the largest mid-stream smelters/refiners, and 10 of the world’s largest copper fabricators. It aims to bring together the global copper industry to develop and defend markets for copper and to make a positive contribution to society’s sustainable development goals.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The European Copper Institute, representing the copper industry, welcomes the opportunity to provide input on the review of the Energy Performance of Buildings Directive. The copper industry is committed to support the decarbonisation of the building sector to achieve the objectives of the Climate Target Plan 2030 and the Renovation Wave communication. Buildings account for 34% of annual copper use in the EU and copper is a key element for decarbonisation of the building stock due to its excellent electrical and thermal conductivity, making it the material of choice for low carbon, efficient and smart building technologies. Copper products have long service lives and can be recycled infinitely at the end of life, making copper a sustainable material. The EPBD has laid the foundation for improving the energy performance of the European building stock but now the time has come to upgrade buildings from a problem area to a key solution for a just and inclusive transition to help cut greenhouse gas emissions in the EU by at least 55% by 2030 compared to 1990. The next revision of the EPBD is an opportunity to ensure buildings, new and existing, can play this pivotal role, provided that the revision includes provisions that (1) really drive the digitalisation of the building sector; (2) put buildings at the centre of the wider smart and secure (electrified) energy system; (3) make electrical safety a prerequisite for a clean and just energy transition; and (4) is supported by standards that move beyond the lowest-hanging fruit options and promote operation-based energy performance. We do not support broadening the scope of the Directive towards health and environmental issues as this risks diluting the strength of the EPBD in improving energy performance of buildings while making its implementation for Member States more complex. Out of the policy options in the Roadmap the European Copper Institute supports Option 3 – Amend the EPBD to translate the actions proposed in the Renovation Wave and the increased ambition towards building decarbonisation into legislation and wishes to bring our recommendations to the attention of the European Commission in the attached paper.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

The European Copper Institute (ECI) has read and welcomes the European Commission (EC) proposal for a new Batteries Regulation, COM(2020) 798/3. This is an ambitious step forward in the direction set by the Strategic Plan on Batteries. The proposal brings about several positive developments: • the shift from a Directive to a Regulation; • the internal market legal base being the guarantee for the upcoming law’s equal application across Europe; • the new category of EV batteries being given their specificities; • the provisions providing authorized recyclers with all the information required to implement automatic dismantling and the detailed composition of battery cells to increase profitability of the recycling processes – the most powerful incentive to increase collection and recovery rates Recycling efficiencies and recovery of materials We very much welcome the efforts by the European Commission to reduce landfill and incentivize the market for increased recycling to properly factor the high value of recovered copper (performing at the same levels as copper produced from virgin ore). There are existing cutting-edge technologies and innovative recycling processes to recover valuable raw materials at high efficiency rates and to relatively easily remove alloying elements and impurities, but these technologies are not yet fully deployed. The copper industry welcomes an increase of investments in the development of better collection, dismantling and sorting technologies, as it will allow for more cooperation among industrial sectors. Solutions to these processes via technologies and infrastructure are available to a large extent but often economically unviable. Potential technological solutions that address inbound inspection and material identification challenges can be found in the research paper “Ferrous and non-ferrous recycling: challenges and potential technology solutions” (Brooks et al., 2018). To stimulate their roll out and to untap their full potential for maximum quality (i.e. purity) and quantity of recovered materials, and in order to achieve the recovery targets for copper, cross-industrial cooperation on recycling technologies needs to be fostered through economic and regulatory incentives, and investment bottlenecks need to be overcome. Nevertheless, the role of primary metal production should not be underestimated in view of the increasing demand for copper due to not only the uptake of electric vehicles but their usage in the new recharging infrastructure. The long lifetime of copper-based products like cables (measured in tens of years) also limits the contribution of recycled copper to meet total demand. Supply chain due diligence for raw materials As copper industry, we echo Eurometaux’s position on due diligence for raw materials in the batteries supply chain. We therefore strongly acknowledge the need for responsible and ethical sourcing of battery raw materials. To this end, we believe that the European Commission needs to adopt a transparent approach with clear definitions, for example, on environmental due diligence, as well as to ensure business confidentiality for commercially sensitive information. In addition, this approach should build on internationally recognized standards and instruments (e.g. UNGPs, OECD Guidance), whilst equally considering and recognizing examples of industry-led best practices, incl. voluntary due diligence schemes and value chain platforms. About European Copper Institute ECI is the voice of the International Copper Association (ICA) in Europe. The International Copper Association, with its 35 members, represents a majority of the world’s primary copper producers, some of the largest midstream smelters/refiners, and 10 of the world’s largest copper fabricators. It aims to bring together the global copper industry to develop and defend markets for copper and to make a positive contribution to society’s sustainable development goals.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

The European Copper Institute (ECI) welcomes the opportunity to comment on the Commission’s inception impact assessment on the Regulation setting CO2 emission standards for cars and vans. One of the missions of the association is to promote the sustainable use of copper in electric vehicles. One of the goals of the European Green Deal is the full decarbonisation of cars and vans by 2050. Considering the lifetime of vehicles, this implies that by 2035, 100% of light duty vehicle sales should be zero emission vehicles (ZEV), as UK has recently announced in its Ten Point Plan for a Green Industrial Revolution (Nov 2020): 'Electric vehicles: Following extensive consultation with car manufacturers and sellers, the Prime Minister has confirmed that the UK will end the sale of new petrol and diesel cars and vans by 2030, ten years earlier than planned. However we will allow the sale of hybrid cars and vans that can drive a significant distance with no carbon coming out of the tailpipe until 2035.' (https://www.gov.uk/government/news/pm-outlines-his-ten-point-plan-for-a-green-industrial-revolution-for-250000-jobs). To better align the CO2 regulation with this goal, ECI suggests to consider the following changes in the current regulation: * To move from a ZLEV benchmark to a ZEV target. in order to focus in zero emission mobility as defined in the EU Green Deal goal. * To include a malus factor up to 5%, i.e. a ZEV factor ranging from 0.95 to 1, replacing the ZLEV factor in the current regulation, and moving from benchmark to target. * To assess the target of 25% of new sales as the ZEV target from 2025 to 2029. 2025 is a key milestone to guarantee the right trajectory and 25% is the minimum value to decarbonise cars and vans by 2050. Aligned with Mr. Herbert Diess, chairman of Volkswagen Group, at an interview with Bloomberg (Nov 2020): 'Diess sees VW's BEV share needs to be about 25% of sales by 2025 to hit the CO2 targets.' (https://twitter.com/colinmckerrache/status/1324285643405561857). * To assess the target of 65% of new sales as the ZEV target from 2030 onwards. Norway is proving that it is a feasible target with an increase of its BEV market share of 27 percentage points in less than three years, from 20.8% in 2017 to 47.9% in Sep 2020 (https://www.eafo.eu/vehicles-and-fleet/m1, filtered by electricity and Norway). * To have the same targets for cars and vans, as both segments have to be decarbonised by 2050, the number of vans is increasing due to the rise of e-commerce and a growing number of cities are implementing zero emission zones. About European Copper Institute ECI is the voice of the International Copper Association (ICA) in Europe. The International Copper Association, with its 35 members, represents a majority of the world’s primary copper producers, some of the largest midstream smelters/refiners, and 10 of the world’s largest copper fabricators. It aims to bring together the global copper industry to develop and defend markets for copper and to make a positive contribution to society’s sustainable development goals.
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Copper industry opposes extending EU ETS to buildings and transport

26 Nov 2020
Topic — The European Commission is reviewing the EU Emissions Trading System to meet higher 2030 climate goals.
Message — The European Copper Institute argues against expanding the emission trading system to the buildings and road transport sectors. They claim this integration is too complex and would distract from more effective existing measures.12
Why — This prevents existing energy and process industries from facing higher carbon costs and losing global competitiveness.3
Impact — Low-income households could face significantly higher energy bills without a realistic way to invest in new technologies.4
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

The European Copper Institute (ECI) welcomes the opportunity to comment on the Commission’s inception impact assessment on the amendment of the EU Effort Sharing Regulation. Our association supports the clean energy transition towards a climate-neutral EU, while safeguarding competitiveness of the industry. Hence ECI is actively involved as a stakeholder in the design and implementation of targeted instruments for the energy and transport sectors. While we welcome the increased attention on emission reductions in non-ETS sectors, we do not support the inclusion of road transport and buildings in the ETS since: * Member States have already introduced CO2 taxes on fossil fuels for road transport, and some for buildings. * The new Energy Tax Directive will aim at addressing the CO2 content of energy sources. If ETS is extended to road transport, the Energy Tax Directive will not be able to cover road transport fuels, leaving Member States without recourse to the energy taxation. There are also significant risks: * An ETS for buildings and transport is likely to be ineffective to reduce carbon emissions, and it would result in higher ETS burdens for Europe's energy and manufacturing industries that are already exposed to rapidly rising energy and climate costs. [1] * Integrating the building and transport sectors in the EU ETS is complex and likely to take years. Such delay in the transition to climate neutrality is not acceptable and will divert attention from more effective measures that are already in place. * For both transport and buildings, the price of CO2 should rise well above 100€/ton to be impactful. In the case of road transport 30€/tCO2 already means an increase of 0.09€/litre, hence going to 100 €/tCO2 will become prohibitive for European consumers. * The introduction of a carbon price for transport and heating fuels could lead to higher energy bills for citizens, especially for low-income households who cannot afford to renovate their homes or replace their cars in the short term, before their current heating system or car reaches end-of-life. * To move road transport and buildings from Effort Sharing Regulation to ETS will de-incentivise Member States in their correspondent efforts to comply with the Effort Sharing Regulation, e.g. by accelerating renovation, by introducing a minimum energy performance standards for buildings, by introducing a minimum share of renewable energy and by prioritizing measures to alleviate energy poverty. In short, including the building and road transport sectors in the EU ETS could distract decision makers from taking effective measures to overcome the main barriers hampering the decarbonisation of these sectors and the alleviation of energy poverty. [1] "...because the buildings and transport sectors are relatively unresponsive to the carbon price, under a single extended ETS cap companies in the existing ETS sectors would have to do more to compensate, and would need to achieve an additional 250 MT of carbon reductions by 2030, and an extra 315 MT of carbon reductions by 2040. This would lead to a loss of competitiveness in these sectors, and therefore small reductions in output and employment." Quotation from: European Climate Foundation, Decarbonising European transport and heating fuels - Is the EU ETS the right tool? June 2020 - https://europeanclimate.org/resources/impacts-of-extending-the-ets-to-transport-and-buildings/ About European Copper Institute ECI is the voice of the International Copper Association (ICA) in Europe. The International Copper Association, with its 35 members, represents a majority of the world’s primary copper producers, some of the largest midstream smelters/refiners, and 10 of the world’s largest copper fabricators. It aims to bring together the global copper industry to develop and defend markets for copper and to make a positive contribution to society’s sustainable development goals.
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Response to Revision of EU legislation on end-of-life vehicles

19 Nov 2020

The European Copper Institute (ECI) welcomes the opportunity to comment on the European Commission’s inception impact assessment on the End-of-Life Vehicles (ELV) Directive. One of the missions of ECI is to promote the sustainable use of copper in electric vehicles. One of the goals of the European Green Deal is the full decarbonisation of cars and vans by 2050. The battery electric vehicle is currently the best available zero-emission technology because it emits three times less greenhouse gas emissions and consumes between 2.5 and 5 times less energy, on a well-to-wheel basis, compared to other technologies. Moreover, in most cases, the total cost of ownership is already lower than for alternatives. To achieve that goal, the number of electric vehicles to be produced and the volume of raw materials required for such production, especially critical ones, are so significant that recycling is going to be of key importance to complement primary raw materials production without slowing down the speed of the transition. During the last years, around four million of end-of-life vehicles (ELVs), which represent one third of the total, are not traceable (deregistered without certification of destruction). The two main causes are treatment at illegal facilities within the EU or export outside EU as used cars. To reduce this number of missing ELVs and to increase the number of vehicles processed at authorised treatment facilities, we suggest to consider two policy options for a targeted modification of the directive: 1) To include provisions that replicate the main characteristics of the Dutch vehicle registration system with a couple of improvements listed below. 2) To require a recent (no older than 12 months) road-worthiness test for a used vehicle that it intended to be exported outside the EU. The Dutch system has proven to be very effective in reducing the share of missing vehicles: the estimated number of ELVs processed through illegal channels in the Netherlands is below 2.3%, compared to 35% mentioned in the impact assessment (attached the ADEME’s report with the full assessment of the Dutch system). The main parameters are: * Holdership’ concept: the annual obligations in terms of inspection and insurance are related to holding the vehicle, not to its use. The Dutch system also includes an annual road tax but it would be difficult to replicate across the EU. * The only options to stop paying the vehicle obligations are to treat it as an ELV, to sell it within the EU, to export it outside the EU or to declare theft. * One electronic platform, run by the Department of Transport, tracks any change of the vehicle status. The vehicle is uniquely relating its VIN-license plate to an owner, from the moment it first enters the market until it leaves it (through export, destruction or theft). * Only authorised operators can update the vehicle status in the system (dealers, authorised treatment facilities, export agents, insurers, etc.). Two improvements or additions to consider: * In case of sale to another member state, to interconnect both registration systems to only allow deregistration in the first one once registration in the second one is confirmed. * In case of an export outside EU, to only deregister a vehicle after it has been effectively exported. ECI also strongly supports the position of Eurometaux. ------------------- About European Copper Institute ECI is the voice of the International Copper Association (ICA) in Europe. The International Copper Association, with its 35 members, represents a majority of the world’s primary copper producers, some of the largest midstream smelters/refiners, and 10 of the world’s largest copper fabricators. It aims to bring together the global copper industry to develop and defend markets for copper and to make a positive contribution to society’s sustainable development goals.
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Response to Sustainable Products Initiative

13 Nov 2020

The European Copper Institute (ECI) welcomes the EC's ambition for a sustainable product policy framework, to decouple economic growth from environmental & climate impacts. We believe a holistic, life-cycle management approach, from product design to efficient recycling, with reliable, relevant and verifiable environmental information, fulfilling appropriate product sustainability requirements, is the most viable approach to achieve this. A mix of the proposed policy options will therefore be the most impactful choice. We also encourage the EC to bring consumer behaviour and operational feasibility higher in its scope, to avoid double and potentially contradictory legislation (e.g. in tracking process emissions), and to take into account sectoral (e.g. recycling performance indicators) and product specificities (e.g. Reg. (EU) 305/2011 with ample instruments for construction product sustainability). Circularity is at the heart of the copper industry as evidenced by 2/3rds of the copper ever produced still being in service today. ECI will continue to support the copper value chain in fulfilling appropriate sustainability requirements through the provision of robust, transparent and reliable industry data for use by product designers and manufacturers. To this end, we are looking forward to the Commission’s definition on sustainability principles and for clarification on products being considered for in scope of the Ecodesign Directive. ECI supports the position of Eurometaux and makes the below recommendations, explained in the attachment. ●Double and/or contradictory regulation between the EcoDesign Directive and product-specific legislation, such as the Construction Products Regulation, needs to be avoided. ●Environmental assessment of products should be based on a life-cycle approach that takes into account end of life and uses robust and mature indicators. ●Methodological limitations for several of the social sustainability impact categories proposed (e.g. human rights, use of resources) need to be addressed before these are deployed. ●Proper recycling efficiency indicators should be established to optimise recycling performance based on resource- and energy-efficiency. ●The recycled content approach for products needs to be carefully assessed as it will not drive recycling rates of metals like copper. ●Industrial responsible sourcing schemes, like the Copper Mark, should be authorized to complement/support existing Life Cycle Assessment methods for the environmental footprinting of products on the EU market (incl. services and industrial processes). ●Material efficiency of a product needs to be considered after optimisation of energy efficiency/operational lifetime environmental impact. ●Requirements for product durability and repairability need to take into consideration technological lifetime, especially for rapidly evolving technologies, and trade-offs between repair and replacement. ●To drive circularity, the market for metal production by-products, such as iron silicate serving as a sustainable substitute for natural aggregates in building and construction products, needs to be incentivised and barriers to be removed (e.g. via content-based approach). ●Disclosure of harmonised environmental impact information is a prerequisite for driving sustainability of products and changing purchasing behaviour of end users, with product-appropriate methodologies and classification of performance, developed by standardisation bodies. ●Product labelling needs to be backed up by an effective surveillance system to protect end users against false claims, maintain credibility of the EU sustainable products market and protect investment of manufacturers in sustainable production. ●Ecodesign Directive working plans should systematically screen product groups against system-level opportunities (such as Lot 8 power cables). ●The policy mix needs to include informing and incentivising consumers, to drive update ofsustainable products.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

The European Copper Institute (ECI) welcomes the European Commission’s ambition to prevent and remedy pollution from air, water, soil, and consumer products. Please see the attached paper which illustrates our views. We will appreciate to be involved in further discussions and consultations, and are happy to provide additional information on request.
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Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

27 Oct 2020 · the Circular Economy

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

The European copper industry is committed to maintaining a prominent role in the field of energy efficiency. It has an exemplary track record in energy efficiency investments and pioneered strategies on carbon reductions in the downstream industrial, residential, service and transport sectors of Europe. The European Copper Institute (ECI), representing the copper industry, would like to thank the European Commission for the opportunity to provide input on the review of the EU energy efficiency rules. On the evaluation of the effectiveness of the EED, ECI wishes to share the following observations: (1) SAFEGUARD THE COMPETITIVENESS OF THE EUROPEAN COPPER INDUSTRY as it already has best available techniques for energy efficiency in place. Material efficiency, recycling, and environmental protection imply a higher energy intensity for material processing and should be acknowledged. To further optimize the energy efficiency and progressively integrate carbon-free energy vectors, sustained support is needed. We recommend to revise the EED in a consistent way with other legislation and to carefully assess the impact on energy intensive industries’ carbon leakage exposure and propose reciprocal carbon leakage measures. (2) PRIORITISE UNTAPPED COST-EFFECTIVE ENERGY EFFICIENCY POTENTIAL considering marginal abatement costs, length of investment cycles, exposure to global competition and role in delivering emission reduction along the value-chain. Facilitate and incentivize the uptake of systems-level energy saving applications (electric motor systems, electrical installations in buildings, electrification of transport and industrial heat, building automation). (3) REQUIRE MEMBER STATES TO INVEST IN DISTRICT HEATING NETWORKS TO RECOVER INDUSTRIAL EXCESS HEAT and guarantee level playing field for all heat sources. (4) INCENTIVISE COMPANIES (IN PARTICULAR SMEs) TO ADOPT ENERGY MANAGEMENT PRACTICES as it would save industry and service sector 26% of their combined energy consumption. Many recommendations from energy audits, even highly cost-effective, are not implemented. Energy management (with simplified schemes for SMEs) based on operational metering data, should become the norm. (5) ENCOURAGE MEMBER STATES TO STREAMLINE THE IMPLEMENTATION OF THE EED AT NATIONAL LEVEL. Under policy option 2 (non-regulatory measures), ECI recommends to assess the impact of the following measures: 1. Regular evaluation and adaptation of the (cost-)effectiveness of national energy efficiency improvement programmes. 2. Harmonisation of energy savings calculations under Art.7 to support the uptake of advanced actions. 3. Adequate monitoring systems to follow-up on the quality and implementation of energy audit recommendations. 4. National information hubs to support SMEs in their search for information on energy audits and energy management practices. 5. Avoid incentives to go for poorly used energy audits for compliance reasons only. 6. Encourage companies to act on audits’ recommendations systematically. 7. Focus national investment and pricing mechanisms on supporting heat recovery from various sources (both industrial and from buildings). Under policy option 3 (revision of the EED), ECI suggests to assess the impact of the following revision options: (Article 5) Extend the scope to all public buildings (also regional and local level) and ensure deep renovations. (Article 8) Make energy audits mandatory for all energy-intensive SMEs; and require implementation of all cost-effective recommendations. Incentivize the implementation of Energy Management practices. (Article 9b) Require the installation of submetering at technical building systems level. (Article 14) Require Member States (MS) to invest in district heating networks to capture industrial excess heat and make it available at competitive prices. Encourage MS to include waste water heat recovery systems in their energy efficiency programs.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The European Copper Institute welcomes the opportunity to provide input on the review of the EU renewable energy rules. The copper industry is committed to keep bringing an important contribution to the deployment of renewable energy in Europe, by ensuring the supply, in a circular and sustainable way, of an essential material for the generation, transmission and distribution of renewable energy. The European Copper Institute wishes to bring the following elements to the attention of the European Commission: 1. The Directive should ultimately assist in the reliable delivery of electricity, renewable fuel and reagents for the EU energy-intensive industry at globally competitive costs. Potential extra-costs supported by the copper industry, such as surcharges linked to renewable energy support schemes, cannot be passed to the customers because copper is a global commodity, with prices set globally on metal exchanges. Thus such extra-costs, if not compensated, directly erode the profitability of the EU copper industry and, as a consequence, could further trigger carbon leakage. Therefore, REDII should be aligned with other EU regulations (emission trading, industrial policy, energy taxation, innovation...) aiming to preserve the competitiveness of energy-intensive industries in the global competitive game. 2. Considering the Energy System Integration Strategy and the Renovation Wave Initiative, together with the fact that the electricity production is decarbonising in a fast and cost-effective way, electrification of the heating and transport sectors should be prioritised. This option additionally brings a significant reduction of urban air pollution, as well as other system benefits. 3. Large scale deployment of renewables will generate important raw material needs. Environment protection and circular economy should be guiding principles. ● The infrastructure deployed should be recovered at the end of its life. ● Materials should be as reusable and recyclable without loss of quality as possible. Materials with high end-of-life value should be prioritised, so that economic drivers add an incentive on top of the regulatory obligations. ● Design-for-recycling should be requested, to ensure that as much material as possible is recuperated during repair and at the end of life. ● The use of certified sustainable raw materials should be incentivised. The renewable energy mandate should enhance the market for sustainable raw materials and products. Infrastructure should be built based on circular, low carbon or carbon-neutral materials. 4. The valorisation of residual heat streams should be incentivised ● In the industrial sector, a relevant potential remains untapped. Support is required to match the cost of alternative fossil fuel assets. ● In the building sector, the energy needed to heat sanitary hot water is gaining importance as it can represent up to 45% of energy consumption in new buildings. This heat ends up in the drain still hot. Up to 70% of energy from shower water could be effectively recovered. The technology exists but adequate support, such as its recognition as a renewable source of energy, is needed for its large-scale deployment. 5. Half of the EU final energy demand is in the heating and cooling sector, where penetration of renewables is low. The EPBD requires new buildings to cover their energy demand to a large extent from renewable sources (ideally on-site or nearby). This guiding principle should be extended to existing buildings undergoing major renovation, in the context of the Renovation Wave. On-site or nearby renewables should be supported, for instance through mandatory minimum requirements in renovated buildings. 6. As the penetration level of renewables in the electricity grid will significantly increase by 2030, storage technologies will be needed. Therefore, an assessment of such need should be required from transmission system operators, together with a plan for its implementation.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

The European Copper Institute (ECI) welcomes the European Commission’s efforts to establish positive rules to substantiate environmental claims as a tool to unlock opportunities for a green and circular economy. Option 1 & Option 2 as outlined in the Inception Impact Assessment of the European Commission can help further develop the Environmental Footprinting methodology before it can be used for decision-making to achieve fair rules for all materials. In line with the position paper of Eurometaux, the European non-ferrous metals association, we are fully supportive of Life Cycle Impact Assessment (LCIA) and Environmental Footprinting (PEF). Such methods provide a solid, standard and scientific approach to assess product/activity performance from a life-cycle perspective. The approach can achieve its objectives insofar as it allows for the assessment of appropriate metrics per industry sector. The EF method improves LCA by integrating data quality requirements and rules that improve consistency. Yet, we remain concerned that some data inaccuracies and knowledge gaps have still not been addressed, in particular related to how raw material uses are assessed. Voluntary, industry-led initiatives should therefore complement such methods in terms of substantiating green claims and achieving improvements in the environmental performance of products. We would therefore welcome that the planned impact assessment for a legislative proposal investigates more specifically our sector’s concerns, along with the proposed solutions. Option 1: Update 2013/179/EU Recommendation upon the outcome of the 2013-18 pilot phase Additional proof point: The adoption of a staggered, sector-specific approach would allow metals sector to accurately measure and provide the most representative figures in view of proving its environmental performance from a life-cycle perspective. The EF methodology stresses the need of using high-quality data for life cycle assessment , includes guidelines to assess the quality of data and provides for verification of data’s correctness. The development of Product Environmental Footprint Category Rules and efforts made to agree on horizontal guidance contribute to increased re-producibility and consistency of results. While we support the use of LCA/EF methods to assess environmental effects, the current status EF impact categories fall short of identifying all relevant suitable parameters on eco-toxicity, human toxicity, resource use for metals (and in particular copper). These impact categories/metrics are not yet well-established and still debated in the scientific/regulatory community. Therefore their inclusion at this stage leads to inappropriate benchmarking and misleading product comparisons. As an engaged stakeholder, the copper industry is committed to improve such methodological gaps – but requires time and therefore calls for consideration of a staggered, sector-specific adoption. Option 2: Voluntary EU legal framework enabling green claims in accordance with the EF methods, as a complement to existing ones The methodology should complement existing LCA tools after essential corrections are made (e.g. toxicity, eco-toxicity and resource use). We encourage the EU Commission to further improve and promote robust LCA practice and harmonized methodology to ensure a high level of consistency and comparability of green claims. ECI strongly supports the establishment of a voluntary EU legal framework, at outlined under Option 2. Some flexibility is needed in cases where another framework could better apply in some sectors. The acceptance/recognition of complementary, already developed industry-led initiatives can ensure an accurate and credible LC assessment of products. The Copper Mark, as a comprehensive, credible assurance framework, can serve as an add-on to the various EF metrics that are being applied to substantiate green claims before policy-makers. The full ECI position paper can be found attached.
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Response to Review of the Construction Products Regulation

18 Aug 2020

European Copper Institute (ECI) represents the Copper Industry and welcomes the opportunity to provide input for the review of the Construction Products Regulation. Copper is used extensively (34% EU annual use) in technical building systems for delivering electricity, heating and water services. ECI supports a future CPR that safeguards and improves the functioning of the internal European market for construction products, and drives safe, sustainable and circular construction in the most robust and cost-effective way, with the lowest possible administrative burden, embracing digitalisation and satisfying most expectations of all stakeholders. ECI’s recommendations for the future CPR are attached.
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Response to Offshore renewable energy strategy

12 Aug 2020

The European Copper Institute (ECI), representing the copper industry, welcomes the upcoming Strategy for Offshore Renewables initiated by the EC. This Strategy is seen as a significant component of the transition to a climate-neutral economy with the ambition to keep a modern, innovative and thriving industry in EU. Copper industry is committed to keep bringing an important contribution to the deployment of offshore wind energy, by ensuring the supply, in a circular and sustainable way, of a key material for the generation, transmission and distribution of renewable energy. ECI wishes to bring the attention of the EC on the following elements of this Strategy for Offshore renewables: 1. The strategy should ultimately assist in the delivery of globally-competitive electricity prices and a resilient power supply. This will support the energy intensive industries in Europe and in particular the development of new industries for a climate-neutral EU by 2050. In particular, market mechanisms should be promoted that ensure stable pricing in Power Purchase Agreements, avoiding the pitfall of short-term opportunistic pricing by power suppliers. 2. Grids are regulated assets, with their costs borne by electricity consumers. Such costs include not only investment but also operation, maintenance, repair and dismantling. In order to minimise the cost for consumers, a TOTEX regulatory approach should be adopted, which takes life cycle costs into consideration. Such type of regulation sets penalties and incentives to transmission system operators, so they take all necessary measures to adopt technical choices leading to high reliability and availability of infrastructure, as well as to consider the residual value of installations, avoiding solutions with low investment cost but high operation and maintenance costs. 3. Environment protection and circular economy should be guiding principles of the Strategy for Offshore renewables. ● The infrastructure deployed should be recovered at the end of its life. Materials should be as reusable as possible. Materials with high end-of-life value should be prioritized, so the economic driver adds an incentive on top of the regulatory obligations ● Substances with a potential to harm the environment should be properly managed through their entire life span and be adequately recovered and disposed of 4. EU industrial and technological leadership should be supported, based on sustainable sourcing policies. ● The strategy for Offshore renewables should include strong support to develop innovative technologies, incl. energy storage and to secure access to the key raw materials required to deploy offshore energy infrastructure ● The use of certified sustainable raw materials should be incentivised. The offshore infrastructure should be built based on recyclable, low carbon or carbon-neutral materials. This requirement would enhance the market for sustainable raw materials and products 5. The strategy should be fully aligned with the various generation scenarios foreseen by 2030 and 2050, notably in terms of generation and transmission capacity. ● Grids should be designed for multiple scenarios and offer a sufficient level of interconnection, redundancy and reliability ● On-shore grid upgrades will be required to fit with the new generation landscape. New land infrastructure projects currently face important public acceptance issues, particularly overhead lines. The German legislation on HVDC (requiring this technology to be fully undergrounded) has proved to be successful in delivering infrastructure on time. An equivalent EU-wide legislation should be replicated. ● The current growth pace of offshore infrastructure is not enough to meet the 2030/2050 objectives. Therefore, the strategy should address the current barriers and offer adequate incentive schemes, focusing on innovation (e.g. floating wind turbines). Schemes to help deployment should learn from the past and anticipate future cost reductions.
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Response to Sustainable and Smart Mobility Strategy

28 Jul 2020

The European Copper Institute welcomes the initiative of the European Commission to elaborate the Sustainable and Smart Mobility Strategy and suggests to include the following elements in its Impact Assessment: Decarbonisation of transport The 2011 White Paper on Transport was especially supportive to decarbonise light duty road transport. Now the European Green Deal took the baton stating full decarbonisation of cars and vans before 2050. We suggest that the Sustainable and Smart Mobility strategy plays for heavy duty road transport, rail, aviation and maritime the same role that the White Paper did for cars, setting inspiring goals and timeframes. Autonomous refuelling / recharging road transport Autonomous vehicles are part of the public discussion within smart mobility. However autonomous charging does not receive the same level of attention. It’s commonly accepted that autonomous vehicles (ADAS level 5) will be available before 2030. On the other hand charging infrastructure is expected to last around 20 years, so the current efforts that Europe is making to deploy charging infrastructure, especially in urban areas where most of the charging sessions take place, should use autonomous charging technologies, like wireless charging at parking slots. It’s affordable and all related standards will be published before middle 2021. More info on this topic and others in our vision paper attached (also available at https://help.leonardo-energy.org/hc/en-us/articles/360015218200-E-mobility-vision-paper) Glad to discuss and provide further information on wireless charging or any other topic of our vision paper.
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Response to Establishment of a smart readiness indicator for buildings

15 Jul 2020

The EU’s post-COVID Recovery Plan has a focus on a green, digital and resilient future, with the Renovation Wave initiative at the heart of it. The European Copper Institute believes that a broad and fast adoption of the Smart Readiness Indicator (SRI) is key to not only accelerating but also improving the quality of renovations and future-proofing the building stock. The energy and carbon savings potential in buildings is significant, and the SRI can provide the necessary holistic approach, to 'think beyond the shell' towards technical solutions and to 'think beyond the building' towards energy system integration. The construction sector can create many jobs very quickly and it is key to a systems approach: it produces very significant energy and carbon savings, it facilitates the integration of distributed renewable energy sources, it supports local energy communities, and through improved smartness ensures the comfort, safety and security of occupants. The SRI could contribute to de-risking energy efficiency investments as it increases probability that the building keeps meeting the predicted energy performance during its whole life-cycle. In-building physical infrastructure, such as wiring and connectors, is a prerequisite for the cost-effective implementation of (connected and interoperable) smart and prosumer-ready technologies at later stage, and should therefore be included in the content of the SRI. Therefore we welcome the addition of “or planned at design stage” in Art.4(1); and we propose to add the following to ANNEX IX: "(p) (new) where possible, available information on system interoperability, in particular on the existence of in-building electrical infrastructure enabling interoperability with the Smart Grid as defined in the Smart Grid Architectural Model (SGAM)" The SRI for buildings would increase market players’ trust in energy performance investments, provided that its quality can be assured and that it keeps current to the fast evolving market of customer needs and smart technologies. We recommend that the legal acts from the beginning include a clear trajectory towards the development an assessment based on measured data, as a follow-up to the check-list approach that is currently proposed. For the SRI to drive the uptake of smart technologies in the internal market, it is important to ensure consistency between the schemes at EU level. Tailoring of the default EU methodology should be restricted to a minimum and done in such a way that comparison between Member States remains possible. We therefore propose, in accordance with recital 4, to amend Article 4(3) as follows: "The standard calculation methodology set out in Annexes I to VI may be adapted in accordance with Annex VII, in particular by making a link to energy performance calculations in the scope of energy performance certification, ensuring however the possibility to convert national calculations and ratings to the default EU SRI, to be able to compare the readiness level in different Member States and regions." About ECI: The European Copper Institute (ECI) represents the copper industry. Copper is used extensively in technical building systems for delivering electricity, heating and water services which represent 34% of annual copper use in the EU. ECI makes the above recommendations because we believe that investment in digitalisation, energy efficiency, renewables, energy flexibility, and safety of buildings can help realise the untapped potential of a 5-fold reduction in energy demand from the bulk of the EU building stock. Buildings are an ideal focal point to reinforce a systems approach in the Green Deal. The Renovation Wave should prioritise sustainable, circular materials, like metals such as copper which is highly recyclable without loss of properties and has well-established recovery chains. Sustainability should be defined in a coherent frame, based on fair and robust assessment methods and indicators.
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Response to Modernising the EU’s batteries legislation

9 Jul 2020

ECI response to the Inception Impact Assessment for the modernization of the EU batteries legislation The European Copper Institute welcomes the initiative of the European Commission to revise the Batteries Directive and suggests to include the following elements in its Impact Assessment: Recycling should be increased by achieving higher economic profitability through: • Reduction of recycling costs • Increase of recovery rates The most effective target is to make the recycling process profitable across the whole recycling value chain. The new Battery Directive should promote measures to reduce recycling costs and to increase the recovery rate of metals. This can be achieved by providing the required information to all authorised recycling actors that enables to automate battery dismantling, together with a precise bill of materials to maximise recovery rates, especially for – however not limited to –critical raw materials. A practical way to implement this provision of information would be through a unique Battery ID Code at pack, module and cell level that allows access to a manufacturers database with all the required information. For EV batteries, there is a need to establish an End of Life Recycling Efficiency Rate (EoL-RER) instead of a Recycled Content target. ECI supports the aim to reduce landfill and incentivize more recycling to properly factor the high value of recycled copper (as performant as copper produced from virgin ore), but setting a recycled content target on EV batteries could distort market competition by introducing a bias towards recycling, to the detriment of reusing or repurposing EV batteries. Therefore, ECI invites the Commission to include the use of End of Life Recycling Efficiency Rate (EoL-RER) in the impact assessment, to minimize landfill and better incentivize the market for increased recycling. At the end of its first life, an EV battery, or part of it, can be reused (further as a vehicle battery), repurposed (i.e. used in another application such as back-up energy storage) or recycled. EoL-RER would apply to the latter option, calculated as the mass ratio between originally used and recycled material, as a separate material or part of a compound (direct recycling). However, the role of primary metal production should by no means be underestimated in view of the increasing demand for electric vehicles, relevant infrastructure and other electrification-related products. On responsible sourcing, and even more importantly on responsible production, whatever tool is proposed, certifications (and not only EF/LCA-based ones) should be allowed and accepted as proof of compliance towards customers (e.g. Copper Mark). ECI welcomes an integrated/holistic approach in dealing with products, chemicals and waste policies that allows to reflect the need for sustainability during the entire life cycle of batteries. Legislation for product design, substitution of hazardous substances, and waste treatment through collection, dismantling and sorting should serve the same goals of reducing GHG emissions, protecting the environment and human health, and contributing to the energy transition and the overall objective of sustainable development, while taking also into account the associated socio-economic benefits.
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Response to Chemicals strategy for sustainability

19 Jun 2020

The European Copper Institute (EU Transparency Register 04134171823-87), part of the International Copper Association (ICA), welcomes the Chemicals Strategy for Sustainability (CSS) and appreciates the opportunity to provide feedback. We agree with and echo the position by Eurometaux. In addition to that, we propose some specific solutions, highlight important information, and point to boundary conditions that must be considered if the Chemicals Strategy for Sustainability is to achieve its objectives. Below is a summary of our input. More detail is in the attached position paper. The CSS must be strongly linked to the policy goals of circularity and climate neutrality. The areas of overlap, divergence and potential need for trade-offs need to be thoroughly appreciated. Copper provides an excellent example to highlight the importance of these links. Copper is a key component of energy-efficient technologies and sustainable value chains that help to achieve climate neutrality, while it is at the same time an enabler of the circular economy due to its carrier role in recycling processes. Recycling streams and naturally occurring raw materials inevitably contain varying amounts of hazardous substances. A truly circular economy means that favourable market conditions must be created to promote safe recycling streams, recycled metals, and final slags – thereby also ensuring the EU’s access to these critical resources. The CSS should focus on promoting the safe processing and use of complex material streams, thereby creating a true win-win story with the Circular Economy Action Plan. The further development of bioaccessibility approaches, which quantify the potential release of hazardous elements from complex materials, will help to achieve this objective. We are and remain firmly committed to REACH as the backbone of chemicals regulation. The REACH Regulation is well suited to address many of the specific challenges related to chemicals. The focus of REACH and related chemicals management regulations should remain on identifying and mitigating risks. The natural occurrence, the complex physiological role, and the essentiality of metals for living organisms must be recognized in all upcoming initiatives on chemicals, including those on grouping of chemicals, on the assessment of endocrine disrupting properties, and on combination effects. Furthermore, these initiatives must consider the extensive scientific information that is available on metals, in a weight-of-evidence approach. The European Copper Institute has ample experience in this regard. Such weight-of-evidence approaches must be further promoted in new initiatives, thereby ensuring that policy actions are taken based on all available scientific knowledge, and avoiding unnecessary animal testing. The one substance – one assessment (OSOA) principle can ensure regulatory efficiency and transparency. It must be implemented in a way that achieves full transparency and incorporates balanced inputs from all stakeholders. Furthermore, the assessment and management of risks must continue to be done at the sector level as it depends on the use and exposure conditions.
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Response to Strategy for smart sector integration

8 Jun 2020

ECI sees the Strategy on Energy Sector Integration as a key element to bridge the transition to a climate-neutral economy with the ambition to keep a modern and thriving industry in Europe. The copper industry is committed to keep contributing towards a climate-neutral energy system, by the supply, in a circular way, of a key material for the energy generation, transmission and distribution infrastructure and for key applications in industry, transport and buildings. 1. Main features of a truly integrated energy system Such system should be reliable, cost-competitive and sustainable. Reliability will come by investing into cost-effective back-up capacities to cope with the challenges of renewable energy production: industrial demand response, energy storage. The integrated energy system should keep energy costs globally competitive, especially for large industrial users. Reliable and cost-effective technological solutions should be more widely implemented from a broad set of options: direct electrification, indirect electrification for the production of synthetic fuels or green hydrogen. Strong support for innovation in these fields is needed. Moreover, the transition to a climate-neutral economy will require additional supply of key raw materials like copper (see World Bank 2020 report). Benefits, synergies Reliability and global cost-effectiveness in energy supply will accelerate the transition towards climate-neutrality with positive impact on the quality of air and will help rebooting the economy. Biggest energy efficiency and cost-efficiency potential In transport or buildings heating/cooling, market-ready technologies (electric vehicles, heat pumps, fuel cells) can be quickly deployed once the required infrastructure is in place, leading to energy efficiency at low cost and avoiding curtailment. 2. Main barriers A full blueprint of the ambitioned integrated energy system should be developed and assess the impact of such integration on energy costs, to give better visibility to industrial users, assist them in developing long-term plans and avoid costly stranded energy assets. Development of infrastructure must be accelerated to improve the penetration of e-vehicles, heat pumps, low-emission heavy transport. 3. More specifically: • Increased decarbonisation through electricity drive In industry, direct electrification is used where feasible, however there is still a need to develop alternative solutions for decarbonisation - indirect electrification and green hydrogen, to be supported by European innovation funds. Also, adequate carbon leakage protection will support investments in decarbonisation by electrification. • Renewable gases Renewable gases (incl. green hydrogen) are options to decarbonise the energy system, provided they are cost-competitive. Innovation support should be provided to allow the use of renewable gases by energy-intensive industries, with secured access to the relevant distribution infrastructure. • Circular economy The use of excess process heat for district heating is a sizeable opportunity to reduce emissions and should be incentivised (fiscality of investments). Synergies exist with the Renovation Wave, via the development of business concepts like ESCOs. To develop the energy infrastructure, priority should be given to circular raw materials like copper. • Energy markets Energy markets have to ensure globally competitive energy costs in Europe. 4. Best practices, concrete projects See attachment 5. Policy, legislative measures Low carbon electricity must be available at globally competitive prices, be made compatible with State Aid regulation and adequate Carbon Leakage protection for the energy intensive industry. Demand response, district heating should be incentivised. Support to innovation is crucial in implementation of cost-effective, reliable energy use technologies for energy-intensive industries. Circular materials have to get priority in the build-up of energy infrastructure.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

European Copper Institute (ECI) represents the copper industry. Copper is used extensively (34% EU annual use) in technical building systems for delivering electricity, heating and water services. ECI makes the below recommendations for accelerating delivery of ambitious clean energy and efficiency objectives, with employment and growth, through the Renovation Wave. Investment in digitalization, energy efficiency, renewables, energy flexibility, and safety of buildings can help realise the untapped potential of a 5-fold reduction in energy demand from the bulk of the EU building stock. Buildings are an ideal focal point to reinforce a systems approach in the Green Deal. The Renovation Wave should prioritise sustainable, circular materials, like metals such as copper which is highly recyclable without loss of properties and has well-established recovery chains. Stimulate renovation rate & depth Building energy management can be improved rapidly across a broad mass of the building stock without disruptive interventions. Energy Performance Certificates (EPC) should reflect operational energy consumption and empower building owners/occupiers. Building Renovation Passports (BRP) should be included in national Long-term Renovation Strategies as they increase renovation rates and depth and accelerate energy savings. Mobilisation of investment Digitalisation technology allows energy savings to be measurable and bankable, but monetisation requires a strong policy framework–targets to create an energy savings market. Credible energy performance of a building translates into property value and can be linked to financial measures to drive life-cycle energy performance. Energy poverty & safety Safe electrical installations are a prerequisite for a clean and just energy transition and the sustainable energy model based on electrification. 25-30% of EU domestic fires are from an electrical source, with dramatic consequences: fatalities, injuries and economic cost to society. Energy poverty is observed as a significant catalyst for electrical safety issues. Domestic building stock renovation must integrate an electrical safety check as a mandatory requirement. Skills & employment Incentivising building automation deployment will create up to 300,000 highly specialized direct jobs in the EU which will benefit national economies. Smart technologies, cabling, digital & data Available advanced metering and building automation and control systems allow policies to be fully pinned on bridging the energy performance gap (over-estimation of energy savings from design-based promises) to ensure savings are real. Accelerating renovation rates and operation-based energy performance standards delivers huge energy and CO2 savings, and provides buildings that can evolve with the needs of the energy transition. Digitalization of EPC schemes would make them more dynamic and informative, with more frequent updates based on credible standards with verification, and this will help accelerate renovation. Space heating, still the highest energy demand in buildings, uses predominantly fossil fuels. Market-ready, mature technologies (e.g. heat pumps, in combination with on-site solar thermal or photovoltaic renewables) can complement architectural solutions. Through built-in energy storage and demand response capabilities, they provide wider system benefits for smart integration as well as healthier in- and outdoor air quality and stimulation of local jobs. Renovation is an opportunity to provide charging infrastructure for e-mobility (conduits for electric cables, simplified permitting) and to leverage the additional storage capacity provided by e-vehicle batteries (smart charging). At least 10% of electrical energy generated in the EU gets lost before it reaches a final consumer. Of this, 30 TWh/year of losses in buildings could be saved by applying the principle of economic cable sizing, the untapped opportunity confirmed by Ecodesign Working Plan 2012-14.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

The European Copper Institute welcomes the initiative of the European Commission to revise the Directive 2014/94/EU (AFID) and suggests to include the following elements in its Impact Assessment: * Binding targets for Member States regarding charging infrastructure for light duty vehicles on roads: at least 150 kW on the Core Network every 60 km both ways, within 18 months after the revised directive / regulation is published (own assessment attached). * Binding targets for cities (and regional governments grouping several towns) to award tenders to deploy charging points: - on at least 20% of public parking spaces (including on-street) before 2025 (NIC. National Infrastructure Assessment page 60 https://www.nic.org.uk/wp-content/uploads/CCS001_CCS0618917350-001_NIC-NIA_Accessible.pdf). - within 300 metres from any residential building (to ensure user acceptance). - strong recommendation upto 7.4kW single phase. For passenger cars, 3.7kW is enough to replenish the required energy to cover average daily driven distance in less than three hours. 7.4kW recommended for heavy users and light commercial vehicles. Higher power means higher capex and will imply in many areas delays in charging infrastructure deployment waiting for the upgrade of the distribution network. * Regulation instead of Directive to shorten the time to have in place the binding targets of charging infrastructure deployment, especially 150kW chargepoints on the Core Network. * Mandatory e-roaming for any publicly accessible charging point. Just plug to start charging, or park in case of wireless (included in the California equivalent regulation, EVSE Standards Regulation, to be published in May 2020 https://ww2.arb.ca.gov/rulemaking/2019/evse2019). * Mandatory smart charging (managing time and the power rate, also called V1G) for any publicly accessible charging point (Element Energy. Batteries on wheels Fig.13 & 14 https://www.transportenvironment.org/publications/batteries-wheels-role-battery-electric-cars-eu-power-system-and-beyond). * Strong recommendation to install V2G as a way to allow a more cost effective integration of renewables while generating revenues for EV owners, to also pay for the additional capex and opex of this functionality (IRENA. Innovation Outlook Smart Charging Fig. 31 & 35 https://www.irena.org/publications/2019/May/Innovation-Outlook-Smart-Charging). * In developing the infrastructure for alternative fuels, specific attention should be brought to keep the energy costs in Europe on a globally competitive level, this to protect the competitiveness of intensive energy users.
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and EPIA SolarPower Europe and

6 Nov 2019 · Keynote speech : powering the European Green Deal

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

10 Jul 2019 · Energy & Climate, E-mobility

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

The latest battery electric vehicle compact models (BEV) currently have a real range of around 300 km. This is more than enough for everyday use. For some models, the total cost of ownership is already equivalent to conventional models and by 2021, this will be the case for many more. What is missing? The EU needs more 150kW+ charging points along the TEN-T Core Network to make BEVs also convenient for long journeys and to convince consumers at the dealer shop to choose BEVs. It is just what Tesla has been doing for years deploying their superchargers (see map [1]). With a 150kW charging point, it is possible to add 200km of range in less than 15 minutes. An implicit requirement is that OEMs offer vehicles that accept 150kW. Equally important is the distribution of these chargers. To eradicate range anxiety from vehicle users, chargers need to be evenly deployed. Our proposal, in accordance with the EU publication “Clean Power for Transport Infrastructure Deployment” [2] is to ensure 150 kW chargers at every 60km. As an example, the implementation of such a proposal for the Spanish TEN-T Core Network - based on an average distance of 50 km between charging centers reachable from both directions of the road - would result in 98 charging centers. Such a targeted proposal should be manageable while resolving a critical aspect in the development of the market for emobility. In the transition to 2030, fast chargers along the TEN-T Core Network will be underutilised and will require financial support until the market develops. References [1] https://www.tesla.com/fr_BE/supercharger [2] EU Publication: Clean power for transport infrastructure deployment (page 26) https://publications.europa.eu/en/publication-detail/-/publication/1533ba56-094e-11e7-8a35-01aa75ed71a1
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Response to Sustainability requirements for batteries

5 Feb 2019

ECI welcomes the opportunity to provide input into the consultation on sustainable batteries. Considering the fast evolution of technology, policy needs to be forward-looking and agile to respond to new developments in this field. The EU is lagging behind other regions in terms of new battery technologies while often leading in regulation on environmental and social protection. A coherent policy framework is needed to support this strategic sector for the EU energy transition. Key points for consideration * A clear and auditable regulation must outline a level playing field across the world for social and environmental requirements applicable to raw materials, components or batteries manufactured and recycled in Europe or imported into Europe. * It is necessary to not just secure access to primary raw materials but also to ensure that scrap and recycling-materials do not leave the EU into areas where they receive a subpar treatment and vanish from the European raw materials base. * Referring to Standardisation mandate M543 regarding material efficiency, we propose to initiate a “battery” specific vertical standard that would cover battery-specific recycling aspects as well as material reporting. Such standard can support the introduction of a mandatory European Raw Materials Passport. * ECI regrets a lack of proportionality of EU chemical legislation such as REACH who targets banning of substances without consideration of future material developments and needs. Such bans will undoubtedly lead to material choices irrespective of future innovation and material supply needs, leading possibly to regrettable substitutions. * The value of materials in some of the new battery technologies does not always cover the cost of the recycling process. Suitable business models need to be developed for recycling such emerging battery types. * Ecodesign regulation should be relatively straightforward, as the market will already require energy performance in terms of energy efficiency and energy density. Beyond energy performance, criteria rewarding environmental and social performance of a product could be considered, as long as these are based on recognised international standards and practices. * As a general principle, regulations should focus on ends, not means. Battery pack design is a means to many ends: efficiency, weight, safety, durability, and recyclability, and cost. Regulations should not focus on the design of battery packs (the means) but rather on targeted outcomes: efficiency, durability, and recycling rates. * The revision of the Batteries Directive and the development of Ecodesign and Energy labelling requirements are intrinsically linked and should not be developed independently one from the other. Since these policies increasingly focus on vehicle batteries, the End of Life Vehicles Directive should be included in the scope as well. On the other hand, the Ecodesign and Energy labelling preparatory study should not be rushed, as the analysis needs to be thorough and accurate to achieve meaningful requirements. * Currently, the dismantling process of batteries is performed manually and represents half of the recycling cost. With robots, this cost could be reduced to just 5% (source: EBA250 meeting 29 Jan 2019). Many research teams are working on this topic. To support this development, a universal battery system code would greatly help to identify cell content and facilitate dismantling by robots. It would also help the business case for recycling. * Additionally, whilst re-use of vehicle batteries in a second life can – certainly now recycling is still in its infancy - offer interesting business opportunities, regulations must refrain from favouring re-use over recycling, since recycling of an old, spent battery system is in many cases more resource-efficient than its re-use.
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Response to Ecodesign requirements for (other) electric motors

19 Nov 2018

ECI’s view on the proposed regulation on Ecodesign for electric motors 19 November 2018 The draft regulation on ecodesign requirements for electric motors addresses very significant electricity saving opportunities. Following the Paris Agreement, a sharp increase in electrification can be expected in the coming years, leading to a strong growth in the use of electric motors. Furthermore, motor and variable speed drive (VSD) technologies are evolving fast. It is, therefore, crucial to regularly assess energy-saving opportunities in motor systems. Referring to the most recent publicly available information, the Preparatory Study Lot 30 Electric Motors and Drives, completed in 2014, one of the most energy saving policy options is the rise of Minimum Efficiency Performance Standards for medium and large induction motors from IE3 to IE4 (9.4 TWh/year). This policy option can deliver its specified savings under economic conditions. This means that in the vast majority of cases it leads to minimised life cycle costs which is beneficial for both motor users and society in general. 🠞 Increase the efficiency of medium and large motors (0.75 up to 1000 kW) to IE4 level. Since 2014, new motor technologies have been introduced into the market, such as permanent magnet or synchronous reluctance motors. Direct on-line operation is not always possible when these new technologies are used. As indicated in point (7) of the draft Regulation, “variable speed drives converted about 265 TWh of electricity from the grid into electricity with a frequency suited for the driven application; this corresponds to 105 Mt of CO2 emissions. This value is expected to rise to around 380 TWh by 2020 and to about 570 TWh by 2030”. This shows how motor technologies not suited for direct on-line operation, which would work in combination with VSDs, are very likely to reach increasingly significant market shares in the years to come. 🠞 Include motor technologies with a market share above a certain threshold into the regulation, regardless of their suitability for direct on-line operation. In the same spirit, ECI welcomes a review addressing requirements for combinations of motors and VSDs placed on the market together as well as integrated variable speed motors (compact drives). ****** References: * Electric Motors in the Energy Transition (http://www.leonardo-energy.org/resources/1468) * Lot 30 completed 2014 study available at https://www.eup-network.de/product-groups/preparatory-studies/completed/?L
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Response to Revision of the Drinking Water Directive (RECAST 2017)

30 Mar 2018

On 1 February 2018 the European Commission adopted a proposal for a revised Drinking Water Directive. Amongst other points it is proposed to reduce the lead content in drinking water from 10µg/L to 5µg/L, with a 10-year transition period. The European copper industry takes its role in reducing potential threats to human health very seriously. As such, the industry has worked hard to reduce the lead content in copper alloys in contact with drinking water as much as is currently technically feasible, and continues to research further reductions. The industry has two main concerns about the proposed further reduction from 10µg/L to 5µg/L: • First, the current EU limit of 10µg/L is in line with the most up-to-date WHO recommendations – see “Guidelines for drinking-water quality, 4th edition, incorporating the 1st addendum”, issued in 2017, here. With 10µg/L being the accepted standard at the global level, verified only last year, the copper industry does not believe it is necessary to further reduce the accepted level of lead in drinking water in the EU at this stage, adding additional burdens. • Second, going from 10µg/L down to 5µg/L will take the industry into unknown technical territory. Should the lead limit be reduced to 5µg/L, no assurance exists whether, across the broad spectrum of applications, the usability of the product would not be compromised. As such, the European copper industry strongly recommends retaining the current safe limit of 10µg/L in the revised Drinking Water Directive. The industry would be delighted to expand further on the above position as needed.
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

17 Nov 2016 · Energy legislative proposals under perspective of green & sustainable energy & growth

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

30 Jun 2016 · decarbonisation of the energy system

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

11 Jun 2015 · European Copper Institute's study to decarbonise Europe

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

11 Jun 2015 · European Copper Institute Study to decarbonise Europe