Page 35 - European Energy Innovation magazine - spring 2023 edition

Spring 2023 European Energy Innovation
ELECTROMOBILITY 35

strategical Act should be to avoid industries. We do not favor direct circularity and sustainability of CRMs
many small initiatives triggering market intervention in the form of sourcing.
competition within and between strategic reserve buying or policies
Member States and create an designed around redistribution 9. Modernize permitting and
integrated and coherent development schemes. licensing
strategy in order to allocate resources Policies building strategic reserves As highlighted in the introduction,
more efficiently. can artificially inflate prices and irrelevant permitting procedures
negatively impact the development of represent a key hurdle. Procedures
2. Financial and political support European should be modernized, made
for recycling producers of value-added goods more robust and transparent
Economic actors meeting the highest dependent on these critical raw and strongly simplified without
existing environmental standards (e.g. materials. undermining existing environmental
mine tailings) and social standards laws (e.g. Industrial Emissions
(e.g. community consultation) 7. Environmental standards Directive, Water Framework, Habitats
should be eligible to financial and The Act should not yield way for Directives) and in compliance with
political support. For EU-sourced weakening any environmental Environmental, social, and corporate
materials, the Act would then work in regulation but rather offer the governance criteria. Support for
relation with the existing package of opportunity to safeguard key ones as permitting authorities with expert
environmental policies which control a condition capacity at national level is also
impacts from its domestic mining necessary and the digitalization of
and refining operations and the high 8. Set appropriate recycling and the permitting process would ensure
EU social standards. second-hand market rules transparency and full engagement
The EU should reduce its dependency from project developers to local
3. Incentivize sustainable and on imports of material of strategic communities.
secondary sourcing importance for production. Sourcing
Sourcing should be both sustainable should take place within the EU 10. Ensure consistency, certainty
and sufficient. The legislation should and should include sourcing of and synergy across legislations
focus on ensuring availability of secondary raw materials from It would be helpful to consider the
supply which respects human waste. As all recycling activities potential links and synergies between
rights and environmental standards are not financially viable today due the CRM act and other legislations
regardless of the country of origin. to the low cost of some primary already in place (e.g. environmental
resources and unavailability of and human rights regulations); and to
4. Sustainable mining in Europe recyclable material, support for ensure consistency across different
While repurposing should always the development of recycling pieces of legislation to meet the
be the preferred option to uphold capacities is crucial to enhance the needs of the CRM demand sector. l
resources, and while mining is a topic
to handle with care and consideration
for local and social contexts, it is
nevertheless important to consider
the full value chain.

5. Considerations for international
sourcing
When solutions for European
sourcing (from repurposing, recycling,
to remining and mining) are not
sufficient, various options for sourcing
CRM internationally should be
considered.

6. The risks of stockpiling
We call for a very cautious
assessment of the need for
stockpiling mechanisms as they may
have unintended negative impacts on
the markets and nascent European

Contact
Email: theo@platformelectromobility.eu
www.europeanenergyinnovation.eu