Driving a resilient and commercially attractive raw material market in Europe: industry recommendations on the CRM Act

The Critical Raw Materials (CRM) Act could make an integrated secondary raw material market in Europe a reality. It could offer industry respite amid escalating CRM demand from primary sources. There is potential for leaps forward in areas like CRM re-use and recycling, but only if the necessary commercial incentives are in place for companies within the Single Market.

Trialogues serve as a decisive chance to define policy conditions that maximise the value of available supply chain expertise, exploit the breadth of the European market to make strides in areas like CRM re-use and recycling, and ultimately forge industrial circularity leaders at European level. To realise that, we call on the EU institutions to:

• Delete Article 23 and enhance Article 20 with guidance on ‘’key market operator’’ designation. This approach would remove audit duplications, streamline risk preparedness and be a first notable deliverable on President von der Leyen’s efforts to cut EU reporting requirements by 25%.
• Introduce harmonising criteria under Article 25 to safeguard the Single Market in the development of national circular measures.
• Uphold safeguards against mandatory information exposure in the CRM data carrier if it would reveal commercially sensitive product attributes.