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CRM proposal falls short on circularity

The proposed Critical Raw Materials Regulation offers welcome safeguards from pollution for water bodies but fails to address the needs of critical entities and falls short in its circularity ambitions.

EurEau gives a cautious welcome to the legislative proposal for a Critical Raw Materials Regulation (16.03.23). We strongly support the Commission’s choice not to exempt strategic raw materials projects from performing environmental impact assessments. We particularly welcomed the explicit mention of the need to assess the impact on potentially affected water bodies and their status under the Water Framework Directive (WFD, 2000/60/EC) in Article 12 of the proposal.

However we were disappointed to see no reference to the materials needed by critical entities as defined in Directive (EU) 2022/2557 (Critical Entities Resilience Directive). EurEau believes that materials essential to the continued operation of essential services such as water supply and sanitation should be considered as critical materials under the proposed Regulation.

The proposal also displayed a striking lack of ambition regarding the circularity of critical raw material supplies. The text provides no quantified objective for the recycling of critical raw materials such as phosphorus, which can be recovered from wastewater treatment processes. The only quantified goal given at EU level concerns a shorter list of “strategic raw materials”, which does not include phosphorus.

While the proposal’s section on circularity sets some welcome objectives for national policies on increasing the circularity of supply for critical raw materials, it falls short of the level of ambition needed. In particular, EurEau has long called for a mandatory minimum level of recycled nutrients from organic sources (such as phosphorus) to be introduced for fertilising products at the EU level. Given the EU’s high reliance on a small number of third countries for its supply of rock phosphate, we continue to believe that this measure should be part of any package aiming to ensure the Union’s access to a secure and sustainable supply of critical raw materials.

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