02 Oct 2023

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.
Download the full position paper here
For more information, please contact
Ray Pinto
Senior Director for Digital Transformation Policy
Vincenzo Renda
Director for Single Market & Digital Competitiveness
Back to Cybersecurity
View the complete Position Paper
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