EU Critical Raw Materials Act should avoid extreme dependencies and improve conditions for investment  

The European Commission plans to present a proposal for a Critical Raw Materials Act before the end of March 2023. This initiative is crucial in setting important conditions for automotive suppliers to deliver the green and digital transition.

An electric car contains more than 200 kilograms of minerals versus around 40 kilograms for a conventional car, highlighting the increased material intensity of next generation vehicles. Without concerted action by government and industry, EU companies may struggle to secure sufficient raw materials and to avoid undesirable dependencies with just a few countries.  

CLEPA proposes that the Act establish an EU agency for critical raw materials and an industry advisory board to anchor close cooperation between government and industry in order to secure a sufficient and diversified supply of raw materials. CLEPA sees a need for coordinated action to deliver trade and raw material partnerships with third countries, a higher recovery rate of materials and improved conditions for investment in EU raw materials supply chains. CLEPA’s adopted position highlights the need to work with industry to improve the recovery rate of materials through design innovation, certification of recycling companies and measures to combat the illegal or inefficient disposal of used vehicles and realistic recycling targets. Ambitious targets for recycled content will be less effective than a comprehensive set of measures to improve the supply of recycled content.  

The Critical Raw Materials Act regulation is unlikely to cover all required elements of a successful EU raw materials strategy. While the regulation will address the main aspects, certain elements will be dealt with through separate legislation, such as the revision of the End-of-Life Vehicle Directive. The Act is therefore likely to be accompanied by a Commission’s communication to provide a comprehensive overview of legislative action.   


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