DiXi Group and 40 other civil society organizations prepared recommendations for the Critical Raw Materials Act

Natural resources are very unevenly distributed on the planet. About 50% of the world’s nonfuel mineral resources, 2/3 of oil reserves, and about 50% of natural gas are concentrated in developing countries. This, in turn, often leads to conflicts and various types of raw material dependence on other countries.

With the outbreak of Russia’s full-scale war against Ukraine, the EU adopted a comprehensive plan to get rid of energy dependence on Russia and accelerate the energy transition called REPowerEU. Now European countries are considering another comprehensive document: The Critical Raw Materials Act, which defines 34 items of critical raw materials in the EU and approaches their supply.

DiXi Group became a signatory to the position paper “A Turning Point: The Critical Raw Material Act’s needs for a Social and Just Green Transition”, which was jointly prepared by 41 civil society organisations.

Key recommendations for the draft Critical Raw Materials Act:

The CRMA’s focus on EU supply security through partnerships lacks a global justice approach. Including concrete measures to ensure sustainability standards, civil society participation, and the protection of human rights and the environment in third countries.

Our recommendations include aligning partnerships with international agreements, implementing robust monitoring and remediation mechanisms, defining “value addition,” supporting domestic industrialisation, involving civil society and Indigenous Peoples, ensuring transparency, and avoiding the undermining of commitments through other regulations or trade agreements.

The CRMA’s focus on accelerating permitting procedures for Strategic Projects risks bypassing environmental and social safeguards and lacks public buy-in. Streamlined permitting must not come at the cost of environmental protection, meaningful public participation. Incorporating elements like Free, Prior, and Informed Consent (FPIC) and Indigenous rights must be at the center of strategic projects.

Additionally, resources to licensing authorities have to be allocated, international agreements referenced, transparency ensured and a subgroup on sustainability and responsible mining within the European Critical Raw Materials Board established. Deep-sea mining due to potential environmental and social impacts has to be prohibited.

For the success of the European Green Deal and the EU’s strategic autonomy, it is crucial to prioritise a circular economy approach in the CRMA. This includes:

implementing an ambitious recycling strategy,
enhancing coherence with the waste hierarchy,
increasing EU recycling capacity targets,
improving collection and separation of critical raw materials (CRM)-containing components,
proposing recycled content targets for all CRM-containing products,
incorporating measures for public procurement,
and ensuring that the recovery of mining waste follows comprehensive regulations and includes plans for remediation of historical pollution.