EU Key Raw Materials Law

CRMA has three goals:

1. Ensure stable supply of essential raw materials to the EU (EU) industry.
2. Enhance the flexibility of the supply chain.
3. Encourage diversification of procurement while reducing dependency.

These goals are designed to achieve the following:

1. Maintain the competitiveness of EU industry by promoting access to raw materials that are essential to advancing green technology.
2. Reduce the possibility of supply chain disruptions, such as during the Covid-19 pandemic and natural disasters.
3. Reduce the threat of economic coercion, especially from China.

Critical Raw Materials (CRM) are classified according to the following criteria:

• Economic significance to the broader EU economy.
• Supply risk assessment.

Strategic Raw Materials (SRM) is a subset of Critical Raw Materials (CRM) and its definition criteria include:

• The importance of promoting green and digital transformation.
• Relevance to defense and space applications.
• Compared with current global output, demand is expected to be higher in the future.

The European Commission will regularly revise the list of key raw materials (CRM) and strategic raw materials (SRM) related to green technology:

Reference: General methods for reporting the use of key raw materials for energy-related products

Mandatory requirements for the company

1. Companies should not rely on more than 65% of the strategic raw material supply in a single third country and at any processing stage
2. Supply Chain Audit: Large companies that use critical raw material subgroups (SRMs) in strategic technologies must undergo a mandatory supply chain audit every two years. Examples of such techniques include, but are not limited to:

• Energy storage and electric vehicle batteries.
• Hydrogen production and utilization equipment.
• Equipment related to renewable energy generation.
• Traction motor.
• Heat pump.
• Data transmission and storage systems.
• Mobile electronic devices.
• Equipment related to additive manufacturing.
• Robotics technology.
• Drone.
• satellite.
• Advanced chips.

Audits must include stress testing of the SRM supply chain, assessing their vulnerability to disruptions by evaluating the potential impact of a variety of situations. This assessment should consider:

• SRM extraction, processing or recycling location.
• The capabilities of economic operators in value chains and market structures.
• Factors that affect supply, such as geopolitical conditions, logistics, energy supply, labor or natural disasters.
• Alternative supply sources and availability of alternative materials.
• Identify users of relevant SRMs throughout the value chain, with special attention to technologies related to green and digital transformation, defense and aerospace industries.

The company should collect information about the key raw materials present in its products in order to be able to meet its obligations.

At least 10% of the resources used by the EU every year should come from within the EU.

At least 40% of the EU's annual demand should be handled within the EU.

At least 15% of the annual consumption of the EU should be met by recycling materials.

Product range for special requirements of permanent magnets:

The relevant product list includes:

• Magnetic resonance imaging equipment
• Wind turbine.
• Industrial robots
• Motor vehicle
• Light transportation
• Cooling generator
• Heat pump
• Motors, including motors integrated into other products such as automatic washing machines, tumble dryers, microwave ovens, vacuum cleaners and dishwashers.

Special requirements for permanent magnets:

1. Specifications for companies that launch permanent magnet products to the market.
2. The product must showcase durable labels with a prominent display, indicating:
1. Does the product contain permanent magnets?
2. If a magnet is present, specify its type (for example, NdFeB, Samarium Cobalt, AlniCobalt, Ferrite).
3. The product should contain a data carrier with a unique identifier, providing:
4. Company contact information.
5. The weight, location and chemical composition of each permanent magnet, including coatings, adhesives and additives.
6. Instructions for positioning and disassembling permanent magnets, including the required tools or techniques.
7. For products whose magnets are located only within the embedded motor, exemptions may be given instead of detailed magnet-specific information.
8. Products with a digital product passport must contain the required information.
9. The information should be related to the product model, or for different units, to a specific batch or unit.
10. Recyclers, market regulators and customs should access this information.
11. Transition period:
1. Three years after the regulations were promulgated.
2. Regulations on specific equipment such as magnetic resonance imaging equipment, motor vehicles and light transport vehicles are enacted five years after the enactment of this.
3. Motors, including motors integrated into other products such as washer, dryer, microwave, vacuum cleaner and dishwasher.
12. Disclose detailed information on recycling content
13. Companies that launch products with permanent magnet weights exceeding 0.2 kg must disclose the percentage of recovered neodymium, dysprosium, praseodymium, terbium, boron, samarium, nickel and cobalt. This information should be publicly available.
14. Customers must access this information before purchasing or entering into a contract.

 

Ahmed Sakr

Product Compliance Consultant

ComplyMarket UG (haftungsbeschraenkt)