EU critical raw materials law

The objectives of the CRMA are three:

1. Guarantee a constant supply of essential raw materials for the European Union industry (EU).
2. Strengthen the resilience of the supply chain.
3. Promote the diversification of supply and at the same time reduce dependencies.

These objectives intend to achieve the following:

1. Safeguard the competitiveness of the EU industry facilitating access to crucial raw materials for the advancement of green technology.
2. Reduce susceptibility to interruptions in the supply chain, such as those observed during the Covid-19 pandemic and natural calamities.
3. Mitigate the threat of economic coercion, particularly from China.

Critical raw materials (CRMS) are classified according to the following criteria:

• Economic importance for the EU economy in general.
• SUPPLY RISK EVALUATION.

Strategic raw materials (SRMS), a subset of critical raw materials (CRMS), are defined by criteria that include:

• Importance in promoting green and digital transitions.
• Relevance for spatial and defense applications.
• High future demand projected in relation to current global production.

The inventory of critical raw materials (CRMS) and strategic raw materials (SRMS) relevant to green technologies will be subject to periodic reviews by the European Commission:

Reference: General method to declare the use of critical raw materials in energy -related products.

Mandatory requirements for companies

1. Companies should not depend on a single third country for more than 65% of their supply of any strategic raw material, without processing and at any processing stage.
2. Supply chain audit: large companies that use subgroups of critical raw materials (SRMS) in strategic technologies must undergo compulsory audits of the supply chain every two years. Examples of these technologies include, among others:

• Energy and electrical mobility storage batteries.
• Equipment for the production and use of hydrogen.
• Teams associated with renewable energy generation.
• Traction engines.
• Heat pumps
• Data transmission and storage systems.
• Mobile electronic devices.
• Equipment related to additive manufacturing.
• Robotics
• Drones
• Satellites
• Advanced chips.

The audit must cover a resistance test to SRM supply chains to evaluate its vulnerability to interruptions by evaluating the potential impact of several scenarios. This evaluation should consider:

• MER processing, processing or recycling places.
• Capacities of economic operators along the value chain and market structure.
• Factors that influence the supply, such as geopolitical conditions, logistics, energy supply, workforce or natural disasters.
• Availability of alternative supply sources and substitute materials.
• Identification of relevant SRM users throughout the value chain, with special attention to relevant technologies for ecological and digital transitions, defense and space industries.

Companies must collect information about the presence of critical raw materials in their products to be able to fulfill their obligations.

At least 10% of what the EU uses every year should come from the EU itself.

At least 40% of EU's annual needs should be processed within the EU.

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

Scope products for special requirements of permanent magnets:

The list of relevant products includes:

• Magnetic resonance image devices
• Wind energy generators.
• Industrial robots
• Motor vehicles
• Light means of transport.
• Cooling generators
• Heat pumps
• Electric motors, including those integrated in other products such as automatic washing machines, dryers, microwaves, vacuum and dishwashers.

Special requirements of permanent magnets:

1. Specifications for companies that introduce in the market products with permanent magnets.
2. Products should highlight a lasting label that indicates:
1. If the product contains permanent magnets.
2. If there are magnets, specify their type (eg, neodimio-hydro-foro, samario-colto, aluminum-nickel-cobalto, ferrite).
3. Products must include data support with a unique identifier that provides:
4. Company contact data.
5. Weight, location and chemical composition of each permanent magnet, including coatings, adhesives and additives.
6. Instructions to locate and remove permanent magnets, including the necessary tools or technologies.
7. An exemption is granted for products in which magnets are found only within integrated electric motors, replacing the specific detailed information of magnets.
8. Products with digital product passports should include the required information.
9. The information must be related to the product or, for different unit model, with specific lots or units.
10. Recyclers, market surveillance authorities and customs must access this information.
11. Transition periods:
1. Three years after the promulgation of the regulation.
2. Five years after the enactment of regulation for specific devices such as magnetic resonance image devices, motor vehicles and light transport vehicles.
3. Electric motors, including those integrated in other products such as washing machines, dryers, microwaves, vacuum and dishwasher.
12. Dissemination of recycled content details
13. Companies that introduce products with permanent magnets that exceed 0.2 kg must disseminate the percentage of neodymium, disposium, prseodimium, terbio, boron, samarium, nickel and recycled cobalt.This information must be publicly accessible.
14. Customers must access this information before making the purchase or contract.

 

Ahmed Sakr

Product Compliance Consultant

Complymarket UG (haftungsbeschraenkt)