European Critical Raw Materials Law

The objectives of the CRMA are triple:

1. Ensure a constant supply of raw materials essential for the European Union industry (EU).
2. Strengthen the resilience of the supply chain.
3. Encourage the diversification of supplies while reducing dependencies.

These objectives aim to achieve the following objectives:

1. Preserve the competitiveness of European industry by facilitating access to raw materials essential to the progress of green technologies.
2. Reducing vulnerability to the disruption of the supply chain, such as those observed during the Pandemic of COVID-19 and natural disasters.
3. Athoring the threat of economic coercion, especially on the part of China.

Critical raw materials (CRM) are categorized according to the following criteria:

• Economic importance for the European economy in the broad sense.
• Risk assessment.

Strategic raw materials (SRM), a subset of critical raw materials (CRM), are defined by criteria comprising:

• Importance in promoting green and digital transitions.
• Relevance for defense and space applications.
• Future demand projected high in relation to current global production.

The inventory of critical raw materials (MRC) and strategic raw materials (MRS) relevant to green technologies will be the subject of periodic revisions by the European Commission:

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

Compulsory requirements for companies

1. Companies should not depend on a single third country for more than 65% of their strategic raw material supply, the gross state and at any stage of processing.
2. Audit of the supply chain: Large companies using a subgroup of critical raw materials (MRS) in strategic technologies must submit to compulsory audits of the supply chain every two years. Examples of such technologies include, without limiting themselves:

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

The audit must include a resistance test on SRM supply chains in order to assess their vulnerability to disturbances by assessing the potential impact of various scenarios.This evaluation should take into account:

• MRS extraction, treatment or recycling places.
• Capacities of economic operators throughout the value chain and market structure.
• Factors influencing supply, such as geopolitical conditions, logistics, energy supply, workforce or natural disasters.
• Availability of alternative supply sources and substitution materials.
• Identification of relevant MRS users throughout the value chain, with particular attention to relevant technologies for green and digital transitions, defense and space industries.

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

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

At least 40 % of EU annual needs should be treated within the EU.

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

Products covered by the specific requirements of permanent magnets:

The list of products concerned includes:

• Magnetic resonance imaging devices
• Wind energy generators.
• Industrial robots
• Motor vehicles
• Light means of transport
• Cooling generators
• Heat pumps
• Electric engines, including those integrated into other products such as automatic washing machines, dryers, microwaves, vacuum cleaners and dishwasher.

Special requirements of permanent magnets:

1. Specifications for companies that launch permanent magnet products on the market.
2. Products must clearly bring a lasting label indicating:
1. If the product contains permanent magnets.
2. If magnets are present, specify their type (for example, neodyme-fer-boron, samarium-cobalt, aluminum-nickel-cobalt, ferrite).
3. Products must include data support with a single identifier providing:
4. Contact details of the company.
5. Weight, location and chemical composition of each permanent magnet, including coverings, adhesives and additives.
6. Instructions to locate and remove permanent magnets, including the required tools or technologies.
7. An exemption is granted for products in which magnets are only integrated into electric motors, replacing detailed information specific to magnets.
8. Products with digital products passport must include the required information.
9. The information must relate to the product model or, for different units, on prizes or specific units.
10. Recyclers, market supervisory authorities and customs should access this information.
11. Transition periods:
1. Three years after the promulgation of the regulations.
2. Five years after the promulgation of the regulations for specific devices such as magnetic resonance imaging devices, motor vehicles and light transport vehicles.
3. Electric motors, including those integrated into other products such as washing machines, dryers, microwaves, vacuum cleaners and dishwasher.
12. Details of recycled content details
13. Companies that launch products with permanent magnets exceeding 0.2 kg must disclose the percentage of neodymium, dysprosium, presodyme, terbium, bore, samarium, nickel and cobalt recycled.This information must be accessible to the public.
14. Customers must access this information before purchasing or contract.

 

Ahmed Sakr

Product Compliance Consultant

Complymarket UG (Beschraenkt)