How would you assess the European Commission’s new communication on raw materials?
Our main point with the raw materials initiative (RMI) is the fact that it doesn’t prioritise the three different pillars. We are clearly in favour of prioritising the third pillar (on resource efficiency and recycling). We also want to insist much more on the substitution possibility for critical materials, which is slightly different from recycling. Currently, the third pillar is really about resource efficiency and recycling, but we would prefer to group together resource efficiency, including substitution and recycling.
For us this should be the starting point of the RMI, because it implies the possibility of gathering knowledge and promoting research and development – which in turn are in line with the competitiveness strategy for Europe. Better emphasis on the third pillar may also contribute to the two other pillars (trade and domestic mining).
Why is prioritising action so important?
Because the risk is that if you do not create such a hierarchy, you may take mining and trade initiatives that may even jeopardise some other good dynamic in terms of research and development, as well as recycling and setting up recycling facilities. At the end of the day jeopardising the third pillar may increase our dependency on external sources.
So our key message is that we need to prioritise action between the three pillars, with the primary focus on the third one. And we also should emphasise more the substitution possibilities. The Commission’s new communication on the RMI is much more precise on the third pillar than the 2008 communication, which is good but a clear improvement is still needed.
What is your view on increasing mining in Europe?
Domestic mining is another issue we insist on. There has been a clear increase in Natura 2000 sites. And obviously there is a kind of reserve in these protected areas at European level.
However, here we have some concerns, because according to our understanding the main mining activity in Natura 2000 is aggregates – mining to get aggregates for the construction industry – whereas construction aggregates are clearly not identified, so far, as strategic materials. They are commodities, but not strategic materials.
We should prioritise action also within this second pillar. If we merely state that domestic mining is also a priority for us, to reduce dependency and to cover our needs – creating any hierarchy and ranking within this pillar – we may extract from Natura 2000 sites materials for aggregates, construction and demolition. This while there’s a tremendous potential to increase construction and demolition waste recycling – a recycling branch that is clearly not optimal yet.