- The Act aims to manage raw material consumption and promote circularity, but lacks specific reduction targets.
- Indigenous Peoples' rights, particularly FPIC, are not explicitly recognised, raising concerns about their participation.
- Reliance on certification schemes for environmental and human rights protections is questioned, with calls for direct monitoring and enforcement.
The European Union's recent political agreement on the Critical Raw Materials Act (CRMA) has elicited a range of reactions, reflecting both advancements and areas of concern. The Act, which aims to regulate the EU's raw material consumption and align with global environmental and human rights standards, has been both praised for its ambitions and critiqued for its shortcomings.
One of the key areas of focus in the CRMA is the reduction of raw material consumption and the promotion of circularity. While the Act increases the recycling target to 25%, it stops short of setting specific targets for reducing raw material demand. This has been seen as a missed opportunity by environmental groups, who argue that managing demand is crucial for securing supply chains and mitigating environmental and social risks.
Robin Roels, Spokesperson for the Raw Materials Coalition, EEB, said “The EU and Member States must prioritise realistic strategies to reduce raw material demand, thus lessening criticality and mitigating environmental and social risks. The Raw Materials Coalition advocates for specific targets, and though the CRMA’s current language on demand moderation is a starting point, further development by implementing institutions is necessary.”
The Act's approach to Indigenous Peoples' rights has also been a point of contention. The inclusion of the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) is a positive step, but the Act does not explicitly recognize the right to Free, Prior, and Informed Consent (FPIC). This omission is particularly concerning given that many strategic raw materials are located on or near Indigenous territories. Advocates stress the importance of ensuring meaningful participation and consent from Indigenous communities in decisions that impact their lands and livelihoods.
Another significant concern is the CRMA's reliance on certification schemes to ensure compliance with environmental and human rights standards for Strategic Projects outside the EU. Critics argue that these schemes are insufficient and call for stronger measures, including direct monitoring and enforcement, to protect against environmental degradation and human rights abuses.
The EU's strategic partnerships with resource-rich countries also raise concerns. These partnerships, aimed at securing raw material supplies, could lead to increased mining in sensitive ecosystems and exacerbate human rights issues. Advocates urge the EU to reduce its reliance on raw materials from third countries and promote sustainable sourcing practices.