Ragn-Sells response to EU raw materials proposal: “Critical raw materials already exist in our waste” 

An outdated perspective on waste prevents the extraction of critical raw materials from waste streams, threatening European self-sufficiency. Only by shifting perspective can we secure our supply of critical materials without harming the climate, environmental company Ragn-Sells says in response to the proposed Critical Raw Materials Act.  
 
– If we are serious about creating a sustainable society, we have to start using the raw materials we already have, over and over again. Despite the growing threat to the supply of more critical materials noted by the EU, we do not make use of the materials that already exist in abundance in our waste, says Pär Larshans, Sustainability Director at Ragn-Sells. 
 
The act recently introduced by the European Commission is intended to secure access to important raw materials, in particular those whose supply is threatened or uncertain for various reasons. The proposal also added another six substances to the list of so-called critical raw materials, expanding the list to 34. 
 
Sixteen of these materials are now also designated as ”strategic” by the EU, primarily metals and minerals important to the green and digital transitions as well as defence and space applications. These include rare earth metals used in electronics and materials needed to produce modern batteries. In many cases, the global market for these elements is dominated by China. 
 
However, while phosphorus and phosphate rock are still listed as critical raw materials, they are not included among the strategic raw materials. This means that a crucial fertiliser nutrient for the agricultural industry is excluded from actions reserved for strategic raw materials, such as streamlined permitting processes and recycling targets. Contrary to the act’s intent, this means a risk of cementing the EU’s dependency on imported phosphorus from countries like Russia and Morocco. 
 
– The price of phosphorus has tripled since 2019, resulting in food shortages and skyrocketing food prices. If farmers cannot afford fertilisers, harvest will be severely diminished. To list phosphorus as a critical but not a strategic raw material is absurd when Europe must do everything in its power to secure its food production, says Anders Kihl, Head of Strategy and R&D at Ragn-Sells. 
 
The act stipulates that recycled materials should cover 15 percent of the EU’s consumption of strategic raw materials in 2030. Still, increasing the capacity for virgin extraction is at the center of the proposal, and the recycling target does not apply to the more extensive list of critical raw materials. While the need to address barriers to increased circularity of raw materials is mentioned in the legal text, it fails to name these. 
 
– While it is positive that the EU is looking to facilitate the recycling of the so-called strategic raw materials, we also have an abundance of the raw materials listed as critical in our waste. Naturally, the recycling of all materials included in the act should be promoted in every possible way, says Mr. Larshans. 
 
The extraction and processing of raw materials are the cause of half of all global greenhouse gas emissions, as well as 90 percent of water stress and biodiversity loss, according to the UN. Only days after the proposal, the UN’s Intergovernmental Panel on Climate Change (IPCC) presented its most comprehensive synthesis report of climate change science so far, emphasising the urgency to reduce emissions in the very near future. 
 
– It’s completely unsustainable for the EU to consume 20 percent of the world’s resources, while producing no more than two percent. To meet this challenge, we cannot rely on more extraction of increasingly depleted resources; instead, we must seriously step up recycling ambitions. Adopting an entirely new perspective on waste as a sustainable source of materials is crucial to securing our supply of critical materials without harming the climate, says Mr. Kihl.  
 
Ragn-Sells welcomes the opening for member states to use economic incentives to increase the circulation of critical raw materials, as well as the Commission’s noting the states’ responsibility as major procurers. However, while the Commission is looking to remove obstacles to extracting raw materials from extractive waste, the act fails to note the challenges that current legislation poses for all other forms of recycling. 
 
For further information, please contact:  
Pär Larshans, Director of Sustainability at Ragn-Sells, +46 70-927 29 63, par.larshans@ragnsells.com 
Anders Kihl, Head of Strategy and R&D at Ragn-Sells, + 46 70-927 26 84, anders.kihl@ragnsells.com 
Emma Ranerfors, Press officer at Ragn-Sells, +46 10-723 24 16, press@ragnsells.com  
 
Fact box: EU’s Critical and Strategic Raw Materials 
Since 2011, the European Commission has produced a list of critical raw materials (CRM) every three years. The list covers substances that are deemed to be of particular importance to the EU economy, but whose supply is threatened or uncertain. For example, geopolitics can be a factor, as in the case of rare earth metals where China controls 98 percent of the world's known deposits.  
 
The Critical Raw Materials Act lists the following substances or element groups as critical raw materials. Strategic raw materials in bold: Antimony, arsenic, bauxite, baryte, beryllium, bismuth, boron, cobalt, coking coal, copper, feldspar, fluorspar, gallium, germanium, hafnium, helium, heavy rare earth elements, light rare earth elements, lithium, magnesium, manganese, natural graphite, nickel – battery grade, niobium, phosphate rock, phosphorus, platinum group metals, scandium, silicon metal, strontium, tantalum, titanium metal, tungsten, and vanadium.