They are not however in the “strategic raw materials” sub-list, so are not eligible for Strategic Projects, Joint Purchasing, recycling and supply targets.
ESPP considers that this Act should support phosphorus stewardship and recycling by requiring monitoring, inciting national circularity measures and facilitating permitting of recycling projects.
ESPP regrets that P4 is not included in the “Strategic” sub-list despite being essential for the specified “strategic” industry sectors (renewable energy, e.g. solar panels; batteries; data and electronics fire safety) and despite the EU’s 100% dependency on supply from three countries (China, Vietnam, Kazakhstan) – see joint industry declaration.
ESPP notes Art. 4.1) which specifies that CRMs covers “raw materials, including in unprocessed form, at any stage of processing and when occurring as a by-product of other extraction, processing or recycling processes, … shall be considered critical raw materials”. The interpretation of this for “Phosphate rock” could be interesting (!).
The following articles of the Act concern all CRMs (not only Strategic Raw Materials), so concern “Phosphate Rock” and “Phosphorus” (P4) :
- 5.2: “incentivise technological progress and resource efficiency” of CRMs,
- 9 and art. 2.14 (definitions): Member States must establish “Points of Single Contact” (can be more than one!) to facilitate and coordinate permitting of installations for “extraction, processing or recycling” of CRMs,
- 13, art. 18: certain CRM project planning simplifications,
- 19: national exploration programmes for CRM resources,
- 20: EU monitoring of CRM trade flows and obstacles to trade, demand, supply and supply concentration, production, bottlenecks, price volatility. This monitoring information (aggregated) will be made publicly available,
- 21: identification and monitoring of key CRM value chain operators,
- 26.1: (within 2 years) national programmes for circularity of CRMs, including incentivising resource and materials efficiency, “collection, sorting and processing of waste with high critical raw materials recovery potential …” and “increase the use of secondary critical raw materials including through measures such as taking recycled content into account in award criteria related to public procurement or financial incentives for the use of secondary critical raw materials”, “increase the technological maturity of recycling technologies”, “support the use of Union quality standards for recycling processes of waste streams containing critical raw materials”, workforce upskilling …
- 2.7: analysis of operating and closed sites to define CRM recovery potential from extractive waste (ESPP note: could concern phosphogypsum deposits),
- 26.7: The Commission will adopt (by May 2025) implementing acts defining a “list of products … and waste streams … considered as having a relevant critical raw materials recovery potential”,
- 30 and art. 31: possible sustainability certification and environmental footprint schemes for CRMs.
EU Regulation 2024/1252 (11th April 2024) “establishing a framework for ensuring a secure and sustainable supply of critical raw materials” https://eur-lex.europa.eu/eli/reg/2024/1252/oj