Stéphane Arditi is product and waste policy officer at the European Environmental Bureau (EEB).
He was speaking to EurActiv's Outi Alapekkala.
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.
Are you afraid that playing the 'security of supply' card to increase domestic mining will be seized upon as an excuse to extract materials that are not critical?
We should first focus on critical materials and commodities. Because otherwise we may end up authorising some mining activity in Natura 2000 sites and endanger biodiversity, even for non-critical materials.
Also, critical materials are defined as materials not available or easily available in Europe. So, we are clearly talking about materials which are not found in Europe so I don't see how our mining activity could help us on that. In addition, it is clear that urban mining and recycling can maybe make a difference here.
Urban mining is the fact that we try to extract or recover the resources which are contained in waste. This is the opposite of virgin material extraction, which we call traditional mining. And urban mining is still an untapped potential.
What should the EU do with regard to waste and recycling policies in order to promote urban mining?
Obviously, broadly speaking, we should increase legal drivers for recycling because one of the main problems faced by the recycling industry is securing investment. If you've got some legal drivers setting high ambitions for recycling - then you also give clear visibility to the recycling industry that they can set their investments, because it is required by law to recycle and for them this is [about] security [and] about ensuring that their investments will be profitable in the end.
In Europe, it is also important to create the conditions for creating the associated jobs.
So, setting a new legal framework that will help and enable these long-term certainties for the recycling industry. But here again, if the recycling industry is competing with virgin material extraction, then they will be more reluctant.
This is exactly what happened with rare earths. Our current recycling techniques and methodologies are not really profitable and there is a kind of reluctance from the industry to develop that further intensively, because the shortage of rare earths is not an absolute shortage, but is linked to Chinese export quotas. A recent report shows that for some individual rare earths there is a clear shortage of supply which can be anticipated but for others it is more about trade. And if there is a new mine opened it can jeopardise investment in the recycling industry.
So here we have got a clear case demonstrating how setting a legal framework and financial insurance for the company could truly help to recycle and recover more materials and boost research to optimise the not-yet-fully-developed technologies – but where the risk of competing with virgin material extraction does not create proper conditions for recycling. Here again this is why we think it is important to prioritise the third pillar and substitution.
We should be mining the EU inventiveness to ensure a leading-edge position in knowledge for Europe. However, this should not be the exclusive option. I'm not saying that only recycling can save us. But prioritising will enable us to get all the potential we've got in terms of research and development, technology and innovation in recycling. This is good for Europe because these activities are located here and could create jobs here.
From that strategy we can then identify where we've got clear loopholes and where we definitely need to act on trade, and set a worldwide coalition with the US and Japan to try to establish more friendly exchanges with China. We could, for example, exchange some technologies for clean and sustainable mining against assurances from China that they will still export some of the materials we cannot substitute or easily recycle.
In terms of EU member states, are there any good examples in terms of recycling and urban mining?
Not necessarily member states but we have some companies and industry practices which give a clear business case. One I can think of is car suppliers producing the catalyst part of the exhaust system in a closed loop 'symbiotic' system with some recyclers, such as Umicore. This kind of business model can also create conditions or a business case for recycling and promote further research and development.
Currently we take inspiration from the Japanese system, because they have clearly identified this closed loop as one of their strategic objectives for industry. And the way they calculate their achievements in terms of recycling is not exactly the same as we have here.
Some time ago, the European Parliament invited Japan to speak about their strategy to recycle and substitute rare earths and deal with the problem. When you look at the Japanese and US strategies they also rely on trade issues and speak about domestic mining, but they make clearer the point on substitution and R&D. I also think that they prioritise more clearly the different points in their strategies.
What is striking in the EU communication is that they start with trading and then go to other pillars. When you go to the US strategy, they start by substitution and resource efficiency. There is no hierarchy in that strategy either, but at least they start with this.
Whereas everybody, including the Commission, says that business as usual is not an option and won't work on this matter, the first pillar of the communication is all about enforcing our business as usual way of dealing with developing countries – grabbing their resources for our own use. So there is some incoherence here.
Meanwhile, the European Parliament clearly seems to have seized the potential of electronic waste. Looking at the last WEEE vote in the plenary, the Parliament clearly set out ambitious targets for collection and recycling. We've got a lot of good elements there: trying to make the export conditions more stringent, boosting the ambition of collection, establishing standards for the recycling, setting objectives for effective recycling process and not only on the input recycling facilities. A lot of amendments show that the Parliament is more aware of the potential of recycling, substitution and setting the proper conditions for investment. This is a good sign for me.
The Parliament's rapporteur on the dossier, German MEP [Karl-Heinz] Florenz, is clearly wise enough to see the potential here. Germany is a powerful industrial country and they understand that they need to grasp the supply shortage risk as an opportunity to develop new technologies and knowledge. And MEP Florenz is clearly on that line.
One danger is to speak only about rare earths and forget that they are only part of the critical materials we have identified. Everybody is talking about rare earths but they are probably not the best representative of the critical materials because they are very specific and very difficult to recover.
But you've got other resources like platinum and lithium which we already know how to recover and where - with a new legal framework, for example - we could really help make recycling more effective and economically viable. This would also contribute more to our internal consumption of these materials, securing supply and reducing dependency.
Simply focusing on rare earths is not representative of the average problem we've got with our resources and criticality of materials.
Do you have any particular message you'd like to get across?
First, we need to reduce our consumption; second, try to substitute and increase the resource efficiency of our processes; and third, recycle. And then where it is not possible to make anything else, we can look at intensifying commercial exchange on some material.
Another thing is that we need to understand the potential of an ambitious e-waste directive and member states and the Commission need not to shy away on objectives.
It is not worth putting into law something that they know they can achieve but which looks like business as usual. Instead, they really need to try to make a law that is challenging enough, that sparks the need to invent new practices and foster new research and development and promote new opportunities for European industry.
So now after the Parliament's first reading of the dossier, it is up to the Council to also confirm the potential of ambitious e-waste legislation.