The proposed CRM Act defines two levels of importance: “Strategic” and “Critical”. Strategic are related to electronics. New targets and tools are proposed for these, but not for “Critical”, so not for Phosphate Rock or P4 (meaning P4/derivatives).
The Strategic Raw Materials (SRMs) are defined as those needed for “strategic technologies underpinning the green and digital transitions or for defence or space applications” (16 materials, all metals or related elements), and are a subset of 34 Critical Raw Materials (CRMs), defined as “all strategic raw materials as well as any other raw materials of high importance for the overall Union economy and for which there is a high risk of supply disruption”. The proposed CRM Regulation sets out actions to be engaged, at either EU or Member State levels. As written, it seems that some of these actions apply to all CRMs, and some only to SRMs.
The Commission’s proposals for the SRM list are indicated to be based on the new JRC Foresight Report (2023). It is therefore very surprising that the essential role of P4 derivatives for electronics, batteries, renewable energy is not recognised and that “Phosphorus” is not included in the list of Strategic Raw Materials. White Phosphorus (P4, referred as “Phosphorus” in the EU CRM documents) is necessary for battery electrolytes, microchip etching, semiconductors, fire safety, all of which are essential for the “Strategic” sectors of green energy, digital and aerospace.
ESPP notes that food materials are excluded from the definition of CRMs but we regret that the proposed CRM Act does not recognise the important links between CRMs and food security. This could be achieved by indicating in the proposed CRM Act the links to the Commission Communication on Fertilisers price and supply.
The Act is a proposed EU Regulation, published 16th March 2023, which is now open to public consultation until 16th May 2023 then will go to the European Parliament and Council for discussion and possible amendment and modification before adoption.
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