The Confederation of Swedish Enterprise’s position on the
proposal for a European Critical Raw Materials Act

Key messages

• Enhance the opportunities for exploration and extraction in the EU more generally. Critical raw materials are often extracted as a by-product of base metal and iron extraction; access to many of these metals will become scarcer in the future. Therefore, the scope of the CRM Act should be widened.
• Strengthen the EU’s critical raw materials value chain by promoting the extraction of minerals in general, rather than defining a list and granting certain projects particularly favourable treatment.
• Enable increased business-driven diversification of source of supply. Business are best positioned to assess and arrange their value chains to meet their needs. The proposed CRM Act should support this by facilitating the emergence of new trade routes globally.
• Avoid punishing companies with administrative burdens in the shape of monitoring and mandatory information collection. The proposed Act is interlinked with several other current or pending pieces of European legislation. It is crucial that these be aligned and synchronised and that double regulation be avoided.
• Make the existence of strategic reserves a national issue, primarily based on national security.
• Promote the material-efficient recycling of critical raw materials.