The most recent meeting of the Waste Advisory Group to the Dept of Environment, Climate and Communications (DECC) examined forthcoming waste legislation; a presentation on the proposed Critical Raw Materials Act; and an outline of the Green Public Procurement Strategy and Action Plan.
My attention was particularly drawn by the new Critical Raw Materials Act. An excerpt from the DECC presentation brief states that:
Critical raw materials (CRMs) are indispensable inputs in our economy, particularly as they are used to manufacture technologies required for the deployment of green energy, for the digital transition or for strategic applications in health or defence. Given the growing needs generated by the twin transitions, the demand for those materials is forecasted to increase exponentially both at EU and global level, leading to supply-demand gaps. In addition, the EU supply of CRMs at both the extraction and processing stage is highly concentrated, sometimes in a single third country.
My understanding of what the proposed act seeks to achieve is to ensure reliability of supply for materials used in, most notably, electronics. As such it seeks to ensure that specified minimum percentages of activities (mining, recycling and processing) are located within the EU; and also to limit the reliance on any one country for CRM supply.
The permaculture principle comes to mind: “Each important function must be supported by many elements”. As such the proposed regulation makes a certain amount of sense. However, notwithstanding the debate about how essential electronics are for human existence, there are certain aspects that are important to consider in the context of such proposed regulations:
- The focus of the regulation is on the raw materials themselves rather than prolonging the life of products already on the market or coming onto the market. Planned obsolescence is currently baked into our economic model and needs to be replaced with a directed focus on repairability and durability of products across the board; particularly in the area of electronics and other products for which CRMs are required.
- Given the importance of CRMs for certain green technologies, further diversification is needed than simply finding a variety of sources for these resources and products:
- As such a shift in focus to zero-CRM-input products should be made to enable CRMs to be available for critical applications such as green technologies. (Look to the permaculture principles for a clear pathway toward zero-CRM-input products.)
- There should also be active investment in global peace building, particularly with a focus on CRM source countries, their neighbours and countries of influence in CRM supply.
- The UN’s International Labour Organisation estimate that almost 50 million people were living in modern slavery in 2021. This extends to slave labour in mining and manufacture of green technologies in China, Africa and South America. Any focus on CRMs needs to include robust supply chain checks to ensure that Europe does not perpetuate our colonial past onto a new era of exploitation in Africa and elsewhere in the world.
I made these points at the WAG meeting and was assured that many of the issues raised were addressed either in the act itself or in parallel regulations that govern social and ecological best practice, ties with source countries etc. That part of me that holds love in my heart for the world around me and the people who dwell here is endlessly impatient at the slow pace of positive change at government level. However perhaps the reassurances are valid, and perhaps EU legislation is gradually edging us towards greater care for the earth and those around us. Time will tell.
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Féidhlim Harty is an environmental consultant and writer. His company, FH Wetland Systems, established in 1996, offers designs and guidance on waterway repair and rewilding, eco-friendly wastewater treatment training and education, and holistic land-use management for catchment protection and regeneration. His most recent book is Towards Zero Waste – How to Live a Circular Life.