Despite the ambition to transition towards a climate-neutral and circular economy, the existing policy framework does not sufficiently level the playing field for recycled raw materials to compete with extracted raw materials. This is even more true for critical raw materials, except precious metals, for which the costs of proper collection and recovery by far exceed commodity prices for critical raw materials mined and often imported from countries applying insufficient human rights, social and environmental standards.

In its compromise proposal on the CRM Act dated 23 June 2023, the Swedish Presidency includes a new requirement aiming at:

• (e2) taking necessary measures to ensure that critical raw materials that are exported under an end of waste status fulfill the relevant conditions in accordance with directive 2008/98/EC and other relevant Union law.

Such a requirement is legally non-sense and administratively counter-productive.