The European Recycling Industries’ Confederation (EuRIC) highlights the need for a Critical Raw Materials Regulation based on scientific evidence and not on biased proposals. Any efforts to include some materials to the list of both strategic and critical raw materials, respectively Annex I - Section 1 and Annex II - Section 1, of the above-mentioned Regulation must be disregarded by policy makers, especially if such requests are not backed by tangible data.

More precisely, demands for including ferrous scrap in the in-question Annexes have multiplied. In that regard, EuRIC would like to point out that, in 2022, the consumption of steel scrap in the EU totaled 79.3 Mt, the import of steel scrap 3.9 Mt and steel scrap exports 17.6 Mt. This shows that the apparent domestic supply of steel scrap in the EU27 is 93 Mt^[1] and that steel scrap is largely abundant to meet domestic demand.

From a more holistic perspective, considering that EU crude steel production for the same year was at 136 Mt, it is easy to deduce that Europe’s recycling industry can meet steel demand, up to a theoretical value of 68.3%. This shows that while steel scrap is considered a material of huge importance on the path to net zero, it does not face any supply problems.

With regard to the criteria that must be fulfilled to be classified as a critical or strategic raw material, steel scrap does not tick any conditions. Adding steel scrap to the list of strategic and critical raw materials would deprive the list of any value as it would theoretically be possible to add any materials outside of any conditions or methodology that must be complied with to have a meaningful list of both SRMs and CRMs.

In addition, EuRIC would like to stress some basic but key facts.

Recycled steel scrap used as the main infeed in electric arc furnaces (EAFs) or as a complementary infeed in blast oxygen furnaces (BOFs) plays a key role in decarbonizing the steel industry in Europe and worldwide. Yet, it is a feedstock abundantly available on the EU and international markets. No steel mill in the EU has ever ceased activity because of a lack of supply of recycled steel scrap.

EuRIC believes that instead of adding to the two lists a secondary feedstock that does not tick any of the criteria set out in the proposed CRM Act, a genuine industrial policy should green industrial capacity in Europe. In the steel sector, this would mean the following:

• Rewarding the environmental benefits of using recycled steel scrap in steelmaking;
• Encouraging the growth of EAF plants in Europe to reach at least the same proportion of steel produced by EAF in the EU as in Turkey or the US (i.e. 70%) and thus boosting the decarbonization of the steel industry;
• Supporting the scrap industry to optimize its collection as well as its sorting and processing to generate additional directly usable scrap quantities.
• Solving the lasting electricity crisis by providing abundant, green and affordable energy, especially electricity, which is a pre-condition for any industrial investment, whether in recycling or in energy-intensive industries.

EuRIC looks forward to working with the steel and steel users’ industries to ensure that steel production in Europe meets its net-zero targets.

^[1] BIR (2023): WORLD STEEL RECYCLING IN FIGURES