techUK Critical Raw Materials

© Assent 2022 / assent.com
Critical Raw Minerals
(CRM): Strategies,
Sourcing and
Circularity.
Presented at techUK: Tech Supply Chain Summit,
Wednesday 23rd November 2022.
Presented by: Eur Ing. Raj Takhar, MSc, CEng, PhD,
Regulatory & Sustainability Expert. Email:
Raj.Takhar@assent.com.

Agenda – 23rd November 2022
About Me
1. Introduction.
2. Comparison of UK, EU and US CRM Lists
3. UK CRM List: Sources of Supply
4. UK CRM List: Industry Uses
5. Comparison of US and EU CRM Reporting
6. Conclusions
7. Q&A.

© Assent 2022 / assent.com 3
About Me

Raj Takhar
About Me
Regulatory &
Sustainability Expert:
Product Sustainability
Assent Inc.
❏ Education: MSc, PhD.
❏ Professional: Chartered Engineer, European Chartered
Engineer.
❏ Doctoral Research: ‘The effect of chemical regulations on
the Aerospace and Defence sector’.
❏ Standards: IPC, BSi, ASD, CENELEC, ISO.
❏ Trade Associations: IPC, MedTech Europe, Digital Europe,
IET.
❏ Stakeholder Groups: (numerous workshops related to
updates to EU REACH), SCIP IT User Group, UK REACH IT
Stakeholders group.
❏ Contact:
❏ Raj.Takhar@assent.com.
❏ https://www.linkedin.com/in/raj-takhar-4791134/

1 Introduction

Introduction (i)
A brief history
1980’s 1990’s
• Brundtland Report
(1987) Mass
production à
Depletion of natural
resources.
• Heightened
consumer
awareness.
• Recycling
becomes a
thing.
• Emergence of
the Internet.
2000’s
• Increased technological
innovations, creating further
demand on natural
resources.
• Emergence of global
accords on climate change
(POPs, ODS, FGAS, etc).
• Sustainability initiatives /
legislative instruments (EU
Ecodesign Directive 2009 /
EU Eco labels / etc).
• EU Chemical regulations
such as EU RoHS, EU
WEEE and EU REACH
implementing supply chain
reporting requirements.
2010’s 2020’s
• UN SDGs (2015) set of global
targets for sustainable growth.
• EU Horizon 2020 investment
project.
• Product specific regulations
flowing as ‘Lots’ from EU
Ecodesign Directive, requiring
data reporting.
• Emergence of Industry 4.0
and ‘Circular Economy’.
• US Conflict Minerals
Reporting.
• EU Circular Economy Action
Plan first published.
• US & EU CRM lists first
published.
• Increasing concerns over China
dominating supply of Critical Raw
Mineral prices.
• EU Waste Framework Directive
(2018) establishes EU Raw
Materials Institute.
• EU Green Deal (2019) 5-year
roadmap of activities, investments
towards Circularity.
• COVID-19 occurs - Mass scale
supply chain disruptions.
• US Executive Orders on CRM
reporting.
• EU several CRM related legislative
instruments.
• UK CRM List and Strategy
Published

Introduction (ii)
Critical Raw Material (CRM) Definitions
UK EU US
These ‘critical minerals’ are not only vitally
important but are also experiencing major risks to
their security of supply. These risks can be
caused by combinations of factors including but
not limited to rapid demand growth, high
concentration of supply chains in particularly
countries, or high levels of price volatility. Many
of these critical minerals are produced in
comparatively small volumes or as companion
metals (meaning they’re produced as by-
products of other mining activities), are non-
substitutable in their applications and have low
recycling rates.
Source: GOV.UK (2022), UK Critical Mineral
Strategy
Those raw materials that are most
important economically and have a high
supply risk are called critical raw
materials. Critical raw materials are
essential to the functioning and integrity
of a wide range of industrial ecosystems.
Source: EU (2020), EU Critical Raw
Minerals List 2020
non-fuel mineral or mineral material
essential to the economic or national
security of the U.S. and which has a
supply chain vulnerable to disruption.
Critical minerals are also characterized
as serving an essential function in the
manufacturing of a product, the absence
of which would have significant
consequences for the economy or
national security.
Source: USGS (2022), US Critical
Minerals List 2022
NOTE: Deliberate use of ‘Critical Raw Material’ (CRM) Vs Critical Minerals has been used as one implies
product & source reporting versus generic mineral and source only reporting (will be explained later)

2 Comparison of UK,
EU and US CRM Lists

UK: CRM List (2022)
# Name # Name # Name
1 Antimony (Sb) 14 Erbium (Er) [REE] 27 Silicon (Si)
2 Bismuth (Bi) 15 Europium (Eu) [REE] 28 Tantalum (Ta)
3 Cobalt (Co) 16 Gadolinium (Gd) [REE] 29 Tellurium (Te)
4 Gallium (Ga) 17 Holmium (Ho) [REE] 30 Tin (Sn)
5 Graphite (C) 18 Lanthanum (La) [REE] 31 Tungsten (W)
6 Indium (In) 19 Lutetium (Lu) [REE] 32 Vanadium (V)
7 Lithium (Li) 20 Neodymium (Nd) [REE] UK Critical Minerals Expert Committee’s Watchlist
8 Magnesium (Mg) 21 Praseodymium (Pr) [REE] 33 Iridium (Ir)
9 Niobium (Nb) 22 Samarium (Sm) [REE] 34 Manganese (Mn)
10 Palladium (Pd) [PGM] 23 Terbium (Tb) [REE] 35 Nickel (Ni)
11 Platinum (Pl) [PGM] 24 Thulium (Tm) [REE] 36 Phosphates (P)
12 Cerium (Ce) [REE] 25 Ytterbium (Yb) [REE] 37 Ruthenium (Ru)
13 Dysprosium (Dy) [REE] 26 Yttrium (Y) [REE]

EU: CRM List (2020)
1 Antimony (Sb) 18 Holmium (Ho) [REE] 35 Palladium (Pd) [PGM]
2 Baryte (Ba) 19 Lanthanum (La) [REE] 36 Platinum (Pl) [PGM]
3 Bauxite (Bx) 20 Lutetium (Lu) [REE] 37 Rhodium (Rh) [PGM]
4 Beryllium (Be) 21 Neodymium (Nd) [REE] 38 Ruthenium (Ru) [PGM]: On UK CMEC Watchlist
5 Bismuth (Bi) 22 Praseodymium (Pr) [REE] 39 Phosphate Rock: On UK CMEC Watchlist
6 Borate (Bo) 23 Samarium (Sm) [REE] 40 Phosphorus (P): On UK CMEC Watchlist
7 Cobalt (Co) 24 Terbium (Tb) [REE] 41 Scandium (Sc)
8 Coking Coal (Cc) 25 Thulium (Tm) [REE] 42 Silicon Metal (Si)
9 Fluorspar (CaF2 ) 26 Ytterbium (Yb) [REE] 43 Strontium (Sr)
10 Gallium (Ga) 27 Yttrium (Y) [REE] 44 Tantalum (Ta)
11 Germanium (Ge) 28 Indium (In) 45 Titanium (Ti)
12 Hafnium (Hf) 29 Lithium (Li) 46 Tungsten (W)
13 Cerium (Ce) [REE] 30 Magnesium (Mg) 47 Vanadium (V)
14 Dysprosium (Dy) [REE] 31 Natural Graphite (C) Key:
15 Erbium (Er) [REE] 32 Natural Rubber (Nr) = Exact match on UK CM List
16 Europium (Eu) [REE] 33 Niobium (Nb) = Match on UK CMEC Watch List
17 Gadolinium (Gd) [REE] 34 Iridium (Ir) [PGM]: On UK CMEC Watchlist = NO Match on UK CM List

US: CRM List (2022)
1 Aluminum (Al) 18 Europium (Eu) [REE] 35 Niobium (Nb)
2 Antimony (Sb) 19 Gadolinium (Gd) [REE] 36 Iridium (Ir) [PGM]: On UK CMEC Watchlist
3 Arsenic (As) 20 Holmium (Ho) [REE] 37 Palladium (Pd) [PGM]
4 Baryte (Ba) 21 Lanthanum (La) [REE] 38 Platinum (Pl) [PGM]
5 Beryllium (Be) 22 Lutetium (Lu) [REE] 39 Rhodium (Rh) [PGM]
6 Bismuth (Bi) 23 Neodymium (Nd) [REE] 40 Ruthenium (Ru) [PGM]: On UK CMEC Watchlist
7 Cesium (Cs) 24 Praseodymium (Pr) [REE] 41 Rubidium (Rb)
8 Chromium (Cr) 25 Samarium (Sm) [REE] 42 Scandium (Sc)
9 Cobalt (Co) 26 Terbium (Tb) [REE] 43 Tantalum (Ta)
10 Fluorspar (CaF2 ) 27 Thulium (Tm) [REE] 44 Tellurium (Te)
11 Gallium (Ga) 28 Ytterbium (Yb) [REE] 45 Tin (Sn)
12 Germanium (Ge) 29 Yttrium (Y) [REE] 46 Titanium (Ti)
13 Graphite (C) 30 Indium (In) 47 Tungsten (W)
14 Hafnium (Hf) 31 Lithium (Li) 48 Vanadium (V)
15 Cerium (Ce) [REE] 32 Magnesium (Mg) 49 Zinc (Zn)
16 Dysprosium (Dy) [REE] 33 Manganese (Mn): On UK CMEC Watchlist 50 Zirconium (Zr)
17 Erbium (Er) [REE] 34 Nickel (Ni): On UK CMEC Watchlist

3 UK CRM List:
Sources of Supply

UK CRM List: Sources of Supply (i)
# Name Sources * # Name Sources *
1 Antimony (Sb) China (74%), Tajikistan (8%), Russia (4%) 14 Erbium (Er) [REE] China (86%), Australia (6%), United States (2%)
2 Bismuth (Bi) China (85%), Lao Pdr (7%), Mexico (4%) 15 Europium (Eu) [REE] China (86%), Australia (6%), United States (2%)
3 Cobalt (Co) Congo DR (59%), China (7%), Canada (5%) 16 Gadolinium (Gd) [REE] China (86%), Australia (6%), United States (2%)
4 Gallium (Ga) China (80%), Germany (8%), Ukraine (5%) 17 Holmium (Ho) [REE] China (86%), Australia (6%), United States (2%)
5 Graphite (C) China (69%), India (12%), Brazil (8%) 18 Lanthanum (La) [REE] China (86%), Australia (6%), United States (2%)
6 Indium (In) China (48%), Korea, Rep. (21%), Japan (8%) 19 Lutetium (Lu) [REE] China (86%), Australia (6%), United States (2%)
7 Lithium (Li) Chile (44%), China (39%), Argentina (13%) 20 Neodymium (Nd) [REE] China (86%), Australia (6%), United States (2%)
8 Magnesium (Mg) China (89%), United States (4%) 21 Praseodymium (Pr) [REE] China (86%), Australia (6%), United States (2%)
9 Niobium (Nb) Brazil (92%), Canada (8%) 22 Samarium (Sm) [REE] China (86%), Australia (6%), United States (2%)
10 Palladium (Pd) [PGM] Russia (40%) 23 Terbium (Tb) [REE] China (86%), Australia (6%), United States (2%)
11 Platinum (Pl) [PGM] South Africa (84%) 24 Thulium (Tm) [REE] China (86%), Australia (6%), United States (2%)
12 Cerium (Ce) [REE] China (86%), Australia (6%), United States (2%) 25 Ytterbium (Yb) [REE] China (86%), Australia (6%), United States (2%)
13 Dysprosium (Dy)
[REE]
China (86%), Australia (6%), United States (2%) 26 Yttrium (Y) [REE] China (86%), Australia (6%), United States (2%)

UK CRM List: Sources of Supply (ii)
# Name Sources * # Name Sources *
27 Silicon (Si) China (66%), United States (8%),
Norway (6%), France (4%)
33 Iridium (Ir) South Africa (84%)
28 Tantalum (Ta) Congo, DR (33%), Rwanda (28%), Brazil
(9%)
34 Manganese
(Mn)
Manganese Ore: Gabon (69%), South Africa (17%), Mexico (8%),
Australia (4%),Others (2%).
Ferromanganese: Australia (21%), South Africa (21%), Norway (16%),
Republic of Korea (12%), Others (30%).
Silicomanganese: Georgia (26%), South Africa (22%), Australia (20%),
Others (32%).
29 Tellurium (Te) Canada (57%), China,(21%), Germany
(17%); Philippines (3%), Others (2%)
35 Nickel (Ni) Nickel contained in ferronickel, metal, oxides, and salt: Canada (42%),
Norway (10%), Finland (9%), Russia (8%), Others (31%).
Nickel-containing scrap, including nickel content of stainless-steel scrap:
Canada (38%), Mexico (27%), United Kingdom (9%), Others (26%).
30 Tin (Sn) China (30%), Indonesia (27%), Burma
(15%), Bolivia (6%), Brazil (6%), Peru
(6%).
36 Phosphates (P) Phosphate Rock: China (48%), Morocco (11%),
United States (10%),
Phosphorous: China (74%), Kazakhstan (9%), Vietnam (9%)
31 Tungsten (W) China (69%), Vietnam (7%), United
States (6%), Austria (1%), Germany (1%)
37 Ruthenium (Ru) South Africa (84%)
32 Vanadium (V) China (55%), South Africa (22%), Russia
(19%)
Sources:
1. EU (2020) COM(2020) 474 - Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability,
2. US Geological Society (2022), Tin Statistics and Information.
3. US Geological Society (2022), Nickel Statistics and Information.
4. US Geological Society (2022), Selenium and Tellurium Statistics and Information.
5. US Geological Society (2022), Manganese Statistics and Information.

4 UK CRM List:
Industry Uses

UK CRM List: Industrial Uses by Sector (i)
Name
Aerospace
Textiles
Electronics
Mobility
/
Automotive
Energy
Intensive
Industries
Renewable
Energy
Agri-food
Health
Digital
Antimony (Sb) x x x
Bismuth (Bi) x x x x x
Cobalt (Co) x x x x x x x x
Gallium (Ga) x x x x x
Graphite (C) x x x x x x
Indium (In) x x x x x x x
Lithium (Li) x x x x x x x
Magnesium (Mg) x x x x x
Niobium (Nb) x x x x x
Palladium (Pd) [PGM] x x x x x x
Platinum (Pl) [PGM] x x x x x x
Cerium (Ce) [REE] x x x x x x
Dysprosium (Dy) [REE] x x x x x x
Erbium (Er) [REE] x x x x x x
Europium (Eu) [REE] x x x x x x
Gadolinium (Gd) [REE] x x x x x x

UK CRM List: Industrial Uses by Sector (ii)
Name
Aerospace
Textiles
Electronics
Mobility
/
Automotive
Energy
Intensive
Industries
Renewable
Energy
Agri-food
Health
Digital
Holmium (Ho) [REE] x x x x x x
Lanthanum (La) [REE] x x x x x x
Lutetium (Lu) [REE] x x x x x x
Neodymium (Nd) [REE] x x x x x x
Praseodymium (Pr) [REE] x x x x x x
Samarium (Sm) [REE] x x x x x x
Terbium (Tb) [REE] x x x x x x
Thulium (Tm) [REE] x x x x x x
Ytterbium (Yb) [REE] x x x x x x
Yttrium (Y) [REE] x x x x x x
Silicon (Si) x x x x x x x
Tantalum (Ta) x x x x x
Tellurium (Te) x x x x x
Tin (Sn) x x x x x x
Tungsten (W) x x x x x
Vanadium (V) x x x x x

UK CRM List: Industrial Uses by Sector (iii)
Name
Aerospace
Textiles
Electronics
Mobility
/
Automotive
Energy
Intensive
Industries
Renewable
Energy
Agri-food
Health
Digital
Iridium (Ir) x x x x x x
Manganese (Mn) x x x x x x
Nickel (Ni) x x x x x x
Phosphates (P) x x x
Ruthenium (Ru) x x x x x x
Sources:
1. EU (2020) COM(2020) 474 - Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability, EU
Critical Minerals List 2020.
2. EU (2020) Study on The EU’s List of Critical Raw Materials
3. EU (2020), EU Critical Raw Material Fact File, detailed breakdown of sources, references US Geological Society research.
4. EU (2022), EU Science Hub – Raw Materials Information System (RMIS), main EU portal on Critical Minerals.
5. US Geological Society (2022), US Critical Minerals List 2022.
6. US Geographical Society (2022) Detailed summary of mineral sources and uses.
7. GOV.UK (2022): Resilience for the Future: The UK’s critical minerals strategy: UK Critical Minerals Strategy, containing UK Critical
Minerals List.

UK CRM List: Typical Uses in Electronics (i)
# Name Use(s) # Name Use(s)
1 Antimony (Sb) • Flame retardants, glass, ceramics, lead-acid
batteries, lead alloys, plastics (catalysts and
stabilizers).
7 Lithium (Li) • Glass, ceramics, lubricating greases, rubber
production, plastics production;, batteries,
aluminum making and other metallurgy (Al-Li
alloys), refrigeration, air conditioning,
rechargeable batteries.
2 Bismuth (Bi) • Solders, alloys, glass, ceramics, lubricating
greases.
8 Magnesium (Mg) • Alloys, stainless steels, batteries, semiconductors,
PV cells;, packaging.
3 Cobalt (Co) • Batteries;, super alloys;, catalysts, magnets,
stainless steels, surface treatments, machinery,
mechanical appliances, electrical and electrical
products, accumulators, electric vehicles.
9 Niobium (Nb) • Flat panel displays;, solders, PV cells, stainless
steels, superconductors, super alloys.
4 Gallium (Ga) • Integrated circuits (IC’s), laser diodes, light
emitting diodes (LED), copper indium gallium solar
cells.
10 Platinum Group
Metals (PGM)
(Palladium &
Platinum)
• Ceramic magnets, aluminum alloys;, glass,
medical applications, auto catalysts, electronics;,
chemicals.
5 Graphite (C) • Optical fibers, infrared optics;, satellite solar cells,
battery cells, high-temperature lubricants, thermal
and electrical conductivity, brushes for electrical
motors, fuel cells.
11 Rare Earth Elements
[REE]
• Glass; ceramics; batteries, industrial lighting;
projectors, medical applications (MRI, imaging),
capacitors, super alloys, magnets, optical
applications, microwave devices (dopant agents),
refrigeration, lasers, electronics, sold-state
devices, metal alloys, catalysts, scintillometers;
lightweight high-strength alloys (aeronautics,
space and defence);
6 Indium (In) • Flat panel displays, solders, photovoltaic (PV)
cells (CIGS, CIS and CdTe), thermal interface
materials, batteries, alloys / compounds,
semiconductors, LEDs, liquid crystal displays.

UK CRM List: Typical Uses in Electronics (ii)
# Name Use(s) # Name Use(s)
12 Silicon (Si) • Rubber components, aluminum alloys, solar
applications, electronics.
18 Iridium (Ir) [See PGM – Entry 10]
13 Tantalum (Ta) • Capacitors, carbides, superalloys. 19 Manganese (Mn) • Batteries
14 Tellurium (Te) • Solar cells, thermoelectric devices. 20 Nickel (Ni) • Stainless steel, super alloys, rechargeable
batteries.
15 Tin (Sn) • Protective coatings. 21 Phosphates (P) • Lightweight alloys (electronics, automotive,
packaging, construction), electronic
components;.
16 Tungsten (W) • Lightweight alloys, lighting, electronics, high-
speed steels, energy uses, aerospace uses,
corrosion resistant metals.
22 Ruthenium (Ru) • [See REE – Entry 11]
17 Vanadium (V) • Semiconductors, PV cells, electronic
components, silicones, high-strength low-alloy
steels
.
Sources:
1. EU (2020) COM(2020) 474 - Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability, EU Critical Minerals List 2020.
2. EU (2020) Study on The EU’s List of Critical Raw Materials
3. EU (2020), EU Critical Raw Material Fact File, detailed breakdown of sources, references US Geological Society research.
4. EU (2022), EU Science Hub – Raw Materials Information System (RMIS), main EU portal on Critical Minerals.
5. US Geological Society (2022), US Critical Minerals List 2022.
6. US Geographical Society (2022) Detailed summary of mineral sources and uses.
7. GOV.UK (2022): Resilience for the Future: The UK’s critical minerals strategy: UK Critical Minerals Strategy, containing UK Critical Minerals List.

5
Comparison of US
and EU CRM
Reporting

Comparison of US and EU CRM Reporting (i)
▸ This section focuses on US and EU implementation of CRM reporting only, as
the UK CRM strategy outlines a strategic methodology which is to be developed
over time.
▸ The aim is to showcase the two different approaches and implications for UK
industry.
Introduction

Comparison of US and EU CRM Reporting (ii)
US Approach
Year/ Date Activity / Legislation Comments
20/12/2017 EO 13817 • US Presidential Executive Order (EO) on A Federal Strategy To Ensure Secure and Reliable Supplies of Critical
Minerals.
• Initial launch of US activities to develop a coordinated strategy for managing CRMs.
18/05/2018 Final List of Critical
Minerals List
• US Federal register entry of final USGS critical raw materials list
• Contained 35 minerals on the list.
December
2019
DFARS 252.225-7009 • A very specific clause in US defense contracts which requires the identification of sources for special metals,
designed to protect US metal industry, whilst allowing for purchase from ‘friendly nations’ to US.
2020 US Energy Act (2020) • Section 7001 REE:, requirement to develop REE and other CRM extraction and recovery technologies.
• Section 7002 Mineral Security: USGS to review and update US CRM list every 3 years, which then flows down
to other federal agencies to then implement strategic plans (analytics, R&D, recycling, educational training to
develop CRM trained workforce).
• Section 7003 China: Monitors investments under China ‘Belt and Road initiative’ in relation to sources of CRM’s.
• Similar themes as per UK minerals strategy.
30/09/2020 EO 13953 • US Presidential Executive Order (EO) on Addressing the Threat to the Domestic Supply Chain From Reliance on
Critical Minerals From Foreign Adversaries and Supporting the Domestic Mining and Processing Industries.
• Identified dependency on 14 critical minerals from overseas.
• US had 80% dependency on China for REE needs.
24/02/2021 EO 14017 • US Presidential Executive Order (EO) on America’s Supply Chains.
• Key message was protecting US supply chains investigating the need to address potential threats posed by
pandemics and other biological threats, cyber-attacks, climate shocks and extreme weather events, terrorist
attacks, geopolitical and economic competition.
• Focus was on the protection of Critical Mineral and Material supply chains

Comparison of US and EU CRM Reporting (iii)
US Approach
Year/ Date Activity / Legislation Comments
24/02/2022 FACT SHEET: Securing
a Made in America
Supply Chain for
Critical Minerals
• Summary of key findings from EO 14017, together with announcement to update existing legislations and
large-scale investment projects
24/02/2022 US Department of
Defense : Securing
Defense, Critical
Supply Chains.
• US defense strategy, essentially an action plan, with a review of CRMs in use by US defense agencies.
• Similar themes as per UK minerals strategy.
24/02/2022 2022 Final List of
Critical Minerals
• US Federal register entry of final USGS critical raw materials list
US CRM Reporting – Concerned with identification of a given CRM and Country of Origin data.

Comparison of US and EU CRM Reporting (iv)
EU Approach
Year/
Date
Activity / Legislation Comments
2009 EU Ecodesign Directive
2009/125/EC
• Annex I 1.3 (f): ease for reuse and recycling as expressed through: number of materials and components used, use of
standard components, time necessary for disassembly, complexity of tools necessary for disassembly, use of
component and material coding standards for the identification of components and materials suitable for reuse and
recycling (including marking of plastic parts in accordance with ISO standards), use of easily recyclable materials,
easy access to valuable and other recyclable components and materials; easy access to components and
materials containing hazardous substances;
2011 EU CRM List • First publication of EU CRM list. Identified 14 CRMs.
2014 EU Regulation
1253/2014 Ecodesign
Requirements on
Ventilation Units
• Annex IV (3) & Annex V (3): The manufacturer's free access website shall make available detailed instructions, inter
alia, identifying the required tools for the manual disassembly of permanent magnet motors, and of electronics parts
(printed wiring boards/printed circuit boards and displays > 10 g or > 10 cm2), batteries and larger plastic parts (> 100
g) for the purpose of efficient materials recycling, except for models of which less than 5 units per year are produced.
2014 EU CRM List • Second publication of EU CRM list. Identified 20 CRMs.
2017 EU CRM List • Third publication of EU CRM list. Identified 27 CRMs.

Comparison of US and EU CRM Reporting (v)
EU Approach
Year/
Date
2018 EU Waste Framework
Directive 2018/851
• Recital 36 (front matter): Certain raw materials are of a high importance to the economy of the Union and their supply
is associated with a high risk. In order to ensure security of supply of those raw materials and in line with the Raw
Materials Initiative …. the Commission has established a list of such materials for the Union in its communication of 13
September 2017 on ‘the 2017 list of Critical Raw Materials for the EU’ and that list is subject to regular review.
• Recital 37 (front matter): To further support effective implementation of the Raw Materials Initiative, Member States
should also take measures to achieve the best possible management of waste containing significant amounts of
critical raw materials, taking economic and technological feasibility and environmental and health benefits into
account.
• Article 9 Prevention of Waste (1) (c): 1. Member States shall take measures to prevent waste generation. Those
measures shall, at least: (c) target products containing critical raw materials to prevent that those materials become
waste.
• Article 22 Bio-Waste (21) (i): (21) Article 28 is amended as follows: (a) paragraph 3 is amended as follows: (i) points
(b) and (c) are replaced by the following: (b) existing major disposal and recovery installations, including any special
arrangements for waste oils, hazardous waste, waste containing significant amounts of critical raw materials, or waste
streams addressed by specific Union legislation;
2019 EU Regulation 2019/424
on Ecodesign
Requirements for servers
and Data Storage
Products
• Annex II 3.3 (a) indicative weight range (less than 5 g, between 5 g and 25 g, above 25 g) at component level, of the
following critical raw materials: (a) Cobalt in the batteries; (b) Neodymium in the HDDs.
• Article 8 Review: The Commission shall assess this Regulation and shall present the results of this assessment,
including, if appropriate, a draft revision proposal, to the Consultation Forum by March 2022. This assessment shall
review the requirements in the light of the technological progress and shall address in particular the appropriateness:
(d) to update the material efficiency requirements for servers and data storage products, including the information
requirements on additional critical raw materials (tantalum, gallium, dysprosium and palladium), taking into account
the needs of the recyclers;

Comparison of US and EU CRM Reporting (vi)
EU Approach
Year/
Date
2019 EU Regulation
2019/1784 Ecodesign
Requirements for
Welding Equipment
• Annex II 3 (h) Information requirements: From 1 January 2021, manufacturers, their authorised representatives or
importers shall ensure that the following information is provided in the instruction manuals for installers and end-
users, and for at least 10 years after the first unit of a welding equipment model is placed on the market, on the free-
access websites of manufacturers, their authorised representatives or importers: (h) a list of critical raw materials
present in indicative amounts higher than 1 gram at component level, if any, and an indication of the component(s) in
which these critical raw materials are present.
2019 EU Regulation
2019/2021 Ecodesign
requirements for
electronic displays
• Article 8 (g) Review: The Commission shall review this Regulation in the light of technological progress and shall
present the results of the assessment, including, if appropriate, a draft revision proposal, to the Consultation Forum no
later than 25 December 2022. This review shall in particular assess: (g) the appropriateness of setting different or
additional requirements to improve dismantling at end of life and recyclability, including in relation to critical raw
materials and in relation to the conveying of information to recyclers;
2019 EU Regulation
2019/1781 Ecodesign
requirements on Electric
Motors and Variable
Speed Drives
• Article 8 (1) Review: The Commission shall review this Regulation in the light of technological progress and shall
present the results of this assessment, including, if appropriate, a draft revision proposal, to the Consultation Forum no
later than 14 November 2023. This review shall in particular address the appropriateness of: (1) setting additional
resource efficiency requirements for products in accordance with the objectives of the circular economy, including
identification and reuse of rare earth in permanent magnet motors;

Comparison of US and EU CRM Reporting (vii)
EU Approach
Year/
Date
2019 EU Batteries Regulation
(Proposal)
• Recital 19 (front matter): Certain substances contained in batteries, such as cobalt, lead, lithium or nickel, are acquired
from scarce resources which are not easily available in the Union, and some are considered critical raw materials by
the Commission. This is an area where Europe needs to enhance its strategic autonomy and increase its resilience in
preparation for potential disruptions in supply due to health or other crises. Enhancing circularity and resource
efficiency with increased recycling and recovery of those raw materials, will contribute to reaching that goal.
• Recital 60 (front matter): Some of the raw materials in question, such as cobalt, lithium and natural graphite, are
considered as critical raw materials for the EU and their sustainable sourcing is required for the EU battery ecosystem
to perform adequately.
• Annex VI Labelling Requirements, Part A (8): critical raw materials contained in the battery.
• Annex XIII Information to be stored in the European Electronic Exchange System, 1 Publicly accessible part of the
system, (e) Battery composition, including critical raw materials.
2020 EU CRM List • Fourth publication of EU CRM list. Identified 47 CRMs.
2022 EU Ecodesign for
Sustainable Products
Regulation (Proposal)
• Key EU legislation which replaces EU Ecodesign directive.
• Enables review of all existing EU product related regulations, where sustainability related reporting information is
deemed to be lacking, product specific delegated acts will appear requiring detailed sustainability reporting and
targets based at the product level, covering reporting of hazardous chemicals, recycled content, user repair
instructions, carbon footprint, LCA data.
• Where a product specific delegated act is defined, this will require detailed reporting which when submitted to a new
central database for EU regulators / notified bodies, will generate new EU Digital Product Passports.
• Based on methodologies defined under EU EN4555x series of standards.
• Initial draft lacks CRM reporting but is likely to be updated either in the updated text or in the delegated acts (like EU
Batteries Regulation proposal)

Comparison of US and EU CRM Reporting (viii)
EU Approach
Year/
Date
2022 EU Regulation Laying
Down Ecodesign
Requirements for
Mobile Phones,
Cordless Phones and
Slate Tablets
(proposal)
• Annex Document covers different product types:
• [Slate Tablets] 2. Information Requirements: (1)Manufacturers, importers or authorised representatives shall provide in the technical
documentation and make publicly available on free-access websites the following information: (b )indicative weight range of the following
critical raw materials and environmentally relevant materials: (i) cobalt in the battery (weight range: less than 10g, between 10g and 20g,
above 20g;, (ii) tantalum in capacitors (weight range: less than 0,01g, between 0,01g and 0,1g, above 0,1g); (iii) neodymium in loud
speakers, vibration motors, and other magnets (weight range: less than 0,2g, between 0,2g and 1g, above 1g), and; (iv) gold in all
components (weight range: less than 0,02g, between 0,02g and 0,1g, above 0,1g). (c) recyclability rate Rcyc. (d) the percentage of
recycled content for the product or a part thereof, where available.
• [Smartphones] 2. Information Requirements: (1)Manufacturers, importers or authorised representatives shall provide in the technical
critical raw materials and environmentally relevant materials: (i) cobalt in the battery (weight range: less than 2g, between 2g and 10g,
speakers, vibration motors, and other magnets (weight range: less than 0,05g between 0,05g and 0.2g, above 0.2g), and; (iv) gold in all
• [Cordless Phones] 2. Information Requirements: (1)Manufacturers, importers or authorised representatives shall provide in the technical
critical raw materials and environmentally relevant materials: (i) cobalt in the battery (weight range: less than 0.5g, between 0.5g and 3g,
speakers, vibration motors, and other magnets (weight range: less than 0,01g between 0,01g and 0.2g, above 0.2g), and; (iv) gold in all
• [Mobile phones other than smartphones] 2. Information Requirements: (1)Manufacturers, importers or authorised representatives shall
provide in the technical documentation and make publicly available on free-access websites the following information: (b )indicative weight
range of the following critical raw materials and environmentally relevant materials: (i) cobalt in the battery (weight range: less than 2g,
between 2g and 5g, above 5g;, (ii) tantalum in capacitors (weight range: less than 0,05g, between 0,05g and 0,2g, above 0,2g);
(iii) neodymium in loud speakers, vibration motors, and other magnets (weight range: less than 0,05g between 0,05g and 0.2g, above
0.2g), and; (iv) gold in all components (weight range: less than 0,02g, between 0,02g and 0,1g, above 0,1g). (c) recyclability rate Rcyc.
(d) the percentage of recycled content for the product or a part thereof, where available.

Comparison of US and EU CRM Reporting (ix)
EU Approach
Year/
Date
2022 France –
Environmental
Labelling Decree (SGS
website link)
• Entry into force from 1st January 2023, staggered dependent on revenue, product types and volume of
products placed onto French marketplace.
• Presence of precious metals: Products: (i) Electrical and electronic equipment, (ii) Passenger cars,
vans, motor vehicles (with 2 or 3 wheels) and (iii) motor quadricycles. Labelling on product packaging
requirement: If greater than 1 milligram: Statement "contains at least [X milligrams] of precious
metals' or "contains at least [X milligrams] of gold, silver, platinum, palladium”
• Presence of REE: Products: (i) Electrical and electronic equipment, (ii) Passenger cars, vans, motor
vehicles (with 2 or 3 wheels) and (iii) motor quadricycles. Labelling on product packaging
requirement: If greater than 1 milligram: Statement "contains at least [X milligrams] of rare earths" or
"contains at least [X milligrams] scandium, yttrium, lanthanum, cerium, praseodymium, neodymium,
promethium, samarium, europium, gadolinium, terbium, dysprosium, holmium, erbium, thulium,
ytterbium, lutetium’
• Recycled content reporting
EU CRM Reporting – Concerned with identification of a given CRM, where used, volume (grams), virgin /
secondary material, Country of Origin data.

6 Conclusions

Conclusions (i)
Exploration Extraction Processing Manufacturing Use(s) Collection and Recycling
Activities to
uncover new
deposits of
Critical Mineral
deposits.
Mining and
extraction of
Critical Minerals.
Identification of
sources (Country
of Origin data)
Critical Minerals
converted from
primary material forms
(minerals, ores,
concentrates) into
processed materials
(metals, oxides, alloys,
powders, etc)
Critical minerals
formed into semi-
finished or finished
products
End use sectors
consuming semi-
finished or finished
products.
Collection of End-Of-Life
(EOL) products.
Refurbishment, repair,
repurposing of EOL products.
Recycling of EOL products to
recover Secondary Critical
Materials.
Initial State CM
Reporting
• Identify CM and country of
origin data [US/EU].
Emerging State
CM Reporting
• Identify CM and country of origin data [EU/US]
• Identify amounts of CM’s contained within products (at gram weight) [EU]
• Identify if CM is virgin or recycled [EU]
Typical CRM Supply Chain Analysis

Conclusions (ii)
Contextualize Your Supply Chain
Simplistic Manufacturing Supply Chain (Domestic & Foreign)

Conclusions (iii)
Apply some simple logic
1. Compile a Master CRM list combining UK / US / EU CRMs.
2. Capture volume of CRM usage reporting at component level (see EU requirements)
3. Capture if CRM used are based on Virgin / Secondary raw materials (EU likely to implement
future eco-modulation fees).
4. Capture CRM Country of Origin information.
5. Review existing supplier contract terms [use a general statement like – report against all global
requirements as defined on your company supplier portal vs very specific regulations / standards
which can become very costly when new reporting requirements arise]
6. Ensure some form of KPI’s exist to ensure supplier conformance to reporting.
7. Provision suppliers with training.
8. Monitor supplier reporting, making any adjustments as needed (training, key stakeholder
escalation)

Conclusions (iv)

7 Questions?

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