Climate Policy Engagement Analysis
Climate Policy Engagement Overview: Despite its positive top-line positions on climate policy, Euromines appears to have engaged negatively on specific climate-related regulations in the EU, including the EU Emissions Trading System. The association has also been unsupportive of elemnts of EU energy policy including the Renewable Energy Directive.
Top-line Messaging on Climate Policy: Euromines has limited top-line communications on climate change in 2023-2024, however previous communications are positive. In a joint statement in September 2022, the organization stated support for the objectives of the EU’s Green Deal and in a press release in April 2022, Euromines supported the goals of the Paris Agreement and the target of net-zero by 2050.
Engagement with Climate-Related Regulations: Euromines appears to have engaged negatively on specific climate-related regulations. In its contribution to the EU Critical Raw Materials Act Questionnaire in November 2022, Euromines was unsupportive of the EU Emissions Trading System (ETS) framework, advocating for the continuation and expansion of indirect CO2 cost compensation to the mining of critical minerals which can reduce the effectiveness of the policy. Euromines was also unsupportive of the EU Parliament Environment Committee’s proposal to increase the ambition of the EU's Carbon Border Adjustment Mechanism (CBAM), stressing risks of carbon leakage in a joint letter in June 2022. The organization also advocated for the weakening of EU Renewable Energy Directive's Delegated Act on Renewable Fuels of Non-Biological Origin (RFNBOs) in a July 2022 joint statement advocating for a grandfathering clause to not apply strict additionality requirements on renewable hydrogen until 2030, and weakening geographical and temporal correlation criteria.
Positioning on Energy Transition: Euromines has supportive top-level communications for the energy transition, but appears to have negatively engaged with policies such as the EU Renewable Energy Directive and the EU Electricity Market Design. In a September 2023 joint letter, the organization recognized the role of critical minerals in energy transition technologies such as electric cars and renewables, while clearly supporting the transition towards these technologies. However, in a May 2023 joint statement, Euromines did not fully support the EU Electricity Market Design, advocating for energy to be supplied in a technology neutral manner and renewable capacity to be expanded at a “realistic” speed. Also, in a July 2022 joint statement, Euromines did not support several elements in the proposed Renewable Energy Directive delegated act on recycled carbon fuels, including advocating for expanding the sectors of use for renewable fuels of non-biological origin (RFNBOs) to include easy-to-abate uses, weakening the policy.