European recyclers warn of a plethora of poorly justified proposed amendments found in ITRE’s draft report on the EU COM proposal on Critical Raw Materials (CRMs) published on 26 and 30 May, 2023. While many tabled proposals highlight the need for transparency ‘when the Commission adds or removes a raw material to the list in Annex I & II, Section 1, the Commission shall provide a clear argumentation and a timeline’, others propose the addition of materials^[1] to the aforementioned annexes without the existence of such an argumentation. European recyclers are of the strong opinion that any proposal laid down in EU legislation must be supported by an assessment which is purely based on scientific evidence.

^[1] Materials such as ferrous scrap (e.g., steel), copper, aluminium and aluminium alloy, silver, zinc must not be included in annex I & II, section 1, of the proposal without a scientific assessment proving the need of it.