News Our Feedback to EC 24 November 2022

Have your say - Raw materials

You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform "Have your say" with the list of all new EU initiatives open for public consultation. You need to register to write your feedback.

European Critical Raw Materials Act

About this initiative: To achieve the green and digital transitions, the EU must significantly increase and diversify its critical raw materials supply, strengthen circularity and support research and innovation.

Feedback period: for stage 3 it is 30 September 2022 - 25 November 2022


Feedback from Europeans for Safe Connections

Europeans for Safe Connections request the EU to abide by EU law in the digital transition, which in too many ways is not a green development. Far from being a solution to climate change, the ecological footprint of the digital economy would reach its peak with the digital transition and 5G.

This environmental footprint must be reduced. Manufacturers must prioritize safer chemicals and environmental protections over profit. Products must have built-in recycling and repairability.

The OECD Report from 2018 Global Material Resources Outlook to 2060 recognizes the role of digitization in the exponential increase in extracted resources (rare earth minerals and metals). The report projects a doubling of global primary materials use between today and 2060. It would also increase water pollution and depletion, habitat destruction, deforestation, and droughts, impacts on flora/fauna and human health.

European citizens have not been involved in the decisions taken to push this resource intensive new technological society or asked if this is the way we want our society to go forward. According to the Aarhus convention EU citizens have a right to public participation in environmental decision-making processes.

According to the EU’s Circular Economy Action Plan, all electronic devices, especially those, which are used for digitalisation, should also be made "fit for a climate-neutral, resource-efficient and circular economy, reduce waste and ensure that the performance of front-runners in sustainability progressively becomes the norm".

We call on the EU Commission to include all device groups that accompany digitalization, into the Ecodesign Directive in order to improve their energy and resource efficiency as well as their energy security and reduction in demand for natural resources.

The Ecodesign Directive 2009/125/EC sets requirements for the environment-related design of "energy-related products" (ErP). Its primary aim is that manufacturers of energy-using products (EuP) will, at the design stage, be obliged to reduce the energy consumption and other negative environmental impacts of products. It also aims at taking other environmental factors into consideration: materials use, water use, polluting emissions, waste issues and recyclability.

According to Directive 2012/27/EU on energy efficiency, the Union places energy efficiency, and the need for decoupling energy use from economic growth at the core of the Union energy strategy. Reduce the massive electricity consumption caused by digital technology, e.g. by prioritizing wired solutions and low energy solutions in the action plan for the European Green Deal.

Article 3 of the TEU, where "The Union shall establish an internal market. It shall work for the sustainable development of Europe based on balanced economic growth and price stability, ... and a high level of protection and improvement of the quality of the environment.

Article 194 (c) of the TFEU: "promote energy efficiency and energy saving and the development of new and renewable forms of energy"

Article 21 (f) of the TEU: "help develop international measures to preserve and improve the quality of the environment and the sustainable management of global natural resources, in order to ensure sustainable development"

Article 37 of the CFR, Environmental protection: "A high level of environmental protection and the improvement of the quality of the environment must be integrated into the policies of the Union and ensured in accordance with the principle of sustainable development."

We also ask to include "Waste from Electrical and Electronical Equipment"(WEEE), other waste products, and the environmental impacts of mining for rare earth minerals and metals used in electronical equipment in the “Zero pollution action plan”.

Best regards
Pernille Schriver
on behalf of Europeans for Safe Connections
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