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Cobalt, Nickel, Lithium and Graphite – All key raw materials for Europe’s strategic autonomy, defence sector and vital components to produce clean energy technologies. Europe urgently needs to increase its investment in those sectors to ensure resilient supply chains.
However, there is a current contradiction happening in the EU risking that all the above mentioned plus its European Critical Raw Materials Benchmark will not be fulfilled. The missing link is a coherent rational approach to chemicals management regulations.
Sounds too technical? It is one of the most substantial topics for the industry and without an updated approach will hinder the investment Europe so urgently needs in the raw materials industry.
Major investments in mining, refining, and recycling are stalling. Investors, who need clear timelines, long-term policy stability, and coherent rules, are being deterred by fragmented regulations, shifting interpretations, and excessive compliance burdens. This regulatory risk is pushing projects and the jobs and innovation they bring outside Europe.
This is the reason why Cobalt Institute together with the Nickel Institute, the International Lithium Association and Carbon and Graphite association sent a letter to the Commission warning that regulatory uncertainty and poorly coordinated policy making are deterring the very investments needed to secure raw material supply chains in Europe. Risking Europe being further behind than other key jurisdictions in the current geopolitical context where strategic autonomy is key.
Take the upcoming proposal on workplace exposure limits for cobalt which could seriously endanger Europe’s industry. A 1 µg/m³ limit, as suggested by ECHA, is too low for industry to operate and risks thousands of site closures and job losses despite weak evidence as to the need for this. Even a 10 µg/m³ limit could harm investment and supply chains, pushing production abroad. Industry hopes for a 20 µg/m³ limit, which, while being the strictest in the world, would keep industry viable while ensuring worker protection and continued supply in the EU.
But also for the Lithium, Nickel and Carbon and Graphite industry the European Commission is proposing measures that can jeopardise their industries. These include the contested classification of lithium salts, overly strict environmental standards for nickel, and ongoing uncertainty around coal tar pitch—an essential material for synthetic graphite production.
We therefore urge the European Commission to consider the importance of coherence between policies and regulations, based on risk and science, ensuring a protective and scientifically sound framework that keeps jobs in Europe and is aligned with the EU's strategic objectives.
The European Union faces a choice: to foster a strong, independent, and competitive industrial ecosystem, or risk further deindustrialisation, job losses, and increased dependence on third-country market supply chains.
Written by Sarah Schneider, Policy and Communications Manager