European Critical Raw Materials Act

Open letter on The European Commission’s proposals for ensuring critical materials self-sufficiency and the development of net-zero technologies as part of the green and digital transitions (European Critical Raw Materials Act)

This statement is by Finland’s largest NGO focusing on mineral exploration and mining, the Finnish Lapland’s largest NGO focusing on mineral exploration and mining, Finland’s largest NGO focusing on migratory fish, Finnish Lapland’s most significant tourism association, other groups and individual specialists from related fields. The statement’s recommendations and appendices parts are in Finnish.

NGO and other organisation signatories:

Rajat Lapin kaivoksille ry (Limits for Lapland’s Mines Association)
Kansalaisten kaivosvaltuuskunta – MiningWatch Finland ry
Villilohi ry (Association for Wild Salmon)
Finnish Lapland Tourist Board ry
Muonion paliskunta (Muonio Reindeer Herder’s Association)
Pro Ylläs
Äkäslompolon kyläyhdistys ry (Äkäslompolo Village Association)
Pro Kuusamo ry
Ylitornion-Pellon Luonto ry (Ylitornio-Pello Nature Association)
Sompion Luonnonystävät ry (Sompio Friends of Nature Association)
Pelastetaan Kolin maisemat (Save Koli Landscapes group)
Ei kaivosta Pyhä-Luoston alueelle (No Mine to Pyhä-Luosto group)
Pelastetaan Päijänne (Save Päijänne group)

Individual signatories:

Satu Jaatinen, MSc Econ., local and county government decision maker, financial markets expert, founder of Pelastetaan Päijänne
Tarja Richard, PhD Phil., Director and Managing Authority for EU Structural Funds, Marseille, France
Peter Brandt, MSc Tech., entrepreneur, expert in waste sealing structures
Helvi Heinonen-Tanski, PhD Agriculture and Forestry, Docent, University of Eastern Finland
Leif Ramm-Schmidt, MSc Chemical Engineering, entrepreneur, expert in demanding industrial wastewater treatment
Niina Helistö, Surveyor, former mine supervisor, founder of Rajat Lapin kaivoksille ry (Limits for Lapland’s Mines Association)
Mika Merkku, Reindeer herder, chair of Rajat Lapin kaivoksille ry (Limits for Lapland’s Mines Association)
Miisa Mink, MSc. Econ., entrepreneur, founder and chair of Saimaa ilman kaivoksia ry (Lake Saimaa without Mines Association)
Marjo-Riina Alhainen, natural product advisor, founder of Saimaa ilman kaivoksia ry (Lake Saimaa without Mines Association)
Marianne Juntunen, PhD Biochemistry,  MSc Tech
Jari Natunen, PhD Biochemistry, special expert at the Finnish Association for Nature Conservation, chair of MiningWatch Finland

Our view is that unified EU legislation is required to guide the mining and battery manufacturing industry, but that the sustainable implementation of the green and digital transitions should be at its core. 

When creating a body that coordinates the matter at the EU level, it must be considered that much remains to be done on the national level. For example, EU directives that deal with the mining and battery manufacturing industries have not yet been fully implemented. 

To name one, the Finnish legislation is yet to be harmonized with the EU’s extractive waste directive 2006/21/EC. According to the directive, mining waste must not cause pollution of the waterways or groundwater, not even after a long period of time. 

Finland differs from most other European countries in that pure groundwater can be found everywhere and that the country is covered by a network of hundreds of thousands of lakes and rivers. Lakes cover 1/10 of our surface area, and 87 % of them are in good or excellent condition. The feasibility of several livelihoods, such as tourism, food manufacturing industry, fishery and reindeer husbandry is largely dependent on Finland’s unpolluted nature (See more in Appendix 1).

Finland’s waterways and groundwater are particularly fragile: they are shallow and harmful substances break down slowly. At the same time, the bedrock in Finland has a low mineral content compared to the traditional mining countries. This leads to larger open pit mines requiring significantly more chemicals and creating enormous amounts of mining waste. Finland’s current mines already produce more than 70% of all Finland’s waste and more than 90% of all hazardous waste.

It would therefore be extremely worrying if strategic projects were to be permitted to bypass the requirements of the nature, water framework or extractive waste directives. It cannot be accepted that preventing climate change or extracting critical raw materials would lead to the pollution of the waterways. Poorly constructed mines can contaminate entire waterways and groundwater areas. The operational conditions of the Finnish tourism industry and the export side of the food industry, as well as Finland’s special position in terms of the purity of its nature, must not be damaged. 

In addition, we would like to point out that fast-tracking the permit procedure to last a maximum of 24 months is currently not possible in Finland. Even with Finland’s current, long permit processing times, there are serious failings in the legislative permitting procedures. The flaws have already led to several catastrophic consequences both to the environment and the state finances. Several decisions to revoke permits have also taken place. (See more in Appendix 2). 

One of the reasons behind Finland’s currently long permit processing times and EIA procedures is that the reports are prepared by consultants, which are paid by the industrial companies. It is common for the reports to be incomplete or contain incorrect information

In addition, there are shortcomings in the national regulations and the authorities’ formal instructions, their resources and sometimes in scientific expertise. Cooperation between the authorities and the companies applying for permits is not sufficiently separated. 

There is also room for improvement in the mining and battery manufacturing industries’ obtainment of the social licence to operate. For example, there are no established procedures for true consideration of the local citizens, other businesses, and the indigenous Sámi people, who are subject to the permit procedure. This, together with incomplete license applications, has led to a large number of complaints at different levels of Finland’s national court system. 

The construction quality of mines in Finland is poor, owing to the fact that compliance with the construction Eurocodes system is not required. The combined ecological effects of mining and battery manufacturing projects are also not sufficiently investigated. 


Additionally, it should be noted that:

Finland’s mining, ore processing and battery manufacturing industries are mainly foreign-owned: often by third parties to the EU. This can cause challenges with the self-sufficiency sought after by the EU. For example, the planned battery manufacturing factory in Hamina is 60 % Chinese-owned. The aforementioned problems have also occurred in this project’s permit procedure.

For the transition to be truly sustainable, funding and investments in innovations vital for sustainability should be encouraged. These cover, above all, technology for environmental protection, utilising mining waste side streams, recycling and reuse, and  replacing battery metals. Similarly, funding and investments that support old-fashioned technology should be avoided. 

An EU country that produces minerals or technology required for the transition should be guaranteed fair and reasonable compensation for the benefits it produces, and that also is concerning the resulting risks. 

The transnational executive board of the European Commission overseeing the Critical Raw Materials project assessments should also include representatives from non-governmental organizations.

Appendices (in Finnish): Appendix 1: Purity of Finland’s Nature and livelihoods. Appendix 2: Explanation of the mining permit process duration and the associated risks. 

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