We cannot imagine the electrification of transport and processes without metals. Similarly, our strategic independence in critical metals invites new investments that create value and jobs. And our businesses feed into downstream value chains. metal recycling for batteries, rare earth from permanent magnets, ripening of metals, of sites of preCAM and CAM, extraction of rocky or geothermal lithium or copper are direct illustrations of this. The same goes for the development of sites around the steels dedicated to new applications. A Green Industry law, which would introduce circularity and CSR requirements for purchases emanating from the administration, would be a welcome additional lever.

But beyond these elements, our manufacturers today need:

• simplification and regulatory stability
• competitive energy costs
• facilitation of innovation
• protection against dumped products extra-european commercial
• financing tools comparable to those used in other countries Western (e.g. IRA in the USA) more ambitious than the NZIA (Net Zero Industry Act) system or the absence of dedicated funding for SRM projects planned within the CRM Act.

Most of our industrialists have high energy needs. This is an intrinsic condition of their production processes. Maintaining or developing a fundamental industrial base for all European industrial chains requires a welcoming context for our members:

ELECTRICITY :

• available in abundance and at competitive cost : the end of the ARENh system must therefore be managed properly so that our actors, hyper electro-intensive, electro-intensive or electro-sensitive, can continue their activities profitably.
• Some of our actors can offer flexibility options, necessary for the proper management of the electricity network, if fair compensation for this constraint as well as triggering compatible with the production constraints of our actors prevail.

GAS :

• Today, and for some of them, even tomorrow, gas, with or without hydrogen, will be necessary.
• its availability and cost must again be at the best levels of the competition.
• energy efficiency : our members explore the possibilities of greater energy efficiency on a daily basis.

HYDROGEN:

• An essential tool for some, an option for others, our sector of activity could be one of the customers to favor in this new market. It is still necessary that it can be delivered to key locations.

WATER :

• Our historical industrialists, very aware of environmental issues and water stress, have adopted solutions aimed at significantly reducing their water withdrawals. This includes water recirculation, treatments before discharge or recirculation, leak detection, rainwater recovery, etc. Most new sites set low water footprint targets just as they set low carbon emissions targets at the very moment of their design.

Water and Water Sobriety objectives:

• Some manufacturers, by the very nature of their production processes, sometimes take significant samples. In accordance with the legal framework and common sense, water consumption is targeted as closely as possible. Recirculating water in a closed internal loop, hunting for water leaks, measuring flows, and capturing rainwater when possible are all measures frequently taken. Wastewater treatment is systematic before discharge.
• In order to limit their “water footprint”, many sites are actively managing their withdrawals and making investments aimed at reducing it and participating in reducing water stress in the regions concerned.
• For the most recent sites, the water footprint, like the carbon footprint, is integrated from the design of the site in order to aim for the best standards. The same applies to the new equipment concerned.

CSR :

• A3M members share values ​​that are deeply rooted within their companies.
• In this context, The industrialists we represent have for the most part implemented strong CSR commitments

CSRD/CR3D :

• If in principle A3M is in line with the essential objectives targeted by these texts, we regret the operational translation which is excessively costly, and which ultimately, from a purely economic perspective, is a factor of burden and constraint not shared by the actors of other countries.
• A3M also fears that, contrary to the objective pursued by the EU, an obviously laudable objective, the public availability of these elements will be the cause of unnecessary controversies led by third parties, whether objective or not, potentially manipulated, also a source of actions and costs harming healthy competition.

MINING LABELS

• In the mining sector, a subject that is often the subject of critical scrutiny by many NGOs, our international miners have chosen IRMA or ICMM type certification to aim for the highest international standards in the field.
• Under the CRM Act, it is planned to promote ores and minerals from sites that meet the best standards such as IRMA, ICMM, etc.
• A3M is fully in favour of this requirement, which is a guarantee for the value chain and the end consumer, of a chain of actors engaged in ethical work that respects people, the environment and the future.

MINING CODE (check the mining code here)

• A3M was directly involved in the work to modernize the French mining code.
• Although now in the process of being finalised, A3M considers that the code largely meets the mutual expectations of the various stakeholders.
• The context of the CRM Act and the Green Industry Act, each aiming to accelerate validation processes (exploration, exploitation, etc.) without this being to the detriment of environmental or neighborhood considerations, are additional positive elements.