Posted on 04/04/2023 in Regulatory 2023
P4 proposed as “Critical” but not “Strategic”

Proposed EU Act keeps P4 as a Critical Raw Material but fails to recognise its need for fire safety of strategic technologies. The proposed EU Critical Raw Materials (CRM) Act, published 16th March 2023, is open to public consultation to 16th May 2023, then will go to Parliament and Council. P4 (confusingly termed “Phosphorus”) remains on the list of 34 Critical Raw Materials* (as does “Phosphate Rock”), but is not included in the subset of 16 Strategic Raw Materials (SRMs). If adopted as proposed, the Regulation would fix, for SRMs only but not for other CRMs, targets for onshoring of processing (the EU currently has no P4 production) and for reducing supply dependency, enable Strategic Projects and enable joint supply purchasing systems. The exclusion of P4 from the SRM list is surprising in that the selection is based on the JRC Foresight Report, also published 16th March, which identifies P4 as needed in all five strategic technology sectors considered and as one of the materials which the highest supply chain risk for several technologies. This Foresight report identifies P4 as needed for battery electrolytes (LiPF6), indium phosphide in semiconductors, and fire safety in “data storage and servers”, but does not note that P4 is also essential for fire safety in many of the other technologies (photovoltaics and renewable energy, laptops and smartphones, heat pumps, 3D printing, aerospace …) nor that it is needed for microchip etching, semiconductor Si to P doping.

pinfa will input to the discussion of this draft Regulation to underline the importance of phosphorus in fire safety in the strategic technology sectors considered, in particular renewable energies, batteries, information & communication technologies, aerospace.

* Critical Raw Materials (CRMs) are defined as “raw materials of high importance for the overall Union economy and for which there is a high risk of supply disruption”

** Strategic Raw Materials (SRMs) are defined as CRMs needed for “strategic technologies underpinning the green and digital transitions or for defence or space applications”.

European Commission press release, 16th March 2023 IP_23_1661 “Critical Raw Materials: ensuring secure and sustainable supply chains for EU’s green and digital future” – includes links to Commission Communication, FAQ, etc.

Proposed EU Critical Raw Materials Act, COM(2023)160, 16th March 2023

JRC Foresight Report 2023 “Supply chain analysis and material demand forecast in strategic technologies and sectors in the EU – A foresight study”, S. Carrera et al., ISBN 978-92-68-00339-8 (266 pages)

Public consultation to 16th may 2023

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