Regulatory advocacy

Positions and consultations

We follow European Commission consultations and draft acts affecting non-ferrous metals and recycling, assess their impact on member companies and present the industry’s position.

European Commission & ECHA · consultations

European Commission and ECHA consultations

Commission initiatives and draft acts, and scientific reports of the European Chemicals Agency (ECHA), affecting non-ferrous metals and recycling. Any company or organisation can submit comments; the Chamber tracks the deadlines and assesses the impact of the drafts on the industry.

OpenECHA scientific report – commentsOccupational exposure limits (OEL)ECHA – European Chemicals Agency

Occupational exposure limits for copper and its inorganic compounds – ECHA scientific report

Scope of the consultation

At the request of the European Commission of 29 January 2026, ECHA has prepared a scientific report on occupational exposure limits for copper (EC 231-159-6) and its inorganic compounds, for the amendment of the Chemical Agents Directive 98/24/EC. The report was preceded by a call for evidence from 1 April to 1 July 2026.

The consultation allows interested parties to comment on the report. The Committee for Risk Assessment (RAC) will adopt its opinion on this basis, with the report attached as an annex. Comments received after the deadline will not be taken into account.

What ECHA proposes – key points for the metals industry

Proposed OEL (8-h TWA): 0.01 mg Cu/m³ for the respirable fraction and 0.1 mg Cu/m³ for the inhalable fraction – for copper and all its inorganic compounds.
No short-term limit (STEL) and no binding biological limit value (BLV); biological guidance value (BGV) of 60 µg Cu/L in urine – the background level of the general population.
Respirable fraction: 28-day rat inhalation study with dicopper oxide (lung inflammation) and lung-deposition modelling; ECHA notes the absence of subchronic and chronic studies.
Inhalable fraction: studies of copper smelter workers (Haase et al., 2021–2022) showing no lung effects at an average exposure of 0.21 mg Cu/m³.
Poland’s current OEL (NDS) is 0.2 mg/m³ (per the overview in the ECHA report); 0.01 mg/m³ for the respirable fraction already applies in, among others, Spain and Sweden.
The derived value may not be appropriate for nanosized copper because of its higher lung deposition.

Prepared by the Chamber from the ECHA scientific report (EC 231-159-6 · CAS 7440-50-8).

Procedure

Commission request to ECHA29 January 2026
ECHA scientific report – comments12 Oct – 14 Dec 2026 · now
Opinion of the Committee for Risk Assessment (RAC)after the consultation; the ECHA report will be annexed to the opinion
Commission proposal – amendment of Directive 98/24/ECafter the RAC opinion

Closed consultations

List of non-OECD countries authorised to import certain non-hazardous waste from the EUDraft act – feedback · 18 Sep – 16 Oct 2026Commission consultation page

EU policy

Circular Economy Act – state of play

The Circular Economy Act is intended to create a single market for secondary raw materials in the EU. Procedural stage, timeline and scope – based solely on documents of the European Commission, the European Parliament and the EESC.

Announced – Commission proposal in preparationLegislative initiative · Art. 114 TFEU

The European Commission is preparing a legislative proposal

In its 2026 work programme, the Commission announced the proposal for Q3 2026. In a news item of 31.08.2026 it stated that the act is due to be adopted before the end of 2026. In the European Parliament the file has the status “announced” (as of 20.09.2026).

Date given by the Commission

before the end of 2026

Originally: Q3 2026 (Commission work programme)

As of 20.10.2026

Where the procedure stands

Diagram 1. Legislative path of the Circular Economy Act

Legal basis according to the Commission work programme: Art. 114 TFEU (internal market), which means the ordinary legislative procedure and mandatory consultation of the EESC. Dates for stages 4–6 are not known before the proposal is published.

Timeline of work

Diagram 2. Timeline of work 2025–2027

Dates in Annex I to the Commission work programme are indicative and may change during preparation, notably in view of the outcome of an impact assessment (footnote to the annex). The “today” line moves automatically.

Scope announced by the Commission

Diagram 3. Objectives and pillars of the Circular Economy Act

Sources: European Commission (01.08.2025, 31.08.2026), Commission work programme 2026, EPRS PE 782.628 (27.01.2026); circularity rate – Eurostat, cited by EPRS. The final scope will only be set by the Commission proposal.

Relevance for non-ferrous metals

End-of-waste criteria

EPRS identifies the lack of harmonised criteria and 27 divergent national regimes as a primary barrier to cross-border flows of secondary raw materials. For metal scrap, EU criteria already apply: Regulation (EU) No 333/2011 (iron, steel, aluminium) and No 715/2013 (copper). Member States named harmonised criteria as a priority (18.11.2025).

WEEE and critical raw materials

Amending the WEEE Directive is one of the pillars of the proposal. EPRS points to recovering permanent magnets from electric vehicles and rare earths from e-waste as a route to the Critical Raw Materials Act target: at least 25% of annual consumption of strategic raw materials from recycling. EU e-waste recycling rate: 30.8% (2023, Eurostat).

Trade in secondary raw materials

In 2024 the EU exported 35.7 million tonnes of recyclable raw materials (largest destination: Türkiye – 12.3 million tonnes) and imported 46.7 million tonnes (Eurostat, cited by EPRS). Member States stressed a level playing field, including for imports.

Demand, prices and simplification

Recyclates are often more expensive than virgin materials or perceived as lower quality, which weakens demand (EPRS). Member States mentioned recycled-content targets and green public procurement, and the Commission simple, clear and digital rules for secondary raw materials and waste. DIWASS already digitalises waste shipments. See DIWASS →

Next steps

Publication of the proposal

Date given by the Commission: before the end of 2026. Once the College adopts the proposal, this section will be updated with its number and content.

Parliament, Council and EESC

The proposal will go to the lead committee of the European Parliament and to a Council working party. Art. 114(1) TFEU requires consultation of the EESC; exploratory opinion NAT/986 was adopted ahead of the proposal.

Key facts

Initiative: Circular Economy Act
Type: legislative, Art. 114 TFEU – Commission work programme 2026, Annex I item 4
In the Commission: Commissioner Jessika Roswall; oversight: Executive Vice-Presidents Teresa Ribera and Stéphane Séjourné (EPRS)
Consultation: 01.08–06.11.2025, initiative 14812
Status in the EP: “Announced” – Legislative Train, as of 20.09.2026
As of: 20.10.2026

Sources

Information note based on official EU documents; not a legal interpretation. Until the Commission proposal is published, its content and timing may change.

EU policy

Critical Raw Materials Act – implementation

Regulation (EU) 2024/1252 on critical raw materials has been in force since 23 May 2024. Copper and aluminium are strategic raw materials under it. Implementation, the amendment, deadlines and strategic projects – based solely on official documents.

In force since 23.05.2024Amendment in procedureRegulation (EU) 2024/1252 · Art. 114 TFEU

The Regulation is in force – implementation and amendment under way

The Commission has recognised 106 strategic projects in total (25.03.2025, 04.06.2025 and 09.10.2026). On 3 December 2025 it presented the RESourceEU plan and amending proposal COM(2025) 946; the Council adopted its position on 4 March 2026, and in the European Parliament the file was referred back to the ITRE committee on 9 July 2026.

Strategic projects

106

47 in the EU + 13 outside + 46 in the EU; 6 involving Poland

As of 20.10.2026

Procedure: Regulation and amendment

Diagram 1. Procedure: Regulation 2024/1252 and amendment COM(2025) 946

The amendment provides, among other things, for the Commission to identify large companies using strategic raw materials (Art. 24), a wider scope for permanent magnet labelling (Art. 28) and pre-consumer waste counting towards recycled content in magnets.

2030 benchmarks and raw material lists

Diagram 2. 2030 benchmarks and raw material lists

Benchmarks refer to the EU’s annual consumption of strategic raw materials; the extraction benchmark applies “to the extent possible in light of the Union’s reserves”. Delegated recycling benchmarks for waste streams – by 1.01.2027 (Art. 5(3)). Source: Regulation (EU) 2024/1252, Art. 5, Annexes I and II.

Implementation timeline

Diagram 3. Implementation timeline 2024–2030

Dates take account of the corrigendum (OJ L 2024/90330 of 03.06.2024), which among other things moved the evaluation of the Regulation to 24.05.2029. Circularity programmes are due 2 years after Implementing Regulation (EU) 2026/1116 entered into force (16.06.2026). The “today” line moves automatically.

Relevance for non-ferrous metals

Recycling and waste streams

Implementing Regulation (EU) 2026/1116 of 26.05.2026 lists waste streams with critical raw material recovery potential, including construction and demolition waste – aluminium, aluminium alloys, copper, copper alloys and cables – and aluminium components and wiring harnesses from vehicles. Member States adopt national circularity programmes by 16.06.2028 (Art. 26).

Scrap – RESourceEU announcements

The RESourceEU plan (COM(2025) 945, 03.12.2025) announces that by Q2 2026 the Commission will propose targeted measures for aluminium scrap and export restrictions on permanent magnet scrap; similar measures for copper scrap are to be considered after further monitoring. The Commission also aims to close loopholes for copper and aluminium scrap fraudulently declared as products.

Strategic projects involving Poland

2025: POLVOLT (Elemental Battery Metals, recycling – incl. Ni, Cu, Co), the Puławy rare earths separation plant (Mkango Resources). 2026: Retków-Grodziszcze deposit (KGHM Polska Miedź, copper extraction), Integrated Recycling Smelter (KGHM, copper and nickel recycling), Urban mining (TDM Electronics, recycling) and CRM4Defence (Leonardo, recycling in Italy, Poland, the UK and France).

Implementation in Poland

On 2.09.2026 the Council of Ministers launched the national critical raw materials exploration programme (Art. 19; EU deadline: 24.05.2025), run by PIG-PIB until 2033. Draft act on securing access to critical raw materials (UC83, Ministry of Climate and Environment) – planned government adoption: Q3 2026. Poland is represented on the Critical Raw Materials Board by the Ministry’s Department of Geology.

Obligations of large companies

By 24.05.2025 Member States were to identify large companies manufacturing, among others, batteries, permanent magnets and other products using strategic raw materials; these carry out a supply-chain risk assessment at least every 3 years (Art. 24). The amendment moves identification of these companies to the Commission.

Permanent magnets

Products with permanent magnets will be labelled (Art. 28 – implementing act on the label due 24.11.2025 per the corrigendum), and those placing them on the market will disclose the share of recovered materials in magnets – from 24.05.2027 or 2 years after the delegated act, whichever is later (Art. 29).

Next steps

Amendment COM(2025) 946

Following referral back to ITRE (09.07.2026), Parliament has to set its position; trilogues with the Council, which adopted its position on 04.03.2026, follow.

Aluminium scrap – trade measure

Initiative 16192: call for evidence 19.12.2025–31.01.2026 (142 responses); Commission adoption planned for Q4 2026.

Critical Raw Materials Centre

Legislative initiative in the Commission work programme 2026 (Q2 2026, Art. 114 TFEU). Consultation 19.05–29.07.2026 (138 responses); according to the European Parliament (20.09.2026) no proposal has yet been tabled.

Next call for projects

The Commission announced the next call for strategic projects towards the end of 2026 (press release of 09.10.2026). By 24.05.2027 – review of the strategic and critical raw material lists.

Key facts

Act: Regulation (EU) 2024/1252 of the European Parliament and of the Council of 11.04.2024 establishing a framework for ensuring a secure and sustainable supply of critical raw materials
Publication: OJ L 2024/1252, 03.05.2024; in force 23.05.2024
Corrigendum: OJ L 2024/90330, 03.06.2024 – incl. dates in Arts 27, 28, 31, 44 and 47 (24.11.2025) and 48–49 (24.05.2029)
Lists: 17 strategic (Annex I), 34 critical (Annex II)
Amendment: COM(2025) 946, procedure 2025/0385(COD)
As of: 20.10.2026

Sources

Information note based on official documents of the EU and the Polish government; not a legal interpretation. The binding text is the Regulation as published in the Official Journal of the EU, together with the corrigendum.

EU policy

Industrial Accelerator Act – state of play

Proposal COM(2026) 100 of 4 March 2026 combines low-carbon and Union-origin requirements in public procurement, faster permitting and conditions for large foreign investments. Aluminium is the only non-ferrous metal covered by the requirements. Procedure, content and dates – based solely on official documents.

Commission proposal in the legislative procedureRegulation · Arts 114 and 207(2) TFEU

Parliament and Council are preparing their positions – before trilogues

In the European Parliament the proposal is handled jointly by the INTA, ITRE and IMCO committees; the draft report was presented on 11 September 2026 and the committee vote is scheduled for 1 December 2026. The Competitiveness Council discussed the proposal on 28 May and 24 September 2026; no general approach has been adopted yet. The EESC (15.07.2026) and the Committee of the Regions (14.10.2026) have delivered opinions.

Aluminium from 2029

25%

minimum share of low-carbon aluminium of Union origin in procurement and support schemes (Annex II of the proposal)

As of 21.10.2026

Procedure: from announcement to application

Diagram 1. Procedure: proposal COM(2026) 100, procedure 2026/0068(COD)

In the Commission work programme 2025 the initiative was called the Industrial Decarbonisation Accelerator Act. Publication was postponed several times; the Regulatory Scrutiny Board first issued a negative opinion. 428 pieces of feedback on the proposal were submitted on Have Your Say (until 18.06.2026).

What the proposal introduces

Diagram 2. Lead markets, permitting and foreign investment in proposal COM(2026) 100

Annex II covers products for buildings, infrastructure and vehicles: in procurement procedures launched from 01.01.2029 and in support schemes established or updated from that date. Low-carbon status will be defined by delegated acts under Regulations (EU) 2024/3110 and 2024/1781 (Art. 10(1)). Source: COM(2026) 100, Arts 4–27, Annexes I–II. Content as proposed by the Commission – may change during the procedure.

Timeline

Diagram 3. Timeline 2025–2029

The EP committee vote and the indicative plenary date (14.12.2026) are taken from the OEIL procedure file – to be confirmed. The date 01.01.2029 is set in the proposal; deadlines counted from entry into force (e.g. acceleration areas – 12 months) depend on the publication date. The “today” line moves automatically.

Relevance for non-ferrous metals

Aluminium – lead market

Aluminium is the only non-ferrous metal with binding requirements: at least 25% low-carbon aluminium of Union origin in products for buildings, infrastructure and vehicles bought through public procurement or supported with public money (Annex II). For steel the proposal requires only low-carbon content, with no origin criterion.

Low-carbon definition and label

The low-carbon threshold is not set in the proposal – it will be defined by delegated acts under the Construction Products Regulation (2024/3110) and the Ecodesign Regulation (2024/1781). The Commission may also establish voluntary emission-intensity classes for products of ETS activities, based on ETS and CBAM data and taking into account incentives for recycled materials (Art. 10).

Copper, zinc, lead

The proposal does not name these metals and sets no demand-side requirements for them. General provisions may apply: acceleration areas covering basic metals (NACE C24), procedures for energy-intensive industry decarbonisation projects (Art. 6) and – in the critical raw materials sector, which includes copper – conditions for large foreign investments (Art. 17).

Recycled content and scrap

The explanatory memorandum states that emission-intensity thresholds should take account of recycled content – the threshold decreasing as recycled content rises; for steel it foresees an adjustment by scrap share. In designing the emission classes the Commission is to consider the need to incentivise recycled materials in all production routes (Art. 10(2)).

Acceleration areas

Each Member State is to designate at least one area within 12 months of entry into force, prioritising industrial and brownfield sites outside Natura 2000 (Art. 25). An aggregated baseline permit is issued for each area (Art. 27). The Commission refers to tacit approval at intermediate stages and a maximum of 18 months for specific projects (Q&A).

Links to other acts

The proposal amends the Single Digital Gateway (2018/1724), NZIA (2024/1735) and Construction Products (2024/3110) Regulations. Acceleration areas are to cooperate within the Critical Raw Materials Board and use CRMA joint purchasing (Art. 26). The emissions label builds on ETS and CBAM data. The Commission estimates that demand measures will add over EUR 600 million in value in steel, aluminium and cement by 2030 (Q&A).

Next steps

European Parliament

Rapporteurs: Anna Cavazzini (Greens/EFA), Christophe Grudler (Renew), Pierre Jouvet (S&D). The draft report (PE792.067) of 11.09.2026 proposes, among other things, raising thresholds to 50% by 2036 and covering plastics; ENVI committee opinion – 07.10.2026. The committee vote is scheduled for 01.12.2026.

Council of the EU

After the ministerial debate (28.05.2026) and the progress report (24.09.2026) the proposal is being discussed in the working party; no general approach has been adopted so far. Trilogues can start once both institutions have set their positions.

Implementing and delegated acts

After adoption: national investment authorities within 1 month, an implementing act on verifying foreign investment conditions within 6 months (Art. 18), the method for calculating the Union-origin share (Art. 16(3)) and delegated acts on emission classes (Art. 10(2)).

Poland

The Sejm’s EU Affairs Committee examined the proposal together with the draft Polish position on 06.10.2026 (sitting no. 163; presented by the Ministry of Development and Technology, rapporteur Andrzej Grzyb MP); 15.09.2026 – government information ahead of the Competitiveness Council.

Key facts

Act: Proposal for a Regulation of the European Parliament and of the Council establishing a framework of measures for the acceleration of industrial capacity and decarbonisation in strategic sectors and amending Regulations (EU) 2018/1724, (EU) 2024/1735 and (EU) 2024/3110
Document: COM(2026) 100 final, 04.03.2026; SEC(2026) 70, SWD(2026) 70–72
Procedure: 2026/0068(COD); EP: joint INTA, ITRE, IMCO committees, ENVI opinion
Legal basis: Arts 114 and 207(2) TFEU
Objective: manufacturing at least 20% of EU GDP by 2035 (Art. 2); 14.3% in 2024
As of: 21.10.2026

Sources

Information note based on official documents of the EU and the Polish Sejm; not a legal interpretation. It describes the Commission proposal – the final text of the Regulation depends on the outcome of the legislative procedure.

EU policy

Carbon Border Adjustment Mechanism – state of play

The Carbon Border Adjustment Mechanism (CBAM) has been in its definitive period since 1 January 2026. Aluminium is the only non-ferrous metal covered. Obligations, deadlines, the extension to downstream goods and implementation in Poland – based solely on official documents.

Definitive period since 01.01.2026Extension in procedureRegulation (EU) 2023/956 · Art. 192(1) TFEU

The mechanism applies – first settlement for 2026 by 30.09.2027

An importer of CBAM goods – cement, iron and steel, aluminium, fertilisers, electricity and hydrogen – needs the status of authorised CBAM declarant if it imports more than 50 t a year (electricity and hydrogen – no threshold). Certificates will be sold from 1 February 2027, and the declaration for 2026 and the surrender of certificates are due by 30 September 2027. Proposal COM(2025) 989 extending CBAM to downstream goods is under negotiation between the European Parliament and the Council.

Certificate price, Q3 2026

€82.32

per tonne CO₂e; Q1 €75.36, Q2 €75.28 – average EU ETS auction price

As of 21.10.2026

Procedure: Regulation, simplification and extension

Diagram 1. Procedure: Regulation 2023/956, simplification 2025/2083 and extension COM(2025) 989

Work is also under way on the Temporary Decarbonisation Fund COM(2025) 990 (Parliament position 15.09.2026) and on the EU ETS review COM(2026) 616 of 17.07.2026, which proposes to reintroduce from 2028 15% of the free allocation phased out in CBAM sectors and to spread the phase-out until the end of 2037.

Importer obligations and the rising charge

Diagram 2. Importer’s annual cycle and share of emissions subject to the CBAM charge 2026–2034

Share derived from the CBAM factor, i.e. the part of free allocation kept in the EU ETS: 97.5% in 2026, 95% in 2027, 90%, 77.5%, 51.5%, 39%, 26.5% and 14% in 2033; none from 2034 (Art. 10a(1a) of Directive 2003/87/EC). Certificate price: quarterly average in 2026, weekly average of allowance auction prices from 2027 (Art. 21). The ETS review COM(2026) 616 proposes to change this schedule.

Timeline

Diagram 3. Timeline 2023–2028

Importers who applied for the status by 31.03.2026 could import provisionally until the decision (Art. 17(7a)). The dates 01.02.2027 and 30.09.2027 follow from Regulation 2025/2083; 01.01.2028 is from proposal COM(2025) 989 and may change. The “today” line moves automatically.

Relevance for non-ferrous metals

Aluminium within CBAM

Covered: CN 7601 (unwrought aluminium), 7603–7614 and 7616; gases: CO₂ and perfluorocarbons. Scrap 7602 and household articles 7615 remain outside. Default values for aluminium carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (Impl. Reg. 2025/2621). In the first days of 2026 aluminium accounted for 0.3% of the mass of CBAM goods declared in the EU.

Copper, zinc, lead

They are not covered by CBAM. In review report COM(2025) 783 of 16.12.2025 the Commission states that its analysis does not currently identify the non-ferrous metals sector – lead, zinc and copper – as a candidate for inclusion, owing to the sector’s complexity. The next review step (2027) is to address indirect emissions and other sectors, such as chemicals.

Aluminium scrap

Proposal COM(2025) 989 brings pre-consumer aluminium scrap (ex 7602) and steel scrap in as precursors; post-consumer scrap stays outside, as covering it could discourage the circular economy. Parliament (15.09.2026) proposes covering all scrap 7602 as a precursor, with evidence for post-consumer scrap and declaration of its quantity. The Council largely agrees with including pre-consumer scrap.

Downstream goods

The Commission proposes covering, from 01.01.2028, 180 products with high steel and aluminium content (94% industrial goods, on average 79% steel and aluminium). The list also includes copper winding wire and conductors (ex 8544) – insofar as they contain steel or aluminium. Parliament widens the list and proposes a 5 t threshold for aluminium products; the Council foresees an annual review of the list.

Free allocation and exports

EU aluminium producers lose free allocation under the EU ETS at the pace of the CBAM factor (diagram 2). The Temporary Decarbonisation Fund COM(2025) 990 – financed from 25% of certificate revenue for 2026–2027 – is to support export production in 2028–2029, including 7 aluminium CN codes. The ETS review COM(2026) 616 proposes to reintroduce 15% of the phased-out allocation from 2028.

Implementation in Poland

The Act of 21.11.2025 amending the act on the system for managing greenhouse gas emissions and other substances (Dz.U. 2025 item 1863) has applied since 13.01.2026. The authorised CBAM declarant status is granted by the Director of the Tax Administration Chamber in Poznań (Dz.U. 2026 item 11), access to the CBAM registry is via PUESC, and KOBiZE handles, among other things, corrections of transitional reports.

Next steps

EP–Council negotiations

The Council adopted its general approach on COM(2025) 989 on 12.06.2026 and aims for agreement before the end of the year; Parliament adopted its position on 15.09.2026 and referred both proposals (989 and 990) for negotiations. No agreement has been announced yet. EP rapporteurs: Mohammed Chahim (extension) and Pascal Canfin (fund).

The year 2027

From 01.02.2027 certificates are sold on the common platform; from 2027 the price is weekly and the quarterly holding at least 50%. By 30.09.2027 the first declaration and surrender of certificates for 2026; repurchase by 31.10, cancellation of unused certificates on 01.11.2027. Default values and mark-ups are to be revised in 2027 at the latest.

Reviews

Each year by 30.04 the Commission checks that the 50 t threshold exempts no more than 1% of emissions – for 01.04.2025–31.03.2026 it was 0.87%, so the threshold stays. The next report on CBAM application is due before 01.01.2028 and every two years thereafter (Art. 30). Feedback on the ETS review COM(2026) 616 can be submitted until 03.11.2026.

Poland’s position

On 12.05.2026 the Sejm’s EU Affairs Committee (sitting no. 138) endorsed the government position on COM(2025) 989: support for the extension and anti-circumvention measures, with a transition period, and opposition to the broad empowerment in Art. 27a. The government position on the fund COM(2025) 990 is negative (sitting no. 146, 10.06.2026).

Key facts

Act: Regulation (EU) 2023/956 of the European Parliament and of the Council of 10.05.2023 establishing a carbon border adjustment mechanism
Publication: OJ L 130 of 16.05.2023, p. 52; applies from 01.10.2023, definitive period from 01.01.2026
Amendment: Regulation (EU) 2025/2083 of 08.10.2025, OJ L 2025/2083 of 17.10.2025
Scope: cement, iron and steel, aluminium, fertilisers, electricity, hydrogen (Annex I)
In progress: COM(2025) 989 – 2025/0419(COD); COM(2025) 990 – 2025/0418(COD)
As of: 21.10.2026

Sources

Information note based on official documents of the EU, the Polish Sejm and the Polish Journal of Laws; not a legal interpretation. The binding texts are those published in the Official Journal of the EU; proposals COM(2025) 989 and 990 may change during the procedure.

Chamber dossiers

Where the Chamber takes a stand

We actively take part in national and EU consultations. Below are the key open dossiers with the Chamber’s positions (PL/EN).

In progress

CRMA

The Critical Raw Materials Act (Reg. (EU) 2024/1252) sets 2030 targets: 10% extraction, 40% processing and 25% recycling of the EU’s annual demand for strategic raw materials, and at most 65% of supply from a single third country. Non-ferrous metals recycling is central to these targets.

DocumentPDF · EN

Monitoring

Waste shipments

We monitor changes in EU waste shipment rules and scrap classification and their practical impact on the operations of member companies.

DocumentPDF · EN

Monitoring

CBAM

The Carbon Border Adjustment Mechanism (CBAM) enters its definitive phase on 1 January 2026, covering aluminium and iron & steel products, among others. We analyse the impact on industry competitiveness and costs.

DocumentPDF · EN

Active

Mining tax

We analyse the impact of the tax on the extraction of certain minerals (incl. copper and silver) on the competitiveness of domestic production – Poland is among Europe’s leading producers of copper and silver.

Expertise

Positions grounded in industry knowledge and data

How we work

From monitoring to representation

Monitoring

We track national and EU legislation and consultations.

Analysis

We assess the impact on member companies.

Position

We formulate the Chamber’s official position (PL/EN).

Representation

We bring the industry’s voice to administration and the EU.

Positions and consultations

European Commission and ECHA consultations

Occupational exposure limits for copper and its inorganic compounds – ECHA scientific report

What ECHA proposes – key points for the metals industry

Procedure

Closed consultations

Circular Economy Act – state of play

The European Commission is preparing a legislative proposal

Where the procedure stands

Timeline of work

Scope announced by the Commission

Relevance for non-ferrous metals

End-of-waste criteria

WEEE and critical raw materials

Trade in secondary raw materials

Demand, prices and simplification

Next steps

Publication of the proposal

Parliament, Council and EESC

Key facts

Sources

Critical Raw Materials Act – implementation

The Regulation is in force – implementation and amendment under way

Procedure: Regulation and amendment

2030 benchmarks and raw material lists

Implementation timeline

Relevance for non-ferrous metals

Recycling and waste streams

Scrap – RESourceEU announcements

Strategic projects involving Poland

Implementation in Poland

Obligations of large companies

Permanent magnets

Next steps

Amendment COM(2025) 946

Aluminium scrap – trade measure

Critical Raw Materials Centre

Next call for projects

Key facts

Sources

Industrial Accelerator Act – state of play

Parliament and Council are preparing their positions – before trilogues

Procedure: from announcement to application

What the proposal introduces

Timeline

Relevance for non-ferrous metals

Aluminium – lead market

Low-carbon definition and label

Copper, zinc, lead

Recycled content and scrap

Acceleration areas

Links to other acts

Next steps

European Parliament

Council of the EU

Implementing and delegated acts

Poland

Key facts

Sources

Carbon Border Adjustment Mechanism – state of play

The mechanism applies – first settlement for 2026 by 30.09.2027

Procedure: Regulation, simplification and extension

Importer obligations and the rising charge

Timeline

Relevance for non-ferrous metals

Aluminium within CBAM

Copper, zinc, lead

Aluminium scrap

Downstream goods

Free allocation and exports

Implementation in Poland

Next steps

EP–Council negotiations

The year 2027

Reviews

Poland’s position

Key facts

Sources

Where the Chamber takes a stand

Current dossiers