Greening metals and minerals production, including CRMs, comes with higher capital and operating costs – a 'green premium'. This reflects investment in decarbonising production processes, ensuring robust environmental and social safeguards and advancing circularity.

Manufacturers appear hesitant to absorb such premia and a credible green-premium market for CRMs is unlikely to emerge without regulatory intervention.

This analysis has laid out a phased, two-tier pathway towards a premium market. The first tier would focus on setting minimum market-access requirements, in order to level the playing field and exclude the worst performers from EU market access. A second tier of instruments is therefore needed to reward those who exceed baseline standards through targeted, conditional incentives.