This chapter examines policies to enhance the environmental sustainability of mining and the circular economy in the sector, with a focus on ten European Union regions. It examines the sector’s environmental impacts, reviews current mitigation policies and good practices, and highlights strategies to align the European Union’s mineral strategic autonomy with environmental objectives, focusing on circularity.
Enhancing Regional Mining Ecosystems in the European Union
Securing the Green Transition and Supply of Mineral Raw Materials
Abstract
Mining inherently generates environmental impacts but is also strictly regulated by European Union (EU) environmental legislation to protect human health and the environment. With the European Union’s growing need for strategic mineral autonomy, increasing environmentally sustainable mining in the European Union is essential.
Environmental impacts are mine specific, with mining waste and water pollution being major concerns. In countries with a strong mining industry, mining waste constitutes the vast majority of total waste generation (close to 80% in Finland and Sweden in 2022), with over half a tonne of waste generated per tonne of mineral extracted.
Most mining waste is non-hazardous (over 95%), but the increasing share of hazardous waste, especially from metal mining, can be an issue in some regions.
While mining can also be an important source of local industrial pollutants released into water bodies, especially of toxic and long-lasting heavy metals, other industries (such as metal, wood and paper, and energy production) often contribute equally or more, highlighting the need for assessing the cumulative environmental impacts when new mining permits are granted.
Mining has become a minor source of local air pollution, with significant declines in greenhouse gas (GHG) and acidifying gases emissions intensities between 2004 and 2022 in the five EU countries studied.
Despite EU policy efforts, challenges remain to better align mining with environmental goals, including better management of conflicting land-use interests, improving environmental permitting, increasing the use of circular economy practices and strengthening environmental monitoring and enforcement.
To help address the above key challenges, this report recommends, among others:
Balancing mining and nature conservation interests for land. Land-use planning instruments are powerful tools for steering decisions on mining. Strengthened collaboration and early participation of local governments in environmental assessments and project discussions may help align conflicting interests and find agreeable, nature-friendly solutions.
Supporting faster, and more predictable, environmental permitting without compromising environmental standards. Improved inter-agency co‑ordination and capacity could help address complex institutional and procedural permitting frameworks. Clearer guidelines for environmental permit applications may reduce the uncertainty around permitting.
Developing new policies to encourage circular economy approaches in mining, including the recovery of useful minerals from “waste materials”. Circular economy opportunities along the entire mining cycle can help design out some waste, optimise production and increase mining waste recovery. Industry-business-academia partnerships are key to circular innovation and knowledge transfer. Integrating circularity for mining in regional development strategies helps bring focus and funding.
Improving environmental monitoring, law enforcement and trust in government. Community-led environmental monitoring and remediation of legacy mines can help enforce environmental law and enhance trust in government’s ability to address non-compliance.
Mining is an industrial activity that involves the extraction of natural resources, which inherently generates an environmental footprint. The environmental impacts of mining occur throughout the entire value chain, from relatively limited effects during the exploration phase to more significant impacts during extraction, transformation, transport and waste management phases. The impacts vary based on the type of mine site and the mineral being extracted. Adopting the best available practices in planning, operation and rehabilitation can help reduce these impacts.
Raw materials are essential for developing industries aimed at phasing out fossil fuels to meet climate goals. Mining also provides key resources for other economic sectors and technological advancements that drive economic growth and social development. While reducing global demand for energy and resources, along with increasing supply of secondary materials, can ease the need for primary raw materials and, hence, new mining, these efforts alone will not be sufficient to meet climate goals. Therefore, ensuring environmentally sustainable mining will be crucial.
This chapter examines policies to enhance the environmental sustainability of mining. It starts by outlining the different environmental impacts of mining, with a focus on the ten EU regions studied. It then describes current policies and good practices at the different levels of government for managing these impacts. Finally, it proposes strategies to help align the strategic autonomy for minerals with environmental goals, with focus on circular economy approaches.
Materials extraction and processing generates environmental impacts
Even when stringently and effectively regulated, raw materials extraction and materials use is associated with environmental impacts, including acidification, eutrophication, land-use changes, as well as water, human and terrestrial ecotoxicity (OECD, 2019[1]).
As with other industrial activities that significantly impact the environment, careful regulation and management are essential to balance human needs with environmental impacts.
Environmental impacts vary by mining stage, type of mining and material processing
Environmental impacts depend on the material extracted, the extraction and processing activities, geology, local environmental characteristics and the mining stage. Key mining stages include exploration, plants construction, exploitation and closure, with most impacts occurring during construction and production (de Haes and Lucas, 2024[2]). Even minor exploration can damage habitats if mismanaged, and improper closure can cause long-term environmental harm, such as water contamination and acidic runoff in sulphidic mining areas (Mononen et al., 2022[3]). Such environmental impacts span beyond the mining area, leaving a larger environmental footprint.
The type of mining and processing activity depends on the material and geology. Opencast mining tends to have a larger, more permanent land impact and generates more waste. Underground mining, while less impactful on land clearing, can cause land subsidence and typically requires more energy, leading to higher GHG emissions (de Haes and Lucas, 2024[2]). Processing metallic materials is often water-intensive and releases more toxic substances than processing non-metallic materials.
The ore type determines the processing route and associated impacts. Hydrometallurgy, used for oxide metals like aluminium and lithium, requires large amounts of water and chemicals. Pyrometallurgy, used for sulphide metals, requires significant energy for heat. Ore grades also influence the energy, water and chemicals needed for extraction.
The rising demand for raw materials may lead to worsening environmental impacts
With continued growth in population and economic output, pressures on resources and the environment are increasing. For instance, the extraction of non-metallic minerals in the European Union grew by 19% between 2014 and 2023, totalling around 3.4 billion tonnes in 2023 (Eurostat, 2024[4]). Similarly, metal ore extraction in the European Union rose by 23% during the same period, reaching approximately 234 million tonnes in 2023. Notably, metal ore extraction in Finland and Spain nearly tripled between 2014 and 2023 (Eurostat, 2024[4]). More material extraction and processing may lead to increasing environmental impacts, even if these activities are stringently and effectively regulated.
Mining waste is a key environmental concern
Mining is a heavily waste-intensive industry
The mining and quarrying sector generates significant volumes of waste materials, including overburden, tailings, drainage water and slag, which can have significant environmental impacts if not managed properly. In EU member states with a strong and active mining sector, such as Finland and Sweden, the sector is by far the largest source of domestically generated waste. Mining waste can reach 80% (or more) of total waste on an annual basis (Figure 4.1).
Note: Mining and quarrying sector refers to Category B in the Statistical Classification of Economic Activities in the European Community (NACE) Rev. 2 activity classification. Domestic extraction includes metal ores and non-metallic minerals. The share of mining waste to extraction is calculated as the ratio of tonnes of mining waste generated to tonnes of extracted raw material (metal ores and non-metallic minerals) in a given year.
Source: Calculations based on data from Eurostat (2024[5]), Generation of Waste by Waste Category, Hazardousness and NACE Rev. 2 Activity, https://ec.europa.eu/eurostat/databrowser/view/env_wasgen__custom_12486228/default/table?lang=en&page=time:2020; Eurostat (2024[4]), Material Flow Accounts, https://ec.europa.eu/eurostat/databrowser/view/env_ac_mfa/default/table?lang=en&category=env.env_mrp.
The share of mining waste to the amount of material extracted can also be high. For example, in Sweden, since 2010, for every tonne of extracted raw material in a given year, more than half a tonne of waste was generated. In mining, typically only a small share of extracted material becomes a refined unit of a mineral commodity, while the rest becomes byproduct or waste. This so-called rock-to-metal (or mineral) ratio varies across mineral commodities and mining operations. Precious metals like gold have rock-to-metal ratios in the range of 1 tonne of metal for every 100 000 million tonnes of material extracted (105–106), while iron ore and aluminium are in the order of 1 tonne of metal for every 10 tonnes of material extracted (Nassar et al., 2022[6]). With increasing domestic extraction rates and declining ore grades, more waste per tonne of material extracted is likely to be generated.
The available data on the volume of waste in active, inactive and closed tailings storage facilities suggest that the volumes are likely to increase in the future according to the Global Tailings Portal.1 Between 2020 and 2025, the expected increase in volume is estimated to be at least 67% in Finland, 34% in Sweden, 27% in Portugal and 24% in Spain, compared to around 25% worldwide (Global Tailings Portal, 2024[7]). The tailings, which have increased drastically in volume over the last century, are commonly identified as the most important environmental risk for most mining operations (Mononen et al., 2022[3]). For example, in Finland, certain consulted stakeholders question the quality of tailings dams and the sufficiency of related legislation and standards, considering past problems of leakages.
The amount of waste generated for each unit of gross value added (GVA) provides some insights into the sector’s waste intensity. While not all economic value the sector generates may be captured by this metric, the waste intensity of the mining sector is still extremely high compared to other sectors. For example, in Greece, the sector’s waste intensity peaked in 2016, generating around 69 000 tonnes of waste per million euros (MEUR) of GVA (Figure 4.2).
Note: Waste intensity calculated as the ratio of the amount of waste generated (in tonnes) to the value of GVA generated by a sector in a given year.
Source: Calculations based on data from Eurostat (2024[5]), Generation of Waste by Waste Category, Hazardousness and NACE Rev. 2 Activity, https://ec.europa.eu/eurostat/databrowser/view/env_wasgen__custom_12486228/default/table?lang=en&page=time:2020; Eurostat (2024[4]), Material Flow Accounts, https://ec.europa.eu/eurostat/databrowser/view/env_ac_mfa/default/table?lang=en&category=env.env_mrp.
For comparison, the construction sector, also a sector generating important waste volumes, generated only 212 tonnes per MEUR GVA in the same year in Greece. In Finland, the waste intensity of mining peaked in 2016, totalling more than 147 000 tonnes of waste per MEUR GVA, compared to 1 100 tonnes per MEUR GVA by the construction sector (based on Eurostat (2024[5]; 2024[8])). However, the waste intensity fell sharply between 2016 and 2022 in all five countries studied and the EU more broadly. This decreasing trend is a sign of sector’s increasing GVA in Finland, Spain and Sweden, potentially linked to increasing mineral prices and metal extraction rates. In Greece and Portugal, the decrease in waste intensity is linked to reduced waste generation, potentially linked to lower extraction rates (e.g. phasing out lignite production in Greece).
The increasing share of hazardous mining waste can be an issue in some regions
According to the available data, more than 95% of mining waste generated in the European Union and the 5 countries involved in this study is non-hazardous waste (Eurostat, 2024[5]). This is not surprising as mining and quarrying produce large amounts of overburden soil, rock and sand, typically classified as non-hazardous wastes. Most waste is sent for landfill disposal (Eurostat, 2023[9]).2 However, the share of hazardous mining waste to total hazardous waste has been increasing, with almost all hazardous waste coming from the mining sector in some countries, such as Finland (Figure 4.3).
Source: Calculations based on data from Eurostat (2024[5]), Generation of Waste by Waste Category, Hazardousness and NACE Rev. 2 Activity, https://ec.europa.eu/eurostat/databrowser/view/env_wasgen__custom_12486228/default/table?lang=en&page=time:2020.
Hazardous waste, in particular from metallic mining, can contain significant levels of dangerous substances, including heavy metals. Their poor waste management can result in heavy metal contamination of soils and water and the presence of toxic elements in the environment. For example, red mud from aluminium production, contributing to increased natural radioactivity, and acid mine drainage (the outflow of acidic water from metal mines) from sulphide mines are major sources of soil pollution (de Haes and Lucas, 2024[2]). Since environmental impacts of mining are largely local, the increasing share of hazardous mining waste in some regions may have significant local impact on the environment.
Regional level waste data are not readily available, making it difficult to assess local impacts
While some waste data are available at the national level, regional level information on the environmental impacts of mining is scarce and not systematically collected and disseminated. This report relied on facility-level environmental data reported to the European Industrial Emissions Portal (E-IEP), formerly called the European Pollutant Release and Transfer Register (E-PRTR), to provide unique insights into the regional environmental impacts of mining (see Box 4.1). In the European Union, according to the Industrial Emissions Portal Regulation (IEPR) (formerly the E-PRTR Regulation), most facilities in the mineral industry, including mining facilities, are obliged to report on significant pollutant releases to water, air, land and off-site transfers. EU member states must ensure that this information is collected and publicly available through the E-IEP.
Regarding waste impacts, only waste sent “off site” for waste treatment is reported to the database, namely transfers of hazardous waste exceeding 2 tonnes per year per facility and non-hazardous waste exceeding 2 000 tonnes per year per facility. This implies that: i) the data from some smaller facilities is not covered by the database; and ii) the database does not provide a full picture of the waste impacts as only a minor share of mining waste is transferred off site in practice.
The available data in the database confirm that very few off-site waste transfers have been reported by facilities in the mineral industry active in the ten EU regions studied. This makes it difficult to draw any conclusions on regional waste impacts from this data.
The E-IEP contains information on significant pollutant releases to the environment (air, water and land)1 as well as off-site transfers of waste and pollutants in wastewater from Europe’s largest industrial facilities, which undertake activities within the scope of the Industrial Emissions Portal Regulation (IEPR) (formerly the E-PRTR Regulation) (E-IEP, 2024[10]). Facilities in sectors covered by the IEPR have an obligation to report on emissions and off-site transfers above certain thresholds as specified in the regulation. The mineral industry, including facilities active in underground and opencast mining and quarrying, as well as the production and processing of metals industry, have such obligations. The E‑PRTR was replaced by the IEPR in May 2024. Under the new regulation, new sectors will be subject to the reporting obligations and industrial facilities will also need to start reporting on their use of resources.
The database provides annual data at the industrial‑facility level as well as aggregated data at the national level for the period between 2007 and 2022 (database version July 2024). This report utilised facility-level data on locations, specifically “cities”, to assign each facility to a region within the five countries studied. Subsequently, environmental impacts related to air, water and waste (off-site waste transfers) were aggregated at the regional level and analysed. Such an analysis appears to be the first of its kind for European mining.
The database has its limitations, including data gaps and the scope being restricted to larger facilities in some cases. For example, all facilities active in underground mining must report on pollutant releases and off-site transfers above certain thresholds. This is not the case for opencast mining as only facilities with an extractive operation surface area beyond 25 hectares must do so. For some countries, limited information is available for the sector, which may be due to under-reporting.
Note: 1. Releases to land from the mineral industry are not available for Finland, Spain and Sweden and are scarce for Greece and Portugal, therefore could not be analysed in this report.
Source: E-IEP (2024[10]), Homepage, https://industry.eea.europa.eu/ (accessed on 23 August 2024).
Key water risks: Water pollution, hydrologic changes and water scarcity
Mining activities also impact the quality of above and underground water bodies. The impacts usually depend on the type of mined ore, the enrichment method used and the water management implemented on site (Mononen et al., 2022[3]). Land-use changes from construction can cause hydrologic changes, erosion, acid mine drainage and changes in surface runoff, groundwater and general water quality. Exploitation and production processes can require significant amounts of water, leading to water scarcity risks in the area as well as contamination to water bodies through wastewater discharges and accidental leaks (e.g. from tailings pond failure) (Mononen et al., 2022[3]). Mining also releases pollutants to water bodies. Emissions of nitrogen can cause eutrophication and releases of heavy metals are of a more toxic nature, often difficult to abate by wastewater treatment infrastructure (EEA, 2024[11]).
To provide insights into the impacts of mining on water bodies in the ten EU regions studied, this report analysed the available data on pollutant releases into water from the mineral industry in the E-IEP. While this database has its limitations (see Box 4.1), it is the main source of comparable environmental data to measure industrial pollution at the subnational level in the European Union. Additionally, water pollutant releases show only a partial picture of water risks from mining.
Available data suggest that while mining is not always the main source of local water pollutants, its releases can be highly toxic
In the five countries concerned, facilities in the mineral industry reported relatively low quantities of emissions into water bodies beyond the limits specified in the IEPR compared to some other industries. The analysis of available data on industrial water pollutants indicates that mining is often not the primary source of water pollutants in the ten regions studied, but it can be. Key factors include the type and scale of mining as well as the presence of other industries in the region. For example, in Lapland, Finland, the paper and wood production and processing industry releases by far the highest share of significant industrial pollutants into water bodies (between 90% and 97% on an annual basis) because of high quantities of chlorides and total organic carbon. In Kainuu, Finland, the paper and wood production and processing industry was the main source of industrial releases to water bodies in the region in 2007 and 2008 (accounting for around 80% of annual emissions). As of 2014, the mineral industry has become the single source of significant industrial releases to water bodies in the region.
The main water pollutants from the mineral industry in the regions are heavy metals, including zinc, nickel, arsenic, mercury and their compounds as well as nitrogen (underground mining) and fluorides (opencast mining). Heavy metal releases into water are especially concerning as these pollutants can cause detrimental long-term impacts on the environment and human health because of their toxic nature.
Examining the releases of heavy metals into water across the five Finnish regions studied reveals significant differences across the regions (Figure 4.4). Central Ostrobothnia, Finland, has no facilities in the mineral industry reporting to the E-IEP as this is not a region with active mines. All emissions to water in the region from the last decade come from the metal production and processing sector. In North Karelia, Finland, heavy metal releases to water bodies (and water emissions in general) have significantly decreased in the last decade, possibly due to the changing nature of industries in the region. Both Lapland and Oulu, Finland, have additional industrial activities releasing heavy metals (and other pollutants) to water, with the mining industry contributing to a significant share of those industrial releases. The existence of multiple industries in a region reinforces the importance of conducting cumulative impact assessments.
Note: In Kainuu, facilities in other sectors did not report any significant emissions as of 2014 and, therefore, are not included in the graph.
Source: OECD calculations based on data from the European Industrial Emissions Portal (2024[10]).
Mining is typically not the main culprit behind industrial emissions to air
Mining in the European Union and the five countries studied is responsible only for a minor share of air emissions according to available data. Carbon dioxide (CO2) emissions drive the air emissions levels, but the emissions of acidifying gases, including nitrogen oxides (NOx), sulphur oxides (SOx) and ammonia (NH3), are also important air pollutants from mining activities. The production of ceramics releases additional pollutants into air, including fluorine, chlorine and other inorganic compounds, and the production of cement clinker in rotary kilns mercury (E-IEP, 2024[10]).
According to the air emissions data in Eurostat, the mining and quarrying sector was responsible for around 1-2% of total annual GHG emissions and for around 0-2% of total annual acidifying gases between 2008 and 2022 in the European Union and the five countries concerned (2024[12]). The mining industry in the European Union and the five countries concerned followed a decarbonisation trend, with air emissions intensities significantly declining over time. Figure 4.5 presents the trends in air emissions intensities per euro of GVA between 2008 and 2022 for Portugal (a decrease of around 45% for mining) and Spain (a decrease of around 90%). Finland, Greece and Sweden followed similar trends.
Source: Calculations based on data from Eurostat (2024[12]), Air Emissions Accounts by NACE Rev. 2 Activity, https://ec.europa.eu/eurostat/databrowser/view/env_ac_ainah_r2__custom_13495839/default/table?lang=en.
Mining is also not the main source of air pollution according to available data
Many of the ten EU regions studied do not have facilities in the mineral industry that report on significant air pollutant releases to the E-IEP. From the five Finnish regions studied, only facilities in Lapland and Oulu reported releases to air from the mineral industry (Figure 4.6). In both regions, emissions of air pollutants from the mineral industry represented only a very minor share (maximum 5%) of the region’s total industrial emissions to air. In Andalusia, Spain, the share of emissions to air from the mineral industry is higher (between 20-30%) than in Finland, yet the majority of these emissions come from the production of cement clinker in rotary kilns rather than from extraction activities.
Industry’s contribution to total industrial emissions to air in the region
Source: Calculations based on data from E-IEP (2024[10]), Homepage, https://industry.eea.europa.eu/ (accessed on 23 August 2024).
Other impacts: Land-use change and impacts on biodiversity and ecosystems
Mining causes significant land-use change and impacts on biodiversity and ecosystems that need to be managed well. Currently, these impacts cannot be quantified at the subnational level due to a lack of good quality and comparable data.
Mining activities, along with the necessary infrastructure – including mining pits, side-stone heaps, soil removal masses, tailings area, landfill sites, buildings and surrounding infrastructure (roads, water and electricity) – directly destroy habitats and displace fauna (Mononen et al., 2022[3]). This may lead to habitat, vegetation and biodiversity loss (or changes), erosion, deforestation alteration of landscapes and soil profiles, and increases in the risk of landslides (Mononen et al., 2022[3]). Mining areas are often enclosed or fenced off, limiting other land uses and hindering the natural movement of animals and their migration routes. This leads to direct habitat loss and fragmentation, where large tracts of land are divided into smaller, isolated patches. As a result, many species that depend on continuous habitat connections can be adversely affected (Shanmukha et al., 2024[13]). The construction stage brings about the most significant changes in the landscape, vegetation and hydrology (Kauppila, 2015[14]). The consequences of tailings storage facilities failure can be catastrophic, including the release of large quantities of hazardous materials and the contamination of aquatic ecosystems at long distances, and the growing occurrence of these storage facilities inside or near protected areas poses substantial risks to biodiversity (Aska et al., 2023[15]). However, to date, impacts on biodiversity are largely under-reported, and legacy and cumulative impacts of mining are poorly understood (de Haes and Lucas, 2024[2]; Aska et al., 2023[15]).
Governments have enacted environmental laws and policies to manage environmental impacts of industrial activities, including mining. Environmental impacts in principle reflect the tolerated levels of pollution as specified in environmental permits, if complied with. The environmental permit regulates how mining can affect the environment. Additionally, the mining industry has adopted voluntary practices and standards to comply with legislation and integrate environmental concerns into their business operations. Circular economy approaches, sometimes mainstreamed into sectoral policies, can also help reduce environmental impacts associated with materials use and minimise mining waste.
Allocation of environmental responsibilities between the different levels of government
In the European Union, the environment is a shared responsibility between the union and its member states. Both can legislate and adopt environmental laws. The European Union must exercise its responsibilities according to the principles of proportionality (i.e. EU actions cannot exceed what is necessary) and subsidiarity (i.e. it may only intervene if it is able to act more effectively than member states at their national and subnational levels). This implies that EU member states still have a relatively large degree of discretion in how and at which level of government they regulate industrial activities in order to protect the environment. National and subnational environmental laws will, therefore, vary.
While environmental regulation related to mining is primarily a national competence in the five countries studied, this is not the case for Spain, where some regions, including Andalusia, have a large degree of autonomy. Moreover, EU regions develop their regional policies, plans and funding priorities. Through these policies, they play an important role in providing enabling conditions for enhancing environmental sustainability in the region’s mineral supply chains.
Environmental legislation and policy
The EU environmental acquis provides an overall direction for national legislation
The EU environmental acquis plays an important role in European mining. It is based on the principles of precaution, prevention, rectifying pollution at source and the so-called “polluter pays principle”. The overall aim is to limit significant damage to the environment and the surrounding ecosystems, and prevent and control the negative environmental impacts of mining.
Currently, there is not a single standalone piece of EU environmental legislation for mining. Rather, the EU environmental acquis impacts mining (and other industrial) activities directly or indirectly through several EU directives and regulations (Table 4.1). EU member states transpose the directives into their national legislation, with EU legislation providing the overall direction for possibly diverse national rules.
EU environmental permitting legislation directly impacts European mining practices. While EU member states regulate environmental permitting through a mix of EU and national laws, the EU legislation sets a framework of conditions and processes that member states must follow. For instance, the Industrial and Livestock Rearing Emissions Directive (IED 2.0) (former Industrial Emissions Directive), the Extractive Waste Directive as well as the Nature Directives all encompass requirements and procedures for environmental permitting. These different EU directives provide guidelines on how these procedures and assessments should be conducted. The environmental permitting of mining projects typically requires an environmental impact assessment (EIA) to evaluate the potential environmental effects of a project before a permit is granted due to mining’s likely significant impact on the environment. The EIA, with its procedure for public engagement in the process, has the largest impact on permitting decisions according to consulted mining industry.
Additionally, each EU member state has its own national competent authorities responsible for managing the permitting process. These authorities can adopt different permitting schemes and procedures, including the involvement of subnational governments in decision-making. This significantly impacts the actual permitting decisions. A discussion of environmental permitting as well as a comparison of environmental permitting procedures in the five countries studied can be found in the next section.
Regional policies also support environmentally sustainable mining
Subnational governments, with a few exceptions that include Andalusia, do not tend to have legislative competences to manage the environmental impacts of mining. Andalusia has exclusive competence to regulate the management of protected natural areas and shares competence with the central government to regulate the management of natural resources and mining.
Regions can also promote environmentally sustainable mining through their regional strategies and plans. The review of regional strategies in the ten EU regions studied suggests that regions tend to advocate, although more broadly, environmental sustainability and circularity in mining within their regional smart specialisation and circular economy strategies (see also Box 4.6). For example, the Lapland Agreement 2022-2025 and Lapland’s Sustainable Smart Specialisation Strategy 2023-2027 promote circular economy, digitalisation and innovation in the region, including for the mining and minerals value chain, as key means to achieve the green transition. The Smart Specialisation Strategy of Centro, Portugal, takes a more general approach by discussing the circular economy more broadly in the context of sustainable use of natural resources, digitalisation and innovation, decarbonisation and the development of sustainable industrial solutions. Digitalisation and innovation are especially key for transforming the industry into a less polluting one. Novel environmentally friendly exploration and exploitation technologies can help reduce the environmental footprint of mining. Optimising industry’s processes and improving the recycling of mining waste can further increase material efficiency and minimise waste.
A rather unique approach is the Regional Mining Strategy of Andalusia 2030, which aims to leverage the extractive industry to sustainably meet the growing demand for raw materials, support the digital and ecological transition, enhance industrial symbiosis, promote continuous digitalisation and ensure the recovery and development of key sectors in alignment with European Union’s climate and economic goals.
Several of the regions studied have developed regional circular economy strategies (for example, Centro, Central Greece and North Karelia). While they promote circular economy practices and business models across industries relevant to the region, the strategies do not specifically target the mining sector, nor do they include specific goals and actions for the sector. In Central Greece, the strategy appears to be largely unknown to mineral producing companies, according to consulted stakeholders. The less targeted approach and a lack of clear goals for the mining sector may hinder the effective implementation of these strategies.
Soft law practices: Industry efforts through corporate social responsibility and due diligence
Besides top-down regulatory approaches to address the environmental impacts of mining, industry has also stepped up its efforts through voluntary instruments and the adoption of due diligence standards. In addition to the physical risks of environmental damage, failure to identify and manage environmental, social and governance (ESG) risks through due diligence can damage a mining company’s reputation, deter investments and limit market access where due diligence requirements cannot be met (IEA, 2023[16]). On the contrary, companies that effectively adopt and demonstrate alignment with circular economy practices may be better able to maintain their social licence to operate and their attractiveness to investors in an increasingly scrutinised industry (McCarney, 2021[17]).
Several initiatives, including guidelines and standards for sustainable and responsible mining, exist and the landscape is rapidly expanding. Examples of industry-led initiatives include the Consolidated Mining Standard Initiative, which brings together four leading voluntary standards into a single, unified standard.3 Multi-stakeholder initiatives include the Extractive Industries Transparency Initiative standard and the Global Reporting Initiative mining standard. The OECD has also developed due diligence guidance for the responsible supply of minerals from conflict-affected areas, as well as specific guidelines for addressing environmental risks in mineral supply chains (Box 4.2).
A good example from the five countries studied is the Towards Sustainable Mining (TSM) standard in Finland, which was adopted in 2014 by adapting the Mining Association of Canada’s TSM protocols to Finland’s national context. TSM helps monitor and develop the mining industry’s sustainability practices and includes 11 protocols focused on 2 core areas: communities and people; and environmental stewardship. Each year, mining sites use TSM to report on the protocols and their indicators, which also form the basis for external audits conducted every three years. While this standard has been a reliable guideline and benchmark for assessing the economic, environmental and social impacts of mining projects in Finland, it has suffered from a lack of engagement from environmental and local stakeholder groups, diminishing its wider acceptability and credibility.
The OECD Handbook on Environmental Due Diligence in Mineral Supply Chains has been developed to help companies integrate environmental considerations into their mineral supply chain due diligence procedures. It introduces environmental issues in the upstream segment of mineral supply chains (from extraction to transformation) and helps both upstream and downstream companies to address environmental risks in their due diligence efforts, directing them to useful resources. The handbook also encourages companies to consider opportunities to integrate circular economy principles into their business models, stressing the importance of understanding and managing the environmental risks associated with both primary and secondary material supplies.
Source: OECD (2023[18]), Handbook on Environmental Due Diligence in Mineral Supply Chains, https://doi.org/10.1787/cef843bf-en.
The role of circular economy approaches in advancing the green transition in mining
Circular economy policies are gaining traction in sustainable mining. One example is the EU Critical Raw Materials Act (CRMA), which sets targets for domestic consumption of critical raw materials to be met through recycling (described in more detail in Chapter 3). Other examples include national and regional circular economy policies and plans, targeting the mining industry.
A circular economy is an economy in which material value is maximised and maintained for as long as possible, whilst material inputs and waste are minimised. The transition to a more circular economy may be achieved through three main mechanisms: i) closing material loops, for instance, by shifting to recycled materials and reusing them in production; ii) slowing down material flows by increasing the lifespan of products; and iii) narrowing material flows through a more efficient use of natural resources, materials and products (McCarthy, Dellink and Bibas, 2018[19]).
Non-metallic minerals and metals are central to the circular economy transition. They are key material inputs into other sectors of the economy, including manufacturing, construction and energy, driving the green transition. Besides their key role in these applications, minerals present properties of durability, recyclability and adaptability which make them apt for closed-loop, circular production systems (Young, Barreto and Chovan, 2021[20]). This offers many opportunities to keep the value of metals and minerals in the economy for as long as possible while minimising waste throughout the entire mineral and metal production value chain (Figure 4.7).
Source: IMA-Europe (2023[21]), Technical Working Group.
Extractive industries already seek strategies to maximise resource use and minimise waste. In general, these are adopted to optimise profits by limiting waste management costs and recovering value from waste materials (de la Torre de Palacios and Espí Rodríguez, 2022[22]). Nevertheless, adopting circular economy practices in mining offers additional business opportunities. For example, they can help reduce upstream emissions and ESG risks, secure a social licence to operate for mining companies, and facilitate access to export markets with more stringent due diligence requirements (Toledano, Brauch and Arnold, 2023[23]). Re-mining and processing of tailings containing non-recovered metals can become economically and technologically feasible over time.
Circular economy approaches in the mining sector can be diverse and apply to different stages along the mine lifecycle
Existing literature and discussions with industry suggest that current circular economy efforts focus on increasing the recycling and recovery rates of mining waste and improving water efficiency in production. While resource recovery (recycling) is a key circular economy business model in mining, other business models can be implemented at different stages of the mine lifecycle:
Mine planning and design: Applying circular economy approaches to mining begins at the design stage, where they are most effective (de la Torre de Palacios and Espí Rodríguez, 2022[22]). Opportunities for minimising waste, recovering materials and increasing resource efficiency identified at this stage will impact all stages of the mine lifecycle, from the mine site’s construction to its operation and closure. Vertical integration of services, from material extraction to the collection and recycling of end-of-life products containing those extracted materials, may also be planned for.4
Mine site construction: At the mine site construction stage, actions can be directed at more circular supply and use of the physical infrastructure, equipment and assets of the company. This may involve procuring more circular (e.g. refurbished, used or bearing recycled content) equipment or sharing, renting and prolonging the lifespan of assets.
Mine site operation (including extraction and processing): During mine operation, measures may be directed at more circular management of natural resources that are extracted and used in mining and processing operations. This may include optimising the efficiency of primary resource extraction through digitalisation and automation and extracting embedded value from mining and processing waste as well as using local off-site resources.
Mine closure: Reaching the end of the mine’s productive life, efforts may be made to reutilise or recover mining waste to ensure maximum value of existing resources is recovered before closure. After closure, rehabilitation and repurposing plans are implemented to avoid long-term negative impacts on the environment, biodiversity and human health and provide an opportunity to create new value for local communities.
Cross-cutting measures: All along the mine lifecycle, data collection can be instrumental to facilitate circular economy practices in mining, such as mapping valuable materials in mining waste, conducting lifecycle and economic feasibility analyses as well as identifying new opportunities to improve resource efficiency in production.
Table 4.2 below summarises the different circular economy opportunities in mining and provides some examples of concrete practices.
Note: LCA = Life cycle analysis.
Sources: Based on Young, A., M. Barreto and K. Chovan (2021[20]), Towards a Circular Economy Approach to Mining Operations. Key Concepts, Drivers and Opportunities, Enviro Integration Strategies Inc., MERG; McCarney, G. (2021[17]), Primary Materials in the Emerging Circular Economy: Implications for Upstream Resource Producers and Primary Material Exporters, https://institute.smartprosperity.ca/publication/emerging-circular-economy; de la Torre de Palacios, L. and J. Espí Rodríguez (2022[22]), “In mining, not everything is a circular economy: Case studies from recent mining projects in Iberia”, https://doi.org/10.1016/J.RESOURPOL.2022.102798; Vesa, J. (2021[24]), Kaivosten sivukivien ja rikastushiekan hyödyntämismahdollisuudet : Esiselvitys, Työ- ja elinkeinoministeriö; and stakeholder consultations.
Aligning the goals of environmental and mineral policies is challenging. Strategic autonomy for minerals aims to ensure a secure and sustainable supply of raw materials by increasing mineral extraction and processing, causing environmental pressures. Environmental policies and legislation aim to prevent and manage such pressures by restricting or strictly controlling the activities that cause them.
In the European Union, mining is a heavily regulated industrial activity by environmental laws (see Table 4.1). In practice, this means that not all mining projects are approved, and those that are, must prevent, to the extent possible, the environmental impacts they cause and manage them in accordance with the environmental permits they obtain from the competent authorities.
Moreover, views and decisions made by different levels of government involved in project approval processes may not always be aligned, contributing to polarisation and unpredictable permitting decisions.
This lack of co-ordination and alignment across sectors and government levels has been identified as an obstacle to advancing investments into sustainable mining projects in EU regions.
Despite efforts to address this issue at the EU and national levels, several challenges remain.
This report identified four common challenges for advancing environmentally sustainable mining projects in the ten EU regions studied based on desk research and stakeholder consultation during case study visits. They are linked to the different stages of the mining project lifecycle, from project start to its completion and monitoring.
Key identified challenges include:
1. Balancing land-use interests: mining and nature conservation.
2. Supporting faster and more predictable environmental permitting without compromising environmental standards.
3. Developing new policy options for circularity, including easier recovery of “waste materials” while ensuring the environment is protected.
4. Improving environmental monitoring, law enforcement and trust in government, considering limited resources.
Balancing land-use interests: Mining and nature conservation
All levels of government use spatial and land-use plans as instruments to shape land use (OECD, 2017[25]). Land-use plans aim to prescribe particular land uses for specific locations.
Balancing competing mining and nature conservation interests for land-use is a common challenge. The location of deposits determines the area suitable for mining, which may coincide with land designated for nature conservation.
The designation of land for nature conservation does not automatically preclude the use of land for other purposes, including exploration and mining activities, even when the protected land concerns Natura 2000 sites (EU Habitats Directive).
In fact, it is not uncommon that mining is found on or in vicinity of land designated for nature conservation, both often located in rural areas (del Mármol and Vaccaro, 2020[26]). For example, in Lapland, the main nature-based livelihoods – mining, forestry, reindeer herding and tourism – co-exist within many environmentally protected areas, including two national parks and several Natura 2000 sites (Figure 4.8).
A lack of co-ordination and communication between government levels may lead to misaligned and unpredictable land-use choices
Ensuring that national interests are represented in local land-use policies while maintaining a level of flexibility at lower levels of government is a common challenge (OECD, 2017[25]). When mining competes for land use with nature conservation, different levels of government use a mix of policies and tools to address such conflicts. The decisions are often based on different grounds and information sources, including EIAs, community consultation or economic ground. Formal rules may not be consistently interpreted and applied. This may lead to misaligned decisions, increasing the risk of unpredictable outcomes.
Indicating location of towns, tourism resorts, environmentally protected areas and existing mines
Note: PA: protected areas. The map is from 2021 and may not reflect current mining projects.
Source: Carvalho, J. et al. (2021[27]), “A look at European practices for identifying mineral resources that deserve to be safeguarded in land-use planning”, https://doi.org/10.1016/j.resourpol.
The EU nature protection legislation provides the overall direction for land-use decisions when mining projects are likely to exhibit significant impacts on nature protected sites. The Habitats Directive outlines the legal obligations for competent authorities of member states to appropriately assess the likely significant effects of mining projects on nature protected areas, including, if appropriate, by obtaining the opinion of the general public (the so-called Appropriate Assessment). In case of a negative assessment, the member state concerned may still allow the project to proceed “for imperative reasons of overriding public interest, including those of a social or economic nature” (Article 6(4) EU Habitats Directive). In that case, compensatory measures must be taken, and the European Commission informed.
These provisions leave a large degree of discretion to member states to implement the required procedures, including the extent to which the general public is consulted, and make key decisions regarding the approval of a mining project when in conflict with nature protection interests.
At the national level, countries can fall back on top-down approaches to help address potential land-use conflicts between mining and nature conservation. Nature protection legislation can prioritise certain interests in specific areas and/or establish stricter rules for allowing mining projects to operate in or close to such areas. For example, in Finland, the Nature Conservation Act (2023) introduced new requirements for exploration works and existing mining operations. New updates include the prohibition of exploration works in certain nature conservation areas and the consideration of endangered species in permit evaluations and land-use planning. In Sweden, the Swedish Environmental Code includes provisions according to which valuable mineral deposits can be declared deposits of national interest and, therefore, become protected from measures that may prevent or be prejudicial to their exploitation (SGU, 2020[28]). Different responsibilities may be found in federal countries.
At the same time, countries adopt bottom-up approaches where subnational governments are strongly involved in decisions that concern their land.
At the regional level, the regional authorities can prioritise certain land-use interests over others through regional development strategies and land-use plans, which set out the desired long-term vision and objectives for the region. The regional land-use plans guide municipal land-use planning and steer decisions that concern the entire region, including transportation services, energy infrastructure and landscapes.
Local level governments provide the final layer of land-use choices through their municipal land‑use planning instruments, which may be the decisive one. This leads to land-use conflicts being ultimately resolved on community level, increasing the pressure on municipal governments to decide on project outcomes. For example, in Portugal, permits for extraction can only be granted in areas that have been designated for extraction within the zoning of municipal land-use plans. If a valuable mineral deposit is discovered outside these designated areas, its exploitation will not be allowed because the mining concession or quarry licence will not be granted. Similarly in Finland and Sweden, for a mining project to go ahead, municipalities need to zone the area for mining in their municipal plans and issue a land-use planning and building permit. Even for minerals of national interest, the Swedish Environmental Code does not guarantee a complete protection of mining interests as municipalities may use their land-use plans to support other interests. In case of a land-use conflict, the courts or relevant authorities will ultimately decide on which interest prevails (Carvalho et al., 2021[27]).
This implies that municipalities possess de facto a veto power over decisions made at the national level, while they may face information asymmetry if not properly involved from early on in the process.
The concept of ecological compensation as a mitigation measure is not yet widely applied
Ecological compensation, often referred to as biodiversity offsetting, is a strategy employed to counterbalance adverse environmental impacts caused by development projects, including mining (Peinemann, 2016[29]). Many governments use this approach to achieve No Net Loss or even a Net Gain of biodiversity by restoring, creating, or protecting habitats to compensate for the ecological harm caused (Sonter et al., 2020[30]). It is typically a measure at the end of the mitigation hierarchy of measures, following prevention and restoration.
Ecological compensation is gaining traction across the European Union (for example, Finland implements voluntary ecological compensation through its updated Nature Conservation Act [2023]). However, its implementation is at an early development stage due to its many legal and practical obstacles (Blicharska et al., 2022[31]). A recent Swedish study also highlighted the risk that ecological compensation impacts the decision-making process and can make it easier to obtain environmental permits for hazardous activities that would otherwise not be granted (Blicharska et al., 2022[31]).
While ecological compensation can be required by law, for example for Natura 2000 sites, municipalities and other actors may conduct ecological compensation that is not required based on a legal process, i.e. voluntary ecological compensation (Blicharska et al., 2022[31]).
A wider adoption of well-designed, and broadly accepted, ecological compensation measures could be an effective way to advance environmentally sustainable mining practices. However, governments may need to rethink their regulatory frameworks to ensure that it is well implemented and thereby contributing to aligning mining and nature conservation interests.
Supporting faster and more predictable environmental permitting in line with environmental standards
Environmental permitting is a key policy instrument to regulate the environmental impacts of mining operations (and industrial activities in general). Mining activities, namely exploitation, generally require an environmental permit due to the activity’s likely significant impact on the environment. The environmental permit determines how the operations will be performed (throughout the mine’s lifecycle, from mine design to mine closure, rehabilitation and post-closure monitoring), and which pollutant concentrations will be allowed. Environmental permits de facto set the level of environmental impact of individual mining projects that is accepted by public authorities and, hence, have been subject to rigorous assessments.
In the European Union, mining companies and competent authorities must navigate a complex set of EU and national rules for environmental permitting as mining affects a large range of environmental assets, and therefore is subject to multiple thematic environmental laws. Several EU directives (including the IED 2.0, the EIA Directive, the Nature Directives and the Extractive Waste Directive) outline the procedural and documentary requirements to obtain a permit, while at the same time giving member states a sufficient degree of discretion to define national modalities. The next chapter will further discuss the co‑ordination across government entities for permitting.
The process typically includes EIAs of the planned activity, identification of mitigation measures as well as consultation of all interested parties (i.e. the EIA process). It also involves navigating through a complex institutional framework of competent authorities responsible for the different environmental fields and permits, and local governments involved in decision-making through land-use planning. While environmental standards can also trigger innovations that benefit the company and improve its competitiveness, permitting in general is considered lengthy and cumbersome.
Companies need to apply for a new or modified environmental permit each time they make a substantial change to its operations to ensure the impacts of this change are reflected in permits. In practice, this can create a disincentive in some cases for companies to adopt new processes and technologies during mining operations, and hence innovate. Permits for mine closure and management of mining waste require a similar process.
Table 4.3 compares the environmental permitting procedures across the five countries studied, illustrating some of the key similarities and differences. In all five countries, two or more environmental competent authorities are involved in environmental permitting, and EIA and public consultation is required for exploitation permits. Key differences tend to be around the role of regions and municipalities in the permitting process. While municipalities have a de facto veto right in Finland, Portugal (for exploration) and Sweden through municipal land-use plans, their opinion does not have a binding effect for example in Greece. Nevertheless, the Greek competent authorities are extremely reluctant to grant a permit in case of strong local opposition. Additionally, the role of regions is more significant in federal (or quasi-federal) countries, such as in Spain, where regions become the competent authorities for granting permits and overseeing the EIA process (e.g. Andalusia).
The following sub-sections dive deeper into a discussion of the common challenges that environmental permitting poses in the five countries studied.
Sources: Regional and national profiles, local expert input and sources included in the table.
The EIA and subsequent public appeals in courts are identified as key bottlenecks
The EIA process is a crucial step in the approval of mining projects, particularly for sensitive areas or larger-scale projects, but it is also the most challenging one. It involves the development of EIA reports that aim to identify the key environmental impacts of mining activities as well as opportunities to address these, and engages the public in the decision-making process. While these steps are necessary to ensure environmental interests are protected, they contribute to the length and unpredictable nature of environmental permitting, possibly hindering new mining investments.
Some jurisdictions have stricter requirements for EIAs than others. For example, in Finland, the interpretation of the Environmental Protection Act has become stricter over recent years, Recent updates include enhanced public participation in EIA processes, with public hearings, mandatory digitalisation of EIAs to ensure transparency and a focus on cumulative impacts, i.e. assessing the combined effects of different projects in a region. New mining projects will be considered alongside existing emissions producing activity in the region for cumulative impacts. Some companies, especially with regard to new projects, struggle to cover all certainties/analysis required for the permitting process, submitting application with information gaps, particularly regarding best available techniques and closure process. This may delay the approvals process.
The continuously increasing requirements and uncertainties regarding the necessary scope and level of detail of the assessments contribute to the challenges related to EIAs. Mining companies must often address broad-ranging issues in EIA reports, resulting in documents that have become extensively lengthy. A 1 800-page‑long EIA report (531 pages without annexes) prepared by Suhanko Arctic Platinum for a large-scale project in Lapland in 2014 is an example of this. In 2022, the project submitted another EIA report (around 670 pages with annexes) for the mine’s discharge pipeline, leading to the need for extended processing times by the competent authorities.
The public consultation element of the EIA process, namely the possibility to appeal the decisions of competent authorities in court (or another impartial body) helps ensure public interests are considered. Yet the appeals process may need to be improved in order not to unnecessarily delay ultimate decisions and increase the predictability of outcomes. For instance, in Finland, appeals can be made at several stages of the permitting process. In Sweden, there is no standard procedure to analyse appeals. The appeals are decided on a case-by-case basis, which may add to the length and cost of permitting procedures. Moreover, in Greece, opposition from local communities through increased appeals at later stages in the permitting process has often been the cause of the significant delays in the development of new mining projects (EC, 2020[39]).
The complexity of EIA assessments also presents a challenge for governments, especially those at the subnational level. Local governments may not be fully informed or have difficulty understanding and communicating the findings from such studies, which may impact their decisions. Processing complex assessments and appeals in a timely manner also requires adequate human resources in competent authorities. Several countries studied have been facing such human resources challenges. As a response, governments have made efforts to streamline environmental permitting procedures to improve their efficiency, including by developing EIA guidelines (e.g. Finland) and digital systems for environmental permitting (e.g. Portugal).
Better co-ordination across competent authorities would benefit administrative efficiency
Finland
The environmental permitting and supervising authorities have been separated on a state level. The Regional State Administrative Agencies (AVI Agencies), established as regional level organs of the state, are in charge of basic public services and environmental permits. Centres for Economic Development, Transport and the Environment (ELY Centres), located in the regions, are acting as EAI supervisory authorities and approval organisations. Currently, there is no clear body for overall co‑ordination and prioritisation across agencies and processes, leading to communication challenges between the two bodies to coherently address revisions and updates to the EIA and environmental permitting. This can make the whole process lengthy and complex. To address this issue, a merger of the two agencies is planned for 2026 to improve efficiency and reduce information gaps.
Spain
Multiple environmental administrations oversee the environmental permitting process. The limited co‑ordination across national and regional ministries and agencies, and a lack of a single co‑ordinating body to prioritise and facilitate decisions makes processing environmental permits challenging.
Portugal
Inter-agency co‑ordination challenges exist mainly with regard to communication between the Portuguese Environmental Agency and the Directorate General for Energy and Geology as well as with other environmental institutions (e.g. the Institute for Nature Conservation and Forests) to address revisions and updates to EIAs in a coherent and timely manner.
Communication and guidance to navigate and understand the process is often insufficient
Despite ongoing efforts to provide up-to-date information and guidance, companies, but also public authorities, face challenges to understand and navigate through the complex and highly technical environmental permitting process for mining. Key issues relate to uncertainties around the information to be submitted, particularly for EIAs and the inter-relations between different permitting processes. The scope of issues to be analysed and the expected level of detail to be provided at each stage of the permitting process is often unclear. It is often uncertain whether and which permit must be obtained first to enable the granting of another permit. One example is the exemption permit under Finland’s Nature Conservation Act in projects that also require environmental and water management permits. Even the authorities may lack clear guidelines on how to resolve such issues.
Other issues include a lack of transparency regarding the timelines of the regulatory process and how the legal rules will be interpreted in specific cases. In countries with multiple competent authorities responsible for environmental permitting, it is not always clear which institution to address for complaints and rectification requests.
Resolving communication and guidance issues could help reduce the length of permitting processes and uncertainty for applicants and stakeholders regarding how to proceed within this process.
Developing new policy options for circularity and easier recovery of “waste materials”
Mining projects face waste management challenges. Mining generates significant volumes of waste but also heavily contaminated waste that may be toxic for human health and the environment, requiring especially careful management. To protect the environment and human health from the risks posed by improper waste management, waste legislation introduces strict rules and procedures, particularly for hazardous waste. At the same time, those rules and procedures may make it less economically feasible for companies to recover mining waste, and hence contribute to environmentally sustainable outcomes.
Other approaches, namely the circular economy, which aims to minimise waste and maximise the use of materials in the economy for as long as possible, can contribute to better environmental outcomes. While interest in circularity in mining is gaining traction, these approaches are yet to be scaled up across the industry.
Waste legislation, while needed, can create obstacles to scaling up mining waste recovery
Implementation of waste legislation can be administratively burdensome and costly, but aims to generate environmental benefits for society at large. At the EU level, the Waste Framework Directive defines and classifies wastes, and sets requirements for waste management, including permits and waste management plans. The EU Extractive Waste Directive targets mining waste. Member states need to put in place measures to prevent or reduce as far as possible any adverse effects on the environment from the management of mining waste. The operator needs to draw up a waste management plan and all waste facilities require a permit and financial guarantee.
Waste legislation can lead to conflicting incentives for mining companies. On the one hand, the legislation creates incentives for waste reduction, as less waste becomes subjected to waste obligations, reducing waste management costs. On the other, waste management obligations and permitting procedures for waste facilities may create disincentives to put in place innovative processes to recover and reuse valuable material that is classified as waste, if costly.
Leftover material from extraction and processing classified as waste cannot be directly reused,: it must first go for treatment to a waste facility with a valid permit, where it can be landfilled, incinerated or recycled. In contrary, material classified as byproduct is not subject to such treatment, and can be reused. Under certain conditions, certain materials may merit to be reclassified to byproducts to facilitate their reuse. The introduction of the so-called “end-of-waste” criteria into the EU and national waste legislation under which a material ceases to be waste and becomes a byproduct, provides an example of such conditions.
Reclassifying certain mining waste streams to byproducts has been limited so far. In some regions such as in Andalusia, most mining waste comes from historical mining sites from a time when specific waste legislation was not in place. Nowadays, companies tend to analyse and classify the mining waste they generate for potential future uses. More recently, the European Commission has prepared a set of end-of-waste criteria for priority waste streams: iron, steel and aluminium scrap; and glass cullet and copper scrap. However, the development of such criteria for additional waste streams by member states has been limited and the process of reclassifying waste to byproducts on a case-by-case basis can be administratively burdensome, and thus often not pursued by companies.
Additionally, when too lengthy, the permitting process of waste facilities may create a disincentive to innovate. New processes or technology may be needed to recover valuable materials from mining waste. Since any major changes to the processes or the introduction of new technology typically require a new environmental permit or reopening of valid environmental permits, this can sometimes limit the adoption of innovative approaches throughout the project duration.
The circular economy and its full potential in mining is not sufficiently deployed
The interest in improving the circularity in the mining value chain is gaining traction as a means to reduce environmental impacts associated with materials use and minimise waste. Circular economy innovations can help develop technologies to extract minerals from tailings, reducing the tailings’ environmental risks to surrounding ecosystems and local communities. Digitalisation and automation can make mining more resource efficient, minimising waste. Developing circular economy practices could also reduce demand for primary minerals and therefore new mining.
Despite these potential benefits, circularity in mining is yet to be fully understood and more widely applied. The existing practices tend to relate to digitalisation and automation efforts as these align more closely with business interests, such as process optimisation, and have therefore advanced more rapidly.
Governments and companies face several challenges for scaling up circular economy practices. These include (see also Box 4.4):
A lack of understanding of the full range of circular economy opportunities, from mine design to mining waste recovery and reuse. Circularity in mining is often understood as mining waste and water recycling. While better utilisation of sidestreams and recycling may be among the most pressing issues to address, some challenges are difficult to address (for example, the issue of transporting large quantities of waste materials, such as waste rock, for reuse and recovery in the construction sector for instance, across long distances).
Companies may not have sufficient incentives to overcome the barriers they face to improving the circularity of their operations. Traditionally, the core business of mining companies is material extraction and processing. Waste recovery and the adoption of new circular economy business models to transform the way the industry manages their assets and resources requires additional investments, skills and expertise.
Consulted stakeholders identified the following challenges:
Existing data gaps regarding the recovery potential of valuable materials from tailings and environmental impact of mining activities.
Investment and infrastructure requirements (the valorisation of tailings is in many cases not commercially viable as these projects are high-risk, technology-intensive and costly).
The cost competitiveness of using primary versus recycled (or other recovered) materials.
A lack of harmonised standards and definitions for “waste” and “resources”, and the need to declassify certain waste to byproducts to facilitate its reuse.
Limited co‑operation between research, vocational training and the private sector to translate innovation projects into business opportunities, and to develop tailored innovative solutions for the recovery of mining waste.
Difficult access to finance for entrepreneurs and companies in the mining industry.
Long distances between remote areas, leading to costly transportation of waste materials relative to the value of materials being transported. Long distances for transportation also generate larger GHG emissions, creating trade-offs with emission reduction goals.
The literature further identifies a need to develop a clearer vision of the transition to a circular economy in mining and processing of metals and minerals and of its practical implications. In this regard, further research is needed on, among others:
the value of upstream waste materials
common standards for recycled materials, including clear rules for trade
innovation in product design and waste recovery.
Source: Adapted from McCarney, G. (2021[17]), Primary Materials in the Emerging Circular Economy: Implications for Upstream Resource Producers and Primary Material Exporters, https://institute.smartprosperity.ca/publication/emerging-circular-economy and based on information received from interviews with mining companies in Centro, Lapland and North Karelia.
Improving environmental data, law enforcement and trust in government
Gaps in environmental data and its communication may hamper informed decision-making
Significant gaps in environmental data and information remain across various areas (Box 4.5), posing challenges for governments to develop effective policies. There are gaps in waste characterisation as well as mapping of mineral potential in tailings. Subnational governments and local communities may also find it difficult to comprehend and communicate the environmental impacts of mining, hampering their ability to make informed decisions about mining projects.
While there is interest in improving environmental data and information, it entails additional resources, which the governments do not necessarily have.
Cross-country comparable environmental data related to the environmental impacts of mining typically exist at the national level; however, even these data have some limitations. Subnational level environmental data are not systematically collected and reported.
Significant data gaps exist especially regarding:
Regional impacts of mining on land and biodiversity, as well as waste generation and treatment. Emissions to air and water are reported under the IEPR by larger mining companies operating in the European Union. However, the database has its own limitations, including data gaps due to a lack of reporting and incomplete coverage of mining facilities (Box 4.1).
Cumulative impacts of industrial activities concentrated in a region. Many regions have multiple industries active in the region, possibly causing significant cumulative environmental impacts on local communities. Currently these impacts are not well understood and/or communicated.
Quantities and characteristics of available minerals in tailings storage facilities in closed and active mines. To support the recovery of mining waste will require an estimation of the quantities and concentrations of materials contained in mining waste, as well as an assessment of their technical and economic recoverability. Under the new CRMA, operators have an obligation to submit such information by November 2026.
A lack of trust in government’s ability to monitor and enforce environmental laws often generates opposition to mining
Governments at different levels also encounter difficulties in implementing and enforcing environmental legislation. In line with the EU IED 2.0 and IEPR, national competent authorities must continuously monitor the performance of industrial facilities and ensure compliance with the permit conditions, making monitoring data available to the public. The EU Extractive Waste Directive also introduces obligations for member states and operators related to mining waste management, including post-closure monitoring for as long as may be required by the competent authority. The directive also regulates closure and after-closure procedures.
There appears to be a general sentiment among certain stakeholders that governments do not systematically enforce relevant environmental legislation or are unable to do so due to capacity constraints. The fact that mine sites can be dispersed across the region aggravates the situation (e.g. highlighted by Greece and Portugal).
These enforcement gaps tend to erode communities’ trust in public institutions, often leading to resistance to mining. For example, in Greece and Portugal, the issue of legacy mines and the lack of trust in government’s ability to adequately monitor a mine’s performance was highlighted as a key factor behind community resistance to opening new mines. Implementation gaps related to the EU Extractive Waste Directive are a key concern for some Finnish stakeholders.
Towards improved alignment between strategic mineral autonomy and environmental goals
Governments at different levels as well as industry have various opportunities to help address the identified common challenges and thus help align strategic mineral autonomy with environmental goals. Several examples of good practices illustrate the opportunities in the sections below.
Better balancing mining and nature conservation interests
Strengthening participation of local governments in environmental assessments and the development of mitigation measures from early on
A stronger collaboration between the different levels of government and industry on land-use planning and environmental assessment can reduce information asymmetry regarding the environmental impacts of mining and help align conflicting land-use interests.
Some experiences suggest that local governments are more likely to issue a negative opinion on nature protection grounds if they have not been properly informed and involved in the mining projects from early on. Other examples demonstrate that with proper involvement and co-operation between all parties concerned in environmental assessments, the assessments can be an instrument to find innovative ways to modify the project so as to prevent significant environmental impacts, and thereby avoiding permit rejections (EC, 2016[40]). The inclusion of local governments whose sites are affected in similar discussions is likely to bring positive outcomes.
Regions, acting as the intermediaries between national and local authorities, have a major role to play in bringing the different parties together, enhancing their co-operation and information sharing.
Regions with significant mining activity have been building expertise in balancing mining and nature conservation interests. This is the case, for example, in Lapland, where over 30% of the land is designated for nature conservation. To identify and reconcile potential conflicts, local educational institutions offer sustainability training programmes, developed in collaboration with mining companies, focused on developing expertise to build social acceptance at the local level by investing in early-stage engagement.
In Centro, there are also positive experiences of municipalities leveraging mining for local development and balancing it with protection of natural areas. For example, Porto de Mós has limestone quarries that are located within a national park and partly in the Natura 2000 network. The local land-use plan helped delineate new areas for extraction, preserving protection of key environmental assets by prioritising certain areas for nature conservation while considering the economic importance of the dimension sector in the area. Similarly, geological and environmental mapping studies for the Cabeça Veada site, located in the Serra de Aire e Candeeiros Natural Park (Natura 2000 site), helped developed a municipal land-use plan that protects exceptional natural habitats, fauna and flora, while at the same time designates areas where mining can take place with or without compensation measures (Carvalho and Cancela, 2018[41]).
Improving the environmental quality and mitigation measures of mining projects
Improving the environmental quality of mining projects and adopting additional mitigation measures can also help address conflicting land-use interests. Governments at different levels as well as industry can rely on a set of guidelines developed by the European Commission for that purpose. Governments can also introduce measures that would support the adoption of well-designed ecological compensation, as a complementary mitigation measure to prevention and restoration.
A methodological guidance on the application of the EU Habitats Directive helps interested parties apply the provisions of the directive, including how to approach the assessments and potential derogations in case of negative assessments (EC, 2021[42]). The European Commission has also published detailed sector guidelines on undertaking mining activities in accordance with Natura 2000 requirements (EC, 2011[43]). The guidelines contain examples of good practices on aligning mining with nature conservation goals and show how some mining projects can ultimately be beneficial to biodiversity by providing highly quality ecological niches. Regions have a role to play in promoting such guidelines to help municipalities negotiate contracts with mining companies and make informed land-use decisions.
Mining companies can also help align their goals with nature conservation through mitigation and compensatory measures. Mitigation measures aim to minimise or even prevent adverse effects of mining on the nature conservation site, while compensatory measures intend to compensate for the effects of mining on habitats and species, i.e. by replacing or improving an existing habitat/species (EC, 2011[43]). For example, in Lapland, mining company Anglo American has implemented a significant voluntary ecological compensation measure in connection with its Sakatti mining project in Sodankylä. The company purchased 2 910 hectares of forest from the Inari joint forest for EUR 10.4 million with the intention of protecting the area under the Nature Conservation Act.5 This is the largest voluntary ecological compensation project in Finland to date. Experience with ecological compensation in Sweden shows that there is a need for: i) better integration into the entire decision-making process; ii) a holistic approach to preservation of biodiversity and ecosystem services; as well as iii) a national level standard for ecological compensation, including the sharing of good and bad practices (Blicharska et al., 2022[31]). Other countries may have similar needs that would need to be addressed primarily at the national level.
Improving the environmental permitting processes
Countries have introduced, or plan to introduce, measures to help streamline and improve the environmental permitting process for mining (Table 4.4).
Measures aimed at improving administrative efficiency
Governments at different levels have introduced the following strategies to help improve the administrative efficiency of environmental permitting (see also Table 4.4):
Improving inter-agency co‑ordination: Most initiatives have focused on restructuring the institutional framework of environmental competent authorities to improve inter-agency co‑ordination and therefore reduce processing times of environmental permits. The recently adopted EU CRMA asks member states to provide all critical raw materials projects with a one‑stop shop for all relevant permits. This is likely to rapidly impact national permitting procedures.
Prioritising certain projects: Prioritising certain projects during permitting is another strategy being tested (including the strategic projects under the EU CRMA). The Finnish experience suggests that this measure can be effective only if the timelines are binding and if other agencies involved in permitting have longer timelines. Countries may also have laws that facilitate permitting of projects of national interest (e.g. Projects of Potential National Interest scheme in Portugal).
Digitalising and simultaneously processing permits: Experience with digital systems more broadly to exchange documents and information between competent authorities and companies has led to significantly reduced processing times for permit applications. Several countries have such systems already in use for environmental permitting (e.g. Finland, Portugal), while drawbacks of such systems (e.g. a lack of flexibility) are reported for large-scale mining projects. Digitalising the permitting procedure is likely to take on due to the new IED, introducing an obligation for member states to establish an electronic permit (e-permit) system by 2035. Simultaneous processing of permits is another strategy being employed by several countries to reduce processing times.
Adequate human resources in competent environmental authorities are also crucial for reducing permitting processing times. Policy officers approving EIAs and permits face high pressure given the responsibility to understand the different environmental risks of the project. To support the decisions of public officers, the involvement of knowledge institutions (e.g. the national geological institutes or a research organisation) could become crucial.
Despite efforts to increase administrative efficiency of environmental permitting, certain aspects of the environmental permitting process may be difficult to expedite. For instance, EIAs require developing and assessing complex studies that need time.
Measures aimed at improving the predictability of environmental permitting outcome
Uncertain environmental permitting outcomes can affect the competitiveness of mining companies and create negative spill-over effects on the often-smaller firms that are subcontractors to the larger mining companies (Söderholm, 2023[44]). This may influence the overall regional development that the smaller sub-contractors are part of.
Governments can help reduce uncertain environmental permitting outcomes by:
Establishing clear guidelines for companies and sharing good practices: Guidelines for companies could improve the quality of applications and streamline permitting processes by offering clear guidance. For instance, they can also help clarify how the legal rules will be interpreted in specific cases. The European Commission has produced guidelines related to the EIA and Natura 2000 sites (EC, 2011[43]). Guidance material also exists at the national and regional levels. The Finnish environmental supervising authority (ELY Centres) is developing guidelines for all regional permitting authorities and companies, including guidelines for closure permits and checklists for best available techniques. While guidelines may help clarify the complex permit framework and reduce the duration of the application process, they are unlikely to solve the permitting issue alone.
Establishing/supporting centres that provide relevant advice and services to companies: Specialised technology and testing centres can help companies prepare environmental permit applications and implement environmental solutions.
Improving engagement with municipalities and companies: A stronger involvement of local governments from early on in mining projects could help find agreeable solutions to mitigate the negative environmental impacts of these projects on local communities.
Improving the processing of appeals: A systematic approach to processing appeals in government agencies and courts may be useful since different appeals may repeat similar concerns for different projects.
Source: Regional and national profiles developed for this study, responses from local experts.
Improving the management of mining waste and increasing the circularity in mining
Addressing the issue of mining waste and improving the circularity in mining are likely to need a holistic approach. This will require a combination of measures to: i) better understand and integrate the circular economy concept in government strategies for mining; ii) develop policy options that help address obstacles arising from waste legislation; and iii) provide an enabling framework and stronger incentives for companies to scale up the circularity in the mining value chain.
Understanding and integrating the circular economy for mining in government strategies
Circular economy opportunities exist along the entire mining lifecycle. Governments typically define the circular economy, its goals and measures in their circular economy strategies. However, these often do not specifically target the mining sector but address circularity in key industries more broadly.
In order to effectively promote a transition towards more circular practices in mining, the strategies at different levels of government may need to clearly define a circular economy approach for mining, as well as outline priorities and examples of more concrete actions for the mining industry to achieve. They must also be coherent with relevant EU and national policies, targets and goals, i.e. the recovery of critical raw materials.
Governments can develop dedicated circular economy strategies for mining (e.g. Spain), integrate mining as a key sector in their broader strategies and plans (e.g. Lapland) or integrate circular economy in dedicated mining strategies (e.g. Central Ostrobothnia) (see Box 4.6). Integrating circular economy within regional smart specialisation strategies (e.g. as is the case in Lapland) can be particularly impactful as these strategies are associated with funding.
A good example of a dedicated circular economy strategy for mining is the Spanish Circular Economy Strategy 2030 for the extractive industry. In Greece, the efficient use of raw materials, including recycling of tailings waste, is one of five axes in the National Policy for the Strategic Planning and Exploration of Mineral Resources (2012). However, this strategy has not been formally adopted, and hence implemented. The Regional Strategy for Extractive Industries 2019-2025 of Central Ostrobothnia provides a good example of how circular economy can be integrated into regional strategies for mining.
Finland’s national circular economy strategy and legislation
Finland’s mining sector, generating the vast majority of total waste, has been a key player in the development of the Finnish Road Map to a Circular Economy 2016-2025. The sector is also a key player in the currently ongoing reform of the Finnish Waste Act into a new Circular Economy Act for Finland, expected to come into force in the coming years.
The Lapland Agreement and the Smart Specialisation Strategy of Lapland
The Lapland Agreement 2022-2025 and Lapland’s Sustainable Smart Specialisation Strategy 2023‑2027 emphasise environmentally sustainable mining and the circular economy as key drivers of the green transition. The Lapland Agreement serves as a roadmap for regional development, highlighting sustainable success in the world’s cleanest and Finland’s most international region. The agreement emphasises collaboration among municipalities, businesses, government authorities, ministries, universities and other stakeholders to promote sustainable development.
Lapland’s Sustainable Smart Specialisation Strategy views the circular economy as a foundation for sustainable growth. Its goal is to strengthen Lapland’s role as a pioneer in the circular economy and to support businesses in transitioning to more resource-efficient operations. In the mining sector, this includes broader utilisation of extracted materials and recycling of process water. The strategy also highlights the importance of digitalisation and innovation in transforming industry into a less polluting sector.
The Central Ostrobothnia’s Regional Programme 2022-25 and its Regional Strategy for Extractive Industries 2019-2025
The regional programme aims to guide development funding, regional planning and spatial planning with a focus on sustainable mining practices. Goals include expanding mining activities, enhancing renewable energy usage and integrating circular economy principles, highlighting the importance of sustainable practices and innovation in mining to drive regional economic growth. The Regional Strategy for Extractive Industries 2019-2025 implements mining-related objectives from the Central Ostrobothnia Regional Programme, focusing on improving the linkages between mining and regional development.
Spain’s Circular Economy Strategy 2030 for the extractive industry
The strategy establishes the foundation for promoting circular economy production and consumption models in mining. In line with the strategy, mining regulations must ensure environmental protection and boost restoration and recovery efforts, including the reuse of tailing dumps, existing mine shafts and restoration of abandoned mining waste facilities. The strategy also promotes research activities for the exploitation and treatment of mining waste. It is also in line with the Spanish Road Map for the Sustainable Management of Mineral Raw Materials, which aims to reinforce the strategic autonomy and security of supply of key raw materials for the energy transition and digital development. The roadmap includes four strategic orientations: i) efficiency and circular economy; ii) sustainable management of mineral raw materials; iii) the security of supply and sustainable imports; and iv) strategies for the energy transition.
Developing policy options to help address obstacles arising from waste legislation
Obstacles arising from waste legislation may be best avoided if this legislation does not apply. Waste legislation does not apply to products and materials that are not waste.
Governments at different levels may therefore want to focus on developing policy options to prevent waste or avoid waste materials becoming waste, rather than loosening the environmental safeguards provided by waste legislation. Waste prevention, which is the highest priority in waste hierarchy, includes actions that reduce waste quantity through strict avoidance, source reduction and direct reuse of products and materials prior to them becoming wastes. In the context of mining, this may include more circular management of extracted materials, as well as natural resources and physical assets used in mining. For example, water and energy efficiency strategies may reduce water and energy consumption (strict avoidance). Extending the lifetime of products, machinery and infrastructure used delays the creation of waste flows (strict avoidance). Optimisation, innovation and digitalisation strategies may reduce the amount of waste generated per tonne of material extracted (source reduction). Industrial symbiosis, whereby byproducts from mining are reused as material inputs by another industry, and vice versa, reduces demand for primary materials (direct reuse). Government may support such practices through their waste management and circular economy strategies and plans. Box 4.7 provides examples of good practices on waste prevention from industry in the different regions studied that can serve as inspiration for policy. A compendium of good practices in the industrial mineral sector across Europe has been also prepared by IMA-Europe (2018[45]).
Governments at the national level may also consider policy options to declassify waste materials to byproducts, if end-of-waste criteria are fulfilled. This may require national programmes for waste characterisation to better understand waste characteristics and impacts of such wastes on the environment and human health. The end-of-waste criteria have so far been developed at the EU level for certain metal scrap, but other waste streams may be considered in the future.
Waste prevention through optimisation, innovation and digitalisation
Centro, Portugal
The region is home to several companies in the ceramics and stone industry (e.g. Mota Ceramic Solutions, Solancis) that can be considered national champions in aligning business interests with innovative practices that support waste prevention (and circular economy). Their investments in digitalisation and automation of the operations, as well as vertical integration (offering services from product design to logistics and, in some cases, even the collection of end-of-life products containing the materials that they have extracted) have helped them to optimise production and minimise waste. For example, Solancis has digitalised its entire production to improve the material efficiency of its product design, the traceability of materials and the reparability of finished products (each piece of a finished product has a digital stamp) leading to less waste being generated.
Extending the lifetime of old mines by repurposing them for other activities
Alentejo, Portugal
The mining rehabilitation projects in Lousal and São Domingos illustrate how former mines can be transformed into research and tourism hubs, providing additional economic value to local communities while utilising existing physical assets of old mines.
Oulu, Finland
The repurposed Pyhäsalmi Mine, the oldest copper and zinc mine in Finland and the deepest active hard rock mine in the European Union (at 1 444 metres), is now part of the Callio Pyhäjärvi concept. The mine’s infrastructure has been used for various scientific and commercial purposes, offering unparalleled facilities for innovative projects and training. The University of Oulu is involved in research and innovation through Callio Lab.
If mining waste cannot be prevented, governments may want to focus on developing policy options for improving the efficiency of permitting procedures for waste facilities (see the previous section on environmental permitting). Faster permitting procedures may help increase the adoption of innovative recycling technologies as the administrative burden of changing technological processes may decrease through faster, but still environmentally stringent, permitting.
Strengthening incentives for companies to adopt circular economy practices
Once the circular economy approach for mining is clearly outlined and understood, governments may need to strengthen incentives for companies to scale up such practices, driving innovation.
Governments can incentivise the adoption of circular economy practices in mining through regulatory, economic and information instruments. These instruments may want to focus on increasing the supply of and demand for recycled materials, which is relevant to mining as mining waste is a key feedstock for secondary supply of minerals. Governments may also focus on removing government subsidies for primary metal production as a tool to stimulate secondary material supply by increasing the price competitiveness of secondary materials (McCarthy and Börkey, 2018[46]).
Examples of existing instruments that support secondary mineral supply include the following:
Regulatory instruments: metal recycling targets (EU CRMA), mandatory minimum recycled content requirements for products containing metals (EU Battery Regulation sets such targets for lead, lithium, nickel and cobalt in industrial, electric vehicles and lighting or ignition batteries), eco‑design requirements for selected products (iron and steel, aluminium and information and communication technology products and other electronics are included as prioritised products in the context of the EU Ecodesign for Sustainable Products Regulation).
Economic instruments: virgin material taxes on aggregates have been applied in Scandinavian countries, green public procurement has been more widely used for construction works to stimulate more environmentally sustainable construction, and direct subsidies through grants and loans have been provided to recycling projects.
Information instruments: digital product passport for batteries, which will apply to electric vehicle batteries, light means of transport batteries and industrial batteries placed on the EU market as of February 2027 (EU Battery Regulation). Each battery will have a quick response (QR) code providing access to a list of detailed information about the battery composition, such as its recycled content (of lead, lithium, nickel and cobalt).
Recycled content requirements for certain minerals may become relevant in the future also for procured electronic and electrical products in the context of green public procurement. New fiscal advantages (e.g. tax credits, corporate income tax reductions) and direct subsidies (grants) may also become more widely used to stimulate secondary mineral production. Information and labelling systems for critical raw materials are also gaining global attention, including traceability standards.
Governments will need to evaluate the extent to which mining waste recovery should be supported. This includes environmental but also economic assessments. It will require waste characterisation and mapping of available volumes of valuable minerals in tailings in the regions (of both existing and closed mines) and assessing their potential recovery, including economic viability. To ensure mine waste recovery and recycling does not lead to adverse environmental effects, evaluation of the environmental and economic impacts of recycling and reusing these materials will also be needed. Such methods include, for example, life cycle assessment (LCA), strategic environmental and social assessment and the environmental and social cost benefit analysis. However, scientific environmental assessment methods for metals, such as LCA, have not been streamlined yet (de Haes and Lucas, 2024[2]).
Recycling targets and requirements under the EU CRMA
Regulatory incentives have been recently introduced for certain materials through the CRMA. It establishes a target to supply 25% of annual consumption of critical raw materials in the European Union from recycling. It also adds new obligations for operators and member states regarding the management of mining waste. In addition to submitting waste management plans, operators will need to provide the competent authorities with a preliminary economic assessment study regarding the potential recovery of critical raw materials from the extractive waste stored in the facility and from the extractive volume prior to it becoming waste. Member states will need to implement measures to promote the recovery of critical raw materials from extractive waste, in particular from closed extractive waste facilities.
Finland’s tax on mining activities
While Finland’s new tax on mining activities is not an environmental tax aimed at reducing extraction activities, it may incentivise secondary material production as a secondary effect (as it increases the cost of primary production).
Finland’s new Mining Tax Act, entered into force in January 2024, introduces a tax for mining companies, aiming to increase fiscal revenue for municipalities to compensate for the negative externalities caused by mining activities. The tax applies to all minerals mined in Finland, including those processed within the country and those exported for processing abroad. Specifically, the tax is set at 0.6% on the taxable value of the metal contained in ore for metallic minerals. For non-metallic minerals, the tax is set at EUR 0.2 per tonne based on the quantity of minerals extracted. Of the total tax revenues, 60% is allocated to the municipalities where the mines are located, while the remaining 40% goes to the state.
Providing an enabling framework for improved circularity and mining waste management
Subnational governments have a crucial role to play in providing an enabling framework for regional development through their regional strategies, programmes and plans, which set priorities and steer long-term development within the region.
They can advance the circular economy in mining by:
Supporting research and development (R&D) and circular innovation (through funding), including innovative recovery and recycling technologies for mining waste, mining waste characterisation studies, waste minimisation technologies for material extraction and processing as well as digital technologies for more resource efficiency.
Stimulating the business environment and entrepreneurship to advance circular economy business models and services (by attracting companies to the region).
Helping to build needed partnerships between various stakeholders and knowledge sharing through circular economy hubs, platforms and industrial symbiosis networks.
Co‑ordinating the co‑operation and communication between different stakeholders at the national and local levels.
Several regional and local initiatives in the ten regions studied already promote circular economy practices, including the recovery of mining waste (Box 4.9). These, however, need to be scaled up across EU mining regions and projects operating in silos need to be connected. A key opportunity is to build stronger partnerships between industry and academia to leverage the research and knowledge of universities. For example, the University of Coimbra, Portugal, has several innovation and circular economy related projects, including on mineralising potential (bioleaching) for high-technology metals and the development of an innovative and sustainable strategy for bio-recovery of critical raw materials from mining waste. The University of Aveiro also has several projects which link innovation and the mining sector. These include a project on training young researchers in developing circular solutions for waste sludge and its reprocessing as well as a project on re-valorisation and risk reduction of mining tailings. Since any innovative solutions must be mine specific, the involvement of mining companies with researchers and entrepreneurs is crucial for the development of collaborative circular-economy-related projects and partnerships.
Lapland, Finland
Lapland is home to several regional networks and hubs that connect and help companies to develop and implement circular economy solutions. A key regional player is Digipolis Circular Economy Centre, which was established by Digipolis (Kemi Technology Park), the town of Kemi and the Lapland University of Applied Sciences, in partnership with Finnish innovation fund Sitra in 2017. The centre runs two important regional initiatives: i) the Arctic Industry and Circular Economy Cluster, which supports smart specialisation in Lapland; and ii) the network of eco-industrial parks, which promotes industrial circular economy, including industrial symbiosis, across Finland.
The Lapland University of Applied Sciences is a key player in the country for developing artificial intelligence and digital technology solutions for the mining sector. Automation and robots used by the sector improve safety but also material efficiency, leading to less waste generated. For example, drilling robots used in underground mining operations are more precise.
North Karelia, Finland
In North Karelia, institutional support for circular mining practices exists primarily through the allocation of significant EU funding to mining innovation and circular economy projects. Further efforts go to building national and international collaboration partnerships. The region’s pilot plant and research laboratories GTK Mintec offers studies and solutions for tailings management, re-mining (processing) and process water recyclability. It hosts a unique pilot plant for material processing and mining waste analysis as well as a processing pilot plant for water management.
In North Karelia, regional business agency Business Joensuu is in the process of establishing a hub of service providers, the so‑called Outokumpu Mining Hub, that could help companies implement circular solutions. This is a platform that aims to connect companies and SMEs to the innovative GTK Mintec ecosystem to provide services in the recovery of valuable raw materials from mining waste and water treatment and recycling. The initiative is a co-operation network between Business Joensuu, the Geological Survey of Finland (GTK) and companies.
Centro, Portugal
The Associação Cluster Portugal Mineral Resources also plays an important role in the innovation ecosystem in the Centro region as it connects industry and academia with the aim to advance efforts towards innovation and circular activities. The cluster is also co‑ordinating a mobilising agenda included in the national Recovery and Resilience Plan, which has supported funding for value-added industrial projects (e.g. contributing to automation, digitalisation and decarbonisation).
Central Greece
In Central Greece, the technical university ecosystem in Athens is also piloting practical innovation projects on circular economy for the mining sector.
Örebro, Sweden
In Örebro, the IUC Industrihubb provides companies with initiatives, training and networks as well as industrial development projects with EU, national and regional co-financing. These projects currently span across activities such as automation, digitalisation, robotisation and strategic skills supply. While the initiative is not currently focused on the mining sector, there is significant potential for Industrihubb to partner with Örebro University and mining companies in the region to deliver skills and technology support to SMEs in the mining sector.
Andalusia, Spain
In Andalusia, a double public and private initiative has been implemented to boost innovation and circular initiatives related to mining sector. On the public side, an EU-funded incentive programme has been launched to improve innovation in exploration, extraction and processing primary and secondary (waste) minerals. Also, EU mining regions collaboration, through the Thematic Smart Specialisation Partnership on Mining (S3P Mining Regions) is promoted. In addition, a multi-actors initiative hosts the European Institute of Innovation and Technology-Spanish National Research Council Raw Materials South Hub in Seville to support innovation projects with EU funding. Regarding the private sector, the ISMC-AMINER cluster has joined the four axes’ stakeholders to achieve the most advanced innovations in inter-regional projects.
Addressing environmental data, law enforcement and trust in government concerns
Strengthening data collection procedures and communication of environmental impacts
There is a need for more systematic data collection and reporting on environmental impacts of mining, especially at the regional and local levels, and making this information easily accessible to public.
Governments have made efforts to enhance environmental data collection and availability. For instance, the new IEPR mandates industrial facilities to report on additional environmental indicators as of 2027, while the European CRMA introduces additional reporting obligations on mining waste towards the end of 2026.
Additional measures are needed to strengthen compliance with current reporting obligations regarding environmental impacts (e.g. those stemming from the IEPR and the CRMA). Cumulative impact assessments also need to be better streamlined into current permitting procedures and the results communicated to mining communities.
Increasing trust in government’s ability to monitor impacts and enforce legislation
Enhancing institutional capacity for monitoring and law enforcement requires additional human resources (i.e. hiring additional environmental inspectors) and/or improving the efficiency of current capacities (e.g. through digitalisation of processes and providing inspectors with adequate equipment).
Governments can enhance monitoring and law enforcement capacities also by supporting and promoting community-led environmental monitoring of mine sites, in partnership with environmental agencies. This can be achieved by providing interested communities with devices to measure water and air pollution. Such initiatives can improve trust in institutions and increase social acceptance of mining if good environmental performance is achieved. For example, since 2015, load handlers of Lake Sysmäjärvi in North Karelia have been investigating acidity issues, with FinnCobalt and Elementis Minerals participating in water quality monitoring initiated by the ELY Centre. Examples from outside of the European Union include sparsely populated regions like Antofagasta, Chile, and Western Australia, where communities conduct environmental follow-ups under public guidelines and in partnership with industry, enhancing the social licence to operate.
Addressing environmental liability of legacy and closed mines can mitigate environmental risks caused by these sites but also help address concerns about nature degradation from mining. Several examples of good practices exist in the area of remediation that may need to be better communicated to mining communities. In Finland, the legislation encourages companies to close and rehabilitate parts of mine sites that are no longer needed during the operations phase. This helps to ensure that the operator is taking care of the closure as expected and helps to reduce negative impacts of the mine on the surrounding environment. In Portugal, the government has established a legal framework that governs the environmental rehabilitation of degraded and abandoned mining areas, implemented by a specialised body (EDM) with access to funding. The regional government of Andalusia has developed a rehabilitation programme for abandoned historical mine sites, established through the European Regional Development Fund in 2006, and is also including in the agreement for new mines the obligation for companies to rehabilitate abandoned mines in the areas where new operations would take place. Combined with enhanced monitoring of environmental impacts more generally, this may provide more confidence to local communities regarding how similar environmental challenges could be avoided in future projects.
Municipalities also have a role to play in negotiating contracts for new mines that would provide local benefits and improve community trust in such projects. For instance, closure plans as well as community goals for rehabilitation and remediation may need to be better reflected from early on in discussions with mining companies to ensure that expectations are clear.
Governments may also want to promote the public accessibility of environmental data from monitoring efforts and its use to support the enforcement of environmental standards.
Efforts of public authorities
The Directorate General for Energy and Geology in Portugal and the Portuguese Environment Agency collaborate closely to monitor mining projects that have undergone EIAs. This includes regular inspections of mining sites, but also the establishment of monitoring committees and remote monitoring systems for certain projects. This joint effort aims to ensure compliance with environmental commitments, promote best practices in resource management and foster trust between stakeholders and local communities.
Industry
Companies can also take additional measures to increase the public’s trust in their environmental performance. To do this and to promote responsible mining practices, key industry players have adopted ESG and other voluntary sustainability standards according to which they are publicly disclosing information on the company’s environmental impacts. Companies have also been involved in projects with local communities to support environmental monitoring efforts.
ESG and voluntary sustainability standards specific to mining include the Initiative for Responsible Mining Assurance and Canada’s TSM standards. These standards could help ensure transparent and open reviews of mining projects, reducing polarisation and increasing community trust in the sector.
To better balance mining and nature conservation interests:
Regions have a major role to play in:
Strengthening participation of local governments in environmental assessments and the development of mitigation measures from early on to help find innovative solutions for preserving the natural capital in the context of a mining project.
Establishing clear and forward-looking land-use plans to help improve synergies with nature conservation needs.
Promoting the use of existing guidelines and good practices on improving the environmental quality of mining projects by better aligning mining with nature conservation goals (e.g. the European Commission guidelines on implementing the EU Habitats Directive in the extractive sector).
National level authorities may:
Consider strengthening the regulatory framework around the use of and design of ecological compensation as a complementary mitigation measure to advance environmentally sustainable mining practices.
To improve process for environmental-related permits in mining projects:
Regions can leverage existing dissemination activities to further share good practices across companies and permitting authorities with regards to EIA application.
National level authorities can:
Enhance government capacity and agility to process permits and address appeals by increasing staff capacity, digitalising the permitting process and establishing a systematic approach to analysing and addressing appeals, considering that appeals might repeat similar concerns for different projects.
Improve inter-agency co‑ordination with frequent and structured communication and co‑ordination meetings between parties to co‑ordinate on strategic priorities, and address appeals in an integrated fashion.
Improve communication and guidelines for companies: i) develop clear guidelines on the information required for the permitting process (including which changes during operations requires a new permit) and the EIA, along with an indication of maximum processing times; ii) possibly develop separate guidelines for the closure permits as well as checklists for best available techniques; iii) share good practices regarding EIA applications; iv) standardise the submission and analysis of appeals by using templates and pre-defined forms as well as by defining a more systematic procedure to analyse and address concerns.
To improve waste management and scale up circular economy practices in mining:
Regions have a major role to play in:
Clearly defining and outlining circular economy priorities and concrete actions for the mining industry in their strategies and plans, especially smart specialisation strategies, including the promotion of waste prevention practices and opportunities along the entire mining lifecycle. Those need to be aligned with the overall policy goals and targets in this area.
Providing an enabling framework for improved circularity and waste management by boosting R&D, innovation and entrepreneurship (through their regional programmes, including funding), facilitating partnerships between various stakeholders (in the form of hubs and platforms) and improving co‑ordination and communication between stakeholders across the different levels of government.
Promoting planning for waste management, including mine waste recovery and rehabilitation projects, from early on in the project development stage to ensure waste management is properly addressed and minimised, where possible.
National level authorities have a role to play in:
Defining national goals, targets and actions for the mining industry in national waste management and circular economy strategies, plans and legislation.
Considering developing national criteria according to which certain mining waste materials could become byproducts and therefore would cease to be subjected to waste legislation, making the reuse of such materials easier. This may require national programmes for waste characterisation.
Improving the efficiency of environmental permitting for waste facilities to incentivise innovation in recycling technologies throughout the project duration.
Strengthen incentives for companies to adopt circular economy practices through regulatory (e.g. metal recycling and recycled content targets), economic (e.g. new fiscal advantages and green public procurement criteria) and information instruments (digital product passports for batteries) that increase the supply of and demand for secondary materials, given mining waste is a key feedstock for secondary supply of minerals.
Support waste characterisation and mapping of available volumes of valuable minerals in tailings in the regions and assess the potential of their recovery and reuse, including the economic viability.
To improve data collection and enforcement of environmental legislation and thereby increase trust in public institutions:
Regions can:
Support and promote community-led environmental monitoring of mine sites, in partnership with environmental agencies. This can be achieved by providing interested communities with devices to measure water and air pollution. Such initiatives can improve trust in institutions and increase social acceptance.
Help improve the communication of environmental remediation projects from legacy mining. This can be done by highlighting project outcomes in regional webpages, supporting fora on closing mines and remediations.
Promote the public accessibility of environmental data from monitoring efforts and its use to support the enforcement of environmental standards.
National authorities can:
Enhance institutional capacity for monitoring mine/quarry sites – metallic and non-metallic – and effectively communicate monitoring outcomes to the municipality and to the wider public (e.g. through the E-IEP). This includes enhancing human resources or technical capabilities (e.g. through digitalisation) of monitoring institutions.
Support studies on cumulative EIAs in mining communities.
Prioritise funding for the rehabilitation of abandoned and legacy mine sites, involving local communities in the discussions.
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← 1. The Global Tailings Portal provides self-reported information and data by over 100 largest publicly listed mining companies regarding their tailings storage facilities. Globally, the database covers approximately 30% of global commodity production. The data are provided for four mines in Finland, one in Portugal, two in Spain and ten in Sweden. No planned volume data are available for Greece.
← 2. With the exception of Portugal where only 11% of mining waste was landfilled in 2020.
← 3. The Consolidated Mining Standards Initiative aims to bring together aspects of The Copper Mark, the Mining Association of Canada’s Towards Sustainable Mining (TSM) standard, the World Gold Council’s Responsible Gold Mining Principles and the International Council on Mining and Metals’ Mining Principles into one, global standard. Once finalised, its implementation is expected to cover almost 100 mining companies across around 600 sites in 60 countries (CMSI, 2025[47]).
← 4. Several companies operating in Europe, especially in the industrial minerals sector, have already integrated upstream and downstream services to advance resource optimisation throughout the mineral value chain. They integrate material extraction with product manufacturing, logistics and even end-of-life product treatment (see the regional profile of Centro for examples).
← 5. The compensation is based on the principle of a “net positive impact”, which aims to ensure that the environmental harm caused by mining is offset by conservation measures that enhance biodiversity to a greater extent than the damage caused. The purchased forest area is located approximately 125 kilometres from the Sakatti mining site and is part of the global Intact Forest Landscape network.