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The EU’s Clean Industrial Revolution: catching up on green tech at the risk of environmental damage

In the face of major investments by the US to accelerate the transition to a clean energy economy and growing dominance by China, the EU is playing catch up on its green technologies industry. However, the Commission’s proposals presented today are a blunt instrument that could do a lot of unnecessary damage along the way, especially to nature and biodiversity.

Today the European Commission launched new proposals, namely the Net-Zero Industry Act (NZIA) and Critical Raw Materials Act (CRM), to boost the European Union’s clean technology industries and reduce its dependence on imported raw materials. 

WWF supports efforts to boost the European manufacturing of clean technologies in order to accelerate the transition towards climate neutrality. But the European Commission is missing out on big pieces of the puzzle: a green transition will not happen without a strong governance framework, an integrated approach across decarbonisation and innovation, nor without  demand-side measures on sufficiency and circularity to reduce the EU’s demand for raw materials.

While fast and efficient permitting is desirable, it should still be achieved through proper planning and appropriate environmental impact assessments. Both proposals undermine  key provisions on nature protection and public participation for example by presuming that net zero priority projects and mining operations are in the “overriding public interest”. First put forward under the RePowerEU proposals for the permitting of renewables, this deregulation approach is the wrong way to go and could generate public opposition. WWF warned of this snowball effect and believes the climate crisis needs to be solved in harmony with nature, through investment in better planning processes.

Net Zero Industry Act (NZIA)

The European Commission proposes a list of sectors that could apply for net-zero industry projects status in order to get faster permitting procedures. Yet the European Commission doesn’t make a distinction between activities that are environmentally harmful and/or unproven at scale (e.g. Carbon Capture and Storage (CCS), nuclear power and non-renewable hydrogen) and those that are clean and in need of rapid scaling up, like solar PV, wind power and heat pumps. 

What’s more, the European Commission fails to acknowledge material and energy efficiency as a big part of the equation.

“The European Commission is mixing apples and oranges in its NZIA. Real green technologies such as the production of solar panels, wind turbines and renewable hydrogen for targeted sectors can’t be put on the same footing as CCS. That risks damaging the overall success of the EU’s NZIA by locking us into fossil fuel dependency for even longer,” said Camille Maury, Senior Policy Officer, Decarbonisation of Industry at WWF Europe.

Camille Maury added: “And once again we see the Commission reaching for the hammer of deregulation when it should be using precision tools. Scrapping rules on nature protection and the participation of civil society and local communities in the planning process is misguided and could easily backfire. We need to tackle the climate and biodiversity crises together, not trade one off against the other.” 

Critical Raw Materials (CRM) Act

WWF acknowledges the EU’s need for critical raw materials to ensure the massive deployment of renewables in order to stop runaway climate change and avoid the EU’s dependency on third countries, as with oil and gas. However, the Commission’s proposal misses several critical elements such as the uncertainty on the potential impacts for nature protection laws and mining projects. 

“The Commission’s proposal contains some positive developments, such as new rules on the environmental footprint for mining projects and the importance of circularity for critical raw materials,” said Tobias Kind-Rieper, Global Lead Mining & Metals at WWF.

Tobias Kind-Rieper added: “But the overriding public interest provision and other exemptions from environmental laws could cause serious and unnecessary damage to our biodiversity and nature, especially to protected areas within the EU. Furthermore, having a target of at least 40% of raw materials being processed and refined within the EU is unrealistic and would also be an obstruction in raw materials negotiation with partner countries.”


Florian Cassier
Climate Communications Officer
WWF European Policy Office
+32 479 33 92 11

Background information

The Net-Zero Industry Act (NZIA) is part of the European Commission’s Green Deal Industrial Plan (GDPI) announced earlier this year as a direct response to the US Inflation Reduction Act on the ongoing dominance of China in many clean tech manufacturing industries. The aim of the NZIA is to ensure the growth of clean technology industries happens in Europe by: establishing an overall clean technology manufacturing goal for the EU, setting up net-zero priority projects and fast track permitting procedures within the EU. The act raises several concerns linked to the scope of what is defined as clean technologies, the conditions industry has to comply with in order to access public funding, as well as potential negative impacts (through deregulation) on public participation, local communities, biodiversity and nature. For WWF, nature and biodiversity are our best ally in preventing climate change and making us more resilient to what warming is now inevitable.

The Critical Raw Materials (CRM) Act is also part of the European Commission’s Green Deal Industrial Plan. With this act, the European Commission wants to ensure an adequate and diversified European supply chain of critical raw materials for both Europe's digital economy and green transition, by: 1. defining the commodities classified as strategic for the EU and monitoring their supply 2.  supporting more projects and attracting private investment to build a resilient supply chain and 3. guaranteeing a level playing field in the internal market by ensuring uniform standards. The act raises several concerns such as the strong focus on the EU becoming an extractivist economy, without taking into account the sufficiency and circularity of raw materials in the EU and abroad, as well as the potential negative impacts of overriding public interest provisions and other exemptions from nature laws on local communities, biodiversity and nature.
Workers on wind farm
© Istock
Workers on wind farm


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