Summary of recommendations:

  1. Article 29 should specify a certification scheme is not a replacement for a company’s responsibility or for government oversight
  2. Additional criteria for certification schemes in Annex IV including they be equally governed multi-stakeholder initiatives, provide access to a grievance mechanism and require publicly noticed third-party audits that are published in their entirety

Read the full paper: Critical Raw Materials Act – IRMA’s recommendations on the European Commission’s draft proposal