Executive Summary
Eurometaux and Eurofer are pleased to know that the Commission along all stakeholders recognise the weaknesses of DMC as lead indicator and hence the need to replace it by RME or RMC (raw material equivalent or consumption) which needs to be improved. In this context and acknowledging the Commission’s will to adopt indicators by 2013 and although the effectiveness of a rushed approach may be questioned, we would like to suggest a staged approach by which the Commission would select a set of provisional existing indicators for monitoring and lessons learning, while in parallel it would define more appropriate indicators to be adopted within a 2-3 year period (for example RMC improved). Data would then be collected on the final set of indicators and targets would only be defined when the latter is robust and satisfactory.

Eurometaux and Eurofer strongly feel that macro-economic indicators should not be used for policy making, nor be disaggregated per sector. For policy making more specific indicators should be used.

Neither the macro-economic nor the more specific resource efficiency (RE) indicators should purely refer to weight flows. Appropriate RE indicators should take into account whether a material is consumed today and lost for the future or if a material is used today and remains available in the future, being a permanent material (as recyclable time and time again).

In this context recycling is a key asset in terms of resource efficiency and needs to be considered properly. Eurometaux and Eurofer are convinced that the End-of-Life (EOL) recycling rate is a most relevant indicator in order to measure and account for metal availability for future generations and should be reflected particularly in a macro-economic RE indicator. The aspects of longevity and durability of metals in their application should also be reflected in the macro-economic RE indicators because these aspects reflect also the availability of metals for future generations. Eurometaux and Eurofer would welcome discussing this with the Commission.

Eurometaux and Eurofer support the adoption of “Raw Material Equivalent” (RME) to replace DMC as reference for resource productivity as it presents the advantage of considering the raw materials embodied in products. However, RME also presents different weaknesses including that of being weight-based, of incentivising minimal rather than optimal use of materials and disregarding the material in stock (see full list of weaknesses under 4). Eurometaux and Eurofer believe that these aspects need to be considered in an enhanced methodology and tested to ensure that the model is robust before any sectoral consideration or consideration for policy decision can be made.

See also detailed comments on the dashboard and thematic indicators under 5 and 6.

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To read the full text, pleasae see the document in attachment.