The UK’s new critical minerals strategy fails to follow through on its own logic

This weekend, to less fanfare than might have been expected, the government published its long awaited critical minerals strategy. Vision 2035 seeks to futureproof the UK’s supply of the materials that the economy depends on. It was an opportunity to significantly increase UK economic resilience and demonstrate leadership in a world where competition for resources is only expected to intensify.

To start with the positives, and give it credit, it takes a step in the right direction on a number of fronts compared to the 2022 strategy it replaces. This includes setting numerical targets that, while non-binding, will focus minds and drive action, promising more granular mapping of demand for critical resources across the economy and allocating at least some funding (though, in the words of Ed Conway, it’s a ‘piddling’ amount compared to other countries).

Overall, though, despite the logic behind it being sounder than its predecessor’s, it fails to follow through on thoughts it introduces, vastly reducing its potential impact.

Failure to follow through on its own logic is notable on three crucial fronts opened up in the strategy:

1. The UK is uniquely vulnerable to supply chain disruption
Green Alliance highlighted long ago that the UK is uniquely exposed to volatile international supply chains for critical minerals, even in comparison to other, similarly developed countries and allies like the EU, Australia and the US. As a nation, we are currently over 90 per cent reliant on imports for 32 of the 34 minerals deemed critical to the economy.

The new strategy goes some way to recognising this, expressing concern about strategic vulnerabilities and acknowledging that, “unlike major producing countries, our domestic mining sector is smaller in scale” and, therefore, that “the UK must set out a path which reflects our unique set of strengths”.

However, it also downplays these vulnerabilities, saying they are “shared by partners such as the EU”. In line with this misplaced confidence, it then largely adopts the same approach as the EU, mirroring the bloc’s 2024 Critical Raw Materials Act with similar, though generally less ambitious, targets. This is designed to reduce reliance on countries like China, which has a virtual stranglehold on some supply chains.

The EU has introduced 2030 targets to limit reliance on any one country’s supply of a critical mineral to no more than 65 per cent, as well as for ten per cent of its annual demand to be met through domestic mineral extraction and 25 per cent through domestic recycling. The UK has set 2035 targets to ensure that no more than 60 per cent of the supply of any critical mineral comes from one country, as well as to increase domestic production to ten per cent of annual demand, and for recycling to provide 20 per cent.

Lower UK production and recycling ambitions makes sense in some ways as we are starting later, from a lower baseline and with less in the way of geological reserves for most minerals. It will also be a stretch to meet even those 2035 targets, given the timelines involved in developing mines and recycling processes.

The requirement that the recycling be domestic, though, is notably missing from the UK’s strategy, which will reduce the impact on domestic industry and resilience, assuming it isn’t an oversight (and the document has been criticised for being ‘riddled’ with spelling mistakes and other errors). The UK has also not followed the EU in a target to increase domestic processing (the EU is aiming for 40 per cent), which seems a misstep, as materials processing is even more geographically concentrated than extraction and there are global gaps in that market.

More significantly, though, less ambitious mirroring of the EU and other countries’ policies, like the US and Australia, does little to address the UK’s unique vulnerabilities.

We will never match these countries’ access to critical raw materials and their ability to shape global markets. What we have argued – and what civil society and even businesses are increasingly calling for – is that the government should champion demand reduction.

The logic should be clear: needing fewer critical minerals makes it easier to access what you need, and to get them from more responsible sources and at more reasonable prices. But, in its strategy, the government accepts and accelerates the idea that demand will simply grow and grow.

In a report published jointly with Zero Waste Scotland last year, we argued that the current scramble for minerals is this generation’s equivalent to the 1970s oil crisis, when concentrated control by the Organization of the Petroleum Exporting Countries (OPEC) motivated countries like Sweden to reduce reliance on oil imports. In 1971, Sweden relied on oil for 71 per cent of its energy. With no domestic fossil fuel reserves, the Swedish government took the strategic decision to reduce oil imports and invest in heat pump technology. Today, Sweden leads the European heat pump market, has the second highest share of heat pump installations, at 43 per cent of households, and has reduced its dependence on oil for energy to just 19 per cent.

A similarly bold UK approach to cutting demand for critical materials would have demonstrated ambition to tackle the country’s unique situation, and would have been a lower risk option than a relentless focus on supply.

We’ve previously shown that had we embarked in 2021 on economy-wide measures with societal benefits, like improving home energy efficiency and increasing public and active travel options, we could have slashed demand for some of the minerals needed for the energy system by as much as half by 2030. Action to curb demand should have been even more urgent in the government’s current document, given the lack of action to date and increasing global tensions.

2. The circular economy is a major solution
The strategy moves things on by recognising that critical minerals present in products and infrastructure should be considered on a par with those still in the ground.

In writing that could have been lifted from one of our reports, it notes: “We have 2 domestic sources of critical minerals: those in the ground and those in our homes and businesses”. (Although we would point to infrastructure as a greater source than homes and businesses.)

But the progress stops there. As in the previous government’s strategy, the circular economy gets its own section, which starts positively with a broad definition of activities to be encouraged: “Building an innovative circular economy to not only recycle, but also reuse, repair and prolong the life of products containing critical minerals allows us to fully utilise the second source.”

Unfortunately, as with the previous strategy, the only aspect of the circular economy it then considers is the familiar ground of recycling. More effort to figure out how to recycle these resources is definitely needed. But this failure to move the thinking on is disappointing as recycling isn’t as important as actions like demand reduction, lifetime extension, repair, reuse, remanufacturing, etc, which get no further attention.

Instead of focusing just on recycling, the government needs to introduce targets, funding and policy on these other areas to address the UK’s unique vulnerabilities and encourage greater uptake of domestic repair, remanufacturing and reuse supply chains. This would have huge impact in industries where the UK is not already a primary manufacturer and where it is unlikely to become one any time soon. For instance, analysis for the Coalition for Wind Industry Circularity has shown that remanufacturing just ten wind turbine components with well established supply chains over the next ten years could create a UK market worth £9.6 billion.

Focusing on reducing demand for, and the reuse of, parts and products would also make recycling targets easier to achieve.

Our research has shown that pairing ambitious energy demand reduction with higher recycling in the energy sector could make it possible to meet nearly all the critical material needs for wind, solar and electric vehicle technologies with secondary materials derived from those sectors by 2050. As it stands, the government’s plan will get us nowhere near that.

3. Supply chains must be responsible and transparent
Buried towards the end of the vision is recognition that “currently, some critical mineral supply chains are associated with significant ESG harms, including human rights abuses, biodiversity loss, deforestation and corruption”.

This is a huge understatement and ought not to be buried at the bottom of a document that goes to great lengths to focus on growth in demand which will inevitably lead to opportunities for those harms to increase.

Unfortunately, despite professing that the government is “committed” to “responsible and sustainable development” and that it “expects…all UK companies to respect human rights, workers’ rights and the environment”, the strategy fails to say how this will be ensured. Without setting out any tangible action, such expectations are not only naïve, but irresponsible.

Civil society organisations that work on these matters have, unsurprisingly, come out swinging. Global Justice Now says it “completely fails” to establish a fair and reciprocal relationship with the Global South, where many critical materials are sourced. Corporate Justice Coalition has criticised the “weak” and “vague” promises, as well as its “disingenuous” wording. Trade Justice Movement says “it reinforces an extractive, corporate-first model that overlooks the human rights, environmental and equity challenges at the heart of global mineral supply chains”. And the London Mining Network has focused on the ever increasing growth the strategy aims to drive, saying that “meeting this demand is unachievable without catastrophic and irreversible damage to the environment and livelihoods of communities worldwide”.

In a previous blog, I argued that “no one will win the global battle for critical raw materials”, as all countries will need access to them if we’re to tackle climate change. Sadly, the government’s new strategy promotes an approach that will see some will lose out more than others while still leaving the UK vulnerable.

 

Photo by Paul-Alain Hunt on Unsplash