Mining Perspectives—on Earth and Beyond
Proposed European Conflict Mineral Regulations

The magazine of the Minor Metals Trade Association

2nd Edition 2014/April www.mmta.co.uk

MMTA’S INTERNATIONAL MINOR METALS CONFERENCE,
INSIDE THIS ISSUEMMTA Conference Update……………….….2
Rolls-Royce Visit.…………………..………….…...327th-29th APRIL 2014, VICTORIA PARK PLAZA, LONDONTime is running out if you have not yet registeredfor THE minor metals conference of 2014.

Resource Depletion Concerns..……….….4
Asteroid Mining……………………...……..…….....6
EU Conflict Mineral Regulation……....….8
Critical Raw Materials Update…….…..…10
Letter From North America…………....….12
All At Sea—Marine Cargo Risks….…..….13
Exporting to China—Compliance…..….14

28th APRIL—Guest speaker: Mark Miodownik, University College London,
University of London, United Kingdom;

Keynote presentation — “China: Great expectations?” by Dennis Unkovic,
Meyer, Unkovic & Scott LLP, USA;

Session 1: Automotive and aerospace:“Sourcing critical metals and raw materials for the automotive industry: Latest
developments for electric, hybrid and low carbon emission vehicles”, byPhilippe Schultz, Renault SA, France;

CONFERENCE SPONSORS“A changing world with different rules – the re-introduction of lightweightmagnesium alloys onto civil aircraft”, by Graham Wardlow, Magnesium
Elektron, United Kingdom;“Recovery of rhenium in Poland”, by Kamil Kozub, KGHM Group, Poland;
NEW “Is Dodd-Frank working for the people of Rwanda and for the tantalitetungsten industry? A ministerial view”, by Evode Imena, Minister of State
for Mining, Ministry of Natural Resources, Government of the Republicof Rwanda, Rwanda;

Session 2: Recycling and secondary:“Latest developments in minor and electronics metals recycling”, by Christina
Meskers, Umicore Precious Metals Recycling, Belgium;“Welcome to the ever-evolving world of super-alloys recycling”, by Duncan
Birchley, Select Alloys & Materials Ltd, United Kingdom;

16:00 MMTA Annual General Meeting
19:00-21:00 Tate Britain Reception – join us for canapés & drinks at Gallery 9 at the newly reopened Tate Britain kindly sponsored by Lipmann
Walton & Co Ltd

28th April
Session 3: Markets in steel, specialty and stainless:Keynote presentation – “Global trends for specialty, tool and stainlesssteels”, by Marcus Moll, SMR, Austria;“Vanadium market overview: Rebar, redox – reasons to be optimistic?, by Jack
Bedder, Roskill Information Services Ltd., United Kingdom;

Session 4: Refractory metals and applications:“Hafnium and zirconium: Growing demand in alloys?” by Cyrille Rontard,
AREVA – Fuel Zirconium Sales, France;“From gritty to nitty-gritty: Mining, investing in its future”, by Andrew Hinkly,
Anglo American Platinum, United Kingdom;“New ways of formulating with flame retardants: A story about antimony
tri-oxide and alternatives”, by Dirk Rimaux, Campine, Belgium;

2“Fanya’s role in the global minor metals industry”, by Scarlett Zhang, The
Fanya Metal Exchange, China;

MESSAGE FROM THE EXECUTIVE TEAM—FRAUD ALERTThe MMTA has been informed that a number of trading companies have recently had
their email systems hacked. According to information received from MMTA members
more than one case has occurred where emails have been intercepted and invoices havebeen amended to incorporate incorrect account details, which has led to funds destinedfor sellers as part of a transaction being diverted to a third party account. Members areadvised to pay close attention to any unexpected changes in account details on an invoice
and should contact suppliers by phone to confirm any changes, rather than by email.
Members are also reminded to pay particular attention if pre-paying money to companies
they do not know, even if their websites and communications appear legitimate.

VISIT TO ROLLS-ROYCE, DERBY—30th APRIL 2014
ONLY A FEW PLACES STILL REMAINING

To round off the MMTA conference, Rolls-Royce has kindly offered to host the MMTA at its
heritage centres in Derby.
Take the coach with us from London Victoria for the tours and lunch,
returning to London by early evening.
The first tour is an overview of the Rolls-Royce story from its beginnings to present day product range.
We will then be taken by coach for a three-course lunch with wine.
After lunch, there will be a tour of the Light Alloy Foundry, where we will see the largest collection of aeroengines in the country, ranging from World War 1 era piston engines, the famous Merlin, right up tomodern day jet engines. The collection also includes examples across Rolls-Royce's product range
including marine and industrial applications. There are a small number of vintage cars, some of whichhark back to the early days of Rolls-Royce and the start of the motor car era. There are also examples ofengines and motor cars from distinguished names such as Armstrong Siddeley and Napier, whose
companies became part of the Rolls-Royce group in their latter years.
The MMTA Member/Conference Delegate cost for this event including lunch and transport
will be £70 (+ vat).
Places are strictly limited for this event. To book, click HERE.

HOW SERIOUSLY SHOULD WE TAKE CURRENT CONCERNSOVER RESOURCE DEPLETION?

Euromines is the recognised
representative of the European metals
and minerals mining industry. The
association's main objective is topromote the industry and to maintainits relations with European institutions
at all levels. Euromines provides
services to its members with regard to
EU policy and serves as a network forcooperation and for the exchange of
information throughout the sector
within Europe. The association also
fosters contacts with the mining
community throughout the world.
Euromines represents large and small
companies and subsidiaries in Europe
and in other parts of the world which
provide jobs to more than 350,000
people. Through the activities andoperations of these members, morethan 42 different metals and minerals
are produced. For some metals andminerals, Europe is the world's leading
producer.

4Euromines members have articulated
their “Views on Indicators of Resource
Efficiency”. Trade-offs always exist
between different environmental
objectives and the environmental,social and economic imperatives ofsustainable development, andresource efficiency should ideally yield
optimum solutions to those. The
European mineral supply industries
fully support the premise that life
cycle management approaches are
required to describe and monitor
resource efficiency. However, someserious methodological issues remain
to be resolved before existing Life
Cycle Assessment (LCA) indicators canbe used to reliably measure theenvironmental impacts of resourceuse. Notably, an improved uniform
model should be developed that
adequately reflects the full range ofresource depletion potentials, so thatefforts are not diverted away from
more acute pressures on theenvironment.
If applied incorrectly, “resource
depletion”, “material footprint” and“material consumption” concepts
divert attention away from theenvironmental impacts of dispersive
use and release by over-estimating

the environmental impact of resource
extraction (e.g., mining of phosphaterock). Recent EU research has
revealed that current assessments of“Abiotic [non-living] Resource
Depletion” vary by several orders ofmagnitude, and that there is noconsensus amongst LCA practitionerson the issue of concern. In practice,some LCAs have prioritised“conservation” of abundant mineral
resources over more pressing
environmental concerns. Insufficiently
informed interpretation of thesestudies (e.g., by a member of the
public confronted with a single
number representing “total
environmental impact”), is likely tolead to counter-productive diversionof effort.
As several geologists and resource
economists have shown, “depletion”
of mineral resources is not considered
likely enough even to besystematically included as an impact
category in Life Cycle Impact
Assessment (LCIA). “Scarcity” of theseraw-materials is an economic issue
arising from a lack of efficient forward-looking use of capital and is notindicative of any environmental
impact.

Such assertions have contrasted
strongly with data typically presented
by geologists and minerals economists.
New studies present an opportunity toanalyse these differences and attemptresolution. A recent report by the
Sustainable Europe Research Institute(SERI) analyses the Resource
Productivity trends of all countries
worldwide between 1980 and 2008. It
confirms that each economy takes aslightly different path according to its
Otherwise, many commentators pointindustrial base, inherent strengths andto declining ore-grades as evidence of
weaknesses and historical context andan environmental issue that should bethat, as a whole, the world has beenof societal concern. However, the oreprogressively de-coupling from
grades referred to in those studies areresource consumption for at least theinvariably “run-of-mine” ore-grades, i.e.
last 40 years. The European
the grade of the ore that is sent by theEnvironment Agency recently
mine for further processing. Run-ofconfirmed that “Resource Efficiency inmine ore-grades are not indicative ofEurope is generally improving and thethe state or condition of the naturalenvironmental pressures related toresource; they are indicative of theresource use are declining” [European
improved efficiency of the mineral
Environment Agency, 2013: http://
supply industry. Run-of-mine oregoo.gl/Lpdq0L].
grades have declined over time due toRather than being truly depleted, thea complex set of influencing factors
majority of mineral resources are used
including the inherent competitive
to continuously serve valuableadvantage of large established mines
purposes in the built environment. The
and - most especially - technological
Resource Depletion impact category
advances that have enabled theshould therefore only be included in
profitable extraction of metals from
LCIAs of products that are consumed
lower-grade ores despite long-term
price erosion. The volume of a mineral (typically those derived from biotic
resources such as fish, crops, somereserve increases as the cut-off grade
forest products, livestock, foodstuffs,of extraction technologies decreases,
oil, gas, peat and coal) for which there
so as technology enables profitable
may be imminent risk of environmental
processing of lower-grade ores, theimpacts if stocks cannot bevolume of the available mineralregenerated. It is suggested that efforts
reserves increases. Production of many
to improve resource depletion
metals, e.g., copper, has increased
indicators and methods should
dramatically over the same period that
continue, in order to make them fit for
run-of-mine ore-grades have declined.
purpose; however they should only be
Still, the net result of resource
applied where sustainable yield isextraction and resource discovery over threatened. At the very least, the fulla given period of time is almost always range of depletion potentials (froman increase in available natural
extremely low to high enough forresource. Meanwhile, the range ofconcern) needs to be captured; andcopper content in discovered porphyry reporting needs to transparently
copper deposits, for example, has
illustrate which datasets are used forremained remarkably similar since
which materials.
1845, with no discernable decrease or
increase over the last 150 years.
Johannes Drielsma, Euromines
Society’s current concerns over‘resource depletion’ are partly fuelledby high prices due to the relatively
recent emergence of the Brazilian,
Russian, Indian and Chinese
economies. However, prior to that,
commodity prices were in continual
long-term decline. Price peaks from the20th Century corresponded to wars andrevolutions – and did not result fromdepletion of the natural resources.

Those concerned about depletion of
abiotic resources have claimed that
Domestic Material Consumption
increases inexorably with Gross
Domestic Product, the resources are
non-renewable, and therefore sucheconomic growth is unsustainable.

NEW RESOURCES IN
THE MEMBERS’ AREA
OF THE MMTA WEBSITE
There is a new category in‘Minor Metals Applications& Overviews’: By-Products
NEW Study of by-products ofcopper, lead, zinc, nickel 2012,
Oakdene Hollins
NEW Study of by-products ofcopper, lead, zinc, nickel, P. Willis,
Oakdene Hollins, 2013
NEW Cu, Ni, Pb, Zn AustralianGovernment 2013
NEW Cobalt as a by-product ofnickel and copper production 2013
NEW US perspective on byproducts and critical materials 2013
NEW USGS By-productcommodities used for the
production of photovoltaic cells 2010
Other new documents andpapers:NEW Indium Recovery andRecycling of LCD panels
NEW Minamata Conference Text
2014 (Mercury)
NEW The life cycle of mobile
phones – a UL White Paper
NEW TTIP: The opportunities forsmall and medium sized enterprises
NEW Critical Metals in the Path
towards the Decarbonisation of the
EU Energy Sector 2013
To log into the Members’ Area, go to
www.mmta.co.uk/members-login
where you can reset your p/w if you
have forgotten it. Your user name isyour email address.

5

ASTEROID MINING—THE FINAL FRONTIER?
Manned mission to Mars? Why not look to the heavens for our mineral resources?

MMTA AGM
The MMTA’s AGM 2014
will take place during
the conference at
16.00 on Monday
28th April 2014.
Venue: Victoria Park
Plaza Hotel, London,UK
All Members arewelcome to attend.
The Notice of AGM
and Agenda havebeen circulated to all
Members and areavailable in theMembers’ Area of thewebsite.
The AGM offers an
ideal opportunity tohear about theongoing work andprojects of the MMTA.
Members areencouraged to attend.
Minor Metals Trade Association

At first glance, it seems
like pure sciencefiction (the spaceshipin the 1979 film Alien
was carrying iron ore
mined from anasteroid), but there arein fact two wellfinanced and serious
companies focused onasteroid mining
already in business:
Planetary Resources
and Deep Space Industries, which have the commercial mining of asteroids andthe development of space industry in their sights. This may be one sci-fi fantasy
for which the technology has caught up.
To add more weight to this growing trend towards space industry, NASA iscurrently holding a call for projects to capture an asteroid and drag it closer toearth for studying. They are also holding a competition with cash prizes for
those who can come up with improved algorithms to identify asteroids #AsteroidHunters for those who are mathematically inclined.
Planetary Resources announced in 2012 its plan to mine asteroids for theirmineral resources. This company also has the not inconsiderable benefit of
having some billionaire investors behind it, including Sir Richard Branson and
Google’s Larry Page. Apart from an asteroid’s mineral wealth, the company
would also like to create a space ‘fuel station’ by using the water found inasteroids to make rocket fuel, using electricity from solar panels to split water
into oxygen and hydrogen. The advantages of this lie in the fact that fuel from
Earth would not need to be transported into space and the re-fuelling needs ofsatellites and spacecraft would be taken care of. This is a first key step tocreating a space infrastructure which could eventually lead to more costeffective space travel and exploration. Cost effectiveness is, of course, the key
factor. The technology may have caught up, but making such mining ventures
financially viable is a different matter. An upcoming NASA mission set to launch
in 2016 (OSIRIS-REx) plans to return 60g of material from an asteroid to Earth;unfortunately, however, this will cost around $1bn to recover.
Deep Space Industries’ vision is to begin prospecting for asteroids suitable formining by 2015 and by 2016 return asteroid samples to Earth. Then in 2023
plans for mining will begin.

Are these projects realistic? Is there enough mineral wealth to justify the expensesof space missions?
Sensational headlines like that below ignore the complications of such
ambitious projects.

Suite 53
3 Whitehall Court
LondonSW1A 2EL
Telephone: +44 (0)207 833 0237
Fax: +44 (0)207 839 1386
Email: executive@mmta.co.uk

Source: Mail Online 7 April 20146

A study published in 2013 may serve to dampen optimism surrounding
some of these objectives. The Harvard astrophysicist, Dr Martin Elvis, argues
that there are only around 10 nearby asteroids that may be suitable forcommercial mining. Asteroids that could be mined for water to make fuelwere also fed into the equation, with Dr Elvis coming to a total of around 18
viable ones. This figure is strongly disputed by Planetary Resources, which
estimates that there are over 1500 asteroids that are as easy to reach as themoon.
Dr Elvis has developed an equation to estimate the number of asteroids in
the Solar System that could be exploited in a cost-effective way. He used thenumber of M-type asteroids, (iron-nickel type with the most platinum groupmetals) and the parameter of delta-v, which is the change in velocity needed
to send the mining equipment to the asteroid and then return with themined ore.
Also contributing to Dr Elvis’s low estimate is the fluctuating prices of ores
meaning that profitability on individual missions is highly variable. Very small
asteroids less than 100m were also discounted as possible resources, as
there would not be enough material to cover the cost of the mission.
However, Planetary Resources says that they are not just planning on
targeting M-type asteroids, but also C-type (carbonaceous) which, theyassert, are the most platinum rich. They also have a more ambitious delta-v
limit than used in Dr Elvis’ calculation. This all means that the work by Dr
Elvis could be off by a factor of 100 or, more optimistically, 1,000.

"We have only discovered 1% of the asteroids in the Solar System - and weare discovering them at a larger and larger rate. We discover two or threeasteroids a day. If we get from 1% to 10%, then the 650,000 asteroids wehave discovered jumps to 6.5 million."
It seems that although there may be potential to mine space, there firstneeds to be very significant capital investment. Infrastructure, including
refining and transportation, are also key challenges to the development of a
viable space industry. It also seems that there is much debate in the science
world on what is realistic or not. It will be interesting to see what the next
few years bring for asteroid mining.

DIARY DATESMMTA’s International
Minor Metals Conference
27th -29th April 2014
Victoria Park Plaza, London
Rolls-Royce Visit
30th April 2014
London/Derby
Legal Aspects ofContracting Course
4th June 2014
MMTA Office, London
Technology & Applicationsof Minor Metals Course
5th June 2014
MMTA Office, London
Drinks Reception
9th June 2014
New York
Sponsored by Metal Pages

Tamara Alliot, MMTA
NASA Asteroid Facts
Asteroid: A relatively small, inactive, rocky body orbiting the Sun.
Comet: A relatively small object whose ices can vaporize in sunlight forming an atmosphereof dust and gas and sometimes a tail.
Meteoroid: A small particle from a comet or asteroid orbiting the Sun.
Meteor Shower: The light phenomena which results when a meteoroid enters the Earth's
atmosphere and vaporizes; a shooting star.
Meteorite: A meteoroid that survives its passage through the Earth's atmosphere and lands
upon the Earth's surface.
About once a year, an automobile-sized asteroid hits Earth's atmosphere, creates an impressive fireball, and burns up before reaching the surface.
Asteroids that populate the main asteroid belt between Mars and Jupiter, can be as big as 940
km across.
Meteorites yield significant amounts of precious metals like platinum, rhodium, iridium,rhenium, osmium, ruthenium, palladium, germanium and gold.

Technology & Applicationsof Minor Metals Course
10th June 2014
New York
41st Anniversary Dinner
21st October 2014
Intercontinental Hotel,
London
New York Dinner
4th December, 2014
Circus, New YorkMMTA Christmas Lunch
17th December 2014
Ironmongers’ Hall, London

7

MMTA SPONSORSHIPFOR 2014
As always, there are arange of sponsorship
opportunities available for
MMTA events throughout
the year. We can tailorsponsorship packages tomeet specificrequirements andbudgets. Just contact the
Executive Team to
discuss, or speak to us at
the conference.
CHECK OUT THE MMTAWEBSITE
We like to keep the MMTA
website looking fresh, so wehave made some changes tothe way it looks. We are also
now able to display Member
companies better in theMembers’ Directory, as well as
displaying Members’ logos on
the homepage. We’ll bechanging these throughout theyear—the first logos on the
homepage are our new
Members from 2013.
A lot of work has been done
improving the Resource Centre
in the Members’ Area, too. We
hope you like the changes.

PROPOSED EUROPEAN CONFLICT MINERAL REGULATIONS—HOW DIFFERENT ARE THEY FROM THE US DODD-FRANK ACT
FOR METAL TRADERS?
The global guidance on
responsible supply chains forconflict minerals was developed
via inter-governmental
consultation at the OECD in May
2011, building on the Kimberleyprocess adopted by the diamondindustry to address widespread
concerns over human rights
abuses.
After lengthy consultation, the European Commission published its
proposed regulations on conflict minerals in early March 2014. The
expectation was that a similar and potentially broader approach to the US
Dodd-Frank Act would be adopted. However, the European Commission
has proposed a very different approach which is likely to have significantly
lower costs for the economy as a whole.
The most striking feature of the EU approach is removal of the burden of
supply chain due diligence from manufacturers. In the US, publicly-tradedmanufacturers and retailers of products containing tin, tantalum andtungsten, their ores and gold, are required to publish reports on their
supply chain due diligence processes and their effectiveness in ensuringthat only conflict free sources are utilised. This is a costly process
requiring suppliers stretching down the supply chain through to smelters
to confirm that they have appropriate systems in place.

“a manufacturer only needs to buy from a ‘responsible importer’ to beable to declare themselves a conflict free manufacturer”.
The EU proposal is somewhat simpler. In effect, as material enters theEuropean Union the ‘importer’ who clears customs can choose to be a‘responsible importer’. A ‘responsible importer’ must have in place supply
chain policies consistent with the OECD guidance, which allow them totrace the metals to smelters and obtain the smelters’ third party audit
certificate demonstrating its compliance with the OECD guidance. Thiseffectively ring fences the European Union, so that a manufacturer only
needs to buy from a ‘responsible importer’ to be able to declarethemselves a conflict free manufacturer.

What options exist for metal traders?
Metal traders selling metals or minerals sourced from outside the EU could
supply these resources duty unpaid. This would pass the requirements for‘responsible importer’ status onto their customer. However, many of thesecustomers do not have the necessary systems in place to fulfil this duty
and are unlikely to accept this, making this an unrealistic option.
A metal trader could choose to only acquire products already in freecirculation within the EU. This however would seem to be a limited
strategy that is unlikely to maximise profitability.
The trader could choose to continue importing into the EU but not as a‘responsible importer’. The risk here is that customers may not wish toacquire materials that are not certified as ‘conflict free’. In US, major
companies such as Apple and Intel have used early compliance with thelegislation for public relation purposes. It is possible that a two tier market
could develop over time.
The other option is of course for traders to instigate systems to allow them8

to operate as ‘responsible importers’. Commercially this is likely to be thepreferred option over time, as many traders will be trading globally,
including locations such as the US where non-compliance might preclude
entry into the supply chain of major businesses.
One of the significant issues with conflict metals is the control of upstreamrisk from source to smelter. Once ore is smelted into metal it is no longer
possible to determine its components’ origin. The draft legislation
introduces a central register of responsible smelters and refiners that havethird party audits available. This is an improvement on the US system
where each customer has to make its own enquiry of the smelter.
Both the US and EU legislation apply to the same substances - tin,tantalum, tungsten and gold - as the OECD guidance and presumably will
expand to other substances if that guidance is extended. The US guidancehas restricted its application to the Democratic Republic of Congo andsurrounding countries in line with UN Security Council Resolutions. The EU
proposed legislation follows the OECD guidance and applies to countries
that are termed “conflict affected” or “high risk areas”. The OECD defines
the areas covered as:

Conflict-affected and high-risk areas are identified by the presenceof armed conflict, widespread violence or other risks of harm topeople. Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or
insurgencies, civil wars, etc. High-risk areas may include areas ofpolitical instability or repression, institutional weakness, insecurity,
collapse of civil infrastructure and widespread violence. Such areas
are often characterised by widespread human rights abuses andviolations of national or international law.

BOWLING REVIEW
Metal Pages were recently
hosts to many MMTA
Members for their Bowling
Extravaganza. The MMTA
General Manager was part of
the winning team, although
could not with any honesty
claim to have been a deciding
factor in the win, top scorers
on the winning team being
Nigel Tunna of Metal Pages
and Mark Beddard ofJohnson Matthey. The losing
finalists' star and top MMTA
scorer until the final secondsof the match, was the sole
MMTA warehouse
representative, Patrick Scholsof Euro-Rijn International BV.

This definition is arguably too subjective and requires a level of knowledgeof geopolitics far beyond many businesses; there are unfortunately many
areas to which some of these circumstances apply and perhaps the final
legislation should incorporate a mechanism for regions to also be centrally
identified.
The proposed EU legislation does not incorporate any transition
arrangements. A smelter might be on the approved list in 2015, but thisdoes not mean that it had appropriate systems in place in 2013.
Consequently it would not be possible to certify existing metal outside the
EU on the day of implementation as ‘conflict free’ under the criteria of theregulation. The OECD guidance did incorporate the concept of‘grandfathered’ stock as part of its Gold Supplement, but did not recognise
this for other materials. It is not clear that this provision exists even for gold
under the latest proposal.
The OECD guidance excludes metals that can reasonably be assumed to berecycled, whilst no reference is made to processes to be applied to tin,tantalum and tungsten, it does suggest procedures for recycled gold thatmight act as a basis of other materials. The proposed EU guidance does
not incorporate these provisions.
Whilst the proposals seem realistic they still require approval by theEuropean Parliament which has previously adopted a more hardline
stance. Some national legislation will be required to implement the
proposals, which may impose further local burdens. The proposal also
incorporates a three-year review of its effectiveness, which could see
amendment to the voluntary status if uptake is poor.

Ian Weekes, Crowe Clark Whitehill
Crowe Horwath International through its local offices is a leading provider of services toInternational traders and is currently advising companies on compliance with conflict minerallegislation.
Crowe Clark Whitehill is the UK member of Crowe Horwath International. Ian Weekes is a UK
based partner at national tax, audit and advisory firm Crowe Clark Whitehill with extensive
experience of working with international trading and warehousing businesses. Ian can becontacted at Ian.Weekes@crowecw.co.uk.

In an imaginative andinnovative display of skill andcontrol, the teams battled
late into the evening, with
Nigel's team securing anarrow win.
Independent observers of thegame may have struggled tofollow the team structure andtransparency of scoring, but
most importantly, the MMTA
office is looking after thewinners'
cup until the
returnmatch.
9

TECHNOLOGY &APPLICATIONS OFMINOR METALSCOURSE
5th June 2014, London&
10th June 2014, New York
The MMTA is offering a oneday training course on thetechnology and applications ofminor metals.
The focus will be on steels andother alloy families in which
minor metals play a key role.
The morning session willoffer an overview oftechnologies and industrial
practices for:

Metal extraction andprimary processingSecondary processing –casting, forging, extrusion,
powder metallurgy, heat
treatmentProduct manufacture –machining, welding,surface treatments andcoatings
Fundamental principles ofalloy metallurgy

Technical rationale behind theuse of minor metals and their
inclusion in common alloys

CRITICAL RAW MATERIALS UPDATE—CRM EXHIBITION &BREAKFAST MEETING‘An updated EU critical raw materials (CRM) report is due for imminent
release (at the time of writing, the revised publication is scheduled for May
2014). The recent CRM Exhibition held at the European Parliament on the
19th February, offered a valuable insight into the methodology behind therevised list, as well as highlighting the huge importance of CRMs, themajority of which are minor metals, to both the European economy and to
our modern way of life.
The Exhibition was hosted
by Bulgarian MEP Prof.
Vladko Panayotov, VicePresident of the Interparliamentary Raw
Materials Group to the EU
Parliament, with his wellattended welcome
address followed by afascinating perspective on
recycling from Egbert Lox,
Senior Vice President
MEP Prof Panayatov, Roy Walton, Tamara Alliot & Maria Cox at theGovernmental Affairs at
Umicore. The primary aim of CRM Exhibition Reception
this 3-day event was to emphasise the importance of CRMs for innovation,competitiveness and economic growth in the European Union. The agenda
included an extremely well-attended breakfast meeting, hosted by the
MMTA, a round-table session and presentations from Oakdene Hollins andRoskill Information Services, both of whom were involved in writing thereport.
Nicholas Morley, Director at Oakdene Hollins, explained that there is no
absolute definition of ‘criticality’, with a material’s criticality being context
dependent – balancing the strategic importance of its applications with its
supply chain risks. When defining a critical material, the combination of
the results of both the World Governance Index (governmental risk) andthe Environmental Performance Index (environmental risk) were used in
the final methodology.
On the economic importance axis they looked at the end-use applications,
including what percentage of each metal went into which EU industrial(mega) sector. On the supply risk axis the focus was on a supply risk due topoor governance – substitutability, recycling rate, country concentrationand governance (potential political unrest or export restrictions) – and/or arisk due to low environmental standards – substitutability, recycling rate,
country concentration and environmental standards, Morley explained.
Robert Baylis, Managing Director at Roskill, further underlined that themain focus of the Critical Raw Materials methodology was on supply risk
and economic importance, not on physical scarcity or on oversupply.
Additional factors for consideration were geology (the case of niobium), by-products (the case of gallium), commercial and value-chain (the case ofcobalt) and price/cost (the case of magnesium).

The afternoon session will
provide an overview ofmarkets and applications forminor metals in key industry
sectors.
For more information on either
course, please contact
executive@mmta.co.uk
Mattia Pelligrini, European Commission, speaking at the MMTA
hosted Breakfast Meeting

10

Where the 2010 report mainly
focused on the governmental
risks, the 2013 report also
identified the need to consider
more factors when evaluating
criticality: ore grades and land
use competition in the
exploration phase, mining
governance and corporate
concentration in the mining
phase, mined and refined
production and by-productdynamics in the refining phaseand price volatility andenvironmental regulation in
the end-use phase. It should
be borne in mind that in 10
years, the world situation could

look very different, as energy and labour costs will only rise. What is
considered a critical material now, could change over time. The main driver
for this change is economics, with prices of raw materials having varied
significantly over the past decade. If production is increased or diversified,a material could cease to be ‘critical’, whilst still remaining economicallyimportant. (Many Thanks to Heleen Vollers of BeST for these summaries)
The Breakfast Meeting hosted in the European Parliament by the MMTA,
was attended by industry professionals, representatives from the European
Parliament and Commission, representatives from producer countries,
including South-Africa, Namibia and Zimbabwe, as well as associations andother stakeholders. Prof. Dr. Paul Rübig, Austrian MEP, took the floor andhighlighted the need for increased competitiveness in European industry
and in particular Small and Medium-Sized Enterprises, which is of particularconcern to many MMTA Members. He was followed by keynote speaker,
Mattia Pellegrini, Head of Unit Raw Materials, Metals, Minerals and Forestbased industries at DG Enterprise & Industry, European Commission. Mr
Pellegrini talked about the work of the European Commission in creating
the first CRM report and the subsequent successes that this list has had. He
reported that the list focused political attention on the subject, mapped the
key issues at stake and notably identified those raw materials that werecritical for the EU economy. The report was also the orientation fordifferent departments in the Commission responsible for industries such as
electronics, defence or medical. He emphasised that the importance of
CRMs should be further integrated into
European policies.
Maria Cox, MMTA General Manager,
also spoke at the breakfast meeting, toincrease the awareness of the role ofthe MMTA, as well as the importantfunction of its Membership in the
supply, trade and uses of CRMs, and toraise the profile of minor metals ingeneral. She emphasized that someMembers express concern when thesematerials, recognised as being
economically important, and often withfew or no substitutes, are also under
threat from EU legislation. Some feelthat due to the impact of REACH
Maria Cox speaking at the CRM Breakfast
Authorisation, the consequence is that
Meeting
the EU is simply crossing elements off
the periodic table and limiting thescope of future European technological innovation, one of Europe’s key
strengths. This is the equivalent of tying the hands of EU business behind
its back when competing with other parts of the world, for whom the entire
periodic table is still available.
The next CRM list should be out in May and is expected to include 20
materials, an increase from the 14 identified on the 2010 list. Associations
and companies with materials on the list are still uncertain as to the positive or negative impact of being designated a CRM. Does the CRM list allow
these materials to be considered favourably from a regulatory or legislative
perspective? Or does it simply create a target list for EU-funded
substitution programs?
Let us know your thoughts.

TRADE CREDIT AND MARINE INSURANCE SURVEY.
We received a large number of responses to our recent survey. Thank you to those who
took part. Here are a couple of key results:
Almost 50% purchase Trade Credit Insurance, 83% of which are on a comprehensive

LEGAL ASPECTS OF
CONTRACTING COURSE
4th June 2014, London

Delivered by Penningtons
Manches LLPThis not-to-be-missed half-day
seminar is an overview ofcontracts for traders and otherinterested parties, useful as both
introduction and refresher, andwill cover the following:

What is a contract?

When is it made?



Does it incorporate yourstandard terms?



Why are standard terms
useful?



Variations

What happens if one side
doesn't perform?

To register your interest, pleasecontact:
executive@mmta.co.uk(whole turnover) basis.
Over 77% hold their own Cargo Insurance policy, with a split between those heavily using
their own policy and those preferring to purchase from the supplier on terms including
insurance, such as CIF.

11

MMTA SUSTAINABILITY
WORKING GROUP
The MMTA is pleased to announce
the launch its new Sustainable
Development Working Group,
which will support Members who
are new to sustainability, and assist
those wishing to improve ordevelop their programmes, as well
as showcasing Members’ ownsustainability work.
The Working Group also aims to
produce reports on the sustainable
uses of minor metals, helping topromote the valuable contributionof minor metals to our modern
way of life.
Why is the MMTA ideally placed
to undertake this work?
With increased consumer
pressure on ‘sustainability’ of
products, there is increased
scrutiny of supply chains.

The distinctive Membershipmake-up of the MMTA—with
its unique geographicalspread, range of metals, mixof SMEs and larger
organisations, and from mine
to consumer,

Our access to data—the
MMTA liaises with othermetals associations andgroups, takes part indiscussion forums and hasaccess to the input of a rangeof Member companies.

Why not join the MMTA
Sustainable Development
Working Group?
All Members with an interest in
Sustainable Development are
welcome to participate. Email
Tamara to register your interest or
for more information.

12

LETTER FROM NORTH AMERICA
Dear Members

suit?

I recently had a quick glance to see if
there is anything interesting
happening on the T-TIP (Transatlantic
Trade & Investment Partnership)
front, especially anything relating tominor metals. Based on what’s
coming out from the office of the U.S.
Trade Representative, there doesn’t
appear to be that much. The EU still
However, for many Ukrainians inseems intent on there being a sepaCrimea, it looks, unfortunately, to berate chapter dealing with both energy
the start of a new, second, winter.
and raw materials. And whilst I am
And, on this front, I should be remiss
sure its chief negotiator, Ignacio
if I did not refer you to the excellent
Garcia Bercero, does a fine job, it“briefing paper” put out recently byappears that he’s not had much
fellow MMTA member Roskill
success on this point with the U.S. –Information Services. Entitledas can be learned from his rather“Economic sanctions on Russia: The
diplomatic statement (given in his lastpotential impact on minor metals andpost-negotiations press conference inindustrials minerals markets”, it looks
March) that although “the discussions
at “the potential impact that sa
Spring it may already officially be, but
apart from a few green shoots inCentral Park and a couple ofdesultory snowdrops on the Highline,
there’s little sign of its arrival here in
New York. We were even supposedto get more snow last night. Thank
goodness it never materialized.

nctions could have on cobalt, nickel,
niobium, titanium, tungsten andvanadium supply chains as well as
those of potash and refractorymagnesia.” I found it most useful.

Having read it, I thought I’d better
also have a look at the relevant U.S.
Geological Survey (USGS) Mineral
Commodity Summaries for 2014
relating to these materials and seejust how much of them it reckons thecountry imports from Russia.
According to the USGS, in its “Import
Sources (2009-12)”, of these Russia
accounted for: Cobalt (contained inmetal, oxide, and salts) – 11%; Nickel– 16%; Vanadium pentoxide – 43%;
and, Potash – 10%. So one wonders,perhaps, just how those purchasersof all that V2O5 are preparing for any
further eventualities.
On an entirely different front, I noted
the other week, with interest, that,
according to Reuters, whilst JPMorgan
is apparently excluding its metal
brokerage business, including its
London Metal Exchange (LME) ring
dealing team, from the $3.5 billion
sale of its commodity business to
Mercuria, it is believed to be including
Henry Bath, its metals warehousing
operation. Is anybody prepared tooffer me odds on any other metals
warehouse owning-banks following

have been positive and have beenvery constructive. We have not yet
reached the point in which we can saythat both of us have identified thechapter…” Hmm! That does notsound very encouraging to me. But
one never knows.

Finally, as you know, I always like tokeep my eyes open for any
interesting scientific advances in theuse of minor metals here in the U.S.
Back on March 3rd, at the American
Physical Society’s March Meeting,
Professor Ivan K Schuller of the
University of California San Diego,
and his colleagues announced thatthey had developed a new magnetic
material, using bilayers of vanadiumoxide (V2O3) and nickel that isparticularly responsive to heat. As
the APS said in its press hand out forthe meeting: “Schuller and hiscolleagues speculate that the material
could serve as the basis for a whole
new class of data storage, sensors
and energy storage devices”. Now,
that could be really interesting!

April has some great things to lookforward to, not least our annual
conference in London! See you there.
Until then, as always, my best wishes
from New YorkTom Butcher
Hard Assets Investor

ALL AT SEA—THE RISKS TO MARINE CARGO
From the perspective of a company wanting
to transport goods by sea, the marine
environment differs considerably from theland environment. Moving cargo by sea
means exposure to the risks of a maritime
adventure, but as 90% of all cargo moves bysea, these risks are manageable and it must
be remembered that this is the cheapest andmost environmentally-friendly way to move
massive volumes of cargo from one side of
the world to the other.

MMTA OFFICE MEETINGROOMFREE USE FOR
MEMBERSCENTRAL LOCATION

However, the sea poses unique challenges,
and both security and insurance are key
considerations in mitigating these challenges. Maria Cox has been speaking
to Peter Cook, CEO of the Security Association for the Maritime Industry(SAMI), and Erwin Slagter of AON Commodity Commodity Trade in the
Netherlands, and a member of the MMTA’s Insurance Task Force.
There are many millions of containers in the system throughout the global
supply chain and the size of container ships has grown incredibly quickly tomeet the demand; ten years ago the largest container ship could carry 9,000
twenty-foot containers, whereas we now have ships that can carry more than
18,000.

Click here to book theBoth Peter Cook and Erwin Slagter identify piracy as a major maritime
concern, and while Somali piracy has focused on hijacking vessels to ransom
crews, elsewhere cargoes are the target. Off West Africa vessels are being
attacked, hijacked and their cargoes stolen. It should be noted, however, that
container ships do move faster (planning speed 23kts) and have a higher
freeboard than other types of ships, making them less vulnerable toboarding by pirates whilst transiting high risk areas.
In areas of SE Asia, it is pilferage of cargoes that is a bigger problem – bothfrom ships and also within ports. Container ships may be less vulnerable topiracy but they are still vulnerable to other forms of crime – and container
theft from ports is a major problem which, Peter Cook states, has seen hugeinvestment in state-of-the-art security systems within the world’s major
ports. Security notwithstanding, according to Erwin Slagter, theft of cargofrom containers is a near-daily occurrence, and sometimes the seals of thecontainer remain intact. There are many ways to steal cargo from containers,
including known cases where valuable cargoes were replaced by rocks withthe same weight, which was only discovered when the receiver was
unloading the container. Such situations could even disturb relationships
with suppliers, however an experienced insurance broker would be able toco-ordinate and solve the matter in a satisfactory way.
The natural environment can be another huge challenge to cargoes. Perhaps
the most recent illustration of what can happen was shown when over 500
containers were washed overboard from the vessel “Maersk Svendborg”
recently. Peter Cook reminds us that the sea is a hugely challenging
environment, and not one to be treated lightly. The cargo is exposed to theelements and therefore heat, cold and wetting risk. This is all dependent not
only the weather itself, but upon what route the ship will take, as well as
where and how well the cargo isstowed on the ship.
A vessel can also sink, have a collisionor be damaged by fire, or even
explosion. There are so many risks
which could lead to loss or damage toa cargo when transporting by sea
from A to B, as well as during storage.
It is incumbent upon the shipper tounderstand the threats and potential
problems posed.

MMTA meeting room.



Screen, projector &flipchart



Wi-fi



Tea, coffee, waterprovided—otherrefreshments can bearranged at cost

Library and PC resources

Flexible booking andcancellation — just email us

13

REPORT FROM THE
ICMM ASSOCIATIONSMEETING, LONDONThe MMTA recently attended the
Associations meeting of theInternational Council on Mining &Metals (ICMM) which brings
together over 20 mining & metals
companies and 34 mining & metals
associations. We were able to learn
more about ICMM’s interactions
with the Asia Pacific Economic
Cooperation metals and chemicals
working groups and how it intends
to engage with this important groupin the areas of metals specific,
including alloy, risk assessment.
The meeting discussed metals
messaging to improve thereputation of metals in general – eg
the development of ‘World Without
Metals’ marketing materials,
because if the value of metals can’tbe established outside of theindustry (ie to the public and to
regulators) it’s difficult to get
traction on regulatory issues thatare negatively impacting the sector.

ALL AT SEA—THE RISKS TO MARINE CARGO, CONT’D….
This will involve assessing not just the security aspects but the means oftransferring risk through insurance, and of limiting potential liabilities andcommercial exposure.
Erwin Slagter adds that even when there is no actual loss or damage to thecargo of the trader, it is still possible that the owner of the cargo is liable forcosts/expenses or has to contribute to the costs of a General Average.
All Risk insurance provides coverage for loss and/or damage caused by an
external cause. Simply said, something must have happened. However there
are also situations where the cause of the loss is "unexplained" and/or
damage is "inherent to the product".
When cargo is sold on FOB terms, and the trader (as seller) has not been(fully) paid, the seller may consider that they do not have to insure, but they
still have a financial interest in the safe arrival of the cargo. Cargo insurance
for such a "seller's risk" would be advisable. The financial interest of a
trader could further be protected by a credit insurance, which would cover
the non-payment of the buyer.
There are many insurance solutions, often tailor-made for trading
companies. The brokers who are active Members of the MMTA are
specialised in designing tailor-made insurance solutions and provide tailormade services and support for commodity traders.

Peter Cook – CEO, Security Association for the Maritime
Industry and Erwin Slagter, Aon Risk Solutions

EXPORTING TO CHINA? HOW TO ENSURE COMPLIANCE WITH
LOCAL PRODUCT LEGISLATION

Access to market was one of the
key discussions with the effect ofdownstream regulation and its
impact on business upstream.
With the metals industry feelingunder threat from the impact of avariety of hazard-based regulations
in many regions of the world, theneed for a harmonised and broad
based approach to promote thebenefits of metals was discussed,
focussing on the importance to theentire value chain.
If there is no market access, there is
no reason for production and noreason to dig the hole in the ground.
The MMTA will continue to follow
these crucial developments.

14

China is an important emerging
market for many metal producers
and traders and since 2010 has
been implementing a raft of new
and revised chemical legislation,
similar to those of Western
economies.
Hazardous chemicals are regulated
in China through a complex
network of regulations, orders andstandards, with an overarching law
for existing chemicals: the‘’Regulation on the Safe Management of Hazardous Chemicals’’, also
known as Decree 591. This networkof legislations specifies how
hazardous chemicals should be
identified, specifies the use of labels
and safety data sheets tocommunicate these hazardous
properties, details how they shouldbe packaged and transported in
China, as well as any entry-exit
inspections to which they are
subjected.
Finally, production of, as well as
import of hazardous chemicals into
China requires registration of theseproducts, and special licenses for
producers, importers, transporters,
and also for owners of warehouses
in China. Registration and licensing
can only be undertaken by Chinese
entities, therefore, by Chinesebased companies or local agents/
representatives appointed byforeign suppliers.

Foreign companies experience thatcompliance with chemical legislationin China is not without challenges:
the first challenge consists of finding
the relevant, applicable legislations:laws, regulations and standards arein most cases only available on
Chinese websites, making themdifficult to locate for those who do
not understand Chinese.
Once the legal text has beenobtained, the next challenge consistsof understanding the requirements:
legal documents are generally only
available in Chinese. Sometimes nonofficial English translations are madeavailable, however it can be difficult
to establish the accuracy of these.
Where reliable translations areavailable, the next hurdle is tounderstand the use of terminology.
Another challenge consists ofmaintaining an overview of thedifferent types of hazardous
chemicals’ lists, determining how
they can be linked to each other andunderstanding their related
requirements. These lists are
updated on a regular basis, with
substances, including metals andmetal compounds, being added or
removed from the lists. This requires
vigilant monitoring to ensure timely
compliance with any new
requirements.

REPORT FROM THE
MINVENTORY WORKSHOP,BRUSSELS
Around 50 attendees gathered in
Brussels for a workshop on the
Minventory portal. The aim of
Minventory, a DG Enterprise-products are considered hazardous
commissioned project, is toin China while not in other regions.
Chinese compliance procedures also implement a pan-European
involve a complex network of
database on raw materials’ deposits.
authorities.
China also has a REACH-likelegislation requiring hazard testingand notification. It is, however,focused on new chemicals, i.e.
chemicals that are not listed on the
Chinese list of existing chemicals, theInventory of Existing Chemical
Substances in China (IECSC). Metals
and metal compounds that havebeen produced and traded for many
years and are included in existingchemicals lists in Europe and North
America should not, however, beassumed to be Included on the
Chinese IECSC list. Not all metalcompounds are included in this list,
and those that are not will require
notification before import into or
production in China.

A lack of knowledge of the Chinese
language and administrative system
can cause uncertainty and makeobtaining clarifications and written
confirmation challenging for foreigncompanies. Nevertheless, theconsequences of non-complianceinclude fines, delays in productdelivery to customers and, in severecases, restriction from future import
Many of the Chinese laws onof certain products. Companies
hazardous chemicals are actuallybased outside of China often rely on
national implementations ofinternational model regulations
local consultants to guide themdeveloped by the United Nations
through the complex Chinese(UN). Implementation is, however,legislation and to overcome thenot based on a like for likelanguage barrier. However, without atranslation, but is achieved through a minimum level of internal expertise
patchwork of interlinked laws andthere is always a risk when relying
related standards. For example, thecompletely on a 3rd party. A
UN Globally Harmonised System on
combination of internal expertiseClassification and Labelling isand a network of outside experts are
implemented through circa 12 laws
needed for effective implementationand 50 standards.
of the Chinese chemicals legislation
National legislation can also deviate
and compliance when exportingfrom the international model
products to China.
regulation by including countryQiang Fu, Rio Tinto
specific requirements e.g. some

It has three main objectives:To create a comprehensive
directory of information
regarding key resources, public
and private, are located within
the EU28 countries,To create online access to thisinformation, and

To develop an action plan for the
harmonisation of European
mineral resources’ data where
this is useful and feasible up to2020.

During the day, which was the thirdand final workshop of the project, thegroup reviewed the portal anddiscussed the ways that the data forprimary, secondary and tertiarymineral resources could be improved
over time, working towards thesecond and third aims of the project.
The first phase of the work has been
completed and involved surveys of
public and private holders of data
throughout the EU at national andregional level.
The project is being delivered by aconsortium of Geological Surveys
from different parts of the EU28, andis being co-ordinated and project
managed by Oakdene Hollins in the
UK. www.minventory.eu

15