Communication from the Commission to the Council and the European Parliament on the competitiveness of the metals industries - A contribution to the EU's growth and gobs strategy {SEC(2008)246}
Date: 2008-02-22
Institutions: European Commission
Subjects: competitiveness, economic and social cohesion, economic growth, metalworking

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 22.2.2008 
COM(2008) 108 final 

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL AND THE 
EUROPEAN PARLIAMENT  

ON THE COMPETITIVENESS OF THE METALS INDUSTRIES 

A contribution to the EU's Growth and Jobs Strategy 

{SEC(2008)246} 

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Introduction 

The  metals  industries  play  an  important  role  in  the  value-chain  of  many  European 
manufacturing  industries.  This  Communication  assesses  the  competitiveness  of  these 
industries  and  makes  recommendations  on  the  way  forward.  It  follows  on  the  2005 
Commission’s  Communication  on  EU  industrial  policy  which  announced  several  sectoral 
initiatives,  including  a  Communication  assessing  the  impact  of  raw  materials  and  energy 
supply on the competitiveness of the European metals industry1, and takes into account also 
the 2007 midterm review of industrial policy.2  

As an intrinsically high energy intensive sector, the metals industries are directly influenced 
by the Community policies on energy and climate change. The European Council underlined 
in  March  2007  “the  great  importance  of  the  energy  intensive  sector”  and  emphasized  that 
“cost  efficient  measures  are  needed  to  improve  both  the  competitiveness  and  the 
environmental impact of such European industries". In this context, the Commission's climate 
action and renewable energy package of 23 January 2008 acknowledges the specific situation 
of energy-intensive industries which are directly exposed to global competition. 

This Communication addresses the key factors influencing the performance of the sector and 
identifies  how  the  Commission,  the  Member  States  and  industry  itself  can  contribute  to 
safeguarding and reinforcing the sector’s competitiveness in the future while contributing to 
the ambitious goals on greenhouse gas emission reductions until 2020. 

The main issues addressed in this Communication take account of the responses to a Public 
Consultation  in  September  2006  which  was  preceded  by  the  adoption  a  Commission  Staff 
Working Document3 providing a detailed picture of the sector in terms of statistics and major 
economic trends.  

1. 

CHARACTERISTICS AND CHALLENGES OF THE METALS INDUSTRIES 

1.1.  Major structural features 

Metals  industries4are  considered  basic  industries  as  metals  production  is  the  first  important 
upstream  step  in  the  value  added  chain  of  many  industries  producing  investment  goods 
(mechanical  engineering,  automotive,  shipbuilding,  aerospace,  construction),  and  consumer 
goods. 

As such, they occupy a central place in the industrial structure of most developed economies 
and in many rapidly growing developing economies. Among the major characteristics of the 
metals industries are: 

Capital intensity: very large investments are required in technology and equipment that have a 
very  long  use  (in  general  not  less  than  20-30  years);  hence  investment  decisions  need  a 
supportive and predictable regulatory framework. 

1 
2 
3 
4 

COM(2005) 474 final, Annex II 
COM(2007) 374 final, 4.7.2007 
SEC(2006) 1069, 2.8.2006 
Ferrous and non-ferrous metals as defined in annex, NACE code 27, Eurostat 

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High  energy  intensity:  the  production  process  of  these  industries  requires  very  high  use  of 
energy. The cost of energy generally represents more than 10 % and can be up to 37% (e.g. 
aluminium and ferro-alloys) in the cost structure of the metal produced. 

Further  data  about  the  EU  metals  industries’  performance  and  share  in  global  economy  is 
added in the annex. 

1.2. 

Importance of raw materials 

Access  to  non  energy  raw  materials  is  a  critical  issue  since  EU  metals  production  is  highly 
dependent on imports of ores and concentrates from third countries. Many metallic minerals 
are being extracted in the EU in relatively small volumes compared with global production, 
e.g. nickel (1, 7%), iron ore (2%), copper (5%).5 

Dependence on imported raw materials is reduced by the fact that metals are almost fully and 
indefinitely  recyclable.  The  use  of  recycled  scrap  has  increased  significantly  in  the  last 
decades and represents today between 40-60% of EU metal production. 

Recycling is much less energy intensive, e.g. secondary smelting of aluminium (using scrap) 
consumes only 5% of the electricity used compared to primary smelting. 

1.3. 

Place in and importance to the European economy 

In 2005, the EU 27 metals industries generated a turnover of approximately € 316 billion and 
employed  1.1 million  persons  (corresponding,  respectively,  to  5  %  and  3.3  %  of  total  EU 
manufacturing).6  

The  metals  industry  is  part  of  a  complex  economic  network  including  not  only  upstream 
sectors, but also large segments of the EU’s manufacturing industry such as automotive and 
construction.  Numerous  critical  links  characterise  this  network,  based,  inter  alia,  on  quality 
requirements and innovation, which go to create the metals value chain. 

The  geographical  proximity  of  the  metals’  supply  chain  and  related  industries,  and  their 
mutual  interests  (technical,  logistical,  research,  innovation  and  customer  service)  is  a 
traditional  strength  of  the  EU  industrial  fabric.  This  has  led  to  close  cooperation  and 
inter-dependence with end users, in particular in the development and the production of high 
quality grades of steel or non ferrous metals. 

1.4. 

Industry structure and SMEs 

Due to large capital requirements large companies tend to dominate the market, especially in 
the case of primary aluminium and flat steel products.  

The  process  of  consolidation  and  restructuring  of  the  European  metals  industries  is  very 
advanced  and  has  been  accompanied  by  increased  integration  in  the  global  market.  Steel 
companies have moved initially from a national base to a Europe-wide base and more recently 
have  reinforced  their  global  nature  through  acquisitions  outside  Europe,  or  have  themselves 
been acquired by companies of non- European background. 

5 
6 

SEC(2007) 771. 
Annex, table 1 

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Nevertheless,  the  first  processing  activity  to  prepare  metals  for  use  in  downstream  sectors, 
which is closely linked with metals production, is mainly carried out by SMEs.  

1.5. 

The impact of globalisation and of the new emerging economies 

Most  metals  and  in  particular  non-ferrous  metals  and  their  raw  materials  are  commodities 
traded  in  the  global  marketplace.  The  price  of  commodities  is  determined  on  the  basis  of 
global demand and supply and has been characterized by large cyclical movements. 

The  economic  development  of  many  emerging  economies  has  contributed  to  an  increase  in 
the  global  demand  and  prices  for  metals  and  metals  products  and  has  led  to  unprecedented 
pressure on raw materials supplies and prices. In recent years production of steel in China has 
grown rapidly with annual increases on average above 20%; over a period of 3 years China 
has moved from a situation of net importer to the world’s biggest steel exporter and is today 
the world’s biggest producer in steel, aluminium, copper, lead and zinc.7 

As a sector providing key inputs  to  manufacturing  industry,  while highly dependent on raw 
materials  and  energy,  and  on  a  skilled  workforce,  the  sector’s  performance  should  be 
considered within the framework of sustainable development. 

1.6. 

The competitiveness pillar 

Through continual restructuring/consolidation aimed at reducing costs and moving to higher 
value  segments  of  the  market,  the  basic  metals  industries  have  succeeded  in  maintaining  a 
high degree of competitiveness.  

The EU metals sector has been moving away from its traditional position as a heavy industry 
with low added value (the indicator of value added per person employed has been higher than 
the average of manufacturing industry). 

Innovation has been a key competitiveness driver; this is reflected in an important change in 
the product mix as well as in the development of new technical applications as it is the case of 
precious  metals.  According  to  the  Innovation  Sector  Index8,  the  industry  shows  an  average 
score  in  terms  of  overall  innovation  performance  compared  to  other  NACE  industrial  and 
services sectors.  

The  EU  metals  industries  are  highly  dependent  on  economic  cycles  and  have  recently 
benefited from a significant increase in demand at world level. This has pushed prices up9 and 
improved  the  general  financial  situation  of  many  of  the  companies  in  the  sector  but  at  the 
same time has posed challenges to other manufacturing industries using metal.  

Despite these positive developments there is some cause for concern: 

-  the  EU  25  is  losing  its  share  of  world  metals  production  (in  particular  in  aluminium  from 
21% in 1982 to 9% in 2005 and in steel from 25% to 16%); to some extent this trend is the 
result of rapidly increasing production in new emerging economies. 

7 
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9 

See also annex, table 4 
PRO INNO Europe initiative – INNO Metrics measure: http://www.proinno-
europe.eu/extranet/admin/uploaded_documents/EIS_2005_European_Sector_Innovation_Scoreboards.pdf 
See annex, figure 3 

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-  the  part  of  the  European  consumption  supplied  by  European  production10,  in  the  last  two 
decades, is declining, in particular for crude steel and aluminium. 

- huge dependence of the EU metals industries on energy prices and imported materials. 

The  restructuring  of  the  EU  steel  industry  during  the  ’80s  and  the  beginning  of  the  ’90s 
provides  a  telling  example.  It  involved  employment  reductions  of  some  two  thirds  (from 
750 000 to less than 250 000) and permanent closures of production capacities of more than 
60  million  tonnes,  in  the  EU  1511.  This  restructuring  was  critical  to  improving  labour 
productivity, restoring the viability of the European steel sector, and overall competitiveness. 

The  transition  economies  in  the  new  Member  States  have  been  hit  particularly  hard  by  the 
steel  restructuring.  However,  there  are  now  encouraging  signals  of  economic  consolidation 
and  recovery.  As  a  result  of  the  approved  programmes  and  plans  aiming  at  demonstrating 
viability12,  productivity  levels  were  significantly  increased  and  obsolete  installations  were 
closed  or  modernised,  with  an  overall  positive  result  on  environmental  protection.  The 
productivity levels (tonnes of steel per worker) of Czech and Polish companies are estimated 
to have grown by 30% between 2003 and 200613.  

1.7. 

The Social pillar 

A skilled and available workforce is a major strength of the EU metals industry.14  

However,  the  industry  finds  it  increasingly  difficult  to  attract  skilled  workers,  with  demand 
for engineers in the steel sector far exceeding supply. 

The Steel Technology Platform has identified the following challenges: 

•  the aging workforce in the steel sector, as well as in related research and technical centres;  

•  need for new competencies including managerial skills and entrepreneurship; 

•  better use of existing training structures and clusters between initial training, R&D and life 

long learning;  

•  mobility both at the level of executives and of technicians.  

Social Dialogue has been a traditional policy tool in the EU steel framework since the creation 
of the European Coal  and  Steel  Community (ECSC)  in  1952.  With  the  expiry  of  the  ECSC 
Treaty,  a  European  Social  Dialogue  Committee  in  the  steel  sector  was  officially  set  up  in 
2006. A similar initiative is being considered for the non-ferrous metal sector on the basis of a 
joint request issued by stakeholders. 

10 
11 
12 

13 
14 

Ratio: production in relation to consumption 
Primary steel production and rolling, as defined under the ECSC Treaty. 
The basic rules for operating this restructuring process were laid down in the Europe Agreements, 1993 
-1996. 
Monitoring reports on steel sector restructuring in the Czech Republic and Poland, EC 
See also annex, figure 2 

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1.8. 

The Environmental pillar 

Production processes in the metals industries are generally high energy intensive and, together 
with mining, can also give rise to other environmental effects (emissions to air, water and soil 
and, in the case of mining, land use requirements). 

Nevertheless,  metals  can  provide  significant  advantages  for  the  environment.  Metals  can  be 
indefinitely recycled without loss of basic properties, and with much less energy consumption 
compared  to  primary  production  from  mineral  ores.  Recycling  contributes  to  less  use  of 
primary  raw  materials  and  less  environmental  impacts  from  metal  mining  and  transport  of 
ores. 

As  regards  energy  efficiency,  despite  regular  growth  in  metals  production  over  the  last  15 
years,  final  energy  consumption  of  Europe’s  basic  metal  industry  has  remained  constant  or 
has even fallen. 

As regards emissions, substantial reductions in some major air pollutants have been achieved. 
Although  metals  production  leads  to  significant  CO2  emissions,  their  share  of  total 
greenhouse  gases  (GHG)  emissions  in  2005  for  the  EU  15  was  5,  7%15.  The  trend  for  the 
period 1990 to 2005 was for a reduction of 11% in the case of iron and steel and of 2 % for 
non  ferrous  metals  despite  an  increase  of  5%  and  11%  respectively  in  the  volume  of 
production in the same period.  

In relation to raw materials eco-efficiency, functionality has improved whilst the quantity of 
material  used  in  the  production  of  metals  has  been  reduced  e.g.  for  steel  and  aluminium 
beverage  cans16.  These  trends  must  be  continually  reinforced  in  order  to  improve  total  eco-
efficiency which is also affected by increasing volumes of production. 

2. 

INTEGRATED  APPROACH  TO  ENHANCE  THE  EU  METALS 

AN 
COMPETITIVENESS 

INDUSTRY’S 

An integrated approach should contain the following elements: 

•  ensuring energy supply at competitive prices, through well functioning energy markets; 

•  creating conditions to allow the sector to meet the Community’s environmental objectives 

and to adapt to the requirements of its ambitious climate change objectives;  

•  encouraging R&D and innovation, and high skills;  

•  creating open and competitive global markets and removing distortions in trade in metals 

and raw materials. 

15 

16 

EEA  Technical  report  n°  7/2007-  however  not  all  CO2  emissions  of  the  metals  industry  are  reported 
under CRF category 2.C as reporting may differ from Member State to Member State 
For steel cans the weight has been reduced 16% and for aluminium 30% between 1980 and 1998 

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2.1. 

Energy policy  

The  competitiveness  of  EU  metals  industries  has  been  affected  by  the  rapid  increase  in  gas 
and  electricity  prices.  Also,  changes  in  securing  long-term  supply  contracts  are  seen  as  a 
major issue.  

As highlighted in the Final Report17on energy sector inquiry, the EU's energy markets are not 
well functioning, thus preventing the full benefits of energy market liberalisation, including in 
terms of prices. 

The  European  Council  has  recognised  in  the  Action  Plan  (2007-2009)  Energy  Policy  for 
Europe18 that a new set of measures is needed to create a truly competitive internal market for 
gas and electricity, including an effective separation of supply and production activities from 
network operations (unbundling). 

In order to give effect to these policy aims the Commission adopted on 19 September 2007 a 
package of legislative proposals to ensure a real and effective choice of supplier and improve 
market transparency, including on pricing. 

As  many  of  the  actions  identified  will  take  time  to  translate  into  visible  effects  for  the 
industries  affected,  a  number  of  Member  States  are  considering  transitional  measures  to 
provide increased predictability for the metal industries.  

In addition to the above proposals the following actions are relevant: 

Actions 

1.  Public  authorities  should  assess  initiatives  related  to  pooled  electricity  generation,  long 
term  contracts  and  partnerships.  Information  should  be  shared  among  Member  States  on 
possible solutions and good practices which are in conformity with competition and internal 
market rules. 

2. The Commission will provide guidance, in an appropriate form (including development of 
case law), on the compatibility of long term energy supply contracts with Community law. 

3.  To  increase  energy  efficiency  the  Commission  will,  within  the  framework  of  the 
Competitiveness  and  Innovation  Programme,  together  with  industry  promote  best  energy 
saving practices within the metals industries.  

2.2. 

Environmental policy 

Climate Change  

As large emitters of CO2 the metals industries will be required to make a major contribution 
to climate change mitigation. 

These industries must achieve high environmental performance and energy efficiency without 
losing  competitiveness.  It  is  not  in  the  interest  of  the  European  Union  that  in  the  future 
production  moves  to  countries  with  less  strict  emissions  limits  (“carbon  leakage”)  as  this 

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Sector Inquiry SEC(2006) 1724, pg 4 
Council of the European Union, 7224/07 Presidency conclusions of 9 March 2007 

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would  have  negative  environmental  and  economic  consequences.  For  this  reason,  the 
Commission's climate action and renewable energy package of 23 January 200819 recognises 
and addresses the specific situation of energy-intensive industries. The package sets out clear 
criteria  for  identifying  the  energy-intensive  industries  that  are  exposed  to  the  risk  of  carbon 
leakage.  The  Commission  will  determine  the  sectors  or  sub-sectors  that  fall  within  this 
category; they shall be allocated allowances free of charge up to 100% under consideration of 
most  efficient  techniques;  the  production  process  may  be  taken  into  account  under  strict 
conditions. In this context, the Commission will assess whether metals industries qualify for 
such treatment. In light of international negotiations of a global climate change agreement for 
the  period  post  2012,  the  Commission  will  further  assess  the  situation  of  energy-intensive 
industries and might propose adjustments in particular in terms of free allocation or inclusion 
of imported products in the Community's Emission Trading Scheme.  

Sectoral  agreements  based  on  industry-specific  conditions  can  stimulate  action  in  reducing 
emissions at the international level. Such sectoral agreements should lead to global emissions 
reductions  of  the  magnitude  required  to  effectively  address  climate  change,  and  should  be 
monitorable, verifiable and subject to mandatory enforcement arrangements.  

Integrated Pollution Prevention and Control (IPPC) 

The  current  EU  legal  framework  on  industrial  emissions  includes  the  IPPC  and  so-called 
“sectoral  Directives.”  In  December  2007,  the  Commission  proposed  a  recast  Directive  on 
Industrial Emissions, merging the IPPC and related "sectoral Directives". The proposed text 
strengthens the role of "Best Available Techniques" (BAT) and of "Emerging Techniques"20. 

The  permitting  requirements  of  the  IPPC  Directive  are  not  always  matched  by  equivalent 
standards in third countries.  

Waste legislation 

In  order  to  improve  waste  management  and  to  provide  better  legal  clarity  while  avoiding 
unnecessary administrative costs and delays, the Commission has made a proposal to amend 
the  Waste  Framework  Directive,  which  is  currently  being  discussed  by  the  EP  and  the 
Council. 

The proposal includes a mechanism to clarify when waste ceases to be waste. For this purpose 
it is envisaged that specific criteria, based on technical specifications, should be adopted by 
the Commission through comitology. 

REACH 

While  metals  fall  within  the  scope  of  REACH  there  are  specific  characteristics  of  such 
substances  which  require  attention,  including  the  assessment  of  metals  incorporated  into 
alloys. 

2.3. 

Standardisation 

Standards in the metals sectors play an important role in particular in the framework of public 
procurement directives and are becoming an important instrument of access to third markets. 

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In particular COM(2008) 16 final 
COM(2007) 844 final 

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The Eurocodes, as European standards, are a Europe-wide means for the structural design of 
buildings and  engineering  works  and,  as  such,  are  of  vital  importance  to  the  European 
construction sector and for the free circulation of structural metal products.  

Actions 

4.  The  Commission  will  prepare  the  measures  set  out  in  its  climate  action  and  renewable 
energy  package  of  23  January  2008  on  energy-intensive  industries,  in  particular  the 
determination  of  sectors  or  sub-sectors  concerned  by  carbon  leakage  and  of  the  appropriate 
allocation. In this context, the Commission will assess whether metals industries qualify for 
such treatment. In light of international negotiations of a global climate change agreement for 
the  period  post  2012,  the  Commission  will  further  assess  the  situation  of  energy-intensive 
industries and might propose adjustments in particular in terms of free allocation or inclusion 
of imported products in the Community's Emission Trading Scheme.  

5.  The  Commission  will  explore,  together  with  stakeholders  and  third  countries,  the  role  of 
sectoral agreements that should lead to global emissions reductions of the magnitude required 
to  effectively  address  climate  change,  and  should  be  monitorable,  verifiable  and  subject  to 
mandatory  enforcement  arrangements.  This  will  include  best  practice  methodologies  related 
to data collection and key performance indicators. 

6. In relation to IPPC, the Commission will ensure closer links between the BAT Reference 
documents (BREFs) elaboration process, the European Research Framework Programme and 
the  Competitiveness  and  Innovation  Programme,  in  order  to  provide  support  for  emerging 
techniques. 

7.  In  the  area  of  waste  legislation,  and  subject  to  the  finalization  of  the  legislative  process 
regarding the Waste Framework Directive, the Commission will aim at ensuring cost effective 
use of metals scrap as a secondary raw material for the industry is facilitated. 

8.  In  the  context  of  REACH,  the  Commission,  in  close  cooperation  with  stakeholders,  the 
European  Chemicals  Agency  and  Member  States  will  develop  technical  guidance  related  to 
substances in special preparations. 

9. As to standardisation the Commission will with Member States, seek to promote the use of 
Eurocodes21 related to metals and to reduce disparities in the way they are applied across the 
EU. 

2.4. 

Innovation Research and Development and skills 

The capacity to innovate will be crucial to maintaining competitiveness. R&D will be called 
on to play an important role at product level and in production processes. 

At  product  level,  innovation  is  essential  to  the  differentiation  of  the  final  product.  Different 
metals compete strongly between themselves and with other materials such as composites, in 
order to demonstrate their superior technical and economic performance. 

As regards production processes, current technologies are relatively mature. Nevertheless, the 
industry  is  active  in  seeking  breakthrough  technological  solutions.  For  example,  the  project 
”Energy saving and ultra low CO2 emissions on steel” (ULCOS) gathers together 48 partners 
in order to produce the critical financing mass to tackle the challenge of cutting emissions in 

21 

In line with Commission Recommendation 2003/887/EC of 19 December 2003  

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the steel sector by a target level of 50%. The first step of this project is to run until 2009 and 
the second one until 2014/15. 

Under  the  Steel  Technology  Platform  (ESTEP)  created  in  2003,  metals  producers  are 
co-operating  with  end  users  and  with  equipment  suppliers  to  tackle  the  new  challenges.  A 
similar  approach  is  applied  for  the  European  Technology  Platform  on  Sustainable  Mineral 
Resources  (ETP  SMR)  established  in  March  2005  to  improve  innovative  capacity,  develop 
new products and increase the efficiency and yield of production processes reducing costs and 
impact on the environment.  

The aluminium industry has formed a European Aluminium Technology Platform to develop 
a coherent approach to research and technology. 

Through  the  7th  Framework  Programme,  the  Research  Fund  for  Coal  and  Steel  (RFCS) 
programme,  and  the  new  Competitiveness  and  Innovation  Programme  (CIP)  and  the 
Structural Funds, the EU provides four major instruments for the co-financing of activities in 
the areas of innovation, R&D and skills.  

Actions 

10.  Industry  should  give  priority  to  innovation  and  research  activities,  inter  alia,  by 
implementing major long term projects (e.g. ULCOS), as well as the strategic research agenda 
developed  by  relevant  European  Technology  Platforms;  it  should  take  advantage  of  the 
opportunities  made  available 
instruments  and  by  encouraging 
international  cooperation,  while  taking  due  care  of  intellectual  property  rights  (IPR) 
protection issues. 

through  Community 

11.  Member  States,  universities,  research  centres  and  industry  should  develop  appropriate 
strategies,  including  partnerships  amongst  European  and  with  third  countries,  to  improve 
skills availability. 

12. Member States and regions are invited to promote innovation in the metals industries and 
support  cluster  resident  technology  transfer  policies.  This  includes  support  for  incubation, 
technology  transfer,  skills,  and  early  stage  finance  of  research  spin-offs  with  particular 
emphasis on helping SMEs and innovative start-ups with a high growth potential.  

2.5. 

External Relations and Trade Policies 

Access  to  raw  materials  is  essential  to  European  industry.  The  Competitiveness  Council  of 
21 May  2007  requested  the  Commission  to  develop  a  coherent  political  approach  to  raw 
materials  supply  for  industry,  encompassing  all  relevant  Community  policies.  The 
Commission will give priority to the establishment of a level playing field both for metals and 
their raw materials in its trade policy, and in the framework of its external relations with both 
industrialized countries and emerging economies.22  

Distorting  practices  have  tended  to  proliferate  in  recent  years  under  a  number  of  different 
mechanisms, including export restrictions, export duties, selective VAT rebates, subsidies and 
others.  For  example,  Russia  applies  taxes  up  to  50%  on  the  export  of  scrap;  India  has  just 
introduced an export tax on iron mineral ore; China does not allow foreign companies to have 
a majority stake in sectors like steel and has introduced a variety of mechanisms that restrict 

22 

See also annex, table 3 and 5 

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the  export  of  metals  raw  materials  or  provide  governmental  support  for  buying  them  from 
external sources. 

Such practices create serious difficulties for European industry and must be tackled using all 
available instruments, including through reinforced dialogue. 

Internationally, the G8 Summit in addressing the issue of raw materials discussed the situation 
on  world  commodity  markets  and  recent  price  increases,  reaffirming  their  commitment  to 
free, transparent and open markets. 23 

Actions 

13. The Commission will continue to use all existing instruments to address trade practices in 
violation of international trade agreements. 

14.  The  Commission  will,  within  the  framework  of  multilateral  and  bi-lateral  trade 
negotiations,  continue  its  efforts  to  oppose  the  use  of  export  taxes  on  metals  and  raw 
materials. 

15. The Commission will present a Communication in 2008 aimed at improving conditions of 
sustainable access to minerals and secondary raw materials at EU and international level24. 

16. The Commission will maintain close industrial dialogue with key third countries. 

23 
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G8 Summit 2007, Declaration, Chair’s summary, 8.6.2007 
Public consultation http://ec.europa.eu/enterprise/newsroom/cf/itemlongdetail.cfm?item_id=1249 

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