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TdH NL feedback on the proposed European Critical Raw Materials Act

June 23rd, 2023

The European Union’s strategic autonomy of critical raw materials supply should be built on equitable and mutually beneficial Strategic Partnerships with third countries. And it can not be detrimental to the wellbeing and livelihoods of children and families there. This is the core of TdH Netherlands’ feedback to the proposed EU legislation on Critical Raw materials submitted today to the European Commission.

Child labour in the mica mines


Julie Verhaar, CEO of Terre des Hommes Netherlands: “We support the proposed European Directive and urge the EU to ensure that securing the supply of critical raw minerals does not come at the cost of human and child rights violations in third countries. This will set the basis for a viable future for children everywhere”.

Mines sites not only have the risk of direct exploitation in the operations in the forms of child labour but also have diverse negative effects on children such as environmental degradation of their communities and a high risk of sexual exploitation around the mines. Our work in the mica mines in Madagascar and India provides ample evidence of this.


Points of concern

Terre des Hommes Netherlands raised a few points of concern, asking the European Union:

  • To further investigate mica and consider adding this material to the critical and strategic raw materials lists, as it is a vital mineral for the green transition, there is a concentration of extraction and production in few countries which represents a high risk of supply disruption and there are currently no alternatives for mica.
  • To actively support and engage with countries that might still need to meet the criteria for strategic partnership prioritisation but show a high risk of child exploitation, including Madagascar.
  • To add vulnerable groups such as children, child protection and zero tolerance for child labour, alongside the requirements for ensuring socially responsible practices in the strategic projects.
  • Strategic projects in third countries should intentionally address issues of skills development,labour rights, investment in local processing capacity, working conditions and living wages so that parents can meet the basic needs of their families, reducing the risk of children being forced to work.

The feedback of Terre des Hommes will feed into the European legislative debate.

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