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The German Environment Agency provides recommendations on the EU Commission's proposal for a Critical Raw Materials Act, aiming to ensure a secure and sustainable supply of critical raw materials. The agency suggests revisions to various articles, including:

Ensuring sustainability and security of supply are equally ranked in the proposal
Including all strategic raw materials in the scope of the revised Industrial Emissions Directive
Deleting articles that may override public interest or grant fictitious permits
Extending the scope of exploration to anthropogenic deposits
Including potential adverse effects on people and the environment in supply risk analysis
Amending national programs on circularity to include all "R-strategies"
Restricting critical raw materials in packaging and introducing labelling requirements
Enabling long-term interim storage of CRM-containing waste
Defining the function of certification schemes and adding relevant standards
Extending environmental footprint declarations to indirect imports and including absolute magnitude of environmental impact.