Polysilicon Classification under EU Acts
Poly Classification NZIA or CRMA ? maybe both ? A Xmas gift for EU producers ?

Polysilicon Classification under EU Acts

I recently came across an interesting priority question for written answer submitted to the European Commission by Christian Ehler, a Member of the European Parliament (MEP). It pertains to the classification of polysilicon under the Critical Raw Materials Act (CRMA) and/or the Net-Zero Industry Act (NZIA).?

My understanding of this question is that it explores how polysilicon should be considered within these frameworks:

CRMA primary purpose is to ensure a secure and sustainable supply of critical raw materials needed for European industries. It focuses on raw materials such as manganese, lithium, and silicon metal, which are key for certain technologies and value chains. These raw materials are vital and may face a supply risk due to dependency on third country imports.

NZIA supports technologies and components that contribute to achieving net-zero emissions , fostering domestic manufacturing of clean technologies. Polysilicon, as a heavily processed product, clearly fits within NZIA. However, it can also fall under the CRMA category due to its reliance on silicon metal.

The implications of classification under these acts are straightforward. Whilst CRMA secures the availability of polysilicon by reducing dependency on imports and possibly encourages stockpiling of silicon metal or polysilicon itself, NZIA will secure the scaling up of ?manufacturing of net-zero products, encouraging ?investment in innovation, and fosters the development of clean technologies.

Polysilicon might ?not be the direct focus of CRMA since it is not a raw material itself but a refined product . However, its precursor, SILICON METAL , is already listed as a strategic raw material under CRMA. Polysilicon might align more closely with NZIA because it is a critical component in solar technology, a cornerstone of net-zero applications.

The question here if it is possible to have a dual classification that would ensure its supply chain protection and innovative support to its industrial development

From my perspective, YES , polysilicon can and should be classified under both acts. Under CRMA, it is a direct derivative of silicon metal, already listed as a strategic raw material, and is essential for downstream industries such as solar energy. Under NZIA, polysilicon qualifies due to its clean energy applications as a key input for solar panels.

My second thought is which companies within Europe will be mostly and significantly benefit … think about Elkem, silicon metal producer AND? polysilicon refiner … and there are long historical ties between Wacker and RW Sillicium; one a silicon metal producer that ensures the feedstock to the other , a polysilicon refiner

I definitely vote for the double classification


https://www.europarl.europa.eu/doceo/document/P-10-2024-002919_EN.html

Craig Arnold

Executive Vice President - Polyolefins, Circular Economy Solutions, Innovation & Technology

2 个月

An “all of the above” approach should be encouraged to secure critical materials across strategic value chains. Supporting policies is a must. The EU needs to act, and act fast, to consciously address known challenges which will only limit sustainable human progress. #action #EUcompetitiveness #sustainability

Jose Carlos Spinola

CEO AT @ JCS Consultancy and Marketing | MARKET CONSULTANCE FOR SILICON METAL, SILICON ALLOYS , MAGNESIUM AND MAGNESIUM ALLOYS.

2 个月

Excelent report Ant. I agree 100% with your comments.

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