FINLAND Trends and Developments Contributed by: Tarja Pirinen, Fiiu Linninen, Malin Holm and Jaakko Klemettilä, HPP Attorneys Ltd
phorus. In addition, many other mineral deposits containing critical raw materials have been iden - tified in Finland. The CRMA regulates the establishment of a point of single contact authority for the permit - ting of critical raw material projects which is responsible for facilitating and co-ordinating the permitting process for projects involving criti - cal raw materials and for providing information, including the acknowledgement that an environ - mental permit application is complete. Further, the CRMA regulates the priority status of the so-called Strategic Projects. Strategic Projects under the CRMA are initiatives that are crucial for reducing dependence on imports and securing the EU’s supply of critical raw materials. These raw materials are vital for key sectors, such as renewable energy and digital technologies. The status of a strategic project can be obtained, for example, by a mining project or a circular econ - omy project. Projects with the status of Strate - gic Project must be given the highest possible national status and be treated accordingly in the permitting procedures. The co-ordination of per - mit processes and communications between the operator and authorities is to be conducted by one national authority (the single point contact) to simplify the process. Further, the CRMA sets binding timelines for the permitting of Strategic Projects. The national implementation of the CRMA regu - lations streamlining permitting procedures and timelines for Strategic Projects under the CRMA is currently ongoing in Finland. Provisions of the CRMA will be specified in a new draft legisla - tive proposal on national implementation of the CRMA, whereby Finland will take advantage of the possibility offered by the CRMA to extend the permitting timelines for strategic projects if the requirements for the extension governed
by the CRMA are met. The proposed changes require new provisions to be added to the exist - ing national legislation and are expected to enter into force in Finland during 2025. Efficient imple - mentation of the CRMA is also defined as one of the six main objectives in the National Min - eral Strategy of Finland which was published in December 2024. It should be noted that the proposed legislation and the facilitation measures it provides for the Strategic Projects will, however, not amend any permit requirements, which would continue to be stipulated by the Mining Act, Environmental Protection Act, and the Water Act, for example. In addition, the objectives for water manage - ment (the aim of good status of bodies of surface water and groundwater and the prohibition to cause deterioration thereof) will apply in permit - ting of Strategic Projects. In addition to facilitating permitting, the CRMA includes an obligation for member states to draw up national exploration programmes and regulations aimed at improving the re-use of critical raw materials from extractive waste, as well as other measures to improve sustainability and the circular economy. This will result – eg, in obligations on the members states to record the decommissioned extractive waste areas in a public database and to consider the economic recoverability thereof through various means. The operators who are obliged to prepare an extractive waste management plan must also submit to the authorities a preliminary economic evaluation study of the potential for extractive waste recovery
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