Mining 2025

FINLAND Trends and Developments Contributed by: Tarja Pirinen, Fiiu Linninen, Malin Holm and Jaakko Klemettilä, HPP Attorneys Ltd

operating and investment environment for circu - lar economy operators. At the same time, it will be assessed whether some parts of the current Waste Act should be divided into separate Acts. The working group responsible for outlining the reform was established in the summer of 2024 and will operate until the end of 2025. Planning of incentives for the introduction of the best technologies and circular economy solutions is also defined as one of the six main objectives in the National Mineral Strategy of Finland which was published in December 2024. The circular economy is a particularly good opportunity for the mining industry because it generates various side streams. According to Statistics Finland, in 2022 mining and quarrying produced circa 76% of Finland’s total waste load measured in tonnes. Making the use of extractive waste more effi - cient is an important theme that operators in the field have the will and ability to grasp. The social order is strong because the mining industry is under excessive pressure to act sustainably and responsibly. On the other hand, more efficient use of extractive waste would also make it pos - sible to curb the consumption of virgin natural resources, as called for in the national circular economy programme. At the same time, energy would be saved, and carbon dioxide emissions would be reduced once excavated and crushed rock would be exploited, not to mention natural values and biodiversity. In a study commissioned by the Ministry of Eco - nomic Affairs and Employment, mining mineral tax has been considered as one feasible way to influence exploitation of waste rock. The mining mineral tax took effect in Finland on 1 January 2024. The revenue collected from the mining mineral tax was estimated to be around

EUR25 million annually, but the view of the min - ing sector appears to be that the estimated revenue was already exceeded in 2024. In the study the mining mineral tax was considered to affect the equation of how rich/poor ore is still worth exploiting as one of the cost factors. It was considered that by keeping the mining mineral tax at a competitive level, it would be possible to improve the chances of exploiting waste rock. On the industrial side, however, it was stated in this regard that waste rock is, after all, an economic definition. The cost level as a whole, including taxes, influences decision-mak - ing about mining and, thus, also the formation and amount of waste rock. Increasing costs is not likely to increase the exploitation of the ore and reduce the amount of resulting waste rock. However, according to the Government Pro - gramme, Finland is planning to revise the min - ing mineral tax as of the government mid-term policy review in middle of 2025 and introduce another tax category for mining mineral tax. The revenue increase has been estimated to be EUR15 million annually. Thus, it cannot be ruled out that the tax burden of mining will be further increased in the coming years. Impact of the Increased Corporate Sustainability Regulation The increase of corporate sustainability regula - tion in the EU also affects the mining industry. The Corporate Sustainability Reporting Directive (2022/2464/EU) entered into force in 2023, and the first in-scope companies will report regarding the financial year 2024 in 2025 according to the implementing national legislation. The reporting is made in accordance with the European Sus - tainability Reporting Standards (ESRS), which require detailed information on environmental, social, and governance aspects. The ESRS introduces a double materiality concept that

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