Europe’s Cobalt OEL: Is Europe About to Undermine Its Own Strategic Ambitions?

By Karolina Chmielewska, Policy & Communications Officer, Cobalt Institute

The proposed EU Occupational Exposure Limit (OEL) for cobalt is entering the final stage of the legislative process, with a decisive trilogue expected on 23 June.

Worker protection must remain the priority. Occupational exposure limits are an essential tool for ensuring safe workplaces, and the cobalt industry supports the introduction of an EU-wide OEL.

However, an important question remains unanswered: has the EU fully considered the wider implications of this proposal for strategic autonomy, defence readiness and critical raw materials resilience?

Despite the significance of the file, no assessment has been conducted of its potential impact on Europe's broader industrial and strategic objectives.

For this reason, the Cobalt Institute is calling for the proposal to be postponed pending a targeted assessment of its implications for strategic autonomy, defence readiness, competitiveness and critical raw materials resilience. This would help ensure that the final OEL protects workers while remaining aligned with the EU's broader industrial and security objectives.

This matters because cobalt is far more than a battery material.

Recognised as both a strategic and critical raw material under the Critical Raw Materials Act (CRMA) and by NATO as one of its 12 defence-critical raw materials, cobalt is essential for aerospace, advanced manufacturing, industrial tools, battery materials and defence applications.

Its importance extends beyond the cobalt value chain itself. Cobalt is a critical component of defence and industrial applications containing tungsten carbide, where cobalt serves as a critical binding material. Following China's export restrictions on virgin tungsten introduced in early 2025, cobalt-containing hard metal scrap has become an increasingly important feedstock for European producers.

At the same time, the Critical Raw Materials Act, RESourceEU Action Plan and forthcoming Circular Economy Package all seek to expand Europe's refining, processing and recycling capacity while reducing external dependencies. Demand for cobalt in Europe is expected to increase by around 350% by 2050.

Yet the current proposal would establish an OEL of 20 µg/m³ and reduce it to 10 µg/m³ after a six-year transition period.

The cobalt industry supports the proposed 20 µg/m³ inhalable alongside a safe level for the respirable fraction, which provides a high level of worker protection while remaining operationally achievable. Together, these limits would constitute the most stringent cobalt OEL in the world, compared with 100 µg/m³ in the UK and United States and 50 µg/m³ in China.

The concern lies with the proposed reduction to 10 µg/m³ after six years and the fact that its broader consequences have never been assessed.

The risk is a self-defeating outcome in which Europe loses refining, manufacturing and recycling capacity while increasing reliance on imports from jurisdictions with significantly less stringent occupational exposure standards.

Europe could ultimately export production, investment and jobs without achieving a corresponding improvement in global worker protection.

The question is not whether workers should be protected, but whether the EU has struck the right balance between worker protection and its broader strategic objectives.

With the final trilogue approaching, there is still time to ensure these wider consequences are properly assessed and that the final framework protects workers while supporting Europe's competitiveness, resilience and security.

Could Your Organisation Be Affected?

With the final trilogue approaching, there is still time to ensure policymakers understand the practical implications of the proposal. If your organisation may be affected, or if you would like to support ongoing engagement efforts, please contact Mike Blakeney, Head of Government and Public Affairs (mblakeney@cobaltinstitute.org) or Karolina Chmielewska, Policy and Communications Officer (kchmielewska@cobaltinstitute.org), before the 23 June.