The European Union’s drive to secure critical mineral supply chains is increasingly confronting issues of land access, water use, community participation and benefit sharing in host regions. Under the Critical Raw Materials Act (CRMA), the EU has set 2030 targets for at least 10% of annual strategic raw material consumption to come from domestic extraction, 40% from processing and 25% from recycling. The legislation also seeks to limit dependence on any single third country to no more than 65% at any relevant processing stage.
The policy covers materials including lithium, graphite, rare earths, nickel, copper, cobalt and manganese, which the EU identifies as important for battery manufacturing, grid expansion, defence, digital infrastructure and energy security.
In 2025, the European Commission approved 60 CRMA strategic projects, including 47 within the EU and 13 outside the bloc. The selected projects span mining, mineral processing, recycling and substitution activities, and are intended to receive accelerated permitting attention, financing support and assistance in developing offtake relationships.
Review Examines Non-EU Strategic Projects
A briefing by the Business & Human Rights Resource Centre and civil society partners examined the 13 strategic projects outside the EU, which are located in Serbia, Zambia, Madagascar, Brazil, Malawi, Kazakhstan, South Africa, Ukraine, Canada, Norway, Greenland, New Caledonia and the United Kingdom. The projects include operations associated with established mining groups such as Rio Tinto and Eramet, as well as projects led by smaller and newer companies.
According to the briefing, none of the promoters of the non-EU strategic projects had both a publicly available human rights policy that included protection for human rights defenders and a published environmental, human rights and social impact assessment for the proposed project. The report identified only three project-associated companies with publicly available human rights policies: Société Le Nickel, part of Eramet, Rio Tinto and Jervois Global. It also found that only Eramet and Rio Tinto were associated with recognised responsible-mining initiatives or relevant standards.
Strategic Status Brings Financial and Political Advantages
CRMA strategic designation can improve a project’s visibility with public institutions and potential lenders, while supporting access to financing channels, private investment and offtake arrangements.
The briefing said the European Commission had provided limited public detail on how sustainability criteria were assessed during project selection. The CRMA requires strategic projects to be implemented sustainably, including through measures to minimise environmental and social harm, respect human rights, engage local communities and maintain transparent business practices.
The legislation permits strategic status to be withdrawn if a project no longer meets the relevant criteria. The report argued that the designation should be reviewed, suspended or withdrawn where projects fail to meet environmental, human rights or consultation standards.
Mining developments can face permitting delays, litigation, local opposition, commodity-price volatility and environmental review disputes. The briefing identified incomplete impact assessments, contested consultation processes and limited disclosure as factors that can affect financing, offtake arrangements, insurance terms, lender appetite and project valuations.
Jadar Remains Unpermitted in Serbia
Rio Tinto’s Jadar lithium project in Serbia remains one of the most prominent non-EU CRMA strategic projects that has not yet received permits.
The project has been presented as a potential source of lithium for European battery supply chains. It has also faced resistance from local communities, environmental groups, students and civic movements over concerns involving water, land, pollution, transparency and governance. The briefing referred to reports that Rio Tinto had moved the Jadar project into care and maintenance.
Nussir Copper Project Raises Sámi and Marine Concerns
In Norway, the Nussir copper project has drawn attention over potential effects on Indigenous Sámi livelihoods, reindeer herding, fisheries and planned submarine tailings disposal in Repparfjord. The project is located in a European jurisdiction with stronger institutional frameworks, but its development has also highlighted the commercial implications of upstream environmental and social disputes. The earlier dissolution of a memorandum of understanding involving the project and Aurubis, Europe’s largest copper smelter, showed how responsible-sourcing requirements can affect relationships between mine developers and downstream buyers.
Water Constraints Affect Graphite and Rare Earths Projects
The Maniry graphite project in Madagascar is located in an area where poverty, drought, literacy levels, displacement concerns and local participation in consultation have been identified as relevant issues. Graphite is used in battery anodes, and the project forms part of wider efforts to diversify supply chains outside concentrated processing and refining centres.
In Malawi, the Songwe Hill rare earths project is located in Phalombe District, an area associated with recurring droughts and chronic water scarcity. Rare earth extraction and processing can require significant water use, making water availability a central local consideration.
South African Project Located in Northern Cape
The Zandkopsdrift manganese and rare earths project is located in South Africa’s Northern Cape, a province with high unemployment and poverty. The briefing identified employment, local procurement, infrastructure, land access, compensation, water protection, pollution and closure liabilities as issues relevant to how critical minerals projects are assessed by affected communities.
All 13 non-EU strategic projects examined in the briefing involve mining or processing activities. Only four include processing. The distribution of mineral processing capacity remains central to questions over value addition, industrial development, skills creation, infrastructure investment and tax revenues in producing countries.
Due Diligence Expectations Extend Across Supply Chains
The report said companies developing critical minerals projects require more than resource estimates, preliminary economic assessments and investor presentations to demonstrate project readiness. It identified public human rights policies, protections for human rights defenders, environmental and social impact assessments, community engagement plans, grievance mechanisms, water and tailings management disclosure, Indigenous consent protocols where relevant and benefit-sharing models as important documentation before construction financing is secured.
For lenders and offtakers, the report said CRMA status alone should not be treated as proof of responsible sourcing. It identified environmental and social performance review rights, audit access, community grievance monitoring, suspension clauses and escalation mechanisms as potential safeguards for buyers, public finance institutions and investors.
European battery manufacturers, carmakers, grid suppliers, defence contractors and public finance institutions are among the downstream participants that may be exposed to environmental, social and governance disputes at mine and processing sites. The CRMA combines extraction, processing, recycling, permitting and financing tools with an industrial-security framework intended to reduce supply-chain vulnerability. Its strategic projects will be developed in locations subject to local land, water, infrastructure and governance conditions.
