The European Union’s Critical Raw Materials Act (CRMA) has moved into an implementation phase where industrial policy is becoming measurable through project selection, permitting frameworks, financing structures, procurement mechanisms, and supply-chain coordination across strategic raw materials.
The regulation sets binding targets for 2030 requiring at least 10% of EU annual strategic raw materials consumption from domestic extraction, 40% from EU processing, and 25% from recycling, while limiting dependence on any single third country to no more than 65% of supply for each strategic material. These benchmarks now underpin project finance, offtake negotiations, public funding decisions, and trade policy across lithium, graphite, nickel, cobalt, rare earth elements, gallium, tungsten, magnesium, manganese, and copper.
Strategic Project Selection Across Europe and Allied Jurisdictions
In 2025, the European Commission selected 60 strategic projects under the CRMA framework, including 47 projects within the EU and 13 in third countries or overseas territories. EU projects span 13 member states and cover extraction, processing, recycling, and substitution, while external projects are located across Serbia, Greenland, Norway, Ukraine, Canada, Kazakhstan, Madagascar, Malawi, Brazil, Zambia, South Africa, New Caledonia, and the United Kingdom.
The selection reflects sector exposure, with 22 lithium projects, 12 nickel, 11 graphite, 10 cobalt, and 7 manganese projects included in the EU list. Additional materials include rare earths, tungsten, magnesium, gallium, germanium, copper, and platinum group metals, highlighting exposure across batteries, magnets, defence systems, semiconductors, grid infrastructure, and industrial metals.
Lithium Development Pipeline Spanning Multiple EU States
Lithium projects feature prominently in the CRMA portfolio, including Eramet’s Ageli geothermal lithium project (France), Savannah Resources’ Barroso Lithium Project (Portugal) with a JORC resource of 39 million tonnes at 1.05% Li₂O, Imerys’ EMILI project (France) targeting 34,000 tonnes per year of lithium hydroxide, and Keliber Lithium (Finland), which has begun mining at Syväjärvi and secured financing involving the European Investment Bank, Finnvera, commercial banks, and shareholders.
Additional projects include Cínovec (Czech Republic) promoted by Geomet, Las Navas and Mina Doade (Spain), Rock Tech’s Guben lithium hydroxide converter (Germany), Lifthium’s Lift One (Portugal), Viridian Lithium (France), and Vulcan Energie Ressourcen’ Zero Carbon Lithium project (Germany). Vulcan’s Lionheart platform includes a financing package of approximately €2.2 billion and targets 24,000 tonnes per year of lithium hydroxide monohydrate in Germany.
Graphite and Anode Material Supply Chains
Graphite-related projects highlight Europe’s transition toward full battery-material chains. Selected EU initiatives include Talga Natural Graphite One (Sweden), Tokai COBEX’s BAM4EVER (France), UP Catalyst’s CO2Graphite (Estonia), NGC Battery Materials’ European Initiative (France, Namibia, Germany), Hycamite (Finland), and SALROM Baia de Fier (Romania), alongside multiple recycling projects producing battery-grade graphite.
External and associated supply chains include GreenRoc Strategic Materials’ Norgraph/Greenland Graphite platform, linking Norway processing with Greenland extraction. The Amitsoq project in Greenland, with a 30-year exploitation licence and a resource of 23.05 million tonnes at 20.41% graphitic carbon, is also part of the broader graphite pipeline. Additional feedstock projects include Balakhivka (Ukraine), Maniry (Madagascar), and Sarytogan (Kazakhstan).
Projects such as Talga’s Vittangi, targeting 19,500 tonnes per year of anode material, demonstrate integration of extraction and refining, while others reflect growing emphasis on active anode material rather than concentrate exports.
Rare Earths, Magnet Supply and Midstream Processing
Rare earth projects under the CRMA include CAREMAG (France) by Caremag SAS, MagREEsource’s MagFactory (France) focused on magnet recycling, Mkango Resources’ Puławy Rare Earth Separation Plant (Poland), Itelyum’s LIFE22-ENV-IT-INSPIREE recycling project (Italy), and LKAB’s ReeMAP project (Sweden) integrating Malmberget, Per Geijer, and Luleå Industrial Park. Outside the EU, selected projects include Songwe Hill (Malawi) and Zandkopsdrift (South Africa).
The structure reflects Europe’s reliance on separation, metal-making, alloying, and magnet manufacturing capacity rather than deposits alone. Recycling and circularity are increasingly embedded in the supply model, particularly for post-2030 material recovery.
Tungsten, Gallium, and Defence-Linked Materials
Defence-critical materials also feature in the CRMA framework. Projects include Abenojar Tungsten’s El Moto project (Spain), Iberian Resources Spain’s P6 Metals (Spain), and Tungsten West (United Kingdom).
Gallium supply is represented by a Greek project led by METLEN Energy & Metals and European Bauxites, combining BAUX-EU, GALLANT, and LEADER, integrating bauxite, alumina, aluminium, and gallium production. Gallium is primarily recovered from alumina and zinc processing streams rather than mined directly, reinforcing reliance on industrial recovery systems.
Copper Projects Supporting Electrification and Grid Expansion
Copper projects included under the CRMA span extraction, processing, recycling, and polymetallic development. EU projects include Aguablanca (Spain) by Rio Narcea Recursos, Atlantic Copper’s CirCular recycling project (Spain), SOMINCOR’s Lombador North Phase 2, Semblana, and 3rd SILO (Portugal), Cobre Las Cruces polymetallic project (Spain), Euro Sun Mining’s Rovina (Romania), and Anglo American’s Sakatti (Finland). External inclusion extends to Nussir (Norway), reflecting broader European supply diversification beyond EU borders.
Second Selection Round and Expanding Competition
In January 2026, the Commission closed its second strategic project call, receiving more than 160 applications, including 95 from within the EU and 66 from outside the bloc. Of these, 75 projects support the battery value chain, while 21 focus on rare earth elements for permanent magnets. The first round received 170 applications, with 60 projects selected, highlighting increasing competition for strategic designation, financing access, permitting acceleration, and policy visibility.
Permitting Framework and Regulatory Acceleration
Strategic projects are expected to benefit from streamlined permitting timelines of 27 months for extraction projects and 15 months for processing or recycling projects. Implementation depends on member state administrative capacity, legal clarity, and coordinated single-contact permitting structures.
The European Critical Raw Materials Board coordinates project selection, financing alignment, exploration, monitoring, recycling policy, and strategic stock discussions across member states and the European Commission.
Procurement Platform and Demand Aggregation
The EU’s Raw Materials Mechanism became operational in April 2026 as a voluntary platform aggregating demand and linking buyers with suppliers, financiers, and storage providers across all 17 strategic raw materials and more than 150 products.
Key milestones include:
- Buyer submissions: 13 April–5 June 2026
- Buyer aggregation: 17 June–2 July 2026
- Supplier submissions: 13 July–9 September 2026
- Results communication: 23 September 2026
The platform is designed to convert fragmented industrial demand into coordinated procurement signals for strategic materials.
Financing Framework and Investment Mobilisation
The RESourceEU Action Plan (December 2025) aims to mobilise up to €3 billion over 12 months for priority raw materials projects, coordinated with the European Investment Bank, member states, and EU funds.
Project financing requirements vary widely, including €2.2 billion for Vulcan’s lithium project, approximately €783 million for Keliber, and substantial capital requirements across EMILI, Barroso, Talga Vittangi, Rock Tech Guben, Caremag, Sakatti, San José, Viscaria, and Amitsoq.
Recycling Targets and Industrial Constraints
The CRMA sets a target of 25% recycling contribution by 2030, while data indicates limited recycling availability across key materials. Of 26 materials linked to the energy transition, seven have recycling rates between 1% and 5%, while 10 materials, including lithium, gallium, and silicon metal, are not recycled at scale.
Selected recycling projects include:
- Northvolt Revolt NorthCYCLE (Sweden)
- Fortum Battery Recycling Hydromet (Finland)
- Orano Batteries Hydrometallurgy (France)
- Elemental Battery Metals POLVOLT (Poland)
- Portovesme CRM Hub (Italy)
- Additional projects involving Umicore, Solvay Chimica Italia, Circular Materials, Atlantic Copper, MagREEsource, and Itelyum
These projects span lithium, nickel, cobalt, manganese, graphite, and platinum group metals recovery.
External Strategic Projects and Supply Diversification
External CRMA-designated projects include Rio Tinto’s Jadar (Serbia) for lithium and boron, GreenRoc Norgraph (Greenland/Norway), Songwe Hill (Malawi), Zandkopsdrift (South Africa), Sarytogan (Kazakhstan), Maniry (Madagascar), Dumont Nickel (Canada), and SMP Brazil (Brazil).
These assets expand Europe’s supply chain beyond the EU while introducing jurisdictional, permitting, and financing variability across allied and partner countries.
Policy Delivery Risk and Market Constraints
The European Court of Auditors (2026) reported that EU import dependency thresholds remain above 65% for lithium, magnesium, gallium, and rare earth elements, with continued reliance on China for several materials and Chile for processed lithium. It also noted limited recycling penetration across multiple critical raw materials. The execution phase now shifts CRMA implementation from project selection toward delivery, financing, permitting completion, offtake contracting, and production readiness across Europe’s critical raw materials supply chain.
