The European Union’s Critical Raw Materials Act (CRMA) was adopted in April 2024 and has been enforced since May 2024. The legislation is intended to secure raw materials for Europe’s green energy transition, digital economy, defence systems, aerospace manufacturing and advanced technologies. It also recognizes mining, processing and recycling as strategic pillars of Europe’s long-term economic security.
The CRMA is linked to geopolitical pressure over access to critical minerals. Europe remains heavily dependent on imports for many strategic materials, with supply chains often concentrated among a small number of countries, particularly China. China controls most global processing capacity for several strategic materials, including rare earth elements, graphite, gallium and magnesium.
Import dependence and concentration in processing capacity
The Democratic Republic of Congo dominates cobalt mining, while Turkey and South Africa are major suppliers of boron and platinum group metals. European policymakers describe the concentration of supply as an economic and security risk. Supply disruptions, export restrictions and rising geopolitical tensions are cited as factors that can affect industrial economies when critical materials are controlled by limited global suppliers.
The CRMA sets out an approach intended to reduce these risks through domestic extraction, refining and recycling targets. It also includes supply chain diversification across the EU. The framework is designed to address both upstream sourcing and downstream processing capacity.
EU identifies critical and strategic raw materials
Under the CRMA, the EU identified 34 critical raw materials and 17 strategic raw materials. The regulation lists goals for 2030 covering domestic extraction, processing within the EU, recycling and limits on reliance on a single non-EU supplier. The targets include at least 10% of annual consumption from domestic extraction.
Additional 2030 goals include at least 40% processed within the EU and at least 25% coming from recycling and secondary recovery. The framework also sets a cap of no more than 65% of annual supply depending on a single non-EU country. Strategic materials named in the legislation include lithium, nickel, copper, graphite, cobalt, tungsten, manganese, platinum group metals and rare earth elements.
These strategic materials are described as vital for electric vehicles, renewable energy systems, semiconductors and defence technologies. The CRMA’s structure is aimed at strengthening resilience while accelerating investment into mining, refining and recycling infrastructure. It also links policy priorities to industrial competitiveness and technological development.
Strategic Projects with accelerated permitting
A key element of the CRMA is the designation of officially recognized “Strategic Projects.” Projects granted this status receive regulatory advantages including accelerated permitting timelines, priority treatment from regulators and simplified administrative procedures. They also receive easier access to financing and recognition as serving the public interest.
Mining extraction projects are expected to receive permits within a maximum of 27 months. Processing and recycling projects face a shortened 15-month approval timeline. In March 2025, the European Commission approved 47 Strategic Projects across 13 member states.
Later in 2025, an additional 13 non-EU projects were added to bring the total to 60. The selected projects cover mining, refining, recycling and substitution technologies. Materials referenced among project scopes include lithium, nickel, rare earths, graphite, tungsten and platinum group metals.
National implementation: France, Spain and Germany
France hosts 10 Strategic Projects, spanning lithium extraction, rare earth recycling, graphite processing and nickel refining. Named projects include Imerys’ EMILI lithium project in central France and Eramet’s Ageli geothermal lithium project. Other listed facilities include Caremag rare earth recycling and GALLICAM nickel processing.
The French pipeline also includes advanced graphite and battery materials facilities referenced under the CRMA framework. France has launched a Critical Metals Fund backed by up to €2 billion, aimed at financing mining, refining and recycling infrastructure across the critical minerals supply chain. French authorities have also modernized mining regulations to improve environmental oversight while speeding up strategic industrial development.
Spain has seven Strategic Projects focused on copper, nickel, lithium, tungsten and recycling. The country is described as having significant untapped mineral resources but historically faced permitting delays and administrative complexity that slowed mining development. The CRMA’s accelerated approval process is described as potentially reducing project timelines while implementation challenges remain.
Spanish authorities are adapting national systems to comply fully with the EU framework under the CRMA. Social opposition is also cited as a factor affecting Spain’s mining sector, with resistance from environmental groups and local communities mentioned for some projects due to ecological impacts and land use concerns. Spain has introduced a national mineral raw materials strategy aimed at supporting exploration, domestic supply chains and industrial growth.
Germany, described as central to Europe’s industrial and automotive base, hosts several high-profile Strategic Projects under the CRMA framework. These include Vulcan Energy’s geothermal lithium extraction project; Rock Tech Lithium’s hydroxide conversion facility; and PCC Thorion’s silicon-based graphite substitution project.
Germany has established a state-backed raw materials fund managed through KfW to support mining, refining and recycling projects domestically and internationally. The fund is described as focused on securing battery supply chains for Europe’s electric vehicle industry while reducing exposure to imported raw materials.
Belgium focus on germanium processing; legal requirements for firms
Belgium emphasizes recycling, refining and urban mining under its CRMA approach. Projects led by Umicore focus on germanium processing and advanced substitution technologies intended to reduce dependence on imported semiconductor materials. Belgium is also described as a hub for EU-level policy coordination because many institutions overseeing the CRMA are based in Brussels.
The CRMA places strong emphasis on recycling as part of efforts to reduce dependence on imported raw materials. Recycling targets are positioned as central to long-term supply strategy for lithium, nickel, cobalt, graphite and rare earth elements used in batteries and renewable energy systems. Urban mining is highlighted as an industrial priority involving recovery from electronic waste, batteries and industrial scrap.
The expansion of Strategic Projects is also linked to legal and regulatory challenges for companies involved in joint ventures or financing structures. Joint ventures, government-backed financing and long-term supply agreements may be subject to scrutiny under EU competition law, merger control rules and State aid regulations. Firms involved in CRMA projects must navigate antitrust compliance alongside foreign direct investment screening.
The listed compliance areas also include State aid approvals, environmental permitting requirements and supply chain reporting obligations. The framework therefore connects project development with multiple regulatory processes beyond permitting timelines alone.
