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Critical Materials & Battery Supply Chains

Critical Raw Materials Act

The CRMA reshapes EU industrial policy around upstream supply. It names the materials that matter, sets capacity benchmarks for the EU itself, caps single-country dependency at 65%, and creates a fast track for projects and international partnerships that move the structure in that direction.

Regulation (EU) 2024/1252

Scope and structure

Establishes a framework to ensure a secure, diversified, affordable and sustainable supply of critical raw materials to the EU. Operates through three levers: lists, benchmarks, and projects.

Adopted
11 April 2024. In force 23 May 2024.
Strategic materials
17 materials listed in Annex I — including battery-grade lithium, cobalt, nickel, natural graphite, magnesium, gallium, germanium, rare earth elements (light and heavy, for magnets), platinum group metals, silicon metal, tungsten.
Critical materials
34 materials listed in Annex II — includes the 17 strategic plus aluminium/bauxite, antimony, arsenic, baryte, beryllium, coking coal, feldspar, fluorspar, hafnium, helium, niobium, phosphate rock, phosphorus, scandium, strontium, tantalum, vanadium and others.
Review
List of strategic and critical materials reviewed at least every three years.

Article 5

2030 capacity and dependency benchmarks

Four targets the EU sets for its own supply structure in strategic raw materials by 2030 — expressed as a share of annual EU consumption.

Extraction
≥10% of EU annual consumption from EU extraction capacity.
Processing
≥40% of EU annual consumption from EU processing capacity.
Recycling
≥25% of EU annual consumption from EU recycling capacity.
Dependency cap
≤65% of EU annual consumption of any strategic raw material — at any relevant stage of processing — from a single third country.

The dependency cap directly targets China's dominance in processing of rare earths, graphite, and several battery materials. The recycling benchmark is the supply-side complement to the Battery Regulation's recycled-content rule.

Title III

Strategic Projects

Designated projects across extraction, processing, recycling, and substitution receive priority status — faster permitting, easier financing, and EU-level recognition.

Eligibility
Contributes meaningfully to security of supply for strategic materials; technically feasible; implemented sustainably; cross-border benefit (for EU projects) or mutually beneficial (for third-country projects).
Permitting deadline
27 months max for extraction projects, 15 months max for processing/recycling projects (from the start of the permit-granting process).
Priority status
Highest national significance under member state law where compatible; treated as being of overriding public interest where required for environmental balancing.
Financing
Access to EU and national financing facilities, including coordinated support via the Critical Raw Materials Board.
Maintained list
Commission publishes and updates the list of Strategic Projects. As of 2025, the list spans extraction, processing, and recycling across multiple member states and partner countries.

Title V

International Strategic Partnerships

Bilateral cooperation frameworks with mineral-rich third countries — designed to diversify supply away from concentrated dependencies and align sustainability standards.

Existing partnerships
Canada, Australia, Argentina, Chile, Kazakhstan, Norway, Greenland, Ukraine, Zambia, DR Congo, Namibia, Rwanda, Uzbekistan — as of 2025, list continues to grow.
Scope
Geological surveys, joint investment, infrastructure, sustainable mining practices, processing capacity, workforce training.
Procurement implication
Partnership status signals EU-aligned supplier countries with stable regulatory horizon — relevant for buyers diversifying away from China-concentrated supply.

Title IV

Monitoring and stress testing

Member states and the Commission jointly monitor supply risk for strategic materials and stress-test critical supply chains.

Commission role
Annual monitoring report covering material flows, prices, capacity, and concentration. Coordinates stress tests on supply chains for each strategic material.
Company reporting
Large companies using strategic raw materials in strategic technologies must audit their supply chains every three years and inform the Commission of supply disruptions.
Strategic stocks
Member states encouraged to build strategic stocks of materials judged supply-critical; Commission coordinates and assesses sufficiency.