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.