EU Critical Raw Materials Act enters into force

Mechanism

The CRMA stacks four instruments:

1. Targets. Hard 2030 benchmarks per strategic material: - ≥10% extraction from EU sources - ≥40% processing within EU - ≥25% recycling input share - ≤65% from any single third country (the "no single supplier" cap, aimed squarely at Chinese dominance in several critical materials)

2. Strategic Projects. Member states or the Commission can designate projects (extraction, processing, recycling, substitution) as Strategic. Designation triggers fast-track permitting, access to financing, and recognition as "overriding public interest" for environmental authorisation.

3. Joint purchasing. The Commission can organise group purchasing arrangements; large strategic-sector users (battery, EV, defence, renewables OEMs) must conduct periodic supply-risk stress tests.

4. Information system. A new EU body coordinates a monitoring system across member states for stocks, flows, and price indicators on the strategic and critical lists.

Why severity 4

The CRMA is the EU's most consequential industrial-policy move on raw materials in a generation. Severity is high because:

• It creates legally binding state-aid pathways and permitting

fast-tracks that change project NPVs (some projects move from marginal to viable).

• It signals a multi-decade pivot toward strategic-autonomy

budgets — IRA in the US, CRMA in the EU, similar measures in Korea/Japan/UK/Canada.

Severity is bounded below 5 because the 2030 targets are ambitious vs current EU positions (≤10% domestic extraction for most materials means ramping multi-year permitting processes), and enforcement is via member-state implementation rather than direct EU funding. The structural effect lands gradually rather than as a single shock.

Strategic materials list (17)

Bauxite/aluminium, bismuth, boron, cobalt, copper, gallium, germanium, lithium (battery-grade), magnesium, manganese (battery-grade), natural graphite, nickel (battery-grade), PGMs, REEs (heavy + light), silicon metal, titanium, tungsten.

Downstream implications

• European mining/processing assets (Eramet, Boliden, KGHM,

Anglo-American European ops) gain optionality on Strategic-Project status — meaningful for their NPV.

• Chinese dominance in REE refining, battery-grade graphite

processing, and gallium production becomes a target — the ≤65% cap is mechanically infeasible for several materials by 2030, which means EU-level support flows to non-Chinese alternatives (Australia, Canada, Brazil, Sweden, Norway).

• Cross-references to MacroLens minerals dossiers: lithium,

cobalt, nickel, graphite, neodymium, silicon, germanium-gallium, copper, tungsten — the CRMA strategic list overlaps closely.

Open questions

• 2030-benchmark enforcement mechanism is soft. What's the

Commission's actual lever if member states miss the ≥40% processing target?

• The list updates every four years; what's the base case for

the 2028 review?