EU CRMA Strategic Projects — first designation (47 EU + 13 third-country, 60 total)

Mechanism

Article 7 of the CRMA (Regulation (EU) 2024/1252) creates a designation procedure: project promoters apply to the Commission, applications are scored by independent experts on technical, financial and ESG dimensions, and the Critical Raw Materials Board (Member States + EP observer) reviews the shortlist before the Commission adopts the list by Implementing Decision.

Designation has three concrete legal effects per project:

1. Fast-track permitting. Member States must process permits within 27 months for extraction projects and 15 months for processing/recycling/substitution projects, with single-point-of- contact obligations and overriding-public-interest status to compress habitat/water-permit challenges. 2. Priority financing access. Article 16 CRMA gives promoters the right to request a dedicated meeting of the CRMA financing subgroup (EIB, EBRD, EIF, national promotional banks); designation also unlocks Innovation Fund, Recovery and Resilience Facility, and Strategic Technologies for Europe Platform (STEP) co-financing. 3. Member State priority. Listed projects move to the top of national permitting and grid- connection queues; in some Member States this also triggers preferential land-access and strategic-asset protections.

The first 47 (intra-EU, 25 March 2025)

Distributed across 13 Member States, covering 14 strategic raw materials. Coverage by material (per White & Case / DG GROW): lithium 22 projects, nickel 12, graphite 11, cobalt 10, manganese 7, with additional REE, tungsten, copper, magnesium, silicon-metal, gallium, hafnium, scandium and synthetic graphite projects. Split by value-chain step: 25 extraction, 24 processing, 10 recycling, 2 substitution (some projects span multiple steps, hence >47). Combined CAPEX envelope: EUR 22.5bn.

The 13 third-country projects (4 June 2025)

Seven in EU strategic-partnership countries (Canada, Greenland, Kazakhstan, Norway, Serbia, Ukraine, Zambia); six in Brazil, Madagascar, Malawi, New Caledonia, South Africa, and the UK. Material focus: ten on lithium / nickel / cobalt / manganese / graphite (battery chemistry); two on rare-earths extraction; the remainder on copper, tungsten and boron. Combined CAPEX envelope: EUR 5.5bn.

Downstream implications

• Operationalises the 2024-05-23 CRMA framework — until now the regulation set targets but had

no project pipeline. The 60 designations are the first concrete signal of where the EU's 2030 benchmarks will be sourced, and which Member States carry the upstream load (Germany, France, Spain, Portugal, Finland, Sweden lead by project count).

• Permitting compression is the binding constraint. EU lithium and REE projects historically

stall 7–10 years on environmental review; the 27-month statutory cap is the most aggressive permitting reform in EU industrial policy and will be tested in court — first major challenge expected on the Rio Tinto Jadar lithium project (Serbia, third-country list).

• Third-country list functions as an EU-side counter to the US IRA §30D FTA-partner mineral-

sourcing mechanism. It locks in non-Chinese refining/processing optionality for European battery and magnet OEMs (BMW, VW, Stellantis, Northvolt successors, VAC) without requiring re-shoring.

• ETF impact: REMX, LIT, COPX, PICK gain a structural EU-buyer-of-last-resort signal. EZU/VGK

upside is concentrated in midstream chemicals (BASF, Umicore) and equipment OEMs (Metso, Sandvik, Outotec) servicing the project pipeline.

• Watch the second selection round (cut-off 15 January 2026, >160 applications received) — the

pipeline depth determines whether the EU's 2030 benchmarks are mathematically achievable.

Open questions

• How many of the 47 intra-EU projects clear the 27-month permitting cap on first attempt vs

trigger Member State derogation procedures?

• Will the financing subgroup actually mobilise EIB/EBRD lending against the EUR 22.5bn capex

pipeline, or do projects continue to rely on private offtake-backed finance?

• Does the third-country list create binding offtake obligations toward EU buyers, or is it a

reputational designation only?

• Cross-impact with the US-EU Critical Minerals Strategic Partnership (filed:

2026-04-24-eu-us-critical-minerals-strategic-partnership) — do EU strategic projects in third countries also count toward US §30D mineral sourcing if processed in FTA-partner jurisdictions?