EU Council General Approach on CRMA Amendment — RESourceEU Trilogue Mandate

Mechanism

The Council's general approach is the legislative procedural step that follows the Commission's RESourceEU proposal (COM(2025) 945 final, adopted 3 December 2025) and precedes trilogue. It establishes the Council's formal negotiating mandate, enabling interinstitutional talks with the European Parliament (which adopted its own position through the ITRE committee).

Key Council amendments to the Commission text:

1. Commission as identifier — Responsibility for mapping and notifying large CRM-consuming companies shifts from member states to the European Commission, creating a single EU-level risk-identification function.

2. Supply-risk notification obligation — The Commission must notify both member states and relevant company boards when CRM supply risks materialise, formalising a public– private alert loop.

3. Risk-mitigation powers — The Council supports broadened Commission authority to propose mandatory risk-mitigation measures for companies facing potential supply disruptions, expanding the original CRMA's primarily strategic-project focus.

4. Permanent-magnet circularity — The Council endorses: - Product passports carrying permanent-magnet information obligations. - Mandatory permanent-magnet labelling on finished goods. - Mandatory recycled-content declarations for permanent magnets. These provisions operationalise the circular-economy pillar of RESourceEU and target China's near-total dominance of NdFeB magnet production.

5. Trilogue unlocked — Adoption of the general approach formally authorises Council presidency to enter interinstitutional negotiations. Trilogue is expected in H1 2026; final text likely Q3/Q4 2026 if Parliament and Council positions converge on notification scope and Commission powers.

Downstream implications

• Permanent-magnet supply chains — labelling and recycled-content mandates will

create compliance costs for EV/wind/electronics OEMs sourcing magnets from China; EU magnet-recycling capacity (Vacuumschmelze, Cyclic Materials, REEtec) becomes strategically relevant once disclosure obligations are law.

• Corporate CRM governance — mandatory board notification of supply risks mirrors

DORA's ICT-risk governance model; large industrials will need internal CRM risk functions ahead of enactment.

• CRMA 2.0 legislative chain — this is step 3 of a 4-step sequence:

(1) CRMA enacted May 2024 → (2) RESourceEU Commission proposal Dec 2025 → (3) Council general approach Mar 2026 ← this filing → (4) Enacted amendment (expected late 2026 / early 2027).

Open questions

• Will the European Parliament's ITRE position align with the Council on Commission

identification powers, or push for broader mandatory stockpiling provisions?

• Will the trilogue text retain the product-passport mechanism in its current form

or narrow it to end-of-life/recycling disclosures only?

• Timeline: if trilogue is not completed before the European Parliament summer recess

(July 2026), final enactment could slip to Q1 2027.