EU Critical Raw Materials Act (CRMA)

[Updated August 20, 2026]

What. Aims at ensuring the EU’s access to a secure, diversified, affordable, and sustainable supply of critical raw materials (CRMs) while reinforcing circularity and strategic autonomy. The Act establishes benchmarks for domestic capacities, promotes responsible sourcing, and integrates traceability requirements to mitigate supply chain risks.

When. Entered into force on May 23, 2024. Strategic benchmarks apply from 2030: 10% of EU annual consumption for extraction, 40% for processing, and 15% for recycling of strategic raw materials (SRMs).

Products. 34 critical raw materials (CRMs), including 17 strategic raw materials (SRMs) such as lithium, cobalt, nickel, silicon, and rare earth elements. Applies to sectors including batteries, renewables, defense, aerospace, digital technologies, and automotive.

Who. EU Member States, economic operators (producers, importers, processors, recyclers), large companies with significant CRM/SRM supply chains, and project developers for 'Strategic Projects'.

Overview

The EU Critical Raw Materials Act (CRMA) is a cornerstone of the EU’s strategy to secure a sustainable and resilient supply of critical raw materials (CRMs) essential for the green and digital transitions. Aligned with the European Green Deal and the Green Deal Industrial Plan, the CRMA addresses vulnerabilities in supply chains by reducing dependency on single sources, enhancing domestic capacities, and promoting circularity.

The Act introduces quantitative benchmarks for 2030 to ensure the EU’s strategic autonomy:

• 10% of annual consumption for extraction,
• 40% for processing,
• 15% for recycling of strategic raw materials (SRMs).

It also establishes a framework for Strategic Projects, which benefit from streamlined permitting and access to funding, and mandates due diligence and traceability to ensure responsible sourcing and compliance with environmental and social standards.

Digital Product Passports (DPPs) are now clearly on the table for the CRMA. The latest position introduces explicit references to DPP-related disclosure requirements for critical raw materials through future delegated acts. One area already attracting attention concerns products containing permanent magnets, where disclosure obligations linked to recycled critical raw material content could start applying from 2027 (Art. 29).

Key Requirements

The CRMA imposes obligations across the CRM value chain to enhance security of supply, sustainability, and transparency:

1. Strategic Benchmarks

Member States must collectively meet the 2030 benchmarks for extraction, processing, and recycling of SRMs. National programs will be developed to monitor progress and address gaps.

2. Strategic Projects

Projects contributing to the security of SRM supply can be designated as Strategic Projects by the European Commission. These projects benefit from:

• Accelerated permitting: 24 months for extraction projects, 12 months for processing and recycling projects.
• Access to funding: Prioritization for EU and national funding, including under the InvestEU program and Recovery and Resilience Facility.
• Administrative support: Coordination with national authorities to facilitate implementation.

3. Supply Chain Monitoring and Risk Preparedness

• The European Critical Raw Materials Board will monitor supply risks and coordinate responses to disruptions.
• Member States must establish strategic inventories of SRMs to mitigate short-term supply shortages.
• Large companies must conduct supply chain audits and stress tests to assess vulnerabilities in their SRM supply chains.

4. Traceability and Due Diligence

• Economic operators must implement traceability systems to track CRMs and SRMs across the value chain, from extraction to end-of-life.
• The Act aligns with the OECD Due Diligence Guidance for Responsible Business Conduct, requiring companies to identify, prevent, and mitigate adverse impacts related to human rights, labor rights, and environmental protection in their supply chains.
• Recycling and circularity: Member States must improve the collection and recycling of CRM-rich waste, including from historical mining sites, to recover secondary CRMs.

5. Diversification of Imports

The EU will strengthen partnerships with third countries to diversify imports of CRMs and SRMs, including through Strategic Partnerships that promote sustainable and responsible mining practices.

Compliance Timeline

The CRMA establishes a phased implementation timeline to ensure gradual adoption and compliance:

| Date | Milestone | |--------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | May 23, 2024 | CRMA enters into force. | | Q4 2024 | European Commission establishes the European Critical Raw Materials Board to oversee implementation and risk monitoring. | | 2025 | Member States must transpose the CRMA into national law and submit their national programs for meeting the 2030 benchmarks. | | 2026 | - First Strategic Projects designated by the European Commission.

• Large companies begin supply chain audits and stress tests for SRMs.
• Member States implement strategic inventories. | | 2027 | - Traceability systems must be operational for SRMs.
• DPP-related disclosure requirements for products containing permanent magnets (e.g., recycled CRM content) may apply (Art. 29).
• Member States report on progress toward 2030 benchmarks. | | 2030 | Deadline for meeting the strategic benchmarks: 10% extraction, 40% processing, and 15% recycling of SRMs within the EU. | | Ongoing | Continuous monitoring, reporting, and updates to the list of CRMs and SRMs based on evolving supply risks and technological needs. |

Affected Parties and Their Obligations

The CRMA applies to a broad range of stakeholders across the CRM value chain:

1. EU Member States

• Develop and implement national programs to meet the 2030 benchmarks for extraction, processing, and recycling.
• Establish strategic inventories of SRMs to mitigate supply disruptions.
• Facilitate the permitting process for Strategic Projects and provide administrative support.
• Monitor and report on progress toward the benchmarks and compliance with traceability and due diligence requirements.

2. Economic Operators

• Producers, importers, and processors of CRMs and SRMs must:Implement traceability systems to track materials across the supply chain.Conduct due diligence in line with the OECD Due Diligence Guidance for Responsible Business Conduct to identify and mitigate risks related to human rights, labor rights, and environmental impacts.Comply with reporting requirements on supply chain risks and sustainability performance, including DPP-related disclosures for products containing permanent magnets (from 2027).
• Recyclers must:Improve the collection and recycling of CRM-rich waste to recover secondary CRMs.Report on recycling rates and the recovery of CRMs from waste streams.

3. Large Companies

• Companies with significant SRM supply chains must:Conduct supply chain audits to assess vulnerabilities and risks.Perform stress tests to evaluate resilience to supply disruptions.Integrate due diligence into their risk management systems and report on findings.

Penalties and Enforcement

The CRMA establishes a robust enforcement framework to ensure compliance with its requirements:

1. Non-Compliance Penalties

Member States are responsible for defining penalties for non-compliance, which must be effective, proportionate, and dissuasive.

Penalties may include:

• Fines for failing to meet traceability, due diligence, or reporting requirements.
• Suspension or revocation of permits for Strategic Projects that do not comply with sustainability or social standards.
• Exclusion from public funding for non-compliant economic operators.

2. Enforcement Mechanisms

• The European Critical Raw Materials Board will oversee compliance and coordinate enforcement actions across Member States.
• Member States must designate national competent authorities to monitor compliance, conduct inspections, and impose penalties.
• Whistleblower protections are included to encourage reporting of non-compliance.

3. Market Restrictions

• Products containing CRMs or SRMs that do not comply with traceability or due diligence requirements may be prohibited from entering the EU market.
• Economic operators found to be in serious or repeated breach of the CRMA may face temporary or permanent bans from participating in public procurement or accessing EU funding.

4. Dispute Resolution

• Economic operators and project developers can appeal enforcement decisions through national administrative or judicial procedures.
• The European Commission may intervene in cases of cross-border disputes or systemic non-compliance.

Integration with Other EU Regulations

The CRMA is designed to complement and integrate with other key EU regulations to create a cohesive framework for sustainable and resilient supply chains:

1. EU Digital Product Passport (DPP)

The CRMA’s traceability requirements align with the DPP, which mandates digital product passports for certain products to enhance transparency and circularity.

Economic operators can leverage DPP data to fulfill their traceability obligations under the CRMA, ensuring interoperability and reducing administrative burdens.

Future delegated acts under the CRMA will introduce DPP-related disclosure requirements, particularly for products containing permanent magnets (e.g., recycled CRM content from 2027).

2. Corporate Sustainability Due Diligence Directive (CSDDD)

The CRMA’s due diligence requirements are consistent with the CSDDD, which mandates companies to identify and address adverse human rights and environmental impacts in their operations and supply chains.

Companies subject to both regulations can adopt integrated due diligence systems to streamline compliance.

3. EU Battery Regulation

The CRMA supports the EU Battery Regulation, which sets sustainability and recycling requirements for batteries, including those containing lithium, cobalt, and nickel.

The CRMA’s focus on recycling and circularity complements the Battery Regulation’s targets for recycled content and end-of-life management of batteries.

4. EU Taxonomy for Sustainable Activities

The CRMA’s Strategic Projects and sustainable sourcing requirements align with the EU Taxonomy, which defines criteria for environmentally sustainable economic activities.

Projects that meet the CRMA’s sustainability standards may also qualify as Taxonomy-aligned, facilitating access to green financing.

5. REACH and CLP Regulations

The CRMA’s focus on chemical safety and environmental protection complements the REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) and CLP (Classification, Labelling, and Packaging) regulations.

Economic operators must ensure that CRMs and SRMs comply with REACH and CLP requirements to avoid regulatory conflicts.

For More Information

For further details on the EU Critical Raw Materials Act, consult the following official resources:

• European Council: Critical Raw Materials Act
• European Commission: Critical Raw Materials Act Factsheet
• European Commission: Critical Raw Materials Act Proposal
• European Council: Reinforcing Security of Supply and Circularity (2026 Update)
• OECD Due Diligence Guidance for Responsible Business Conduct
• EU Digital Product Passport (DPP)

Industry associations and sustainability initiatives also provide guidance on CRMA compliance:

• Eurometaux: Critical Raw Materials
• Responsible Minerals Initiative (RMI)
• International Council on Mining and Metals (ICMM)