Challenges and opportunities of the European Critical Raw Materials Act

Abstract The Critical Raw Materials Act (CRMA) is an essential regulatory framework designed to address the pressing challenges faced by the European Union (EU) in the strategic sectors of decarbonization, digitalization, and aerospace and defense. It aims to tackle the lack of secure and sustainable access to critical raw materials (CRMs) by increasing anticipation and mitigation of supply risks, fostering domestic CRM potential, and promoting sustainable sourcing practices. Part of a broader “Green Industrial Plan” and aligned with the “Net-Zero Industry Act” (NZIA), the CRMA strives to position the EU as a leading hub for clean tech industries. The NZIA and CRMA packages respond to international trends of protecting clean energy technology and resources, akin to the US Inflation Reduction Act. Defining materials as “strategic” based on their relevance and expected demand for strategic technologies, the CRMA regulation establishes benchmarks for minimum shares of EU demand to be covered by domestically sourced and processed as well as recycled raw materials and aims at reducing dependencies on single third country suppliers in all steps of the supply chain. A communication complements the regulation by focusing on increasing CRM supply security and sustainability through circularity, standardization efforts, skill development, and strategic actions for research and innovation. Establishing a “CRM Club” and partnerships with like-minded countries intend to strengthen international partnerships to safeguard CRM supply security and facilitate sustainable investment in resource-rich nations. Challenges arise concerning the concept of “strategic raw materials” and meeting benchmarks, particularly in materials availability, recycling targets, diversification, and the establishment of necessary skills. Data gaps, potential national differences, coherence with national legislation, long-term economic viability, and potential fuelling of international tensions also pose significant challenges to the effective implementation of the CRMA. Addressing these challenges and embracing the opportunities presented by the CRMA are crucial steps toward achieving sustainable resource management and advancing the EU’s clean tech industries.