Through the Critical Raw Materials Act, the European Union is attempting to become more autonomous in the supply of critical raw materials.
The energy and digital transition has a little-seen side: a handful of materials without which certain technologies simply cannot exist. These are critical raw materials, 34 according to the latest European classification, defined as such because they are simultaneously indispensable to the economy and difficult to source reliably. Within this group, the European Commission considers 17 of them strategic: these are the ones most directly tied to the supply chains of the transition, from energy to digital technologies, through to defence and aerospace. The issue lies not so much in the scarcity of these materials as in the fact that very few countries have all but monopolised their production and refining. The European Union is largely dependent on foreign sources — a position of vulnerability from which it intends to recover through the Critical Raw Materials Act.
The European Commission began addressing critical raw materials as early as 2020 with the Action Plan on Critical Raw Materials, a strategic document that identified the main dependencies and the first lines of intervention, from supply diversification to the development of recycling and European industrial supply chains.
It subsequently adopted Regulation (EU) 2024/1252, known as the Critical Raw Materials Act, which entered into force in 2024. Being a regulation, it is directly applicable in member states without the need for formal transposition. It nonetheless requires a series of measures at national and European level to be fully implemented: exploration programmes, accelerated permitting, monitoring tools and coordination among member states. Aiming for self-sufficiency would be utopian: the objective is, rather, to reduce the most critical dependencies and build a minimum industrial capacity along the supply chain.
It is the Critical Raw Materials Act itself that defines the aforementioned list of 34 critical raw materials and, within it, the subset of 17 strategic raw materials. It is on the latter that the 2030 quantitative targets are focused, covering all stages of the value chain. At least 10 per cent of Europe's annual consumption of strategic raw materials must be covered by domestic extraction, 40 per cent by processing and refining capacity located within the Union, and 25 per cent by recycling. To these is added a diversification constraint: for each strategic raw material, no more than 65 per cent of demand may depend on a single third country.
To achieve these objectives, the regulation introduces specific tools across the entire supply chain. Projects classified as strategic — mines, refining and recycling facilities — benefit from accelerated permitting procedures, with maximum timelines of 27 months for extraction and 15 months for downstream activities. Member states must map available resources, develop national exploration programmes and strengthen supply chain monitoring, while large companies identified as exposed are required to carry out periodic stress tests to assess supply resilience. At European level, the Commission coordinates the system, publishes scenarios on future demand and promotes international partnerships to diversify supply sources.
But the European Court of Auditors makes clear that realising these ambitions will be neither easy nor swift. Developing a mining project in Europe can take up to 10–15 years, between permits, environmental assessments and administrative procedures. This means that, even with clear objectives such as those set by the Critical Raw Materials Act, an increase in domestic production cannot happen in the short term. The regulation provides for accelerated procedures, but starts from a situation in which projects are few and timelines are long, while demand is already growing today.
Added to this is a scale constraint. Even where resources and projects exist, European production remains far too small relative to requirements. This is why the regulation sets relatively modest targets — 10 per cent for extraction and 40 per cent for processing — which nonetheless must be reached starting from very low levels. In other words, the task is not to expand an existing system, but to build one almost from scratch across several segments of the supply chain.
The most critical bottleneck, however, remains an industrial one. The Court of Auditors highlights that Europe is particularly weak in the processing and refining stages, which are those with the highest added value and the most concentrated globally. Even when a raw material is extracted or imported, it often has to be processed elsewhere before it can be used. This reduces the effectiveness of extraction policies because, without downstream capacity, dependence persists.
On recycling, finally, the figures reveal a still limited margin. For several critical raw materials, the end-of-life recycling rate stands at zero per cent, while in the best cases it remains insufficient relative to demand. The problem is twofold: on the one hand, many technologies are still too recent to generate significant flows of recoverable materials; on the other, industrial-scale facilities and processes are lacking. This makes it difficult to achieve the 25 per cent target set by the regulation within the envisaged timeframe.