Brief

The European Union’s Critical Raw Materials Act (CRMA) establishes a legally binding framework to ensure the EU’s long-term access to critical minerals essential for its green, digital, and security ambitions.

By 2030, the Union aims to sharply reduce foreign dependence through strategic benchmarks for extraction, processing, and recycling, while also enhancing permitting procedures and cross-border coordination.

Although deep-sea mining projects are not yet recognized within the scope of "Strategic Projects," the Act creates a structured pathway for their future inclusion pending stronger environmental assurances. This regulation thus provides a landmark opportunity for stakeholders in offshore mineral development who can demonstrate compliance with sustainability and transparency expectations.

Origins

The CRMA is a direct response to the EU’s acute dependency on a handful of foreign suppliers for over 90% of certain strategic minerals vital to its clean energy, defense, and digital industries.

The COVID-19 pandemic, the war in Ukraine, and growing geopolitical rivalries underscored the vulnerabilities of Europe’s raw material supply chains.

To address these risks, the European Commission crafted a regulation that not only delineates a list of critical and strategic raw materials but also mandates quantitative goals to be met by 2030.

The Act is explicitly linked to the European Green Deal and the Digital Decade agenda, signaling its foundational role in Europe's industrial policy.

Supply Targets

The CRMA mandates that by 2030, at least 10% of the EU’s annual consumption of strategic raw materials must be extracted domestically, 40% processed within the Union, and 25% sourced through recycling.

These targets are reinforced through a set of support measures that include fast-tracked permitting (27 months for extraction projects and 15 months for processing or recycling), and the classification of qualifying developments as "Strategic Projects" eligible for preferential treatment.

Such projects benefit from streamlined administration and may override local opposition under public interest exemptions, provided environmental standards are met.

Import diversification is another cornerstone: the EU must ensure that no third country provides more than 65% of its annual supply for any one strategic raw material.

This provision is designed to reduce overreliance on countries such as China, while simultaneously encouraging partnerships with emerging economies through so-called Strategic Projects abroad.

These projects must deliver both supply security to the EU and tangible local benefits to host countries, such as job creation and infrastructure investment.

Deep-Sea Mining

Deep-sea mining is not currently covered by the CRMA's Strategic Project framework.

However, the Act leaves the door open, stating that seabed mining projects may become eligible once environmental risks are fully understood and mitigation technologies prove capable of protecting marine ecosystems.

The inclusion of this conditional language suggests that proponents who can demonstrate high environmental performance and robust monitoring could eventually qualify.

Stakeholder Implications

For industry, the CRMA creates a clear and urgent mandate to localize and de-risk supply chains.

Developers and technology vendors capable of meeting the EU’s permitting, environmental, and transparency requirements will be well positioned for funding and regulatory support.

This includes those working on seabed technologies that can demonstrate alignment with future sustainability standards.

Public regulators must rapidly coordinate to implement single points of contact for permitting and ensure administrative deadlines are met.

Environmental NGOs and civil society actors are afforded stronger oversight roles through mandatory environmental impact assessments, public disclosure obligations, and a commitment to high social safeguards for third-country projects.

For third-country governments and multilateral partners, the CRMA signals a willingness by the EU to deepen resource diplomacy.

Partnerships are most likely to advance with countries demonstrating political stability, legal transparency, and environmental stewardship.

Governance

Governance Implementation is overseen by the European Critical Raw Materials Board, comprising member state and Commission representatives. The Board is charged with recognizing Strategic Projects, coordinating risk monitoring, and advising on investment facilitation.

A suite of EU funding tools — including InvestEU, the Innovation Fund, and the Recovery and Resilience Facility — are aligned to support qualifying initiatives.

Additionally, the CRMA establishes mandatory corporate risk assessments for large manufacturers dependent on strategic raw materials. These companies must map their supply chains and report vulnerabilities, though disclosure remains internal.

The Commission will complement this with a live dashboard and stress tests for each material category.

Certification is a key compliance mechanism. Only raw materials assessed through recognized third-party schemes with robust social and environmental standards will qualify under EU guidelines.

In parallel, the Commission will develop lifecycle-based environmental footprint labels to guide procurement and public investment.

Key Takeaways

  • Establishes binding 2030 benchmarks for extraction (10%), processing (40%), and recycling (25%) of strategic raw materials.
  • Prioritizes Strategic Projects with fast-track permitting, funding access, and potential environmental waivers.
  • Leaves open conditional inclusion of deep-sea mining pending further environmental research and technology validation.
  • Requires corporate supply chain risk assessments and mandates member-state stockpile coordination.
  • Anchors raw material governance to sustainability standards, certification schemes, and EU-wide industrial strategy.