CRMA: Europe’s new weapon to protect critical raw materials


The Critical Raw Materials Act (CRMA) is a significant regulatory framework aimed at addressing the challenges faced by the European Union (EU). Predominantly,  in the strategic sectors of decarbonization, digitalization, aerospace, and defense. It is designed to ensure secure and sustainable access to critical raw materials (CRMs), which are essential for various industries. The CRMA is part of a broader “Green Industrial Plan” and aligns with the “Net-Zero Industry Act” (NZIA). Effectively reflecting the EU’s commitment to becoming a leading hub for clean tech industries. This legislation is a response to global trends in protecting clean energy technology and resources. They are similar to policies in the United States, such as the Inflation Reduction Act.

The key objectives of the CRMA include 

  • Anticipation and Mitigation of Supply Risks: The CRMA aims to enhance the EU’s awareness of CRM-related risks in supply chains. Thereby reducing vulnerabilities and ensuring a stable supply of raw materials.
  • Fostering Domestic CRM Potential: The regulation establishes benchmarks for the minimum share of EU demand to be covered by domestically sourced, processed, and recycled raw materials. This promotes the development of domestic extraction, processing, and recycling capabilities.
  • Promoting Sustainable Sourcing Practices: The CRMA encourages sustainable practices, such as circularity, standardization efforts, skill development, and research and innovation actions.
  • Diversification of Suppliers: The regulation seeks to reduce the EU’s reliance on single third-country suppliers, which can pose risks to supply chains.

The CRMA defines materials as “strategic” based on their relevance and expected demand for strategic technologies. It introduces specific benchmarks that must be met for domestic sourcing, processing, and recycling of strategic raw materials. Hence, ensuring that the EU reduces its dependency on single third-country suppliers and fosters its domestic CRM capabilities.

However, the implementation of the CRMA faces several challenges

  • Concept of “Strategic Raw Materials”: Defining which raw materials qualify as “strategic” based on their importance and expected demand can be complex and may require ongoing assessment.
  • Meeting Benchmarks: Achieving the established benchmarks for domestic sourcing, processing, and recycling may be challenging for some raw materials and industries.
  • Materials Availability: Ensuring the availability of specific raw materials within the EU can be complicated, and it may require extensive exploration and extraction efforts.
  • Recycling Targets: Meeting recycling targets for certain materials, particularly those with complex recycling requirements, can be demanding.
  • Diversification: Reducing dependency on single third-country suppliers while maintaining a stable supply chain is a delicate balance.
  • Establishment of Necessary Skills: Building a skilled workforce in mining, processing, and recycling industries is essential to meet the CRMA’s objectives.
  • Data Gaps: There may be gaps in data and information about the availability and sources of critical raw materials.
  • Coherence with National Legislation: The CRMA needs to align with the national legislation of EU member states, which can vary.
  • Long-term Economic Viability: Ensuring the economic viability of domestic extraction, processing, and recycling activities is essential for the sustainable implementation of the CRMA.
  • International Tensions: The CRMA’s focus on reducing dependency on single third-country suppliers may lead to international tensions, particularly with non-EU suppliers.
Nickel-Ore- CRMA Law by EU

CRMA’s Response To The Challenges

The CRMA is part of a global trend toward increased protectionism regarding technological developments and resources necessary for the clean energy transition. This trend is evident in policies such as the US Inflation Reduction Act and similar initiatives in other countries. While the USA has been concerned about critical raw materials since World War II. The EU started addressing supplier risks in the mid-1970s. The approach to critical raw materials evolved in the early 2000s, focusing on the origin of raw materials and the stability of supply from third countries.

To address the challenges associated with critical raw materials, the CRMA proposes various measures, including supporting strategic projects, coordinating financing, increasing circularity. Thereby, strengthening partnerships with like-minded countries, and enhancing risk monitoring and mitigation.

The CRMA is expected to impact a wide range of stakeholders, including the mining and processing industries. It also includes manufacturing companies, local communities, consumers, national governments, non-EU suppliers, and investors. These stakeholders will need to adapt to the new regulatory framework, navigate the complexities of meeting benchmarks and ensuring compliance. They will have to seize opportunities for sustainable resource management and clean tech industry advancement.

The CRMA is a dynamic regulatory framework that reflects the EU’s commitment to securing critical raw materials for its strategic industries while promoting sustainability and domestic capacity. The implementation of the CRMA will involve ongoing dialogue, collaboration, and adaptation among various stakeholders, both within and outside the EU. This framework presents opportunities and challenges, and its success will depend on how effectively these are addressed in the coming years.

Mini Mines’ Approach to Resource Conservation

Mini Mines has always advocated preservation of all types of raw materials, with innovative solutions designed to reuse and recycle materials. Our Hybrid Hydrometallurgy technology is without doubt the best way to recycle precious metals from Li-Ion batteries. Our process has a very low carbon footprint, without compromising on the quality of the metals extracted. At Mini Mines, we ensure that product wastage is minimized and metals extracted are of high purity.

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