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The EU’s Critical Raw Materials Strategy in Crisis: Why the Critical Raw Materials Act is Falling Short

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The EU's Critical Raw Materials Act faces severe setbacks as only a quarter of strategic projects stay on track, threatening Europe's goal to cut dependency on China.

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Two years after the implementation of the European Union’s landmark Critical Raw Materials Act (CRMA), the bloc’s ambitious drive to shake off its heavy reliance on Chinese supply chains is running into severe structural roadblocks. According to recent analyses shared by the European Environmental Bureau (EEB), only one in four critical mineral projects granted special strategic status is progressing on schedule. Meanwhile, EU industry chief Stéphane Séjourné is preparing to unveil a fresh list of ventures slated to receive privileged access to funding, fast-tracked permitting, and matchmaking support from Brussels.

The initial batch of 47 strategic projects, announced early last year, covered 14 of the bloc’s 17 designated raw materials—spanning lithium, nickel, cobalt, and graphite for EV batteries, rare earths for wind turbine magnets, tungsten for military gear, and gallium for semiconductors. The portfolio also included 13 projects located outside the bloc. However, EEB policy officer Diego Marin highlights that at least one in three mining and processing projects is delayed, stalled, at risk, or entirely defunct. Financial, regulatory, and political obstacles continue to cripple operations despite legislation designed to accelerate groundwork. In an August letter to the Commission, representatives from 23 strategic projects warned of „immediate jeopardy” and expressed concerns that adding new projects would merely dilute their privileged status.

The EU’s 2030 targets mandate that the bloc mine at least 10 percent, process 40 percent, and recycle 25 percent of its domestic requirements, while capping reliance on any single non-EU nation at 65 percent. Breaking dependency on China—which supplies over 80 percent of general critical materials and up to 90 percent of rare earths, as highlighted by Commission President Ursula von der Leyen—remains the core policy driver. While Commission officials maintain that lithium, cobalt, and rare earth goals might be met, severe shortfalls loom in nickel processing, recycling, and across the manganese supply chain, compounded by the upcoming expiration of China’s export control pauses in January.

Skepticism remains high across the industry. Jan Moström, former CEO of Swedish mining giant LKAB and outgoing president of Euromines, warns that Europe will fall far short of its objectives. Independent findings from the global think tank ODI and the European Court of Auditors (ECA) echo these warnings, citing a lack of proper tracking and widespread schedule slips. Although Brussels has mobilized over 2 billion euros via initiatives like the RESourceEU plan and a proposed critical raw materials center, major mining executives like Boliden CEO Michael Staffas question the tangible benefits of the „strategic project” label. LKAB CEO Johan Menckel notes that national legislation and clashing bureaucratic authorities in countries like Sweden easily bypass the targeted 27-month permitting windows.

Social pushback and corporate bankruptcies further compound the crisis. Sweden’s Per Geijer deposit—home to Europe’s largest rare-earth reserves—faces fierce opposition from the indigenous Sámi community, who warn the project threatens their reindeer-herding heritage and accuse officials of cultural complicity. Meanwhile, Europe’s lithium-refining ambitions are faltering: France’s Viridian Lithium filed for bankruptcy after failing to secure capital, with a spokesperson labeling the strategic project label a „curse,” while Portugal’s José de Mello Group dropped its refinery plans due to funding gaps. Furthermore, Rio Tinto’s Jadar project in Serbia remains frozen amid intense public backlash over environmental and corruption concerns. As EEB’s Marin aptly concluded, public aversion to backyard mining means Europe „can’t permit our way out of a market problem.”

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