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Critical Raw Materials Act
The Critical Raw Materials Act is a regulation proposed by the Commission on the 16th March 2023, with the aim to set the basis for a renewed European approach to the use of key materials, focusing on the extraction, processing, recycling, monitoring and diversification of critical ores, minerals and concentrates, while strengthening its international outreach to current and future partners. In November 2023, the co-legislators came to an agreement regarding the final regulation.
The Act targets several issues related to critical raw materials, such as low diversification of EU supply sources, the untapped potential of local supply, weak monitoring and risk management capacity to anticipate and prevent supply disruptions of critical raw materials, adverse social and environmental impacts of production of CRMs, insufficient support for circularity and insufficient research and innovation.
The key targets in the proposed regulation are:
- To strengthen the EU’s capacities along the different stages of the value chain. Ensuring that by 2030:
- EU extraction capacity covers at least 10% of the EU's annual consumption of strategic raw materials;
- EU processing capacity covers at least 40% of the EU's annual consumption of strategic raw materials;
- EU recycling capacity covers at least 25% of the EU's annual consumption of strategic raw materials.
- To diversify the EU’s imports of raw materials, where no third country should provide more than 65% of the EU's annual consumption (for each strategic raw material).
Furthermore, the CRMA includes he establishment of a two-tier criticality list of materials: 17 Strategic (SRMs, highest priority for the clean transition) and further 17 Critical (CRMs, other raw materials with considerable economic importance and supply risk, mild level of disruption). The text provides for further Commission revision of this list in three years.
Projects that significantly enhance EU supply security of SRMs, show technical feasibility, and meet sustainability standards may be designated as Strategic Projects. These projects will receive priority treatment in Member States with expedited permitting—approval timelines are capped at 15 months for processing and recycling, and 27 months for extraction.
Large companies exposed to potential shortages of strategic raw materials in key technologies, such as batteries or hydrogen producers will have to regularly carry out risk assessment of their supply chain regarding their strategic raw materials, including reference to vulnerabilities to supply chain disruptions.
If an urgent international market disruption occurs, the EU could coordinate Joint Purchases for European businesses. A CRM Board, including Member State and Commission representatives, would manage this process and advise on improving the Union’s critical raw materials supply security.
In June 2025, the European Commission launched the Raw Materials Mechanism under its Critical Raw Materials workstream to help industry diversify supply chains and support new raw materials projects. The initiative connects suppliers, investors, and stakeholders in green, digital, aerospace, and defence sectors, aggregates demand for 17 strategic raw materials, accesses global supplies, and encourages stockpiling when needed.
What’s in it for hydrogen?
Hydrogen technologies like electrolysers and fuel cells rely on critical raw materials (CRMs), particularly Platinum Group Metals (PGMs) such as platinum and iridium, which are essential for components like membranes and stacks. Since PGMs are scarce and concentrated in countries like South Africa and Russia, they could become supply bottlenecks for the EU. Other materials—including nickel, cobalt, ruthenium, and palladium—may also pose challenges as demand grows, though their criticality remains under assessment given hydrogen's current limited impact on these supply chains.
According to the 2024 ECA report and projections for EU RFNBO targets, Europe may install 20–25 GW of electrolysers by 2030, up from 0.4 GW today. This growth will further drive demand for PGMs and metals like nickel and copper, risking potential shortages and price increases amid competition with other clean tech sectors.
The EU’s Critical Raw Materials Act establishes synergy with the other pivotal elements of the Green Deal Industrial Plan, such as the Net-Zero Industry Act (NZIA). The package awards hydrogen and its related technologies, components and materials, the status of strategic importance for Europe’s competitiveness, energy security and resilience, in the path towards a net-zero economy.
After launching a call for Strategic Projects post-CRMA publication, the Commission identified 47 initiatives in 13 EU countries focused on strategic raw materials. These include 25 extraction, 24 processing, 10 recycling, and 2 substitution projects, covering 14 of the 17 CRMA-listed materials. Six projects specifically target platinum group metals.
Links to Legislation and additional information:
European Parliament Legislative Observatory: Framework for ensuring a secure and sustainable supply of critical raw materials
European Critical Raw Materials Act Proposal
