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Critical Raw Materials Act
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.
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 the 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.
In 2025 and 2026, the EU moved from the adoption of the Critical Raw Materials Act towards its operationalisation and reinforcement. Key initiatives include the launch of the Raw Materials Mechanism under the EU Energy and Raw Materials Platform, the RESourceEU Action Plan, the upcoming European Critical Raw Materials Centre, and a targeted revision of the CRMA. Together, these measures aim to strengthen market monitoring, demand aggregation, joint purchasing, strategic stockpiling, supply diversification and circularity.
These initiatives are expected to create important synergies, by shifting the framework from target-setting towards more active market coordination and supply-chain resilience. They may also support the identification of strategic dependencies, improve coordination between Member States and industry, and facilitate investment in mining, processing, refining and recycling capacities.
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.
Growth of the market for hydrogen technologies 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.
For the hydrogen sector, recent developments in 2025 and 2026 are particularly relevant, since tronger EU coordination on critical raw materials could help reduce supply-chain vulnerabilities, improve access to key inputs, and support the scale-up of European manufacturing capacity for hydrogen technologies.
Links to Legislation and additional information:
Press release on CRMA proposal (2023)
