Exploring the EU Critical Raw Materials Act
One piece of the puzzle
The European Union (EU) understands that to stay relevant, safe, and secure, it must ensure it has what it needs to flourish. This is difficult when some of the materials needed are not found naturally within the EU. The EU Regulation for CRMs entitled, “REGULATION (EU) 2024/1252…establishing a framework for ensuring a secure and sustainable supply of critical raw materials and amending Regulations (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1724 and (EU) 2019/1020” defines Critical Raw Materials (CRMs) in this way:
“...a set of non-energy, non-agricultural raw materials that are considered to be critical due to their high economic importance and their exposure to high supply risk, often caused by a high concentration of supply from a few third countries.”
Where are CRMs found?
The diagram below shows how the CRMs are used. If you look at the center column, you see they are found in the following technologies: batteries, fuel cells, wind, traction motors, photovoltaics, robotics, drones, 3D printing, and information and communications technology (ICT); most of the technologies that we use daily.
The list
For years, the EU has been creating an exhaustive list of CRMs. The first list of 14 materials was created in 2011. In 2014, the list was updated to 20 materials. In 2017, 27 materials were on this list, and 30 in 2020. In 2023, 34 materials were defined as CRMs. Since the cadence for updating the list is every three years, we can expect an update this year. The annotated periodic table below includes only the first three lists: 2011, 2014, and 2017. I couldn’t find an updated version.
The gist of the regulation is that the EU knows that many of these elements and materials are not naturally available in the EU. Therefore, they need to figure out how to ensure their future with respect to critical materials. A Material System Analysis was done to visualize how materials flow into and out of the EU. You can see a visualization of this below.
2030 Benchmarks
With this information, benchmarks by 2030 were set for the CRM value chain, which can be seen here:
at least 10% of the EU’s annual consumption for extraction
at least 40% of the EU’s annual consumption for processing
at least 25% of the EU’s annual consumption for recycling
no more than 65% of the EU’s annual consumption from a single [third] country
The webpage describing the act talks about “Creating secure and resilient supply chains.” Now here is where it gets interesting. The webpage goes on to say,
“EU countries will take measures to improve the collection of critical raw material-rich waste and ensure its recycling into secondary critical raw materials. EU countries and private operators will have to investigate the potential for recovery of critical raw materials from extractive waste.”
This means that not only is the EU going to increase its collection of electronic waste, but it is also pushing to recover the waste with the intention of reusing it. This is the essence of circular flows: taking items at the end of their useful life and giving the materials another life.
Green Deal Industrial Plan
This act is only one of many within the Green Deal Industrial Plan, which is a companion to the EU Commission’s Net Zero Industry Act. While the CMA Act went into force in 2024, the EU is still in the early stages: defining the list, funding research, policy changes, and banning exports of critical items (such as permanent magnets). There is a long way to go, especially if they hope ot accomplish the benchmarks above. I am hopeful that this regulation will provide the impetus towards increased “urban mining,” aka mining the e-waste.