The EU Critical Raw Materials Act, Regulation (EU) 2024/1252, is now a core framework for businesses involved in critical raw materials, strategic raw material supply chains, permanent-magnet products, and recovery-focused waste streams. It is designed to strengthen the EU’s supply security, accelerate strategic projects, improve circularity, and create product- and material-level information obligations in selected areas.
If your company imports, processes, manufactures, recycles, or places relevant products on the EU market, the CRMA may already affect your permitting, supply-chain mapping, documentation, product information, or internal risk controls. The exact obligation depends on your role in the supply chain.
Our goal is simple: help your teams understand what the CRMA requires, what is already in force, what still depends on secondary legislation, and what practical documentation you should be building now.
The CRMA is an EU regulation that aims to secure a resilient and sustainable supply of critical raw materials for the Union. It supports:
while also creating market-facing information rules for certain permanent-magnet products and, later, potentially for selected critical raw materials through environmental-footprint declarations.
The regulation sets 2030 benchmarks for strategic raw materials. The EU aims to approach or reach at least:
The regulation distinguishes between strategic raw materials and critical raw materials. Annex I lists the strategic raw materials; Annex II lists the critical raw materials.
They are currently:
Some are also conflict minerals, like cobalt or tungsten.
They are currently all of the above, in addition to :
Antimony
Arsenic
Baryte
Beryllium
Coking coal
Feldspar
Fluorspar
Hafnium
Helium
Niobium
Phosphate rock
Phosphorus
Scandium
Strontium
Tantalum
Vanadium
Important grade-related nuance: some broader critical-material categories are only strategic for particular grades or applications:
Additionally, one strategic entry – rare earth elements for permanent magnets – covers portions of two critical entries.
The Commission must review and, if necessary, update both the strategic and critical lists by May 24, 2027, and at least every three years thereafter.
Aspect | Critical raw materials | Strategic raw materials |
|---|---|---|
Main concern | High importance to the EU economy combined with high supply risk | Essential to strategic technologies, with rapidly growing demand and difficulty increasing supply |
Main sectors | The EU economy broadly | Green technologies, digital technologies, defence and aerospace |
Selection criteria | Economic importance and supply risk | Strategic importance, projected demand growth and difficulty increasing production |
CRMA focus | Monitoring, exploration, circularity, sustainability and supply-risk management | Strategic Projects, production benchmarks, supply diversification and stronger supply-chain measures |
For many companies, the CRMA is not just a policy text. It changes what buyers, suppliers, legal teams, sustainability teams, and technical teams need to document and verify.
Large companies in specific downstream sectors must assess raw-material supply-chain vulnerabilities.
Project promoters can apply for Strategic Project status and gain faster permitting and financing support.
Businesses placing covered permanent-magnet products on the market will need:
The act also matters because it creates a compliance bridge between upstream raw materials operations and downstream product regulation. If you are waiting until a customer asks for traceability or recycled-content proof, you are likely waiting too long.
You are likely affected if you are any of the following:
If you are an SME, the regulation does not create a general SME carve-out. The main explicit size threshold is the “large company” test in Article 24, but other obligations apply based on activity, product scope, or market-placement role rather than company size. You may also be indirectly impacted with third-party requests.
Member States must identify large companies in listed downstream sectors, and those companies must:
If significant vulnerabilities are found, the company must make efforts to mitigate them, such as diversification or substitution.
If your project is in extraction, processing, recycling, or substitution and it materially improves EU supply security, Strategic Project status may provide faster permitting and financing coordination. Applications must be evidence-based and use the Commission’s single template. Once recognized, the promoter must report progress to the Commission every two years and maintain a free-access website with relevant information for local populations.
Covered products incorporating permanent magnets will need a label and, for the specified magnet types, a data carrier linked to a unique product identifier that provides access to removal and composition information. These are practical traceability obligations, even though the regulation does not call them a “digital product passport.”
For covered products with more than 0.2 kg of specified permanent magnets, businesses will need to publish the share of certain materials recovered from post-consumer waste, but the operational details still depend on a delegated act establishing calculation and verification rules. The timing therefore remains secondary-act dependent.
Before placing a product covered by Articles 28 or 29 on the market, the responsible person must ensure:
except where the regulation excludes certain type-approved vehicles.
The CRMA does not yet impose a universal footprint declaration for all critical raw materials. The Commission must first prioritise materials, assess necessity and proportionality, and adopt material-specific rules. Once those rules exist for a specific critical raw material type, operators placing that material on the market will have to publish the declaration and make it available before sale.
They should upgrade:
so they can obtain:
They should also decide internally who is responsible for “placing on the market” determinations and who owns supporting evidence for customer and regulator requests.
They should verify whether:
They should also prepare to support downstream customers with traceability data that is consistent across plants and batches.
They should perform a product-screening exercise against Article 28 and create a controlled bill-of-materials process for permanent magnets. If products are covered, they should start planning:
Large manufacturers in the listed downstream sectors should also institutionalise Article 24 risk assessments and board-level escalation rules
They should:
Where recyclers recover materials from products with permanent magnets, removal and composition data may become especially valuable.
A common mistake is assuming that the CRMA is only about mining or only about future policy. It already reaches downstream manufacturers and waste operators in targeted ways, and several obligations are best prepared long before their formal application date, because the difficult part is data collection and internal governance rather than last-minute labeling.
Another mistake is treating the CRMA as though all obligations are already fully specified. They are not. Some of the most practical details still depend on delegated or implementing acts, and businesses should avoid overbuilding systems around assumptions that the Commission has not yet codified.
Need a practical CRMA readiness review for your materials, products, suppliers, or recycling streams? We can help you:
The earlier you structure the data, the easier CRMA compliance becomes.
The checklist, timeline, and templates below are distilled from Articles 24, 28 to 31, 33, 45 to 47 of Regulation (EU) 2024/1252, together with Implementing Regulations (EU) 2025/2194 and 2026/1116. They are designed as operational starting points rather than legal substitutes.
Topic | Trigger | What to do | Earliest or fixed timing | Evidence to retain |
|---|---|---|---|---|
Scope screening | Any EU operator dealing with:
| Map activities against:
| Immediate |
|
Large-company assessment | Company exceeds 500 employees and EUR 150m turnover and operates in listed sectors | Run Article 24 risk assessment of strategic raw-material supply chain | At least every 3 years after identification |
|
Strategic Project option | New or expanded:
| Assess Article 6 criteria and, if suitable, prepare application using the Commission template |
|
|
Permanent magnet product screening | Product in Article 28 list | Identify whether product contains permanent magnets and what type | Immediate readiness task |
|
Label and data-carrier readiness | Covered Article 28 product with specified magnets |
| Depends on Art. 28 implementing act; format act due by Nov. 24, 2026 |
|
Recycled-content disclosure readiness | Covered Article 29 product with >0.2 kg specified magnets |
| Depends on Article 29 delegated act and its entry into force |
|
Conformity and CE process | Product covered by Article 28 or 29 | Complete
| Before placing product on the market |
|
Environmental-footprint watch | Critical raw material placed on market | Monitor whether the Commission adopts material-specific Article 31 rules | Priority report due Nov. 24, 2026; obligation only after material-specific rules |
|
Recycler data controls | Recycler or waste operator dealing with listed streams |
| Immediate |
|
Penalty preparedness | Any in-scope operator | Track Member State penalty rules and adjust governance and audit controls | Member State penalties due by Nov. 24, 2026 |
|
The timeline below highlights dates that matter most for business planning. Where a duty depends on a future delegated or implementing act, that dependency is shown explicitly.
This flowchart is designed as a fast internal triage tool for compliance teams. It reflects the regulation’s architecture rather than every edge case.
Use this as a short supplier intake form for CRMA readiness. The regulation does not prescribe this exact form, but the questions are structured around the information businesses will likely need for the Articles 24, 28, 29, and 31 workflows.
Questions |
1. Legal entity name, registered address, and contact person |
2. Which critical raw materials do you supply (could be within your products)? Please identify grade / processing stage. |
3. In which country and region are the supplied materials extracted, processed, refined, and recycled? |
4. Does the supplied product or material contain permanent magnets? If yes, what type and approximate weight? |
5. Can you provide composition data, including coatings, glues, additives, and alloying information where relevant? |
6. Do you have evidence of recycled content recovered from post-consumer waste? If yes, what methodology do you use? |
7. Do you operate under any recognised or third-party sustainability certification scheme? |
8. Can you provide environmental-footprint or life-cycle-study information if later requested for Article 31 readiness? |
9. What records can you provide to support traceability, mass balance, and chain-of-custody verification? |
10. Are there any restrictions on disclosure because of trade secrets or security concerns? If yes, please specify. |
11. Who is authorised to sign compliance statements and provide updated evidence? |
The first major legal uncertainty is that several of the most operationally important CRMA obligations depend on secondary acts that either set detailed formats or activate the underlying duty. That is especially true for Article 28 labeling format, Article 29 recycled-content calculation and verification, Article 31 environmental-footprint rules, and Article 34 data-carrier, customs, and alignment rules. A strong risk control is to distinguish between framework duties already visible in the regulation and technical obligations that only become operable after secondary acts. Build data capability now, but avoid locking in technical specifications too early.
The regulation is directly applicable, but penalties are national. That means the intensity of enforcement, penalty amounts, and procedural posture will vary by Member State after November 24, 2026. A practical control is to maintain a jurisdiction tracker covering every Member State in which the business places products on the market, holds stock, operates facilities, or uses a single point of contact.
A third uncertainty concerns the boundary between CRMA obligations and overlapping EU legislation. The CRMA itself says that, where other Union harmonisation legislation creates equivalent permanent-magnet information requirements for listed products, those rules apply in place of Article 28. It also empowers the Commission to align CRMA implementation with broader harmonisation legislation. In practice, that means product teams should not assess the CRMA in isolation from type-approval, ecodesign, battery, WEEE, waste, and market-surveillance frameworks.
A fourth uncertainty is timing under Article 29. Because the disclosure duty begins on May 24, 2027 or two years from entry into force of the delegated act, whichever is later, the real market date depends on the delegated act. Businesses should therefore avoid hard-coding a 2027 go-live date unless and until the delegated act’s entry-into-force date makes that valid. The stronger control is to prepare the evidence trail now and put the disclosure publication workflow on a regulatory trigger.
In the Commission’s December 2025 RESourceEU Action Plan, the Commission stated that it was proposing to amend the CRMA so that recycled-content declarations would cover both pre- and post-consumer waste, rather than the current Article 29 focus on post-consumer waste. That is not the current law, but it is a clear signal that businesses should design traceability systems broadly enough to separate pre-consumer and post-consumer sources.
The most common pitfalls are practical rather than theoretical:
They are:
Yes. It is a regulation, so it is directly applicable in all Member States. Member States still have specific tasks under the act, including single points of contact, exploration programs, reporting, and penalties.
No general company-wide due-diligence duty is set out for all operators. The clearest recurring supply-chain assessment duty is Article 24 for certain large companies in listed downstream sectors. Other obligations are activity- or product-specific.
Under the EU Critical Raw Materials Act, critical raw materials are economically important to the EU and vulnerable to supply disruptions. Strategic raw materials are a priority group within the critical list because they are essential to green, digital, defence and aerospace technologies, while their future demand may exceed supply and their production can be difficult to increase. Therefore, all strategic raw materials are critical, but not all critical raw materials are strategic. Strategic materials also receive greater policy attention through the EU’s 2030 capacity and supply-diversification benchmarks.
Not as a standalone importer regime in the text reviewed here. But importers are often the operational party expected to secure origin, processing, recycling, and composition evidence needed for compliance and customer disclosures.
No. That obligation only applies once the Commission adopts calculation and verification rules for a specific critical raw material type after its necessity and proportionality assessment.
Not in full. The regulation sets the framework and deadlines, but key operational details depend on secondary acts and, for some products, later application dates.
No. Member States must lay down their own penalty rules by November 24, 2026. The regulation requires them to be effective, proportionate, and dissuasive, but does not set a uniform EU-wide fine schedule.