On 25 March 2025, the European Commission ('Commission') announced the list of 47 Strategic Projects designated under the Critical Raw Materials Act ('CRMA'). Each of these Strategic Projects will support in forming strong and sustainable value chains for critical raw materials and building strategic independence for the EU.
What is the CRMA, what are Strategic Projects and why are they important?
Strategic raw materials have been identified by the CRMA as likely to create supply risks in the near future due to growth in their demand, current supply levels and the challenges encountered in scaling up production. These strategic raw materials are commonly used in sectors such as renewable energy, defense technologies, battery technologies and aerospace. Examples include lithium, cobalt and nickel amongst others.
As third countries are primarily relied upon for the supply, processing and recycling of these strategic raw materials, the EU is mindful of security of supply. The CRMA, which entered into force in May 2024, was passed in order to respond to these challenges.
The CRMA sets the following benchmarks for domestic capacities to be achieved by 2030:
- 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
As part of its objective to build sustainable value chains for critical raw materials, the CRMA creates a framework to support Strategic Projects. For a project to be designated as a Strategic Project it needs to be technically feasible and identified as contributing to the EU's secure supply of strategic raw materials.
How are Strategic Projects selected and what benefits do they receive?
Applications for Strategic Projects opened in 2024 and were assessed by independent experts on the following factors:
- Technical, financial and sustainability-related aspects
- Classification under the United Nations Framework Classification for Resources
- Whether they meet the CRMA criteria
Based on the above selection process, the Commission shortlisted a list of potential projects. This list was then further assessed by the Critical Raw Materials Board, which consists of Member States and the European Parliament as an observer. The final list of 47 Strategic Projects was finalized and published following this consultation.
Selected projects benefit from two main advantages: streamlined permitting and access to finance. With streamlined permitting, the intention is to have a shorter permit granting process, with extraction projects not exceeding 27 months and other projects not exceeding 15 months. This contrasts with current permitting processes, which can range from five to 10 years.
As for financing, the Strategic Projects are expected to have a capital investment requirement of around €22.5 billion. These projects will receive support from the financing sub-group of the Critical Raw Materials Board, who provide advice on financing of projects and bring together various institutions including the EIB and financial institutions. The sub-group will also meet to discuss how each Strategic Project can be supported financially.
Regional and national authorities will also be able to make use of funding from the European Development Fund and Cohesion Fund to support Strategic Projects, providing further financial assistance.
Whilst it remains to be seen how streamlined permitting and access to finance will be in practice, the potential benefits of being classified as a Strategic Project include dedicated financial advice and support, access to key investors and project promoters having more predictability through expedited permitting.
Overview of the 47 Strategic Projects
The 47 Strategic Projects are located across 13 EU Member States and cover the following phases of the raw material value chain:
- Extraction activities – 25 projects
- Processing – 24 projects
- Recycling – 10 projects
- Substitution of raw materials – 2 projects
More specifically, the Strategic Projects concern the following strategic raw materials:
- Lithium – 22 projects
- Nickel – 12 projects
- Graphite – 11 projects
- Cobalt – 10 projects
- Manganese – 7 projects
- Tungsten – 3 projects
- Magnesium – 1 project
Future Strategic Projects
The Commission plans to open applications for a new round of Strategic Projects at the end of summer of 2025 and potential applicants are encouraged to apply.
Melanie Amaya Mazza (White & Case, Trainee Solicitor, London) contributed to the development of this publication.
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This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.
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