Schalast | Raw materials management / raw materials strategy

During the coronavirus pandemic, many companies have recognized that international dependencies on raw materials can become a strategic problem due to disrupted supply chains. As a result, there are now a number of instruments at the EU level to counteract this recognized problem, such as the Critical Raw Materials Act (CRMA), which came into force in May 2024. The aim of the CRMA is to ensure the supply of strategic and critical raw materials. As a unilateral foreign trade instrument, it is not concerned with EU companies' access to strategic or critical raw materials in third countries, but with ensuring the supply and recycling of critical raw materials.

Strategic raw materials include copper, cobalt, germanium and tungsten. Critical raw materials are, for example, bauxite, feldspar, silicon metal and tantalum.

For companies, it is important to know, for example, whether a project is to be classified as a “strategic project” under the CRMA in the context of approval procedures. This is because this classification means that the project is given special consideration. For example, companies are also obliged to carry out stress tests in which the companies must then show where strategic raw materials are extracted, processed or recycled. Furthermore, there are product-related regulations for permanent magnets.

The CRMA has some overlap with the EU Supply Chain Due Diligence Directive (CSDDD), as respect for human rights along the value chain for critical raw materials is to be verified. However, the CRMA does not specifically address issues of export and export bans of critical raw materials.