EditEU vulnerable to critical raw materials shock despite flagship law, auditors warn
Progress remains limited as to the goals of the EU producing 10% of its strategic raw materials domestically and processing 40% within the bloc
The European Union remains dangerously dependent on a handful of foreign suppliers for the raw materials needed for its green and industrial transition, with its flagship Critical Raw Materials Act so far failing to produce tangible improvements in supply security, the European Court of Auditors (ECA) has concluded in its special report.
“Geopolitical crises can also disrupt EU supplies. Commission trade data show that imports of critical raw materials used in renewable energy technologies originating from Ukraine fell from around 345,000 tonnes in 2021 to about 60,000 tonnes in 2024 following Russia’s invasion of the country”, the report warns.
Despite new EU legislation, trade partnerships and strategic projects, the bloc has not meaningfully diversified imports, struggles to develop mining and processing at home and is underutilising recycling, leaving its net-zero ambitions vulnerable to geopolitical disruption.
The Critical Raw Materials Act requires that by 2030 no more than 65% of any of the EU’s 17 strategic raw materials should originate from a single non-EU country. However, several key materials already exceed this threshold at the processing stage, including lithium, magnesium, gallium and rare earth elements.
In mining, 99% of the EU’s boron supply currently comes from one external country – Turkey. The European Court of Auditors’ data show that the EU also relies to a significant extent on China for several key raw materials needed for the energy transition, including magnesium, germanium, gallium, barite, tungsten and others.
Although the EU has intensified external action in recent years, including trade agreements, strategic partnerships and roadmaps, the auditors say it remains unclear whether these efforts have actually increased supplies. Quantitative evidence is lacking, while geopolitical tensions and trade disruptions continue to threaten supply security.
Strategic partnerships have improved cooperation but contributed little to securing access to raw materials, partly due to missing or delayed roadmaps and the absence of concrete supply projects.
The Court recommends the Commission assess the real impact of trade agreements and partnerships on supply security and adjust future agreements accordingly.
The auditors call on the Commission to launch a consultation and develop evidence-based recommendations to ease investment in the exploration, mining and processing of critical raw materials, and to consider follow-up policy measures, with implementation targeted by 2027.
Domestic production faces structural barriers
The EU has set indicative targets to produce 10% of its strategic raw materials domestically and process 40% within the bloc, yet progress remains limited. Exploration activity is still underdeveloped and largely confined to general geological mapping, while targeted mineral exploration carries high financial risk and a low success rate. Processing capacity is weak due to limited technologies and a shrinking number of facilities.
High energy costs compound the problem and it remains too early to judge whether recent industrial competitiveness initiatives will improve the situation.
“Financing is another major obstacle”, the report finds. Mining and processing projects struggle to secure funding, and the Commission has still not proposed including mining and processing activities in the EU sustainable finance taxonomy, despite an earlier commitment.
Permitting procedures also delay projects. Lengthy administrative processes, environmental requirements and social considerations slow approvals. The Commission has clarified mining conditions in Natura 2000 areas but not under the Water Framework Directive, while one-stop-shop permitting solutions are still being developed.
The auditors call on the Commission to facilitate investment across exploration, extraction and processing through evidence-based policy recommendations.
Recycling potential underused
Sustainable resource management could significantly reduce demand for primary raw materials through recycling, substitution and improved efficiency. The European Critical Raw Materials Act (CRMA) sets a non-binding target for 25% of strategic raw materials consumption to come from recycled sources by 2030. CRMA, in force since May 23, 2024, strengthens the EU’s access to a secure, sustainable supply of critical materials (like lithium, cobalt, and rare earths) for the green and digital transitions. It aims to reduce reliance on single-source suppliers by boosting domestic extraction, processing, and recycling.
However, the Court of auditors says the EU has not fully exploited this potential. The Net-Zero Industry Act does not address raw material substitution, and delayed implementing acts risk postponing national circular economy plans.
Existing recycling targets do not sufficiently incentivise recovery of individual materials or the use of recycled content. High processing costs, limited feedstock availability and technological barriers continue to undermine the competitiveness of the European recycling sector.
Regulatory obstacles — including rules affecting waste shipments — further limit commercial viability. The Court suggests binding recycling targets where technically feasible and measures to facilitate the movement of waste containing critical raw materials within the EU.
Strategic projects may fall short by 2030
CRMA introduced “strategic projects” intended to accelerate mining, processing and recycling through faster permitting and greater visibility, but their effectiveness is uncertain.
There is no dedicated EU funding for these projects and permit appeals can still cause delays. By November 2025 the Commission had launched only two calls for proposals, although the law requires at least four annually from 2025.
Eligibility is also limited to strategic raw materials, excluding other critical materials needed for the energy transition. Many selected projects, especially those at early development stages or lacking off-take agreements with EU buyers, are unlikely to contribute significantly to supply security by 2030.
The auditors suggest widening eligibility to more critical materials and prioritising projects with confirmed European customers.
Governance and methodology gaps
The ECA also identifies weaknesses in the overall policy framework. It recommends improving trade data, demand forecasts and the methodology used to define lists of critical and strategic raw materials.
Future targets should be better justified and clearly linked to EU renewable energy and net-zero industry objectives. The Commission should also monitor EU funding allocated to raw-materials initiatives and assess its impact on supply security.
Overall, the auditors conclude that the EU has created an ambitious policy framework but still lacks operational delivery, meaning strategic dependence on external suppliers is likely to persist unless implementation accelerates rapidly.
Caption: Stéphane Séjourné, executive Vice-President of the European Commission for Prosperity and Industrial Strategy, speaks during a press conference on the Critical Raw Materials Act in Brussels, Belgium, 25 March 2025. The Commission has adopted a list of 47 Strategic Projects to boost domestic strategic raw material capacities, EPA/OLIVIER HOSLET
Updated: February 9, 2026 - 07:47
