On the proposal for a regulation of the European Parliament and of the Council amending regulation (EU) 2024/1252

The Commission’s targeted amendments to the Critical Raw Materials Act (CRMA) reflect the need to strengthen the Union’s strategic autonomy, enhance the resilience of critical raw materials (CRMs) supply chains, and foster the development of a circular and sustainable European industrial base. The Commission identified challenges in ensuring the availability of strategic raw materials, particularly rare earth permanent magnets essential for clean tech and proposed clarifications and targeted measures to improve the implementation of recycling and reporting. The ongoing implementation of the CRMA also underlines a risk of fragmentation of the Single Market, arising from disparate identification by individual Member States of the large companies required to perform risk assessments of their supply chains under Article 24. The Commission is therefore mandated to monitor and ensure effective implementation.

The recent report of the European Court of Auditors (ECA) highlighted that the EU faces vulnerabilities in critical raw materials supply, gaps in the collection and recycling of post-consumer waste, and the lack of dedicated funding. In particular, the ECA stressed the need for improved risk preparedness, transparency in recycled content, and a strategic approach to partnerships with third countries. These findings underline the importance of coherent Union‑level action to strengthen resilience, ensure predictable access to CRMs, and support investment in industrial ecosystems. The Rapporteur was guided by the findings of the ECA in shaping the proposals contained in this report, shaping measures to improve transparency, risk mitigation, and strategic investment within the CRMA framework.

At the core of the amended CRMA framework is the principle that predictable implementation and the whole value‑chain integration are essential for mobilising investment and industrial capacity across the Union. The Rapporteur therefore supports maintaining a minimum of two cut‑off dates per year for programme calls, ensuring regular, predictable opportunities for project promoters, while preserving flexibility for the Commission to organise additional targeted calls where operational needs arise. Beyond frequency, targeted calls should encourage projects that integrate across the entire value chain — from extraction and processing to refining, manufacturing, recycling, and downstream demand — strengthening industrial ecosystems, avoiding fragmentation, and anchoring investment in resilient, commercially viable supply chains. In parallel, where supply disruptions create material vulnerabilities, companies should be equipped to mitigate risks through measures they deem appropriate. Options the Rapporteur considers include strategic stock replenishment, improved material efficiency, diversification of sources, substitution, and recycling. Joint purchasing mechanisms can contribute to stockpiling to enhance predictability and transparency, particularly for smaller market actors.

The Rapporteur considers that a resilient and future‑proof CRMA must rest on clear definitions and a robust framework that supports both industrial deployment today and the circular economy of tomorrow. For this reason, the amendments clarify what constitutes manufacturing and post‑consumer waste, to ensure legal certainty across Union law and avoid ambiguity in recycled content reporting. In the short term, recognising materials recovered from manufacturing waste can help establish a European recycling industry and improve resource efficiency, while internal process materials that remain within the manufacturing stream should not be counted toward recycled content shares because they do not constitute waste. The Rapporteur supports the Commission proposal to include Union-originated waste shares in the scope of the CRMA to foster European’s recycling capacity.

Strategic investment, innovation, and industrial preparedness are also central to the Rapporteur’s vision for the CRMA. Recognising that the market risks associated with CRM projects — including price volatility and long development cycles — can deter private capital, the amended text underlines Contracts for Difference (CfDs) as a tool to provide revenue certainty for strategic extraction, processing, and recycling projects. The Rapporteur notes that boosting Europe’s refining capacity is primarily an economic challenge, not a technological one, and CfDs can help overcome market barriers that hinder investment. At the same time, policies that promote technologies and processes to reduce dependence on constrained materials — through substitution, material efficiency, and recycling — will enhance competitiveness and sustainability across EU industry. Consistent with the ECA’s call for a strategic approach to partnerships, the Commission should regularly assess international collaboration to identify effective initiatives that bolster diversification and supply resilience, mindful of the Union’s international obligations.

The Rapporteur also emphasises that Commission services must be fully equipped and adequately resourced to carry out their new responsibilities under Article 24, as well as all other tasks foreseen in this Regulation, particularly the assessment and monitoring of strategic projects. Sufficient capacity is essential to ensure that targets are implemented effectively, projects are evaluated rigorously, and the Union can achieve its strategic objectives.

Lastly, the Rapporteur underscores that strengthening EU strategic autonomy in critical raw materials contributes to industrial, economic, digital and defence resilience. Ensuring that recyclable materials remain within the Union will reinforce supply security, while judicious assessment of export restrictions on secondary material streams can reduce avoidable losses and retain economic value within internal markets. Stronger obligations for large companies to prepare for supply disruptions, combined with enhanced recycling infrastructure and Union‑level collection targets assessed in the 2028 evaluation, will help close material loops and unlock higher recycling rates. Leveraging relevant Union financial instruments and initiatives such as future competitiveness programmes and instruments, can further de‑risk and accelerate strategic projects.

The Rapporteur is of the opinion that these targeted amendments create a coherent, technically achievable, and investment‑friendly framework, which balances the needs of short‑term industrial deployment with long‑term strategic objectives, reinforces EU autonomy, and promotes a sustainable circular economy for critical raw materials.

Pursuant to Article 8 of Annex I to the Rules of Procedure, the rapporteur declares that he included in his report input on matters pertaining to the subject of the file that he received, in the preparation of the draft report, from the following interest representatives falling within the scope of the Interinstitutional Agreement on a mandatory transparency register, or from the following representatives of public authorities of third countries, including their diplomatic missions and embassies:

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