​In 2011, the European Commission published its first critical raw materials list.  It contained 14 metals, selected following a defined methodology.  The list was reviewed every 3 years, and over the years, the methodology and the collection of data was adjusted and became more robust. The current list contains 30 materials, mostly elements.

The lists of critical raw materials never had any legal consequences.  For most substances on the list, it was positive to be on the list as it allowed them to demonstrate their importance in legislative procedurs, like substance evaluations, trade agreements and other.  The need to formulate policies on critical raw materials and to define a supportive legal framework developed over the last few years.  Certain CRMs were used by dominant producing countries as a trade retaliation instrument. Some industrial sectors suffered and are suffering from shortages of raw materials or components like semiconductors where CRMs play an important role.  The EU also realizes that CRMs play a pivotal role in the enabling of green technologies.  Finally, the Russian aggression against Ukraine displayed Europe’s dependence on imports of energy raw materials.

​

Europe wants to mitigate the risks of supply from third countries and has announced a Critical Raw Materials Act to address the risks and to provide a legal framework.  The proposal is based on a public call for evidence and public consultations that took place at the end of last year.

​

We will report here on the publication of the proposal for a CRM Act after its publication, which is expected end of March 2023.