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A regulatory approach
Where the United States has answered the mineral contest with an alliance, a trade framework and a national stockpile, the European Union has chosen a fundamentally different path. The EU's strategy is regulatory rather than alliance-based: it seeks to secure access to critical minerals through binding legislation, centralised decision-making and conditional financing, while preserving its freedom to keep trading with China. The aim is not to join a protected Western mineral market under American leadership, but to retain European control over European supply chains — including resources located in non-member states such as Norway and Greenland.
The backdrop is structural weakness. The EU has very few mineral deposits of its own, and for some materials it depends on China almost entirely: China refines the overwhelming majority of the world's rare earth elements, accounts for roughly 98 percent of global gallium refining capacity, and supplies close to 97 percent of the EU's magnesium. European stockpiles are so low that the actual figures are classified, and the European Court of Auditors has warned that efforts to diversify supply have so far produced limited results.
Why now
The EU adopted CRMA in 2023, and it entered into force in May 2024, but for more than a year it remained largely a framework on paper: permitting was slow, financing thin, and domestic capacity barely moved. What turned critical minerals from a long-term policy goal into an urgent one was not the regulation itself but events outside it. When the US concluded its minerals agreement with Ukraine in spring 2025 — securing preferential access to deposits in the middle of the European continent — and then escalated its pressure on Greenland, which holds some of Europe's largest untapped mineral reserves, the EU saw two of its few realistic alternatives to Chinese supply being drawn into a US-led framework. China's tightening export controls on rare earths, gallium and germanium through 2025 sharpened the pressure further. The EU's response, RESourceEU, was in effect an admission that CRMA alone was not delivering, and that the bloc was running out of time and options.
The Critical Raw Materials Act (CRMA)
CRMA is the centrepiece of the EU's strategy. Politically agreed in late 2023 and in force since May 2024, it is a binding regulation — the strictest form of EU legislation, which must be incorporated into national law exactly as written and which overrides conflicting national legislation. It sets four targets for 2030: the EU shall extract 10 percent, process 40 percent and recycle 25 percent of its own mineral needs, and rely on no single third country for more than 65 percent of any strategic raw material. The regulation governs a Critical Raw Materials list of 34 critical and 17 strategic minerals, updated at regular intervals.
CRMA obliges member states to explore for minerals, identify extraction areas and facilitate processing capacity to meet the EU's production targets — without an upper limit on scope. It is both the political instrument and the legal machinery of the strategy in a single act.
Decision-making in Brussels
CRMA's operating mechanism is the designation of Strategic Projects, decided not by member states but centrally by the EU Critical Raw Materials Board in Brussels. Any company — with no requirement that it be domestic — can apply directly to the EU for strategic status. Approval brings prioritised, fast-tracked decisions and access to financing, in exchange for binding commitments to supply minerals to the EU market.
The scale is already visible. The first round produced 60 approved projects — 47 within the EU and 13 in third countries — and a second round closed in January 2026, drawing more than 160 applications. Through this mechanism the decision over a third country's mineral production is, in practice, transferred from national authorities to Brussels.
RESourceEU: control through financing
The EU's most distinctive tool is financial rather than legal. Through the RESourceEU Action Plan, adopted on 3 December 2025, the Commission committed to mobilise around 3 billion euros of EU funds for the critical raw materials value chain within twelve months. This includes at least 700 million euros from the Innovation Fund's 2026 call, the European Investment Bank's commitment of up to 2 billion euros per year for CRM-related projects, and coordinated instruments such as InvestEU, the Battery Booster and IPCEI — all drawn together under a new CRM financing hub.
Crucially, the Commission has tied this money to delivery. From 2026 it is launching a new approach to project financing built on securing offtake in the EU, and has stated it will work with the EIB and EBRD to set stringent conditions ensuring that EU-funded projects deliver to their intended markets. This is the core of the strategy — control without ownership. The EU does not need to own a mineral project to direct it; it secures the resource by making the project financially dependent and binding that dependency to delivery obligations, integration into the strategic-project list, and submission to the EU's decision-making process.
The regulatory ecosystem
CRMA does not stand alone. A surrounding body of regulation reinforces it. The Net-Zero Industry Act introduces resilience and sustainability criteria into public procurement and auctions for net-zero technologies; the Corporate Sustainability Due Diligence Directive (Directive (EU) 2024/1760) requires large companies to identify and address adverse impacts across their chains of activities; the Foreign Subsidies Regulation gives the Commission power to investigate and restrict companies benefiting from distortive third-country subsidies; and the defence instruments EDIP and SAFE direct procurement and funding toward suppliers established in the EU and associated states.
Some of these preferences are now explicit. Under RESourceEU, the Commission has confirmed that the Horizon Europe work programme for 2026–2027 will restrict the participation of Chinese entities and Chinese-controlled EU-based entities in all critical-raw-materials research and innovation actions, and that it intends to replicate this approach across other EU funding instruments. Where such direct exclusion is not used, the same end is reached through framing rather than prohibition: recurring terms such as resilience, strategic autonomy, de-risking and trusted partners function as a structural filter against non-European supply chains, avoiding the explicit "buy European" clause that would be legally exposed under WTO and EEA rules.
A belated stockpile
For all its regulatory ambition, the EU recognized only recently that the 2030 targets do not address the supply risk that exists today. On 20 May 2026 it emerged that the EU had drawn up a shortlist — tungsten, rare earth elements and gallium, with magnesium, germanium and graphite likely to follow — for its first coordinated mineral reserve, and was in talks with major ports such as Rotterdam over storage. It is the European answer to the American Project Vault, but it arrives late and modest: where the US is building reserves equivalent to a year's consumption, European reserves are estimated to last only weeks in a crisis.
The great weakness in the EU's mineral strategy
The EU's internal market is smaller than the Western market the United States is assembling, and it lacks an instrument for price guarantees that could make new mineral projects viable, which ties the EU to continued free trade with China. While the union tightened sanctions against Chinese suppliers, the EU simultaneously moved to grant exemptions for banned Chinese chips in order to shield the car industry – a reminder that European industry cannot function without Chinese raw materials. The strategy thus asks potential investors in the mineral extraction industry to accept European control without being able to guarantee a minimum price. In July 2026, the EU published a study confirming, among other things, that the United States invests EUR 46 million against the EU's EUR 5–6 million, and that the American model is market-based while the EU's model is based on state aid and loans. It further confirms that the EU has an inadequate strategic stockpile and, not least, that the EU offers investors no price guarantee. That this study appeared only in July 2026 underlines how far behind the EU is. The findings should have been identified back when Trump issued the presidential order on price floors in January.
Of decisive importance for Norway
The EU has very few realistic alternatives to Chinese supply on the European continent, and Norway is foremost among them, with the third largest deposits of rare earths in the world. Norway is also in a unique position in that mineral extraction can be financed through the oil fund.
The Labour government intends to incorporate the CRMA into the EEA Agreement, which would mean that Norway cannot invest from the oil fund, and that the EU gains control over Norwegian mineral deposits.
A thorough introduction of what this means for Norway is presented in The Mineral Petition.
Other Critical Minerals Strategies
Critical Minerals in Charts
SOURCES
I – EU Mineral Legislation – CRMA
European Commission – Critical Raw Materials Act
European Union EUR-Lex – Critical Raw Materials Regulation (EU) 2024/1252
European Union – List of Critical Raw Materials
II – Strategic Projects and Decision-Making
European Commission – Selected Strategic Projects under CRMA – 60 Total (47 EU, 13 Third Countries)
European Commission – Strategic Projects Gain Momentum in Second Selection Round
European Commission – Second Call for Strategic Projects Launched – Deadline 15 January 2026
III – EU Financing Mechanisms
European Commission – RESourceEU Action Plan, COM(2025) 945 final
European Investment Bank – EIB Steps Up Financing for Critical Raw Materials – Up to €2 Billion
Jacques Delors Centre – The EU's Critical Raw Materials Predicament: ReSourceEU to the Rescue?
EU Parliament - US critical minerals policy and its implications for the EU’s strategic autonomy
IV – Dependence and Diversification
European Court of Auditors – Special Report 04/2026: Critical Raw Materials for the Energy Transition
Bloomberg – EU to Seek Carve-Out for Banned China Chips
V – The Regulatory Ecosystem
European Commission – Net-Zero Industry Act
European Commission – Corporate Sustainability Due Diligence
European Union EUR-Lex – Corporate Sustainability Due Diligence Directive (EU) 2024/1760
European Commission – Foreign Subsidies Regulation
European Commission – European Defence Industry Programme (EDIP)
European Commission – Security Action for Europe (SAFE)
VI – EU Mineral Reserve
Reuters (via Mining Weekly) – EU Shortlists Tungsten, Rare Earths for First Stockpile to Curb China Reliance
South China Morning Post – EU Picks Tungsten, Rare Earths, Gallium for First Critical Mineral Stockpile
The Deep Dive – EU Mineral Reserve Shows 2030 Targets Do Not Cover 2026 Risk
VII – External Pressure: Ukraine and Greenland
Reuters – US and Ukraine Sign Minerals Deal
European Commission / Government of Greenland – Memorandum of Understanding on Cooperation in the Raw Materials Value Chain
VIII – Norway and the EU
European Commission – Norway and EU Strategic Partnership on Raw Materials
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