Towards the very end of the shortest month of the year, the European Commission unveiled its plan to boost the economic prowess of industry with a clear focus on energy-intensive industries and clean-tech. As a key pillar, the deal also zooms into critical raw materials, indispensable for the sectors and technologies needed for a competitive and climate-cognisant direction for the EU economy.
Before zooming into what the deal intends to do, it is worthwhile to remind ourselves shortly of the state of play.
The EU Critical Raw Materials Act, the EU’s main legislative tool to ensure a safe, secure and sustainable supply and management of key materials, was published in the EU Official Journal in spring of 2024. Notably, this act includes certain non-binding targets related to the EU’s annual consumption of extraction (10%), processing (40%) and recycling (25%) in addition to a cap on consumption from one single country (65%) by 2030. In this regard, the European Commission may recognise “strategic projects” with the intention of speeding up, permitting and easing the access to financing.
One of these 16 “strategic” raw materials is “silicon metal”, a highly versatile material used in everything from EV batteries, production of silicones, solar energy and semiconductors. It is estimated that today China controls 76% of the market with Norway representing 6%. While it is clear that Europe will not be taking the lead, it does have a relevant share with a possibility to focus more on mining projects. It would, however, be remiss to not mention the challenges and opposition to an increased focus on exploiting such materials. A key example is when two non-majority shareholders of silicone company Elkem (majority shareholder is “China’s Bluestar”), underlined in 2021 the need for them to respect the rights of the indigenous Sami population who were opposed to plans for a quartz mine in Norway (Násávárre). An official authorisation is currently pending dialogue between Elkem and the reindeer herders. In short, the road towards an increasingly more self-reliant and autonomous EU must also address the challenges and weigh up the cost/benefits of how to increase activities within Europe’s borders.
What does the “Clean Industrial Deal” suggest in this regard?
The European Commission has committed to “prioritise” the implementation of the Critical Raw Materials Act by publishing a first list of strategic projects in March 2025. As a reminder, the European Commission was initially aiming to have the list ready by the end of 2024. 170 applications were received by the deadline of 22 August 2024 (≈70% from within the EU and 30% from outside). It is worth noting that projects in third countries or in overseas territories should comply with the same level of social and environmental sustainability (e.g., meaningful engagement with local communities). A meeting of the “European Critical Raw Materials Board” (EC and national ministries/authorities) took place on 20 February and included the opinion of the board on the list of projects. This will have to be taken into account but it is non-binding and the European Commission has the last word.
With the idea of leveraging the EU as a whole to secure better pricing, the Commission will launch an “EU Critical Raw Material Centre” to allow the joint purchase of raw materials on behalf of interested companies. It may also carry out other tasks such as ensuring strategic stockpiling. In times where the future of geopolitics is extremely uncertain and given the vulnerability of the EU to face limits placed by third countries on exports (e.g., as seen in the past with China and Graphite), stockpiling is increasingly critical. The centre is expected in Q4 of 2026
The deal further highlights that the European Commission will consider concrete additional measures to make recycling of these materials more attractive than their export. This emphasis on creating a thriving market of secondary raw materials will be an important pillar of the future Circular Economy Act. What’s more, the European Commission will foster so called “Trans-Regional Circularity Hubs” to develop economies of scale. As with the CRMA, strategic projects will be identified but the focus will be placed on boosting the circularity and ensure materials are kept within the economy as long as feasible. Naturally, the extent to which materials can be recycled will depend on how they are applied. For instance, given its wide dispersion in chemical applications and metallic alloys, silicon metal is not typically recycled. These hubs are also expected in Q4 of 2026.
The CRMA already provided concrete targets and a general direction to secure an increasingly European-led future for its raw material needs. With the Clean Industrial Deal there is, however, revamped momentum to bolster the EU’s strategic autonomy, reduce reliance and diversify supply.
In this respect the deal could be seen as the start of an odyssey to revamp the acquisition and control of raw materials. Where the journey will end up is still to be written but the direction of travel is clear.
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