Critical Raw Materials Act (CRMA) — Regulation (EU) 2024/12

Does our supply chain depend on a single-country source for lithium, cobalt or rare earths — and what happens when the EU starts enforcing diversification?

Any large company (>500 employees, >EUR 150 million turnover) using strategic raw materials in batteries, chips, wind turbines or similar technologies must complete a supply-chain risk assessment by 24 May 2025 [Art. 24], and Member States must lay down penalty rules by 24 November 2025 [Art. 47] — procurement teams that still depend on a single third-country source for more than 65% of any strategic material face mandatory mitigation action [Art. 5(1)(b)].

Short Answer

Regulation (EU) 2024/1252 (the Critical Raw Materials Act, CRMA) creates binding EU-wide benchmarks for domestic extraction (at least 10%), processing (at least 40%) and recycling (at least 25%) of strategic raw materials by 2030 [Art. 5(1)(a)]. It requires Member States to identify large companies that use strategic raw materials in key technologies and obliges those companies to conduct triennial supply-chain risk assessments [Art. 24(1)-(2)]. Products containing permanent magnets — from wind generators and EVs to industrial robots and heat pumps — must carry recyclability labels and data carriers once implementing acts enter into force [Art. 28]. The Regulation also establishes the European Critical Raw Materials Board for ongoing supply-risk monitoring and stress-testing of every strategic material at least every three years [Art. 20(3)].

Who is affected

Large companies with more than 500 employees and net worldwide turnover exceeding EUR 150 million [Art. 2(29)] that manufacture batteries, hydrogen equipment, renewable energy equipment, aircraft, traction motors, heat pumps, data transmission/storage equipment, mobile electronic devices, additive manufacturing equipment, robotics, drones, rocket launchers, satellites or advanced chips [Art. 24(1)]. Additionally, any entity placing on the EU market products with permanent magnets listed in Art. 28(1) (MRI devices, wind generators, EVs, household appliances, industrial robots, etc.) faces labelling, data-carrier and recycled-content obligations.

Deadline

Staggered deadlines — the next upcoming ones: by 24 May 2025, Member States must draw up national exploration programmes [Art. 19(1)] and identify covered large companies [Art. 24(1)]; by 24 November 2025, Member States must establish penalty frameworks [Art. 47] and the extractive-waste database [Art. 27(6)]; permanent-magnet labelling applies two years after the implementing act on format (due by 24 November 2025) [Art. 28(1)-(2)]; recycled-content disclosure for magnets applies by 24 May 2027 or two years after the delegated act, whichever is later [Art. 29(1)]; the 2030 capacity benchmarks are the overarching target [Art. 5(1)].

Risk

Article 47 mandates Member States to lay down 'effective, proportionate and dissuasive' penalties by 24 November 2025, but does not prescribe a ceiling — penalty levels will therefore vary by Member State. Non-compliance with permanent-magnet labelling and recycled-content requirements (Arts. 28-29) triggers market surveillance action and potential product withdrawal under the CE-marking conformity framework [Art. 33]. For large companies, failure to conduct the mandatory supply-chain risk assessment [Art. 24(2)] may result in enforcement action under national implementing rules.

Proof

Legal status

• In force
• as of 2026-04-17
• Consolidated version of 03.05.2024 (incorporating corrigenda C1 and C2)

Primary sources

• EUR-Lex — Full text
• European Commission — CRMA — EU critical raw materials strategy

What to do now

Legal / DPO

•Map your entity against the Art. 2(29) definition of 'large company' (>500 employees, >EUR 150 million worldwide turnover) and check whether your products fall under Art. 24(1) technologies — if both thresholds are met, the triennial risk assessment obligation is binding.
•Review your permanent-magnet product portfolio against the Art. 28(1) list and prepare the labelling, data-carrier and information-retention obligations (lifetime + 10 years) that will apply once the implementing act on format enters into force [Art. 28(2), Art. 28(7)].
•Monitor your Member State's transposition of Art. 47 penalty rules (due by 24 November 2025) and build an internal compliance timeline that aligns with the staggered deadlines across Arts. 19, 24, 26, 27, 28 and 29.

Compliance

•Establish a triennial supply-chain risk assessment process covering mapping of extraction/processing/recycling origins, supply-disruption factors and vulnerability analysis as required by Art. 24(2)(a)-(c), and prepare board-level reporting per Art. 24(5).
•Set up a monitoring process for the Commission's strategic-stocks benchmark [Art. 23(2)] and supply-risk dashboard [Art. 20(4)] to feed internal mitigation strategies and diversification decisions [Art. 24(4)].
•Coordinate with your Member State's single point of contact [Art. 9] if your organisation is a project promoter or key market operator — information obligations under Art. 21 require proactive data sharing on CRM projects and market activities.

IT / Security

•Implement data-carrier and unique-product-identifier infrastructure for permanent-magnet products as specified in Art. 28(3)-(4) — the data carrier must link to product-level information on magnet weight, location, chemical composition and removal instructions, accessible to recyclers and authorities.
•Ensure your product-information systems can store and serve the Art. 28(4) dataset for the product's full lifetime plus 10 years [Art. 28(7)], including through insolvency scenarios — consider escrow or resilient hosting.
•Prepare IT systems for the recycled-content disclosure obligation [Art. 29(1)] and, where applicable, the environmental footprint declaration [Art. 31(6)-(7)] — both require public, free-access web availability.

Product / Engineering

•Audit every product in your portfolio against the Art. 28(1) product list (MRI, wind generators, EVs, e-bikes, heat pumps, industrial robots, household appliances, electric motors) and identify which contain NdFeB, SmCo, AlNiCo or ferrite permanent magnets requiring labelling.
•Design for magnet removability now — Art. 28(4)(c) requires removal instructions and recyclers will need access; integrate circular-design principles per Art. 26(1)(e) to reduce future compliance cost and meet recycled-content thresholds.
•Plan for the recycled-content disclosure per Art. 29(1): for permanent magnets >0.2 kg total weight incorporating NdFeB, SmCo or AlNiCo types, you must publicly report post-consumer recycled shares of Nd, Dy, Pr, Tb, B, Sm, Ni and Co — establish supplier data pipelines early.

Key Terms

Strategic raw materials: Raw materials listed in Annex I, Section 1 of the CRMA, selected for their strategic importance, projected demand growth and difficulty of increasing production [Art. 3].
Critical raw materials: Raw materials listed in Annex II, Section 1, which include all strategic raw materials plus any material exceeding the supply-risk threshold of 1 and economic-importance threshold of 2.8 [Art. 4(2)].
Strategic Project: A raw material project recognised by the Commission under Art. 6-7 that contributes meaningfully to EU supply security, is technically feasible, sustainable, and has cross-border benefits or mutual benefit with third countries.
Large company: A company with more than 500 employees on average and net worldwide turnover exceeding EUR 150 million in the most recent financial year [Art. 2(29)].
Supply risk: A metric calculated in line with Annex II, Section 2 of the CRMA, measuring the likelihood and potential impact of disruptions to a raw material's supply [Art. 2(13)].
European Critical Raw Materials Board: An advisory body established under Art. 35, composed of representatives from all Member States and the Commission, tasked with overseeing strategic-project applications, supply monitoring and strategic-stocks coordination.
Offtake agreement: A contract between an undertaking and a project promoter committing to purchase a share of raw materials produced by a specific project over a defined period, or granting an option to do so [Art. 2(16)].

Frequently Asked Questions

Which raw materials are classified as 'strategic' under the CRMA?

The strategic raw materials are listed in Annex I, Section 1 of the Regulation. They include, among others, lithium, cobalt, natural and synthetic graphite, rare earth elements, bismuth, boron, gallium, germanium, magnesium, manganese, nickel (battery grade), platinum group metals, silicon metal, titanium metal and tungsten [Art. 3(1)]. The Commission must review and, if necessary, update this list by 24 May 2027 and every three years thereafter [Art. 3(3)].

What are the 2030 capacity benchmarks?

By 2030, the EU aims for domestic extraction capacity covering at least 10% of annual consumption, processing capacity of at least 40%, and recycling capacity of at least 25% of annual consumption of strategic raw materials [Art. 5(1)(a)]. Additionally, no single third country should supply more than 65% of the EU's annual consumption of any strategic raw material [Art. 5(1)(b)].

Who qualifies as a 'large company' subject to the supply-chain risk assessment?

A large company is defined as having more than 500 employees on average and net worldwide turnover exceeding EUR 150 million in the most recent financial year [Art. 2(29)]. It must also operate in one of the sectors listed in Art. 24(1), such as batteries, renewable energy equipment, aerospace, chips, robotics, or heat pumps.

What products are affected by the permanent-magnet labelling rules?

Art. 28(1) lists: MRI devices, wind energy generators, industrial robots, motor vehicles, light means of transport (e-bikes, e-scooters), cooling generators, heat pumps, electric motors (including those integrated in other products), automatic washing machines, tumble driers, microwaves, vacuum cleaners and dishwashers. MRI devices, motor vehicles and L-category vehicles receive a later application date of 24 May 2029 [Art. 28(10)].

When do the permanent-magnet labelling obligations begin?

The labelling obligation under Art. 28(1) applies two years after the implementing act on label format enters into force. That implementing act is due by 24 November 2025 [Art. 28(2)], so the earliest likely start for most products is late 2027. For MRI devices, motor vehicles and L-category light means of transport the obligations apply from 24 May 2029 [Art. 28(10)].

What is the recycled-content disclosure obligation for permanent magnets?

From 24 May 2027 (or two years from entry into force of the delegated act on calculation rules, whichever is later), any entity placing covered products on the market with permanent magnets >0.2 kg must publicly disclose the post-consumer recycled share of Nd, Dy, Pr, Tb, B, Sm, Ni and Co in those magnets [Art. 29(1)]. The Commission must also set minimum recycled-content shares by 31 December 2031 at the latest [Art. 29(3)].

Are there penalties for non-compliance?

The Regulation itself does not prescribe fixed penalty amounts. Instead, Art. 47 requires each Member State to establish its own penalty regime by 24 November 2025, ensuring penalties are 'effective, proportionate and dissuasive'. Non-compliance with product requirements (Arts. 28-29) additionally triggers the CE-marking conformity and market surveillance framework [Art. 33].

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