EU Critical Raw Materials Act

The CRMA's objectives are threefold:

1. Ensure a steady provision of essential raw materials for the European Union (EU) industry.
2. Bolster the resilience of the supply chain.
3. Encourage diversification of sourcing while diminishing dependencies.

These aims are intended to achieve the following:

1. Safeguard the competitiveness of the EU industry by facilitating access to raw materials crucial for advancing green technology.
2. Reduce susceptibility to disruptions in the supply chain, such as those witnessed during the Covid-19 pandemic and natural calamities.
3. Mitigate the threat of economic coercion, particularly from China.

Critical Raw Materials (CRM) are categorized based on the following criteria:

• Economic significance for the broader EU economy.
• Assessment of supply risk.

Strategic Raw Materials (SRM), a subset of Critical Raw Materials (CRMs), are defined by criteria including:

• Importance in promoting the green and digital transitions.
• Relevance to defense and space applications.
• High projected future demand relative to current global production.

The inventory of Critical Raw Materials (CRMs) and Strategic Raw Materials (SRMs) pertinent to green technologies will be subject to periodic revisions by the European Commission:

Reference: General method to declare the use of critical raw materials in energy-related products

Mandatory Requirements for Companies

1. Companies should not depend on a single third country for more than 65% of its supply of any strategic raw material, unprocessed and at any stage of processing
2. Supply Chain Audit: Large companies utilizing Sub-group of Critical Raw Materials (SRMs) in strategic technologies must undergo mandatory supply chain audits every two years. Examples of such technologies include, but are not limited to:
   • Energy storage and electric mobility batteries.
   • Equipment for hydrogen production and utilization.
   • Equipment associated with renewable energy generation.
   • Traction motors.
   • Heat pumps.
   • Data transmission and storage systems.
   • Mobile electronic devices.
   • Equipment related to additive manufacturing.
   • Robotics.
   • Drones.
   • Satellites.
   • Advanced chips.
3. The audit must encompass a stress test on SRM supply chains to assess their vulnerability to disruptions by evaluating the potential impact of various scenarios. This evaluation should consider:
   • Locations of SRM extraction, processing, or recycling.
   • Capacities of economic operators along the value chain and market structure.
   • Factors influencing supply, such as geopolitical conditions, logistics, energy supply, workforce, or natural disasters.
   • Availability of alternative supply sources and substitute materials.
   • Identification of users of the relevant SRM throughout the value chain, with particular attention given to technologies relevant for the green and digital transitions, defense, and space industries.
4. Companies should collect information about presence of critical raw materials within their products in order to be able to fulfill their obligations.
5. At least 10% of what the EU uses each year should come from within the EU itself.
6. At least 40% of the EU's yearly needs should be processed within the EU.
7. At least 15% of the EU's annual consumption should be met through recycling materials.

Scope products for Special Requirements of Permanent Magnets:

The list of relevant products includes:

• Magnetic resonance imaging devices
• Wind energy generators.
• Industrial robots
• Motor vehicles
• Light means of transport
• Cooling generators
• Heat pumps
• Electric motors, including those integrated into other products like automatic washing machines,   tumble driers, microwaves, vacuum cleaners, and dishwashers.

Special Requirements of Permanent Magnets:

1. Specifications for companies introducing products with permanent magnets to the market.
2. Products must prominently display a durable label indicating:
   1. Whether the product contains permanent magnets.
   2. If magnets are present, specifying their type (e.g., Neodymium-Iron-Boron, Samarium-Cobalt, Aluminum-Nickel-Cobalt, Ferrite).
3. Products should include a data carrier with a unique identifier providing:
4. Company contact details.
5. Weight, location, and chemical composition of each permanent magnet, including coatings, adhesives, and additives.
6. Instructions for locating and removing permanent magnets, including tools or technologies required.
7. An exemption is granted for products where magnets are solely within embedded electric motors, replacing detailed magnet-specific information.
8. Products with digital product passports must include required information.
9. Information should relate to the product model or, for varying units, to specific batches or units.
10. Recyclers, market surveillance authorities, and customs should access this information.
11. Transition periods:
    1. Three years post-regulation enactment.
    2. Five years post-regulation enactment for specific devices like magnetic resonance imaging devices, motor vehicles, and light transport vehicles.
    3. Electric motors, including those integrated into other products like washing machines, dryers, microwaves, vacuum cleaners, and dishwashers.
12. Disclosing Recycled Content Details
13. Companies introducing products with permanent magnets exceeding 0.2kg must disclose the percentage of recycled neodymium, dysprosium, praseodymium, terbium, boron, samarium, nickel, and cobalt. This information should be publicly accessible.
14. Customers must access this information before purchase or contract.

Ahmed Sakr

Product Compliance Consultant 

ComplyMarket UG (haftungsbeschraenkt)