EU Critical Raw Materials Act Compliance: Latest CRMA Updates, Requirements & Business Checklist

The EU Critical Raw Materials Act, also known as the CRMA or Regulation (EU) 2024/1252, is reshaping how companies manage critical raw materials, supplier data, permanent magnets, recycled content, and supply-chain risk. It is especially important for manufacturers, importers, OEMs, suppliers, product compliance teams, sustainability teams, and procurement teams placing products or materials on the EU market.

The CRMA entered into force in May 2024 and establishes a framework for securing a sustainable and diversified supply of critical raw materials in the European Union. It supports the EU’s green transition, digital transition, defence sector, aerospace sector, battery value chain, renewable energy industry, electronics industry, and other strategic technologies.

For businesses, the CRMA is not just a raw-material policy. It is a product compliance, supplier management, traceability, risk assessment, and documentation challenge.

Companies should prepare now because CRMA compliance will depend on their ability to answer practical questions such as:

• Do our products contain critical or strategic raw materials?
• Do our products contain permanent magnets?
• Which suppliers provide the relevant materials, components, or evidence?
• Can we prove recycled content claims?
• Can we map where strategic raw materials are extracted, processed, or recycled?
• Can we provide product-level data through a label, data carrier, or digital product passport?
• Can we keep compliance evidence traceable and audit-ready?

Step 3: Collect Supplier Evidence

• Send structured supplier questionnaires.
• Request magnet type, mass, location, composition, coatings, glues, and additives.
• Request origin, processing, and recycling location data.
• Request recycled-content evidence.
• Request environmental footprint data where relevant.
• Validate supplier responses and identify missing evidence.

Step 4: Assess Supply Chain Risk

• Identify single-source suppliers.
• Check country concentration risks.
• Assess geopolitical, logistics, price, and availability risks.
• Evaluate alternative suppliers or substitute materials.
• Document mitigation measures.
• Prepare internal reporting for management or board review where required.

Step 5: Prepare Product Information and Disclosures

• Prepare permanent magnet information.
• Prepare data carrier or digital product passport readiness.
• Prepare recycled-content disclosure workflows.
• Prepare environmental footprint declaration workflows.
• Make required information accessible where the CRMA requires public or pre-contract access.

Step 6: Maintain Audit-Ready Records

• Keep evidence linked to products, components, suppliers, and declarations.
• Track document versions.
• Set reminders for missing or outdated evidence.
• Maintain long-term record retention.
• Update compliance data when products, suppliers, or regulations change.

What Should Companies Do Now?

Companies should not wait until every delegated or implementing act is final before preparing. CRMA compliance depends on supply-chain data that can take months to collect, especially when suppliers are outside the EU or when material information is several tiers upstream.

The most practical actions now are:

EU CRMA Compliance at a Glance

What Is the EU Critical Raw Materials Act?

The EU Critical Raw Materials Act is the EU’s legal framework for improving access to raw materials that are economically important and exposed to high supply risk. These materials are essential for products and technologies such as batteries, solar panels, wind turbines, semiconductors, aerospace components, defence technologies, electric motors, and electronic devices. The European Commission highlights lithium, cobalt, nickel, gallium, boron, titanium, and tungsten as examples of raw materials used in strategic sectors.

The CRMA sets EU-level 2030 benchmarks for strategic raw materials. By 2030, the EU aims to ensure that EU capacity can cover at least 10% of annual EU consumption from extraction, 40% from processing, and 25% from recycling. It also aims to ensure that no single third country supplies more than 65% of the EU’s annual consumption of each strategic raw material at any relevant processing stage.

For companies, these targets signal a long-term shift: the EU expects stronger supply-chain visibility, more recycling, lower dependency risk, and better product-level transparency.

Why the CRMA Matters for Manufacturers, Importers, and Suppliers

The CRMA matters because it turns raw material resilience into a business compliance issue. Many companies do not buy raw materials directly, but they still depend on them through components, subassemblies, batteries, magnets, electronics, motors, and finished products.

A manufacturer may not purchase neodymium directly, for example, but it may place products on the EU market containing NdFeB permanent magnets. An importer may not control the mining or refining stage, but it may still need supplier evidence to support permanent magnet information or recycled-content disclosure.

That is why CRMA compliance is likely to affect:

• Product compliance teams responsible for EU market access
• Procurement teams managing supplier data
• Sustainability teams working on circularity and recycled content
• Engineering teams managing BOMs and product specifications
• Legal teams assessing regulatory obligations
• Quality teams preparing audit-ready documentation
• Sales teams responding to customer compliance requests

In simple terms, CRMA compliance is about knowing what materials are in your products, where the risk sits in your supply chain, what evidence your suppliers can provide, and how you will prove compliance when customers or authorities ask.

Latest EU Critical Raw Materials Act Updates

1. The CRMA is now in force and being implemented

The CRMA was published as Regulation (EU) 2024/1252 and entered into force in May 2024. The regulation establishes the legal framework for securing sustainable access to critical raw materials and includes measures related to supply-chain resilience, circularity, permanent magnets, recycled content, and environmental footprint declarations.

For companies, this means the CRMA should no longer be treated as a future policy topic. It is an active regulatory framework with staged obligations and implementing measures.

2. Strategic Projects were approved inside and outside the EU

The European Commission officially approved CRMA Strategic Projects in the EU on 25 March 2025 and Strategic Projects outside the EU on 4 June 2025. These projects are intended to strengthen extraction, processing, recycling, and substitution capacity for strategic raw materials.

This matters for companies because Strategic Projects may influence future sourcing options, long-term supply resilience, supplier qualification, offtake strategies, and procurement planning.

3. RESourceEU Action Plan launched to strengthen supply security

On 3 December 2025, the European Commission adopted the RESourceEU Action Plan to accelerate efforts to secure EU access to critical raw materials such as rare earth elements, cobalt, and lithium. The plan builds on the CRMA and aims to protect industry from geopolitical and price shocks.

For businesses, this confirms that the EU is moving from regulatory framework to practical industrial action: diversification, joint purchasing, recycling, stockpiling, external partnerships, and investment in strategic projects are becoming more important. The Council also notes that RESourceEU includes future actions on internal market measures, joint purchasing, stockpiling, innovation, circularity, external partnerships, permitting simplification, and investment in mining, processing, and recycling projects.

4. Proposed amendments focus on large companies, risk mitigation, and permanent magnets

The Commission proposed amendments to the CRMA as part of the RESourceEU package. The proposal aims to streamline and clarify CRMA rules, improve circularity, increase recycling capacity, and strengthen the secondary market for critical raw materials.

The proposed changes are relevant because they may transfer responsibility for identifying large companies using critical raw materials from Member States to the European Commission. They also clarify how risk assessments, risk mitigation, and company accountability should work.

5. Council adopted its position in March 2026

On 4 March 2026, the Council adopted its position on amending the CRMA. The Council supported stronger transparency and accountability for large companies, clarified the Commission’s authority to propose risk-mitigation measures, and allowed the use of digital product passports to comply with information obligations for permanent magnets.

This update is especially important for manufacturers of magnet-containing products. It shows that CRMA compliance is moving toward structured, digital, product-level information sharing.

Are You Affected by the EU Critical Raw Materials Act?

You may be affected by the CRMA if your company manufactures, imports, distributes, or places on the EU market products, components, or materials linked to critical or strategic raw materials.

The highest-risk groups include:

ComplyMarket’s CRMA compliance guidance identifies three practical groups: large manufacturers of strategic technologies using strategic raw materials, companies placing certain permanent magnet-containing products on the EU market, and companies placing critical raw materials as materials on the EU market.

Key CRMA Compliance Requirements for Companies

1. Supply Chain Risk Preparedness

Large companies using strategic raw materials to manufacture strategic technologies may need to conduct raw material supply-chain risk assessments. These assessments should identify where strategic raw materials are extracted, processed, or recycled, evaluate supply disruption risks, assess vulnerabilities, and support mitigation actions where needed.

Strategic technologies can include batteries, hydrogen equipment, renewable energy equipment, aircraft, traction motors, heat pumps, data storage, mobile electronics, robotics, drones, satellites, and advanced chips.

For companies, this means CRMA compliance may require:

• Supplier mapping
• Country-of-origin data
• Extraction, processing, and recycling location data
• Material substitution analysis
• Alternative supplier assessment
• Risk scoring
• Mitigation planning
• Board-level or management-level reporting

2. Permanent Magnet Information Requirements

The CRMA introduces product-level information requirements for certain products containing permanent magnets. Companies may need to indicate whether a product contains permanent magnets and identify the magnet type, such as NdFeB, SmCo, AlNiCo, or ferrite.

For relevant products, companies should prepare to collect and manage data such as:

ComplyMarket’s CRMA service page states that product information for permanent magnets may need to be kept complete, accurate, up to date, and available for the product lifetime plus 10 years.

3. Recycled Content Disclosure for Permanent Magnets

The CRMA includes recycled-content disclosure requirements for certain permanent magnets. For applicable products, companies may need to publicly disclose the share of specified metals recovered from post-consumer waste in the permanent magnets. These metals include neodymium, dysprosium, praseodymium, terbium, boron, samarium, nickel, and cobalt.

This requirement is highly relevant for companies placing products on the EU market that contain permanent magnets above the applicable threshold. ComplyMarket’s CRMA guidance notes that the disclosure applies when total magnet weight exceeds 0.2 kg for relevant magnet types.

Companies should prepare by collecting:

• Supplier declarations
• Magnet composition data
• Recycled-content evidence
• Waste origin information
• Calculation method documentation
• Verification records
• Product-level disclosure data

4. Environmental Footprint Declarations

The CRMA also introduces environmental footprint declaration requirements for companies placing certain critical raw materials on the EU market once the Commission adopts calculation and verification rules for the relevant material. The declaration may include information such as the responsible party, raw material type, extraction or processing region, footprint result, performance class, and public study link.

This matters for companies selling critical raw materials as materials, but it may also affect downstream customers because they may need reliable supplier evidence for sustainability, procurement, ESG, and product compliance requirements.

CRMA Compliance Deadlines and Milestones

What Data Should Companies Collect from Suppliers?

Many companies will struggle with CRMA compliance not because they do not understand the regulation, but because they do not have the right supplier data. The earlier companies start collecting supplier evidence, the easier it will be to prepare for compliance, customer requests, audits, and disclosure obligations.

A practical CRMA supplier data request should include:

This supplier-data foundation is important because CRMA obligations depend on traceable and reliable information across the product lifecycle.

Why Manual CRMA Compliance Is Risky

Many companies may initially try to manage CRMA compliance using spreadsheets, emails, PDFs, and disconnected supplier forms. That may work for a small number of products, but it becomes risky when companies have hundreds or thousands of components, multiple suppliers, frequent product updates, and changing EU requirements.

ComplyMarket’s CRMA service states that its platform can centralise BOMs, material composition, magnet attributes, supplier declarations, and supporting evidence; automate supplier data collection; run recurring Article 24 risk assessments; publish controlled disclosures; and maintain long-term traceability.

CRMA Compliance Checklist for Manufacturers and Importers

Use this checklist to assess whether your company is ready for the EU Critical Raw Materials Act.

Step 1: Check Applicability

• Identify whether your company places products or critical raw materials on the EU market.
• Identify whether your products contain critical or strategic raw materials.
• Identify whether your products contain permanent magnets.
• Determine whether your company may be considered a large company under CRMA-related risk preparedness requirements.
• Identify which legal entity is the manufacturer, importer, distributor, or responsible economic operator.

Step 2: Map Products, Components, and Materials

• Review your product portfolio.
• Build or update your bill of materials.
• Identify motors, batteries, electronics, magnets, sensors, actuators, drives, and strategic components.
• Link product families to suppliers and material data.
• Create a permanent magnet register where applicable.

1- Start with product scoping
Identify which products may contain permanent magnets, critical raw materials, or strategic raw materials.

2- Build a CRMA data model
Define the fields you need for BOMs, magnet attributes, supplier declarations, recycled content, origin data, and footprint evidence.

3- Engage suppliers early
Suppliers may not already have the requested data. Give them structured templates and clear response deadlines.

4- Create a risk assessment workflow
Map raw material risks, assess vulnerabilities, and document mitigation options.

5- Prepare for digital disclosure
The Council’s March 2026 position allows product passports to be used for permanent magnet information obligations, making digital traceability an important compliance strategy.

6- Use software instead of disconnected files
A centralised compliance platform helps reduce manual work, improve traceability, and keep evidence ready for customers, authorities, and internal stakeholders.

How ComplyMarket Product Compliance Software Helps Meet CRMA Requirements

CRMA compliance requires more than understanding the law. It requires a system for collecting, validating, maintaining, and reporting product and supplier data.

ComplyMarket product compliance software helps companies manage CRMA-related obligations by centralising product data, material information, supplier declarations, evidence, risk assessments, and disclosure workflows.

ComplyMarket supports companies with:

• CRMA applicability assessment
• Product and BOM scoping
• Supplier data collection
• Material and magnet data management
• Permanent magnet compliance workflows
• Recycled-content evidence management
• Environmental footprint declaration preparation
• Supply-chain risk assessment
• Mitigation tracking
• Audit-ready evidence retention
• Digital Product Passport readiness

ComplyMarket’s CRMA service includes applicability assessment, supplier data packages, risk preparedness tools, permanent magnet compliance packs, disclosure workflows, and evidence requirements.

ComplyMarket’s material compliance software also supports supplier engagement, supplier risk assessment, material risk assessment, and supplier information collection. Its website states that the platform supports supply chain sustainability and product compliance management by collecting information from suppliers.

Why ComplyMarket Is Useful for CRMA Compliance

For many companies, the biggest CRMA challenge will be data control. A compliance team may need information from engineering, procurement, suppliers, sustainability, legal, and quality teams. Without a central system, this can become slow, inconsistent, and difficult to audit.

ComplyMarket helps companies move from reactive compliance to structured compliance by enabling them to:

• Know which products are in scope
• Identify affected components and permanent magnets
• Collect supplier evidence in a structured way
• Link declarations to products, components, and suppliers
• Track missing or expired evidence
• Run supply-chain risk assessments
• Prepare disclosure workflows
• Support digital product passport requirements
• Maintain traceability for customer and authority requests

This is especially important because the CRMA is connected to broader EU trends: supply-chain resilience, circularity, recycled-content transparency, environmental footprint information, and product-level digital data.