✅ Who must comply (in practice)

Your obligations depend on what you place on the EU market and your role in the value chain:

1) Large manufacturers of “strategic technologies” using strategic raw materials

EU Member States must identify large companies that use strategic raw materials to manufacture listed strategic technologies (e.g., batteries, hydrogen equipment, renewable energy equipment, aircraft, traction motors, heat pumps, data storage, mobile electronics, robotics, drones, satellites, advanced chips).
Those companies must conduct raw materials supply chain risk assessments at least every three years (and mitigate significant vulnerabilities).

2) Companies placing certain products with permanent magnets on the EU market

If you place listed products on the market (e.g., wind generators, industrial robots, motors, heat pumps, appliances, certain vehicles), CRMA introduces label + data-carrier/unique identifier requirements for permanent magnets (timed to Commission implementing acts).

3) Companies placing critical raw materials (as materials) on the EU market

Where the Commission adopts calculation rules for a raw material, sellers placing that critical raw material on the market must provide an environmental footprint declaration and ensure customers can access it before contract conclusion (including distance selling).

📌 Core “Critical Raw Materials” requirements (detailed)

🧠 Article 24 — Company risk preparedness (strategic technologies)

Large companies (as identified) must perform a supply chain risk assessment that includes:

• Supply chain mapping: where strategic raw materials used are extracted/processed/recycled
• Risk factor analysis: factors that might affect supply
• Vulnerability assessment: exposure to disruption
• Mitigation efforts if significant vulnerabilities are found (diversify supply chains and/or substitute materials)
• Optionally produce a board-level report with results, sources, risks, and mitigation measures (Member States may require it).

What enforcement looks like operationally: supplier data requests, documented assumptions when suppliers don’t provide information, repeatable methodology, and an executive-approved mitigation plan.

🧲 Article 28 — Recyclability of permanent magnets (label + data carrier + unique identifier)

For listed product categories, companies must:

• Apply a clear, indelible label indicating:
• whether the product contains permanent magnets, and
• the magnet type (NdFeB, SmCo, AlNiCo, ferrite).
• Provide a data carrier on/in the product (after the implementing act timeline) linked to a unique product identifier that gives access to:
• responsible economic operator identity & contact
• magnet weight, location, chemical composition, plus coatings/glues/additives
• safe access & removal instructions (steps/tools/technologies)
• Keep that information complete, accurate, up-to-date, and available for product lifetime + 10 years, including after insolvency/cessation (you may authorize another party to maintain it).

Important timing and scope notes

• The Commission must set the label format via an implementing act by 24 November 2026; obligations apply two years after that act enters into force.
• Information must be accessible to repairers, recyclers, market surveillance, and customs.
• Defence/space products are exempt.

♻️ Article 29 — Recycled content disclosure (and future minimum shares)

For certain products with permanent magnets, you must publicly disclose the share of specified metals recovered from post-consumer waste present in those magnets (Nd, Dy, Pr, Tb, B, Sm, Ni, Co) — when applicable.

• Deadline trigger: by 24 May 2027 or two years after the Commission’s delegated act on calculation/verification rules enters into force (whichever is later).
• Applies when total magnet weight exceeds 0.2 kg (for relevant magnet types).
• The Commission must adopt the delegated act with calculation/verification rules by 24 May 2026.
• After that delegated act (and in any event by 31 December 2031), the Commission may set minimum recycled-content shares via delegated acts, with transitional periods and possible exclusions.

🌿 Article 31 — Environmental footprint declaration (for critical raw materials as materials)

Once the Commission adopts calculation & verification rules for a given critical raw material, any company placing that material on the EU market must make available an environmental footprint declaration.
The declaration must include (among other items): responsible party, raw material type, extraction/processing/refining/recycling region, footprint result, performance class, and a public study link.
You must:

• publish it on a free-access website and keep it understandable,
• ensure customers can access it before being bound by a sales contract (including distance selling).
  The Commission must submit a prioritisation report by 24 November 2026 on which CRMs to assess first for proportionality/necessity of an obligation.

🧭 What a company must do to comply (step-by-step)

1) Scope your CRMA applicability

• Identify whether you:
• manufacture strategic technologies using strategic raw materials (risk preparedness),
• place listed magnet-containing products on the market (Article 28/29),
• place critical raw materials on the market (Article 31).
• Map your “EU market placing” entities (manufacturer/importer/authorized rep).

2) Build a defensible data backbone

• Bill of materials + magnet registry: magnet type, mass, location, composition, coatings/glues/additives.
• Recycled content evidence chain: supplier declarations + calculation method aligned to the delegated act once adopted.
• Footprint-ready datasets: site energy, process data, transport, secondary datasets, verification trail (to match adopted rules when they apply).

3) Put supplier controls in contracts and onboarding

• Mandatory upstream data fields (origin/processing/recycling locations; composition; recycled content).
• Response SLAs and audit rights; escalation when suppliers refuse or cannot provide data (use Commission/public info where allowed for risk assessment).

4) Implement governance and evidence retention

• A repeatable risk assessment procedure (every 3 years), plus mitigation tracking.
• A controlled technical documentation set for products and the required conformity procedure.
• Record retention aligned to product lifetime + 10 years for magnet information.

5) Publish what CRMA requires (without breaking confidentiality)

• Free-access pages for:
• recycled content shares (Article 29),
• environmental footprint declarations (Article 31).
• Ensure “pre-contract availability” in ecommerce/quotations.

📅 Key compliance dates (practical snapshot)

• 23 May 2024: CRMA entered into force.
• 24 May 2025: Member States identify covered large companies for Article 24; those companies must be ready to run the 3-year risk assessment cycle.
• 24 May 2026: Commission delegated act for recycled content calculation/verification rules (Article 29(2)).
• 24 Nov 2026: Commission implementing act for magnet label format (Article 28(2)); plus footprint prioritisation report (Article 31(2)).
• 24 May 2027 (or later trigger): recycled content share publication starts (Article 29(1)).
• 31 Dec 2031: latest date by which the Commission must adopt delegated acts setting minimum recycled-content shares (after the Article 29(2) act enters into force).

📦 What you get from this CRMA compliance service

• Applicability assessment (Articles 24/28/29/31) and a gap analysis
• Supplier data package: templates, contract clauses, evidence requirements
• Risk preparedness toolkit: assessment model, scoring, mitigation register, board-ready reporting pack
• Permanent magnet compliance pack: label/data-carrier/UPI requirement mapping + product technical file structure
• Disclosure workflows: recycled-content and footprint publishing processes + ecommerce “pre-contract access” controls

⭐ Why ComplyMarket

ComplyMarket turns CRMA obligations into a controlled, auditable workflow—without chasing spreadsheets or email trails.

With ComplyMarket’s Material Compliance management and reporting platform you can:

• Centralize BOM, material composition, magnet attributes, supplier declarations, and supporting evidence
• Automate supplier data collection with validation rules aligned to CRMA Articles 28/29/31
• Run recurring Article 24 risk assessments with dashboards, mitigation tracking, and board-ready reporting
• Publish compliant disclosures (recycled content shares, environmental footprint declarations) via controlled web outputs
• Maintain long-term record retention (including “product lifetime + 10 years” information continuity) with full traceability

For companies that must comply with Critical Raw Materials requirements, ComplyMarket is the best end-to-end solution to manage data, evidence, reporting, and ongoing compliance at scale.