In search of critical raw materials: What will the EU Critical Raw Materials Act achieve? An analysis of legal and factual implications of the CRMA

The Critical Raw Materials Act (CRMA) is a key EU legislation aimed at securing critical raw materials (CRMs) for green, digital, and defense sectors by enhancing extraction, processing, and recycling within the EU. It introduces measures to expedite permitting for strategic projects focused on strategic raw materials (SRMs), granting them "public interest" status and imposing stricter timelines. Our assessment indicates that while the CRMA could shorten permit processes, it will not significantly reduce overall project lead times. Concerns include reduced public participation in environmental impact assessments, as well as political influence and transparency deficiencies in the tasks of the European Commission. Despite introducing obligations for recycling and exploration, challenges such as low social acceptance, high costs, and administrative and budgetary burdens hinder the CRMA's goals. Crucially, the CRMA lacks a focus on reducing resource use, which is necessary to mitigate the environmental and social impacts of raw material projects.