On 3 September 2020 the European Commission released an updated action plan on critical raw materials (CRMs).  In doing so, it has added bauxite, lithium, titanium and strontium to the existing list of CRMs, which now stands at 30 materials.

The Commission also released a foresight report at the same time, on raw materials for strategic technologies and sectors. The report considers the raw material needed for growing technologies, particularly those in clean energy, electric mobility, ICT, robotics and 3D printing and evaluates future supply risks .

The Commission aims to build resilient and complete EU supply chains for critical raw materials, which is a particularly prominent issuing follow the supply chain disruption caused by the Covid-19 pandemic.

To this end, the action plan includes the launch of an industry-driven European Raw Materials Alliance in Q3 of 2020, intending to follow the model of the European Battery Alliance. The European Raw Materials Alliance will initially focus on rare earth and magnet value chains, with a view to expanding to cover the remaining critical raw material and base metal needs.

The addition of lithium demonstrates the importance of batteries to achieving the EU’s 2050 climate-neutrality scenarios. Under the EU’s Green Deal roadmap, the Commission committed to proposing legislation to ensure a safe, circular and sustainable battery value chain. In June 2020 the European Commission published an inception impact assessment on a proposal for a new regulation on batteries to replace the Batteries Directive. This proposal is expected to be published in September.

The action plan also includes the development of sustainable financing criteria for the mining and extractive sectors in relation to CRMs by the end of 2021. The list of critical raw materials will additionally be important for the promotion of circular economy principles, to ensure a strong market for secondary resources. Eco-design requirements are likely to look to improve the design of electrical and electronic equipment in order to increase the recycling of CRMs.

Updated EU list of Critical Raw Materials

2020 critical raw materials (new as compared to 2017 in bold)
Antimony Hafnium Phosphorus
Baryte Heavy Rare Earth Elements Scandium
Beryllium Light Rare Earth Elements Silicon metal
Bismuth Indium Tantalum
Borate Magnesium Tungsten
Cobalt Natural graphite Vanadium
Coking coal Natural rubber Bauxite
Fluorspar Niobium Lithium
Gallium Platinum Group Metals Titanium
Germanium Phosphate rock Strontium


If you have any questions about the EU’s CRM action plan, please contact the author or any other member of the Reed Smith EHS team.