On 4 June 2025, the European Commission published a decision recognising 13 critical raw material projects located in non-EU countries as “Strategic Projects” under the Critical Raw Materials Act (“CRMA”, Regulation (EU) 2024/1252). This first set of Strategic Projects based outside the EU adds to the 47 Strategic Projects based within the EU announced earlier this year. These Strategic Projects are recognized as significantly contributing to the security of the EU’s supply of strategic raw materials, and will benefit from preferential access to finance and other advantages. For more information on the CRMA and the framework for Strategic Projects, see our previous blog post here.

Overview of the 13 Non-EU Strategic Projects

The non-EU Strategic Projects that the European Commission has selected extract, process, recycle, or substitute materials critical to the EU’s green and digital transitions, including:

  • Battery-grade materials: Projects focusing on lithium, cobalt, manganese, and graphite, located in Canada, Brazil, and Ukraine.
  • Rare earth elements: Projects in South Africa and Malawi aiming to supply essential inputs for electric vehicles and wind turbines.
  • Other strategic materials: For instance, a project covering tungsten (UK).

Together, these projects are expected to mobilise approximately €5.5 billion of private and public investment and play a key role in diversifying and securing the EU’s critical raw materials supply chains.

Strategic Projects: Criteria and Benefits

Under Article 6(1) CRMA, a project can be designated as strategic if it (1) significantly contributes to the security of the Union’s supply of strategic raw materials, (2) is technically feasible within a reasonable timeframe, and (3) is implemented in a sustainable manner. Non-EU projects must also be mutually beneficial by creating added value locally. The Commission assessed applications based on these criteria, with support from external experts.

Designated Strategic Projects benefit from several advantages, including:

  • Preferential access to finance. Article 16 CRMA allows promoters to request a dedicated meeting of the CRMA financing subgroup—bringing together the EIB, EBRD, national promotional banks and private lenders—to map a full financing package, with particular emphasis on Global Gateway Initiative.
  • Commercial leverage. The Strategic Project status signals alignment with EU policy and sustainability standards, helping promoters secure long-term offtake contracts with European buyers.
  • Structured engagement with Brussels. Under Articles 7 and 8 CRMA, projects benefit from structured engagement with the Commission, including biannual reporting and inclusion in the Commission’s Strategic Project list—raising visibility for investors and policymakers alike.

Next Steps for Project Promoters

The application process for Strategic Project designation remains open, with separate cut-off dates announced periodically by the European Commission. The next batch of applications is expected to be evaluated later in 2025. Project promoters interested in applying should ensure their projects meet the eligibility criteria and monitor Commission communications for the announcement of upcoming cut-off dates.

***

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Carole Maczkovics Carole Maczkovics

Carole Maczkovics is a market leader in State aid law, with a robust background in the economic regulation of network industries (energy and transport) and in public contracting (EU subsidies, public procurement, concessions).

Carole has a proven track record of advising public and…

Carole Maczkovics is a market leader in State aid law, with a robust background in the economic regulation of network industries (energy and transport) and in public contracting (EU subsidies, public procurement, concessions).

Carole has a proven track record of advising public and private entities in administrative and judicial proceedings on complex State aid and regulatory matters before the European Commission as well as before the Belgian and European courts. She also advises clients on the application of the EU Foreign Subsidy Regulation (FSR) and UK subsidy control regime.

Carole has published many articles on State aid law and on the FSR, and contributes to conferences and seminars on a regular basis. She is a visiting lecturer at King’s College London on the FSR and at the Brussels School of Competition on the application of regulation and competition law (including State aid) in the railway sector. Carole gives trainings on State aid law at EFE, in Paris. She also acts as Academic Director of the European State aid Law Institute (EStALI).

Photo of Sam Jungyun Choi Sam Jungyun Choi

Recognized by Law.com International as a Rising Star (2023), Sam Jungyun Choi is an associate in the technology regulatory group in Brussels. She advises leading multinationals on European and UK data protection law and new regulations and policy relating to innovative technologies, such…

Recognized by Law.com International as a Rising Star (2023), Sam Jungyun Choi is an associate in the technology regulatory group in Brussels. She advises leading multinationals on European and UK data protection law and new regulations and policy relating to innovative technologies, such as AI, digital health, and autonomous vehicles.

Sam is an expert on the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act, having advised on these laws since they started to apply. In recent years, her work has evolved to include advising companies on new data and digital laws in the EU, including the AI Act, Data Act and the Digital Services Act.

Sam’s practice includes advising on regulatory, compliance and policy issues that affect leading companies in the technology, life sciences and gaming companies on laws relating to privacy and data protection, digital services and AI. She advises clients on designing of new products and services, preparing privacy documentation, and developing data and AI governance programs. She also advises clients on matters relating to children’s privacy and policy initiatives relating to online safety.

Photo of Matthieu Coget Matthieu Coget

Matthieu Coget counsels clients to develop and execute policy engagement strategies, to navigate through political risk, and to build and manage coalitions to accomplish their objectives at both the EU and Member State levels.

He also provides guidance on complex regulatory issues, particularly…

Matthieu Coget counsels clients to develop and execute policy engagement strategies, to navigate through political risk, and to build and manage coalitions to accomplish their objectives at both the EU and Member State levels.

He also provides guidance on complex regulatory issues, particularly in EU trade, energy, and food law. He frequently advises on the evolving regulatory developments in EU industrial policies.

Matthieu’s practice primarily services clients in the food and beverage, automotive, energy, and technology sectors.

He also maintains an active pro bono practice, addressing EU regulatory matters and supporting policy engagement initiatives.