RESourceEU Action Plan – Strengthening the EU’s Access to Critical Raw Materials

By Carole Maczkovics, Sam Jungyun Choi & Matthieu Coget on December 16, 2025

Posted in EU Law and Regulatory, International Strategy, International Trade, Minerals, Policy and Legislation

On 3 December 2025, the European Commission adopted the RESourceEU Action Plan, signaling that Europe’s industrial competitiveness will increasingly depend on its ability to secure and diversify critical raw material (“CRM”) supply chains. For companies, inside and outside the EU, RESourceEU is more than a technical update: it marks a policy shift toward a more interventionist and security-driven approach to CRM governance.

The analysis below outlines the drivers behind the initiative, its main components, and the implications for multinationals trading into the EU.

Background to RESourceEU

As with REPowerEU in the energy context, RESourceEU reflects the Commission’s view that market forces alone cannot deliver the speed and scale of diversification required in a context of heightened geopolitical risk. This is especially the case given China’s dominant role across several CRM value chains and its recent use of export controls. The initiative, published on the same day as the EU’s revamped economic security strategy (see our blog), is presented as a practical extension of the Critical Raw Materials Act (“CRMA”) (see our blog).

The Commission acknowledges that achieving meaningful diversification will depend on effective implementation. Expanding extraction, processing and recycling capacity in Europe, improving circularity, and operationalizing strategic partnerships will require sustained political commitment and close coordination with Member States and industry. RESourceEU therefore sets an operational framework, but its impact will ultimately turn on the ability of the EU and national authorities to execute consistently over time.

Content of RESourceEU

The European Critical Raw Materials Centre, New Institution for CRM Security

A central element of RESourceEU is the creation, from 2026, of a European Critical Raw Materials Centre. Drawing on the experience of Japan’s JOGMEC, the Centre reflects a shift toward a more active industrial policy posture for CRMs. It will develop systemic intelligence on CRM value chains, help steer investment and de-risking finance into priority projects, and support strategic stockpiling and joint purchasing by matchmaking demand and supply. The Centre will also build on the new Raw Materials Mechanism (“Mechanism”) under the EU Energy and Raw Materials Platform (“Platform”, see below), which aggregates demand and facilitates offtake arrangements.

Companies can participate in and contribute to the Centre’s activities through the Mechanism under the Platform by engaging in demand aggregation, joint purchasing and offtake agreements, as well as through Strategic Projects and EU-supported financing instruments coordinated by the Centre.

Accelerating Priority CRM Projects

A second pillar focuses on accelerating CRM projects – both in the EU and outside the EU – that can reduce strategic dependencies. The Commission notes that several projects (see our blog) could materially diversify supply, and will therefore be fast-tracked through financial and regulatory support, as follows:

RESourceEU aims to mobilize €3 billion in EU funds within 12 months for priority CRM projects, in cooperation with the European Investment Bank (“EIB”) and Member States. Financing has already been unlocked for projects such as Vulcan’s lithium extraction in Germany, which received €250 million from the EIB.
Given uneven national implementation, RESourceEU also commits to removing bottlenecks and reinforcing permitting support and guidance, building on the accelerated permitting timelines introduced under the CRMA.

Building a Circular CRM Economy

With recycling rates for many rare earth elements still extremely low, the Commission frames circularity as a strategic requirement. It will propose, by Q2 2026, restrictions on the export of scraps and waste of permanent magnets, an essential feedstock for European recyclers that is increasingly shipped abroad. The Commission will also propose targeted measures on aluminum scrap, and may consider similar action for copper scrap following further monitoring.

RESourceEU further includes a proposal for a targeted amendment to the CRMA to expand product labelling requirements for permanent magnets and to require declarations of recycled content from both pre- and post-consumer waste. These measures aim to enhance transparency, incentivize recycling, and strengthen EU secondary raw materials markets.

Creating a Market for Diversified Supply

To reduce transaction costs and help companies diversify sourcing, RESourceEU builds on the Platform by operationalizing a dedicated Mechanism as a matchmaking tool. The Mechanism is intended to connect suppliers of strategic raw materials (from the EEA and strategic partner countries) with EU buyers, enable demand aggregation and private joint purchasing, and facilitate the conclusion of offtake agreements. Registration on the Platform was launched in November 2025, with the first matchmaking round scheduled for March 2026.

This demand-side mechanism complements ongoing work with Member States on a coordinated EU stockpiling approach.

Shielding the Single Market Against Hostile Interference

From May 2026, the Internal Market Emergency and Resilience Act (“IMERA”) will give the Commission tools that can be activated in so-called “vigilance” or “emergency” modes. The Commission will then be able to address information requests on production capacities and stocks, as well as supply chain disruptions or shortages, and to carry out joint purchases, mandate priority-rated requests and coordinate stockpiling distribution.

In accordance with the CRMA, Member States and the Commission have begun stress-testing CRM supply chains, with upcoming exercises focusing on rare earths and defense-relevant materials. To reinforce safeguards, CRMA Strategic Projects will be treated as “Projects or Programmes of Union Interest” under the FDI Screening Regulation, strengthening scrutiny of foreign investments. In addition, the Horizon Europe 2026–2027 work programme will restrict the participation of Chinese and Chinese-controlled entities in all CRM-related research and innovation actions.

Diversification of Partnerships with Non-EU Countries

The EU has currently concluded 15 Strategic Partnerships with resource-rich non-EU countries and will launch negotiations with Brazil. To support concrete projects, the EU will rely on Global Gateway financing, EFSD+ guarantees, EIB support, and dedicated investment frameworks with Ukraine, the Western Balkans and the Southern Neighborhood. Multilaterally, the EU will deepen cooperation through the G7 Critical Minerals Production Alliance, the G7 roadmap for standards-based markets, and the G20 Critical Minerals Framework, with the goal of promoting transparent and resilient global supply chains.

Consequences for Non-EU Suppliers to the EU Market

For multinational companies outside the EU, RESourceEU appears to signal a shift in how the EU will approach access to CRMs and assess supply-chain resilience. The combined measures announced are likely to influence market conditions for companies supplying CRM-intensive products into the EU. Foreign producers can expect closer scrutiny of supply diversification, traceability and resilience to price or geopolitical shocks. At the same time, new tools such as the Raw Materials Mechanism are intended to facilitate market access by improving transparency, reducing transaction costs and supporting offtake arrangements with European buyers.