As the established world order to which we have become so accustomed since its creation out of the ashes of the Second World War begins to crumble before our eyes, pulled apart by right-wing nativist populism and the inability of the political mainstream to answer the cries for help from those that globalism has left behind, great power competition has surged in its place creating geopolitical instability unparalleled in our lifetimes.  In no sector is that competition so ferocious as it is in the scramble to secure reliable access to critical raw materials (CRMs) and the control of their processing.

China has, for decades, been slowly building its power in this area.  First cornering the market on solar panels and then moving onto both the actual CRM and their processing.  Some statistics underline the extent of Chinese dominance of the global CRM market:

  • The IEA assesses that China is directly or indirectly (though mine ownership) responsible for the extraction of around 60% of the world’s CRMs.
  • Chinese market share of global extraction of natural graphite and tungsten exceeds 80%. 
  • China is the world’s leading refiner for 19 of the IEA’s ‘20 strategic minerals’, with an average refining market share of around 70%.
  • China accounts for around 60% of magnet rare-earth mining, more than 90% of rare-earth refining and around 94% of permanent-magnet production.

This market dominance has created a dangerous market imbalance and supply dependency which Beijing has not been afraid to leverage for geopolitical advantage.  In late 2024, China effectively banned exports to the United States of gallium, germanium and antimony and prohibited the export of all controlled dual-use items for US military users or military purposes. The export of other materials to the US, including graphite, were subjected to much stricter end-user and end-use checks. In April 2025, additional Chinese export controls were imposed on a group of rare-earth elements and related magnets which led to scarcity of essential materials, affecting US automotive, aerospace, electronics and defence production and supply chains.

That supply disruption focused global attention on the extent of Chinese dominance and the acute vulnerability it has caused.  The world suddenly realised the centrality of CRMs to sectors including defence (and it is worth reading this report from Appian which sets out in stark terms just how much the defence sector relies on CRMs), energy, aerospace, computing, semi-conductors, AI and batteries.  The geopolitics of competition forced countries at the ‘wrong end’ of supply chains to realise that access to CRMs had ceased to be a solely an economic question, but had become increasingly a national security concern.  The government intervention response access has converted the modern global CRM market into one which is shaped as much by considerations of national-security and policies supporting strategic procurement and government-backed supply-chain resilience as by commodity prices.

EU Legislative Response

Faced with the US and China’s titanic struggle for geopolitical power and with CRMs now central to so much of modern life, the EU responded to President Macron’s call for the need for the EU to focus on creating its own strategic autonomy to secure its supply chains with a series of significant legislative and funding initiatives. That response has spawned a veritable forest of EU legislative and funding initiatives, designed to build more resilient and diversified supply and value chains.  A quick summary of the main elements EU’s legislative CRM agenda makes this hyperactivity clear:

  • September 2020: Critical Raw Materials Resilience Action Plan (the starting point of the EU’s CRM strategy) identified excessive dependence on a small number of third-country suppliers and set out plans to diversify supply; develop EU extraction/ processing; increase recycling; create more resilient value chains; and established the European Raw Materials Alliance (ERMA).
  • April 2024: European Critical Raw Materials Act identified 34 Critical Raw Materials and 17 Strategic Raw Materials.  Established 2030 benchmarks (10% of EU consumption extracted in the EU; 40% processed in the EU; 25% supplied through EU recycling,; no single third country to account for more than 65% of EU consumption of a strategic material at a relevant processing stage).  Created Strategic Projects; accelerated permitting, monitoring and stress tests; and established strategic-stockpile coordination.
  • March & June 2025: First CRMA Strategic Projects selected inside and outside the EU, marking the transition of the CRMA from regulatory framework to actual mining, processing and recycling projects. Commission reports 47 EU projects with a further 13 outside.
  • December 2025: RESourceEU Action Plan – strengthened the EU CRM strategy following Chinese export restrictions.  Created an action plan to accelerate diversification and domestic production; mobilise €3 billion for projects; develop joint purchasing/offtake arrangements; coordinate stockpiles; and reduce selected dependencies by 2029.
  • December 2025: Proposal to amend the CRMA to improve circularity; recycling capacity; secondary CRM markets; resilience; and CRMA implementation.
  • April 2026: launch of the Raw Materials Mechanism to aggregate EU demand and connect buyers with suppliers, financial institutions and storage providers.
  • June 2026: Proposed Regulation to create a European Critical Raw Materials Centre designed around joint purchasing, stockpiling, investment support and raw-materials intelligence.
  • September 2026:  Commission launches a project to select an implementing entity for a pilot CRM stockpiling mechanism.
  • September 2026: Commission President announces creation of CRM Corporation and the enhanced EU partnership with Canada.

This institutional architecture is completed by the Global Gateway (GG) launched in 2021 to create the EU’s external infrastructure investment strategy (and extended by the CRMA to include CRM projects); and the Global Investment Hub (GIH) which is the operational mechanism designed to help private-sector projects outside the EU gain access to EU finance.  Together these initiatives combine to de-risk private sector investment.  Add in Canada, which gives the EU a reliable new CRM source, and a clear structural pathway emerges:

  • The CRMA tells Europe what minerals it needs and why.
  • Strategic Partnerships identify the countries it wants to obtain them from.
  • GG provides the external economic and infrastructure framework.
  • The GIH enables the involvement of private companies to turn those political priorities into financeable projects.

A Development Aside

There is an interesting and important international development sub-stream to these GG and GIH.  As set out in this blog, African countries are seeking (rightly, in my view) to move up the value chain so that they do not simply export (cheap) raw materials and then reimport (expensive) finished products which incorporate the original raw materials. 

  • The GG can be used to help accelerate that process.  It is expressly flexible enough to allow the EU to invest in infrastructure associated with raw-material supply chains – including extraction and processing facilities, as well as electricity, roads, railways, ports, logistics, skills, regulatory capacity and other infrastructure required to get a mineral from the mine into an industrial supply chain. That shifts the EU’s intervention to one which, in return for creating a reliable and diversified supply chain between a third country and the EU, deliberately sets out to finance the infrastructure and processing capacity in a third country which allows the capture of more of the value chain locally.
  • And the GIH can come in behind the GG to assemble non-financial support, including political backing/economic diplomacy, discussions with host governments over regulatory or market-access issues, technical assistance and feasibility work, and help constructing European commercial or financial consortia.

Canada Calling and UK Beckoning

President Von der Leyen’s State of the Union speech and Mark Carney’s response earlier this month signalled the intent of the EU and Canada to intensify cooperation in the CRM sector.   This effectively adds Canada to Namibia as vital source countries for CRMs.

Across the Channel, the UK has not been idle either (in particular its Vision 2035 CRM Strategy which, amongst other goals, sets out a strategic mapping exercise and identifies projects for joint UK-Canada public-finance investment; and the 2026 UK-US MoU on CRM).  But it remains is a long way behind the EU in terms of its institutional architecture and the availability of UK funding pales into insignificance when compared with the financial firepower the EU has brought to bear on the subject. 

Comment

It is unclear what the exact roles and coordination of CRM Centre and the CRM Corporation will be. President Von der Leyen described the Corporation as helping Europe obtain and stockpile the materials required for electric vehicles, semiconductors, batteries, clean technology and defence.  Whilst Executive Vice-President Stéphane Séjourné described it as the CRM Centre’s financial arm, focused on investment and public-private financing partnerships.  However, whatever their exact roles and however they eventually fit together, what is clear is that the combination of the Centre and the Corporation will decisively shift the EU’s role from one of legislative coordinator to one of direct market intervention in procurement, reserves and financing.

With Brexit having shut the UK out of the EU, London can only gaze with envy at the EU’s legislative hyperactivity and the wide range of funding opportunities available to EU-based companies. However, with imagination, the increasingly urgent need to secure reliable access to CRMs and their supply chains could create a beneficial trade-off which would enable UK companies to access the EU’s plethora of funding possibilities; assist the UK Government’s EU political reset; and at the same time give the EU access to the benefits of The City of London as a centre of financial and mining-market excellence, as well as the UK’s defence sector expertise.  

The unstable global geopolitics create a challenging backdrop to the scramble for access to CRMs.  But everyone recognises that ensuring reliable supply and supply chains is crucial to stable economic growth.  The EU’s emerging response is impressive, but not yet fully pulled-together. Threading a way through the thicket of EU legislative initiatives is likely to require employing advisors who are well-placed and knowledgeable, but the returns on that investment will be considerable.

For companies with mining sector experience – both funding and operational – there is a window of opportunity.  As the EU’s institutional framework begins to take shape, positioning themselves as strategic advisors to the UK and the EU will enable them to play a key role in shaping the future of the sector in both jurisdictions. Such hands-on involvement by industry and private financing driving close public-private sector collaboration not only has the potential to rapidly close the gap between policy objectives and delivery to secure access to reliable sources of supply and supply chains, but also to facilitate private sector access to the CRM financial resources that the EU has made available. Given the global geopolitical chaos, rising political and military tensions and the increasingly urgent scramble for CRMs to feed both the energy transition and the defence sector, it makes sense to bet on the EU’s emerging institutional framework to deliver reliable access to raw and processed CRMs.  But the time for imaginative and proactive private sector involvement in shaping that framework to deliver for the future is now.

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Photo of Thomas Reilly Thomas Reilly

Ambassador Thomas Reilly, Covington’s Head of UK Public Policy and a key member of the firm’s Global Problem Solving Group, draws on over 20 years of diplomatic and commercial roles to advise clients on their strategic business objectives.

Ambassador Reilly was most recently…

Ambassador Thomas Reilly, Covington’s Head of UK Public Policy and a key member of the firm’s Global Problem Solving Group, draws on over 20 years of diplomatic and commercial roles to advise clients on their strategic business objectives.

Ambassador Reilly was most recently British Ambassador to Morocco between 2017 and 2020, and prior to this, the Senior Advisor on International Government Relations & Regulatory Affairs and Head of Government Relations at Royal Dutch Shell between 2012 and 2017. His former roles with the Foreign and Commonwealth Office included British Ambassador Morocco & Mauritania (2017-2018), Deputy Head of Mission at the British Embassy in Egypt (2010-2012), Deputy Head of the Climate Change & Energy Department (2007-2009), and Deputy Head of the Counter Terrorism Department (2005-2007). He has lived or worked in a number of countries including Jordan, Kuwait, Yemen, Libya, Iraq, Saudi Arabia, Bahrain, and Argentina.

At Covington, Ambassador Reilly works closely with our global team of lawyers and investigators as well as over 100 former diplomats and senior government officials, with significant depth of experience in dealing with the types of complex problems that involve both legal and governmental institutions.

Ambassador Reilly started his career as a solicitor specialising in EU and commercial law but no longer practices as a solicitor.