The European Union’s green, digital, and defence transitions are fundamentally tethered to the secure and sustainable supply of Critical Raw Materials (CRMs). While the entry into force of the Critical Raw Materials Act (CRMA) established ambitious, quantifiable 2030 benchmarks for domestic extraction, processing, and recycling, the legislative window for structural design has closed. We have entered the decisive phase of operational execution.

As the REPTIS Project Consortium, spearheading key technological innovations and dissemination actions within this ecosystem, we are proud to announce the publication of our joint Policy Brief and Policy Paper:

“Unlocking Critical Raw Materials (CRMs) in Europe: From CRMA Targets to Industrial Delivery”.

The analysis reflects contributions from Horizon Europe projects active across the critical raw materials value chain, including REESOURCE (main promoter), AVANTIS, BLOOM, PERMANET, PERSEPHONE, REEPRODUCE, REMHub, RESQTOOL, START, SUPREEMO, and REPTIS.

The findings are rooted in directional practitioner evidence collected during the Raw Materials Week 2025 side event, “Crossroads of Innovation: Shared Challenges and Joint Solutions in Raw Materials” (21st November 2025) where a broad cross-section of industry leaders, academic scholars, SMEs, and policy experts gathered to map out the realities of European CRM value chains.

The Core Finding:

Implementation, Not Scarcity. A central takeaway of this comprehensive assessment is that the primary risk to achieving the EU’s 2030 benchmarks is not geological resource scarcity or a lack of technological capability, but rather systemic implementation bottlenecks and investment uncertainty. With fewer than five years remaining on the horizon, Europe faces structural obstacles that threaten to stall mature innovations within the regulatory and financial “valley of death”.

Through extensive stakeholder surveys and thematic panels, the collaborative consortium identified four primary barriers to industrial deployment:

1. Financing and investment risk: While early-stage research is well-funded, transitioning pilots to commercial-scale deployment remains highly vulnerable to market volatility and unhedged price signals.
2. Regulatory and cross-border fragmentation: Circular economic flows are frequently impeded by inconsistent national waste classifications and disjointed cross-border transport rules, adding unnecessary administrative costs to recycling initiatives.
3. Permitting and administrative turbulence: Despite the CRMA’s introduction of fast-track pathways for strategic projects, the actual administrative capacity and interpretation vary widely across Member States, undermining investor confidence.
4. Social and Community Alignment : Evidence indicates that ignoring early, transparent community engagement, particularly in primary extraction, can introduce social delays that easily outweigh well-structured financial incentives.

Strategic Pillars for REPTIS and the European Ecosystem

The brief outlines six core policy recommendations designed to unlock industrial delivery:

• De-Risking through blended finance: Implementing public financial instruments that combine grants with guarantees and offtake-linked support.
• Regulatory harmonisation: Standardising waste definitions without complete legislative overhauls to smooth intra-EU logistics.
• Introduce mandatory product and magnet information: Mandating product-level details and aligning them with Digital Product Passports to optimize end-of-life recycling for permanent magnets.
• Parallel Value-Chain development: Acknowledging that advanced recycling and responsible primary extraction must be scaled concurrently, as secondary supply alone cannot fulfill the exponential demand driven by the twin transitions in the medium term.

We invite our network, scientific peers, and industrial partners to read the full Policy Brief and Paper to explore these actionable insights. Coordinated, timely implementation is our only viable path to anchoring a resilient, domestically secure CRM value chain in Europe.

Download the Documents (Zenodo):

Policy Paper:

Policy Paper-Unlocking Critical Raw Materials (CRMs) in Europe: Bottlenecks, Challenges and Prospective Priorities

Policy Brief:

Unlocking Critical Raw Materials (CRMs) in Europe: From CRMA Targets to Industrial Delivery