Critical Raw Materials Act (CRMA): What EU Law Requires from Companies and How Strategic Projects Work in Spain

The European Critical Raw Materials Act is Regulation (EU) 2024/1252, known as the CRMA. It has been in force since 23 May 2024 and, like all EU regulations, applies directly in Spain. The official Spanish version refers to 'materias primas fundamentales' (fundamental raw materials), whereas search engines and the press call them 'críticas' (critical). They are the exact same thing.

It operates with two lists. Annex I covers 17 strategic raw materials: bauxite, alumina and aluminium; bismuth; boron of metallurgy grade; cobalt; copper; gallium; germanium; lithium of battery grade; magnesium metal; manganese of battery grade; graphite of battery grade; nickel of battery grade; platinum group metals; rare earth elements for permanent magnets; silicon metal; titanium metal; and tungsten. Annex II covers 34 critical raw materials: all the strategic ones plus others such as antimony, helium, hafnium, scandium, tantalum, and vanadium.

The distinction is not merely in the name. Only a strategic material grants access to the strategic project status. Rare earth elements for magnets (neodymium, praseodymium, terbium, dysprosium, gadolinium, samarium, and cerium) form a single strategic entry. Antimony, by contrast, is critical but not strategic. Quality also counts: lithium and nickel are strategic at battery grade, and the 'graphite of battery grade' entry includes synthetic graphite, not just natural graphite.

A material enters the critical list if it reaches a supply risk of 1 and an economic importance of 2.8. The Commission will review the strategic list by 24 May 2027 at the latest and every 3 years thereafter, meaning the classification of your material may change.

Article 5 sets 2030 benchmarks for the Union's annual consumption of strategic raw materials overall: extraction capacity to cover at least 10%, processing capacity for 40%, and recycling capacity for 25%. Furthermore, no single third country should account for more than 65% of the Union's consumption of any individual strategic raw material.

These are targets for the Commission and Member States, not quotas for your company: nobody requires you to purchase a European percentage. However, they explain the rest of the Regulation: strategic projects with accelerated permitting, joint purchasing, and monitoring of single-supplier dependency. The 65% threshold puts the spotlight on supply chains such as rare earths and magnets, which China has subjected to export licensing since April 2025.

To measure progress, the Commission carries out stress tests on each strategic supply chain at least every 3 years, and Member States may send surveys to 'key market operators'. If your company receives one, you may refuse to provide data that would reveal trade or business secrets. Member States also report the level of their strategic stocks, although the CRMA does not oblige them to hold or release them.

This is the most cited and most misunderstood obligation. It only affects a 'large company' as defined by the CRMA: an average of more than 500 employees and a net worldwide turnover of more than €150 million in the last financial year for which annual financial statements have been prepared. And it only applies if the company uses strategic raw materials to manufacture batteries for energy storage or e-mobility, equipment related to hydrogen or renewable energy, aircraft, traction motors, heat pumps, data transmission and storage equipment, mobile electronic devices, additive manufacturing or robotics equipment, drones, rocket launchers, satellites, or advanced chips.

The obligation is not triggered automatically. Article 24 requires each Member State to identify these companies by 24 May 2025 at the latest, and within 12 months of each update to the strategic list. Once identified, the company must assess, at least every 3 years and to the extent that information is available, the risks to its supply chain: a mapping of where its strategic materials are extracted, processed, and recycled, an analysis of factors that might disrupt supply, and an assessment of its vulnerabilities.

The assessment is not submitted to any public authority. The company may present a report to its board of directors setting out the results, the source of the information, and mitigation measures, and the Member State may require it to do so. If a supplier does not provide the data, the assessment can be carried out using information published by the Commission or other publicly available data. If significant vulnerabilities are detected, the company must take reasonable efforts to mitigate them, for instance by diversifying suppliers or substituting the material.

On 3 December 2025, the Commission proposed tightening this article (proposal COM(2025) 946): the Commission itself would identify the companies, which would have 6 months to conduct the assessment, present the results to their board, and reply to the Commission within 30 days. As of 15 October 2026, it remains a proposal pending the European Parliament's position at first reading, with a plenary vote scheduled for 20 October. Our firm prepares the assessment and the board report as a bespoke assignment.

Article 28 requires labelling for magnetic resonance imaging devices, wind energy generators, industrial robots, motor vehicles, light means of transport, cooling generators, heat pumps, electric motors (including those integrated into other products), automatic washing machines, tumble dryers, microwaves, vacuum cleaners, and dishwashers. The visible, indelible label must state whether they incorporate permanent magnets and of which type: neodymium-iron-boron, samarium-cobalt, aluminium-nickel-cobalt, or ferrite. Products containing magnets of those types must also incorporate a data carrier with a unique identifier giving access to the responsible party, the weight, location, and chemical composition of each magnet, and instructions for removing them safely. If the magnets are exclusively contained in electric motors, providing the location and removal instructions for the motors is sufficient.

This obligation begins 2 years after the entry into force of the implementing act establishing the label format, which the Commission was due to adopt by 24 November 2025 (a corrigendum changed the 2026 date in the original text). For magnetic resonance imaging devices, motor vehicles, and category L vehicles, it applies from 24 May 2029. Defence and space products are excluded. The obligation lies with the party placing the product on the market, who may authorise another person to act on their behalf.

Article 29 adds a transparency obligation: if the neodymium, samarium-cobalt, or aluminium-nickel-cobalt magnets in one of those products have a total weight exceeding 0.2 kg, you must publish on a free-access website the share of neodymium, dysprosium, praseodymium, terbium, boron, samarium, nickel, and cobalt recovered from post-consumer waste. This applies by 24 May 2027 at the latest, or 2 years after the entry into force of the delegated act establishing the calculation methodology, whichever is later. For magnetic resonance imaging devices, motor vehicles, and category L vehicles, it applies 5 years after the entry into force of that delegated act. A product containing 3 motors with 0.08 kg of magnet each totals 0.24 kg and falls within the scope.

If you buy from China, the issue arises earlier. Announcement 18/2025 of 4 April 2025 remains in force and subjects to export licensing samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium, as well as samarium-cobalt magnets and neodymium magnets containing terbium or dysprosium; it does not mention finished products with magnets already assembled. Gallium, germanium, antimony, and certain graphites also require a Chinese licence. The announcements of 9 October 2025 are suspended until 10 November 2026. Your supplier applies for the licence before MOFCOM, which decides within 45 working days, and your company signs the end-user certificate: Managora drafts it for you through our China end-user certificate service page, where you can check the current fee.

Regarding import costs, our import study determines the TARIC heading, customs duty, and VAT for each product. The customs declaration is filed by your company or a registered customs representative; we leave the complete study ready with everything required for that declaration.

Any project promoter for the extraction, processing, or recycling of strategic raw materials, whether inside the Union or in a third country, may apply. The Commission recognises the project if it meets 5 criteria: making a meaningful contribution to the security of the Union's supply, being technically feasible within a reasonable timeframe, being implemented sustainably (covering environmental protection, labour and human rights, engagement with local communities, and corruption prevention), and bringing cross-border benefits if located in the Union or mutual benefit if located in an emerging market.

The promoter submits the application to the Commission using the single template set out in Reglamento de Ejecución (UE) 2025/2194 (Implementing Regulation (EU) 2025/2194), via their EU Login account. It must include, among other items, the project classification according to the United Nations Framework Classification for Resources, the timetable and status of authorisations, a plan to facilitate public acceptance, ownership and control of the participating undertakings, the business plan, and estimated job creation. The CRMA does not provide for any tasa (official fee).

Applications are assessed through calls with cut-off dates. The first call opened on 23 May 2024 and closed on 22 August 2024; the second closed on 15 January 2026, and the Commission will announce a new one towards the end of 2026. The Commission checks whether the application is complete within 30 days of the cut-off date and takes a decision within 90 days of completeness, extendable by a further 90 days in exceptional cases. If the Member State whose territory is concerned objects, the project is not recognised.

What you gain is time and legal weight. The project is considered to be of public interest, and may be considered of overriding public interest for the purposes of EU habitats, water, and birds legislation. The permit-granting process cannot exceed 27 months for projects involving extraction and 15 months for projects involving only processing or recycling (24 and 12 months if the project was already in the permit-granting process), with an exceptional extension of 6 or 3 months. The time taken by the promoter to prepare the environmental impact assessment report does not count towards those deadlines. However, recognition does not exempt the project from any authorisation.

Once recognised, obligations follow: a report to the Commission every 2 years on progress, authorisations, and financing, notification of changes to the project or to the control of participating undertakings, and a public website for the local population. Managora prepares the legal and documentary file for the application and subsequent reports; the promoter submits them via their EU Login, while the resource classification and technical feasibility stem from the project's own technical studies.

The first list (Decisión (UE) 2025/840 of 25 March 2025) recognised 47 projects across 13 Member States, 7 of them in Spain. On 4 June 2025, 13 projects in third countries were approved. On 9 October 2026, the Commission selected 46 more across 16 Member States, 2 of them Spanish, bringing the total to 106. The table in this guide lists all 9 Spanish projects.

Each Member State had to designate single points of contact by 24 February 2025 at the latest, 1 per relevant administrative level and stage of the value chain. Spain has 1 per autonomous community and, for state-level projects or those affecting more than 1 autonomous community, 2: the Subdirección General de Minas (MITECO) for extraction and the Subdirección General para el Impulso de Proyectos Industriales (Ministry of Industry and Tourism) for processing and recycling. In Andalusia, for example, the Dirección General de Minas handles extraction and processing; in Extremadura, the Dirección General de Industria, Energía y Minas; in Galicia, the Dirección General de Planificación Energética y Minas. The single point of contact must confirm within 45 days whether the application is complete, and that date starts the permitting clock.

Before the single point of contact, the procedure is governed by Spanish administrative law and allows representation: Managora submits the applications on your behalf via power of attorney. Mining technical projects and environmental impact assessments must be signed by the project's qualified engineer; we do not draft them. The Spanish Mining Act remains Ley 22/1973 (the Spanish Mining Act), unchanged since 2014, although the Action Plan approved on 10 March 2026 provides for amending it to integrate the CRMA.

There is an immediate deadline that many operators overlook: Article 27 obliges operators of extractive waste facilities to submit, by 24 November 2026 at the latest, a preliminary economic assessment study regarding the potential recovery of critical raw materials from that waste. It is filed before the competent mining authority. We can submit it as your representatives; we do not draft the technical content of the study.

Real Decreto 731/2026 of 16 September (Royal Decree on Strategic Investment Projects, published in the BOE on the 17th and in force since 18 September 2026) creates the declaration of Strategic Investment Project (Proyecto Estratégico de Inversión). Eligible projects include those involving the extraction, processing, or circular economy of critical raw materials and net-zero technologies. The acquisition of shares or equity stakes, capital increases or reductions, and corporate restructurings are excluded.

The application is filed electronically via the online portal designated by the Strategic Investments Committee (Comité de Inversiones Estratégicas), and includes a formal declaration of compliance with Hacienda (the Spanish Tax Agency), the Seguridad Social (the Spanish social security system), and other public authorities, as well as declaring that the applicant is not in insolvency, bankruptcy, or payment default, using the form to be approved by the Committee. The Committee issues the preliminary declaration within 1 month and the Government Delegated Commission for Economic Affairs (Comisión Delegada del Gobierno para Asuntos Económicos) adopts the final decision within 3 months of the application; if no decision is issued, the application is deemed rejected. The royal decree does not provide for a tasa. Managora can submit it on your behalf via power of attorney.

The Net-Zero Industry Act (Regulation (EU) 2024/1735, applicable since 29 June 2024) is the sister regulation for clean technology manufacturing plants. Permits for a manufacturing plant cannot exceed 12 months below 1 GW of annual capacity and 18 months from 1 GW upwards. If recognised as a net-zero strategic project, the limit is 9 months below 1 GW, 12 months from 1 GW upwards or where capacity is not measured in GW, and 18 months for CO2 storage. That recognition is not granted by the Commission: the promoter applies to the Member State, which decides within 1 month of a complete application; if rejected, the promoter may apply to the Commission.

Do not confuse the 3 statuses: a CRMA strategic project is recognised by the European Commission, a Net-Zero Industry Act strategic project by the Member State, and a Strategic Investment Project by the Government of Spain. Each is applied for separately before its respective body.

Article 25 sets up a Commission system to aggregate the demand of undertakings established in the Union that consume strategic raw materials and to seek suppliers for that joint volume. Participating companies may jointly negotiate prices and conditions in compliance with competition law, while entities subject to Union sanctions are excluded as suppliers. This is the Raw Materials Mechanism: registration opened on 18 November 2025 and, according to the Commission, as of 9 October 2026 it has generated more than 30 matches across 10 materials. The company registers itself; we prepare your registration file.

RESourceEU is the Commission's action plan of 3 December 2025 (COM(2025) 945). It plans to mobilise €3,000 million in European funds over 12 months, establish a European Critical Raw Materials Centre in 2026 for market intelligence, stockpiling, and joint purchasing, and launch a stockpiling pilot in early 2026. It also announced that, by the second quarter of 2026 at the latest, the Commission would propose restricting exports of permanent magnet scrap and waste. It is a communication, not a legislative act: on its own, it imposes no obligations on your company.

The CRMA does not set fines. Article 47 instructs each Member State to lay down its own penalties regime, with a deadline that expired on 24 November 2025 according to the corrigendum. Any fine amount you read attributed directly to the Regulation does not come from the CRMA itself.