Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2024/1252
Date: 2025-12-03
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: evaluation of resources, exchange of information, exploitation of resources, large business, raw material, risk management, security of supply, supply chain, waste recycling

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   EUROPEAN COMMISSION  Brussels, 3.12.2025  COM(2025) 946 final 2025/0385 (COD)  Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2024/1252 (Text with EEA relevance)  
 
EXPLANATORY MEMORANDUM 

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

The Critical  Raw Materials  Act  (Regulation (EC) No 2024/1252) provided the EU with  the 
objectives  and  a  first  set  of  tools  to  ensure  that  the  EU  industry  has  access  to  a  secure  and 
sustainable supply of the critical raw materials (CRMs). CRMs are needed to manufacture the 
strategic  technologies  crucial  for  the  clean  and  digital  transition,  as  well as  for  defence  and 
aerospace  applications.  Yet,  since  the  CRMA’s  entry  into  force  on  23  May  2024,  the 
geopolitisation  of  critical  raw  materials  supply  has  been  heightened  by  a  series  of  Chinese 
export restrictions on rare earths elements and other critical  raw materials. In parallel, other 
global  players  have  stepped  up  action  to  secure  access  to  CRMs  for  their  industries  by 
financing CRM projects and diversifying their supplies through partnerships. 

It  is  within  that  context  that  the  Commission  has  adopted  on  3  Decembre  2025  the 
RESourceEU  action  plan  to  accelerate  the  achievement  of  the  CRMA  and  reinforce  the 
European  Economic  Security  Communication1.  The  Action  Plan  contains  measures  on  the 
financial de-risking and regulatory support for CRM projects with immediate diversification 
potential,  as  well  as  measures  to  operationalise  its  partnerships  with  third  countries,  protect 
the  Single  Market,  and  create  a  lasting  market  for  diversified  supplies  of  critical  raw 
materials.  Among  the  measures  to  meet  those  objectives,  the  Commission  is  proposing 
targeted  amendments  to  Regulation  (EC)  No  2024/1252  (the  Critical  Raw  Materials  Act  or 
“CRMA”) in order to streamline, clarify and simplify some of the rules to improve circularity, 
in order to increase recycling capacity and to strenghten the secondary market for critical raw 
materials. 

Firstly, the proposed amendments to the CRMA aim to create a lasting market for the Union’s 
raw materials value chain. For that purpose, the amendments seek to strenghten the resilience 
of Union industrial sectors manufacturing strategic technological products with strategic raw 
materials, a subset of CRMs. The ongoing implementation of the CRMA underlines that there 
is  a  risk  of  fragmentation  of  the  Single  Market  from  disparate  identification  by  individual 
Member  States  of  the  large  companies  that  have  to  perform  risk  assessment  of  their  supply 
chains  under  Article  24  of  the  CRMA.  This  risk  of  fragmentation  demonstrates  that,  when 
market failures lead to  where companies fail to undertake mitigation strategies to limit their 
vulnerabilities,  additional  action  may  be  warranted  by  the  Commission.  In  addition  to 
incentivising companies  to invest in the resilience of their supply chains, these amendments 
would also drive the demand for diversified CRM supply sources. 

Secondly, the imminent need to quickly increase production of CRMs requires the expansion 
of the circularity framework to increase the  recovery and the reuse of critical raw materials, 
particularly for rare earth permanent magnets2. The Commission therefore proposes to amend 
the  CRMA  by  expanding  the  scope  of  products  covered  by  labelling  and  clarifying 
information  obligations under Article 28  CRMA. For the same reasons, the Commission  is 
also  proposing  to  include  pre-consumer  waste  to  the  recycled  content  obligation  for  rare 
earths  permanent  magnets,  also  in  light  of  the  fact  that  pre-consumeer  waste  is  more  easily 
recycled and currently more accessible than post-consumer waste.  

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COM/2025/977 final 
Mc Govern, L., Tapoglou, E. and Georgakaki, A., Material streams from wind energy decommissioning 
2025, 
Publications  Office 
to 
https://data.europa.eu/doi/10.2760/0326924, JRC139814 

European  Union, 

Luxembourg, 

2050, 

the 

of 

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Lastly, the Commission is proposing to introduce additional flexibility in the number of calls 
required  per  calendar  year,  given  the  high  number  of  applications  per  call  and  the  need  to 
ensure a coherent assessment of each application. This proposal is based on the Commission’s 
implementation of the  Article 7 of the CRMA  on the selection of Strategic Projects.  A first 
call was opened in  2024, leading  to  the selection of 47  Strategic Projects in  the EU  and 13 
Strategic Projects outside of the Union3. A second call was launched by the Commission on 
25 September 2025.  

• 

Consistency with existing policy provisions in the policy area 

The  amendments  contained  in  this  proposal  will  ensure  resource  efficiency  and  support  the 
secure and sustainable supply of CRMs. It will in particular strengthen the Union’s strategic 
autonomy by securing and ensuring the diversification of its supply chains. The RESourceEU 
Action  Plan  initiative  reinforces  other  measures  to  advance  the  Union’s  industrial  and 
economic security policy goals and contributes to the objectives set out in the Communication 
on  the  Clean  Industrial  Deal  and  is  closely  linked  to  the  European  Economic  Security 
Doctrine. 

At  the  same  time,  the  amendments  will  support  the  clean  and  digital  transformation,  by 
ensuring  availability  of  essential  resources  used  by  industries  of  various  sectors.  The 
amendments  will  improve  traceabilityto  support  end-of-life  recovery  and  promoting  the 
gradual  uptake  of  recycled  raw  materials,  thereby  contributing  to  a  coherent  and  aligned 
framework for enhancing circularity and securing the Union’s supply of CRMs. 

• 

Consistency with other Union policies 

This  proposal  is  consistent  and  ensures  complementarity  and  synergies  with  other  Union 
policies. 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

In line with Article 114 of the Treaty on the Functioning of the European Union, the proposed 
regulation  aims  to  contribute  to  the  well-functioning  of  the  Single  Market,  notably  by 
strenghtening and clarifying the rules ensuring a secure and sustainable supply of CRMs for 
the Union. 

• 

Subsidiarity (for non-exclusive competence) 

The overall objective of the proposal is to ensure uniformity and streamline certain procedures 
at Union level, in order to prepare large companies operating in one or more Member States, 
to face in the supply chains disruptions and have mitigations measures in place. 

The objectives of this proposal cannot be achieved by the action of Member States alone. 

• 

Proportionality 

The  proposal  complies  with  the  proportionality  principle  in  that  it  does  not  go  beyond  the 
minimum required to achieve the stated objectives at the Union level and which is necessary 
for that purpose. 

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Selected strategic projects under CRMA 

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• 

Choice of the instrument 

A regulation amending the CRMA Regulation is an appropriate legal instrument to implement 
the RESourceEU objectives. 

3. 

• 

N/A 

• 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Ex-post evaluations/fitness checks of existing legislation 

Stakeholder consultations 

While  no  formal  stakeholder  consultation  was  carried  out,  the  proposed  amendments  result 
from technical workshops with representatives of the entire permanent magnets value chain, 
exchanges within the framework of the CRM Board, as well as the technical work undertaken 
by  the  Joint  Research  Centre  in  preparation  for  the  secondary  legislation  under  Articles  28 
and 29 of the CRMA.  

• 

Collection and use of expertise 

Due to the nature of the proposed amendments and the urgency, there was no collection and 
use of expertise for this proposal. 

• 

Impact assessment 

Due to the urgent nature of the proposal, no impact assessment was carried out. 

Regulatory fitness and simplification 

• 

N/A 

• 

Fundamental rights 

This proposal does not have consequences for the protection of fundamental rights. 

4. 

BUDGETARY IMPLICATIONS 

 The proposal does not have implications for the Union budget. 

5. 

• 

OTHER ELEMENTS 

Implementation plans and monitoring, evaluation and reporting arrangements 

This  proposal  amends  the  CRMA  and  includes  changes  to  the  implementation  plans  for 
Member States, in particular by removing the obligation for Member States to identify large 
companies  and  transferring  this  obligation  to  the  Commission.  This  change  simplifies  and 
streamlines administrative procedures at Union level. 

The  obligations  and  reporting  arrangements  for  certain  companies  are  clarified  through 
targeted changes to a very limited number of articles. 

• 

Explanatory documents (for directives) 

N/A 

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• 

Detailed explanation of the specific provisions of the proposal 

Article 1 amends Regulation (EU) 2024/1252. 

Article  1,  point  (1)  modifies  the  number  of  cut-off  dates  for  open  calls  for  applications  for 
Strategic projects under the CRMA. 

Article 1, point (2)(a), streamlines the obligation to identify large companies by tansferring it 
from national administrations to the Commission. 

Article 1, point (2)(b) requires the Commission to notify large companies of their obligations. 

Article 1, point (2)(c) clarifies the obligation for large companies and the aspects to consider 
for their risk preparedness assessment.  

Article 1, point (2)(d) clarifies the obligations that large companies need to comply with for 
the mitigation measures 

Article 1, point (2)(e) strengthens the obligation for large companies to maintain their board 
informed of the risk assessment.  

Article 1, point (2)(f) allows the Commission to request information from large companies on 
their  compliance  with  the  risk  assessment  obligations,  and  empowers  the  Commission  to 
specify if needed the mitigations measures for large companies through delegated acts.  

Article 1, point  (2)(g) deletes a paragraph that is  not  adapted anymore since the obligations 
under article 28 CRMA are placed on the Commission.  

Article 1, point (3) expands the list of products containg permanent magnets to be considered 
by the Commission for their labeling. 

Article  1,  point  (4)  clarifies  and  expands  the  scope  of  Article  29  CRMA  by  including  pre-
consummer  waste  of  permanent  magnets  to  enable  more  comprehensive  action  by  the 
Commission is more comprehensive for recycling permanent magnets. 

Article  1,  point  (5)  adapts  the  rules  for  the  exercise  of  the  delegation  to  include  the  new 
empowerment under Article 1, point (2)(f). 

2025/0385 (COD) 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

amending Regulation (EU) 2024/1252 

(Text with EEA relevance) 

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THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Article 114, thereof, 

Having regard to the proposal from the European Commission, 

After transmission of the draft legislative act to the national parliaments, 
Having regard to the opinion of the European Economic and Social Committee4, 
Having regard to the opinion of the Committee of the Regions5, 

Acting in accordance with the ordinary legislative procedure, 

Whereas: 

(1) 

(2) 

(3) 

(4) 

(5) 

Since  the  entry  into  force  of  Regulation  (EU)  2024/1252  on  23  May  2024,  the 
Commission has been collecting data and information from stakeholders and Member 
States concerning the implementation of it. 

Access  to  secure  and  sustainable  critical  raw  materials  is  essential  for  the  Union’s 
objectives of clean and digital transition as set out in the Clean Industrial Deal6. They 
are also essential components for the Union’s industries, in all areas including defence. 
Due to the current geopolitical situation the Union’s supply and security of critical raw 
materials is put at risk and therefore, the current framework should be strengthened. 

Under  Regulation  (EU)  2024/1252,  the  Commission  is  required  to  set  up  calls  for 
application  for  Strategic  Projects  with  at  least  four  cut-off  dates  per  year.  Given  the 
high  number  of  applications  for  recognition  of  Strategic  Project  under  each  call  per 
call  received  for  the  identification  of  Strategic  projects  of  strategic  critical  raw 
material  projects  and  to  ensure  a  better  assessment  of  the  various  applications,  it 
should be possible for the Commission to limit the number of such calls per year. 

Under  Regulation  (EU)  2024/1252,  Member  States  are  required  to  identify  large 
companies by May 2025 and within 12 months of each update of the list of strategic 
raw materials pursuant to Article 3(3). Nevertheless, large companies that use critical 
raw materials can operate in more than one Member State. To avoid  a duplication of 
the identification of these large companies by the various national administrations and 
to  prevent  a  risk  of  fragmentation  of  the  Single  Market,  it  should  be  for  the 
Commission to identify these large companies operating in the Union. 

It  is  essential  to  strengthen  the  risk  preparedness  of  the  large  companies  that  are 
identified by the Commission, it is essential that their obligations are strengthened, and 
therefore  large  companies  should  be  required  to  take  measures  to  mitigate  their 
vulnerabilities,  including  by  diversifying  their  raw  material  supply  chain.  The 
Commission  should  be  able  to  receive  the  information  regarding  their  compliance 
necessary for an effective monitoring and ensure they are prepared in case of supply 
disruption.  The  Commission  should  specify  the  mitigation  measures  that  large 
companies should adopt in case of vulnerabilities, it should be able to do so by means 
of delegated acts.  

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COM(2025) 85 final 

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(6) 

(7) 

(8) 

Large companies should, as part of that risk assessment, map where the strategic raw 
materials they use are extracted, processed and recycled from, and analyse the factors 
that could affect their supply and assess their vulnerabilities to supply  disruptions. In 
order to have a clear understanding of  their vulnerabilities, they should also map the 
supply  chain  of  the  components  containing  critical  raw  materials.  To  reinforce  their 
preparedness large companies should report on their risk assessment to the companies’ 
board of directors or management board. 

The Commission should continue to monitor the situation and the risk preparedness of 
large companies, ensuring their readiness in case of disruption of their supply chains. 
To  that  end,  and  when  it  decides  so,  the  Commission  can  request  information  from 
large  companies  on  their  compliance  and  mitigation  measures  as  required  by  this 
Regulation.  

The  recognition  of  pre-consumer  recycled  materials  complements,  the  recovery  of 
post-consumer waste by ensuring that manufacturers can improve short-term resource 
efficiency  while  maintaining  strong  incentives  to  build  and  expand  end-of-life 
collection  and  recycling  systems.  Additional  product  categories  and  pre-consumer 
waste are therefore essential to improve recycling, strengthen traceability and increase 
the availability of secondary materials thereby supporting the Union’s overall resource 
efficiency and security of supply. 

(9) 

To  attain  the  objectives  set  in  the  RESourceEU  Action  Plan,  Regulation  (EU) 
2024/1252 should therefore be amended accordingly, 

HAVE ADOPTED THIS REGULATION: 

Article 1 
Amendments to Regulation (EU) 2024/1252 

Regulation (EU) 2024/1252 is amended as follows: 

(1) 

in Article 7(3), the second subparagraph is replaced by the following: 

‘The first such cut-off date shall be no later than 24 August 2024. The Commission 
shall set cut-off dates up to four times per year.’; 

(2) 

(a) 

Article 24 is amended as follows: 

paragraph 1 is replaced by the following: 

‘1. By [P.O.: please insert date corresponding to the date of entry into force of this 
Regulation  plus  2  months]  and  within  six  months  of  each  update  of  the  list  of 
strategic raw materials, the Commission shall identify the large companies operating 
in  the  Union  that  use  strategic  raw  materials  to  manufacture  batteries  for  energy 
storage  and  e-mobility,  equipment  related  to  hydrogen  production  and  utilisation, 
equipment  related  to  renewable  energy  generation,  aircrafts,  traction  motors,  heat 
pumps,  equipment  related  to  data  transmission  and  storage,  mobile  electronic 
devices, equipment related to additive manufacturing, equipment related to robotics, 
drones, rocket launchers, radar, satellites or advanced chips.’; 

(b) 

the following paragraph 1a is inserted: 

‘1a.  The  Commission  shall  inform  the  large  companies  it  has  identified  under 
paragraph 1 of such identification and of their obligations under this Article.’; 

(c) 

paragraph 2 is replaced by the following: 

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2.  Large  companies  as  referred  to  in  paragraph 1 shall by  six  months  of  the 
information of their identification and at least every three years and to the extent the 
required  information  is  available  to  them,  carry  out  a risk  assessment  of  their  raw 
materials supply chain of strategic raw materials, including:  

a) a mapping of the supply chain of components containing strategic raw materials; 

a  mapping 

b) 
extracted, processed or recycled; 

of where 

the 

strategic 

raw  materials they 

use 

are 

c) an analysis of the factors that might affect their supply of strategic raw materials; 

d) an assessment of their vulnerabilities to supply disruptions.’; 

(d) 

paragraph 4 is replaced by the following: 

‘4.  If  significant  vulnerabilities  to  supply  disruptions  are  detected  as  a result  of  the 
risk  assessment  referred  to  in  paragraph 2,  large  companies  as  referred  to  under 
paragraph 1  shall  take  efforts  to  mitigate  those  vulnerabilities,  including  by 
diversifying its raw materials supply chains, considering secondary raw materials, or 
substituting the strategic raw materials.’; 

(e) 

paragraph 5 is replaced by the following:  

‘5.  Large  companies  as  referred  to  in  paragraph  1  shall  present  to  their  board  of 
directors  or  management  board  the  results  of  the  risk  assessment  referred  to  in 
paragraph 2.’; 

(f) 

the following paragraphs 5a and 5b are inserted: 

‘5a.  The  Commission  may  request  large  companies  referred  to  in  paragraph  1  to 
explain  how  they  comply  with  the  obligations  set  out  in  this  Article.  They  shall 
provide  that  information  no  later  than  30  days  after  receiving  the  request  from  the 
Commission.’   

‘5b.  The  Commission  is  empowered  to  adopt  a  delegated  act  in  accordance  with 
Article 38 to supplement this Regulation by specifying the risk mitigation measures 
that the large companies referred to in paragraph 1 of this Article are to  take when 
significant  vulnerabilities  to  supply  disruptions  are  detected  in  accordance  with 
paragraph 4 of this Article.  

The  Commission  shall  base  such  risk  mitigation  measures  on  an  assessment  of  the 
available  information  on  supply  risks,  the  trade  flows  between  the  Union  and  third 
countries,  and  the  potential  obstacles  to  trade  in  critical  raw  materials  and  shall 
specify the maximum shares of reliance on a single third country in the supply chain 
of critical raw materials.’; 

paragraph 6 is deleted; 

in Article 28(1), the introductory wording is replaced by the following:  

‘1. From two years after the date of entry into force of the implementing act referred 
to  in  paragraph  2,  any  natural  or  legal  person  that  places  on  the  market  magnetic 
resonance  imaging  devices,  wind  energy  generators,  industrial  robots,  motor 
vehicles,  light  means  of  transport,  cooling  generators,  heat  pumps,  electric  motors 
including where electric motors are integrated in other products, automatic washing 
machines,  tumble  driers,  microwaves,  vacuum  cleaners, dishwashers,  hard  disk 
drives, transducers, loudspeakers, drones for civil use or motorised toys shall ensure 

(g) 

(3) 

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that  those  products  bear  a  conspicuous,  clearly  legible  and  indelible  label 
indicating:’; 

(4) 

(a) 

Article 29 is amended as follows: 

paragraph 1 is replaced by the following: 

‘1.  By  24  May  2027  or  two  years  from  the  entry  into  force  of  the  delegated  act 
referred to in paragraph 2, whichever is later, any natural or legal person that places 
on  the  market  products  referred  to  in  Article  28(1)  which  incorporate  one  or  more 
permanent  magnets  referred  to  in  Article  28(1),  point  (b)(i),  (ii)  and  (iii),  and  for 
which  the  total  weight  of  all  such  permanent  magnets  exceeds  0,2  kg  shall  make 
publicly  available  on  a  free-access  website  the  share  of  neodymium,  dysprosium, 
praseodymium,  terbium,  boron,  samarium,  nickel  and  cobalt  recovered  from  pre-
consumer  and  post-consumer  waste,  including  the  shares  of  such  waste  produced 
within the Union, present in the permanent magnets incorporated in the product.’; 

(b) 

in paragraph 2, the first subparagraph is replaced by the following: 

‘2.  The  Commission  shall  adopt  a  delegated  act  in  accordance  with  Article  38  to 
supplement this Regulation by establishing rules for the calculation and verification 
of the share of neodymium, dysprosium, praseodymium, terbium, boron, samarium, 
nickel and cobalt recovered from pre-consumer and post-consumer waste, including 
the  shares of  such  waste  produced  within  the  Union, present  in  the  permanent 
magnets incorporated in the products referred to in paragraph 1 of this Article.’; 

(c) 

in paragraph 3, the first subparagraph is replaced by the following:  

‘3.  After  the  entry  into  force  of  the  delegated  act  adopted  pursuant  to  paragraph  2, 
and in any event by 31 December  2031, the Commission shall adopt delegated acts 
supplementing  this  Regulation  by  laying  down  minimum  shares  for  neodymium, 
dysprosium, praseodymium, terbium, boron, samarium, nickel and cobalt recovered 
from,  pre-consumer  and  post-consumer  waste, including  the  shares  of  such  waste 
produced within the Union, or any combination thereof   that must be present in the 
permanent magnet incorporated in the products referred to in paragraph 1.’; 

(d) 

in paragraph 3, third subparagraph, point (a) is replaced by the following: 

‘(a)  The  existing  and  forecasted  availability  of  neodymium,  dysprosium, 
praseodymium,  terbium,  boron,  samarium,  nickel  and  cobalt  recovered  from pre-
consumer and post-consumer waste sources as well as Union recycling capacity;’; 

(5) 

(a) 

Article 38 is amended as follows:  

in paragraph 2, the first sentence is replaced by the following:  

‘2.  The  power  to  adopt  delegated  acts  referred  to  in  Article 3(2),  Article 4(2), 
Article 5(3),  Article 6(2),  Article  24(5b),  Article 28(12),  Article 29(2)  and  (3), 
Article 31(1)  and  (8),  and  Article 34(1)  shall  be  conferred  on  the  Commission  for 
a period of eight years from 24 June 2024.’; 

(b) 

in paragraph 3, the first sentence is replaced by the following:  

‘3.  The  delegation  of  power  referred  to  in  Article 3(2),  Article 4(2),  Article 5(3), 
Article 6(2),  Article  24(5b),  Article 28(12),  Article 29(2)  and  (3),  Article 31(1)  and 
(8) and Article 34(1) may be revoked at any time by the European Parliament or by 
the Council.’; 

(c) 

paragraph 6 is replaced by the following: 

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‘6.  A  delegated  act  adopted  pursuant  to  Article 3(2),  Article 4(2),  Article 5(3), 
Article 6(2), Article 24(5b), Article 28(12), Article 29(2) or (3), Article 31(1) or (8) 
or Article 34(1) shall enter into force only if no objection has been expressed either 
by  the  European  Parliament  or  the  Council  within  a period  of  two  months  of 
notification of that act to the European Parliament and the Council or if, before the 
expiry of that period, the European Parliament and the Council have both informed 
the  Commission  that  they  will  not  object.  That  period  may  be  extended  by  two 
months at the initiative of the European Parliament or of the Council.’. 

Article 2 
Entry into force 

This Regulation shall enter into force on the twentieth day following that of its publication in 
the Official Journal of the European Union. 

This Regulation shall be binding in its entirety and directly applicable in all Member States. 

Done at Brussels, 

For the European Parliament 
The President 

For the Council 
The President 

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