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Critical Raw Materials Alliance

CRM Alliance

The Critical Raw Material Alliance promotes the importance of critical materials to the EU and supports a critical materials policy.

Lobbying Activity

Response to Advanced Materials Act

8 Jan 2026

The Critical Raw Materials Alliance (CRM Alliance) welcomes the initiative to develop an Advanced Materials Act (AMA) as a valuable addition to the EUs broader framework for industrial competitiveness, innovation, and resilience. We strongly support efforts to strengthen Europes technological leadership and to accelerate the transition towards a sustainable, circular, and low-carbon economy. Advanced materials will play a central role in achieving these objectives. However, the successful development and deployment of advanced materials fundamentally depend on the availability of secure and sustainable supplies of critical raw materials (CRMs), which constitute the essential building blocks of many advanced technologies. In this context, the CRM Alliance puts forward the following key recommendations: Take into account the specific market conditions and supply-chain characteristics of each critical raw material. Balance circularity and sustainable use with the need for secure and reliable access to CRMs. Ensure full coherence between the Advanced Materials Act and the Critical Raw Materials Act. Strengthen industrial deployment and scale-up capacity for advanced materials in Europe. Approach substitution of CRMs with caution and based on robust evidence, recognising technical and economic constraints. Invest in skills development and the preservation of technological know-how across the value chain. Simplify regulatory and permitting procedures to accelerate industrial implementation. Develop a list of Crucial Advanced Materials that are essential for Europes strategic autonomy.
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

25 Apr 2024 · Global competitiveness of EU companies

Response to European Critical Raw Materials Act

27 Apr 2023

Please see attached the response from the CRM Alliance.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

30 Mar 2023 · Critical raw materials act

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

30 Mar 2023 · Critical Raw Materials Act; investment conditions; international partnerships

Meeting with Emma Wiesner (Member of the European Parliament)

29 Mar 2023 · EUs regler för kritiska råmaterial

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

28 Mar 2023 · Critical Raw Materials

Response to 2023 Strategic Foresight Report

13 Mar 2023

The CRM Alliance represents primary producers, traders and associations of raw materials that the European Commission has determined to be critical to the EU economy. Please see attached our position statement.
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Response to European Critical Raw Materials Act

24 Nov 2022

The Critical Raw Materials Alliance (CRM Alliance) would like to submit their contribution to the CRM Act. Please see attached.
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Meeting with Reinhard Bütikofer (Member of the European Parliament) and Commerzbank AG

8 Sept 2022 · Exchange of views

Meeting with Pascal Canfin (Member of the European Parliament)

1 Apr 2022 · Critical Raw Materials

Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

Please see the CRM-Alliance contribution attached.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

Please find attached the Critical Raw Materials Alliance contribution to the revision of REACH.
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Response to Revision of EU legislation on end-of-life vehicles

18 Nov 2020

The Critical Raw Materials Alliance (CRM-A) represents primary producers, traders and associations of raw materials that the European Commission has determined to be critical to the European economy (CRMs). The CRM-A has closely examined the Commission’s plan to review the ELV Directive and supports the aim to reassess it in light of the growing electric vehicle market and the increased use of new materials, electronics, CRMs and carbon fiber, and to line up its objectives with the targets set in the European Green Deal and Circular Economy Action Plan. In reference to the different policy options outlined in the roadmap, the CRM-A supports a targeted modification of the ELV Directive through an update of its provisions in order to line up the different existing EU waste legislations, promote circularity in the automotive sector, and improve the enforcement of the Directive; however, we would like to highlight some key challenges and recommendations: Realistic targets for re-use and recycling – Recycling is not always the most feasible or economic viable option for many CRMs. We therefore call on the Commission to consider social, economic and environmental costs related to recycling and to rethink the ‘reuse supply chain’ when reviewing the ELV Directive. Material restrictions – The CRM-A believes that substances should only be regulated under REACH and not under the ELV Directive to avoid future incoherencies and duplication of work. At the same time, restricting certain hazardous materials might halt the innovation process. Substituting CRMs often leads to less performing products and in many cases to products with a lesser lifetime. The latter is against environmental objectives. Regulatory and administrative burden – CRMs are often a primary target and subject to increasing notification requirements. This is often the result of an accumulation of different initiatives, which negatively impacts the innovation and competitiveness of EU industries. Regulatory coherence and inconsistency – The high number of regional, national, EU, and international regulatory frameworks targeting CRMs and waste management often feature contrasting and/or overlapping provisions, rendering it difficult for industry to identify the applicable legislation and to comply. The CRM-A therefore calls on the Commission to avoid future overlap and ensure coherence with other EU initiatives such as the Waste Framework Directive, RoHS or REACH. The CRM-A thus welcomes the Commission’s roadmap towards lining up the ELV Directive with other existing regulatory frameworks and towards a better implementation and enforcement of the directive. At the same time, we believe that Commission must ensure that the revised version of the ELV Directive does not translate into a loss of competitiveness and innovation for EU industry. Greater coordination between EU regulatory bodies is necessary in order to allow the development of an efficient, effective and proportionate framework regulating waste from ELVs. We strongly recommend the Commission to engage with industry to identify sector-specific issues along the value chain and develop adequate solutions. Additionally, the Commission also needs to consider the international regulatory contexts and ensure a certain degree of international alignment. The ELV Directive should make dismantling and recycling of ELVs more environmentally friendly, while recognizing the life-improving properties and non-substitutional use of CRMs, and avoiding overregulation and an increased administrative burden on industry.
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Response to Chemicals strategy for sustainability

9 Jun 2020

The Critical Raw Materials Alliance (CRM-A) represents primary producers, traders and associations of raw materials that the European Commission has determined to be critical to the European economy (CRMs). Members of our alliance are directly impacted by EU chemicals legislation, such as REACH and RoHS, and have first-hand experience with the benefits that these pieces of legislation bring, as well as regulatory inconstencies and lack of coordination in implementation between them. The CRM-A has reviewed the European Commission’s plan to reduce risks associated with producing and using chemicals. We support the aim of simplifying EU rules on chemicals by ensuring increased harmonization of work between EU agencies and legislation. In particular, the work done for the various assessments (hazard and risk assessments, RMOA’s, socio-economic impact assessments) should not be unnecessarily duplicated. The current EU regulatory approach targets CRMs under several different frameworks which negatively impact investment, innovation and development: Regulatory burden – CRMs are often a primary target, in particular when scientific data about a substance is already available. This results often in an accumulation of initiatives, which negatively impacts EU industries in terms of loss of investment, competitiveness and innovation. Innovation and development barrier – Technological evolution is dependent upon CRMs. The targeting and restriction of CRMs through policymaking will deprive the EU of the necessary raw materials to thrive in terms of innovation and technological development, particularly in the field of green technologies. Contradicting policies – Currently, some EU policies contradict each other. For example, some substances are restricted for environmental concerns, while they are an essential component of batteries and the promotion of electric vehicles. Regulatory incoherence and inconsistency – The high number of regional, national, EU, and international regulatory frameworks targeting CRMs often feature contrasting and/or overlapping provisions, rendering it difficult for industry to identify the applicable legislation, yet alone comply. Our alliance has witnessed substances targeted under several regulatory frameworks simultaneously in the EU, such as evaluation under REACH and RoHS, even though these feature overlapping objectives and scopes. Such approaches contribute to legal uncertainty and negatively impact investments. We therefore greatly support the ‘one substance – one assessment’ principle. In conclusion, we welcome the Commission’s roadmap towards simplifying and strengthening the legal framework. At the same time, we believe that consideration must be given to ensuring the framework is sustainable and consistent. Greater coordination among EU regulatory bodies is necessary in order to allow the development of a CRM regulatory framework that is effective, efficient and proportionate. We would welcome the EU to proactively cooperate with industry in order to adequately identify the issues associated with these materials and adopt the best regulatory solutions which preserve the availability and applicability of CRMs. Future regulation must provide security and predictability for those who consider important and long-term investments in sourcing of substances identified as Critical Raw Materials by the European Commission. Regulation also needs to consider the international regulatory contexts so as to avoid the investment moving to third countries. A level of international alignment is therefore necessary. The Chemicals Strategy should enable the promotion and protection of the safe use of CRMs, given their life-improving properties and their non-substitutable use in critical applications. The different decision-making bodies involved in the use of CRMs in the EU and at national levels should act coherently to avoid overregulation, redundant burdens and contradictory decisions for industry.
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

26 Sept 2018 · Critical Raw materials

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

28 Sept 2016 · raw materials & EU trade policy