It’s the implementation, stupid: Why CRMA targets hinge on delivery

Europe’s green and digital transitions rely on secure access to critical raw materials, especially rare earth elements and permanent magnets. In response, the EU has adopted the Critical Raw Materials Act (CRMA), setting clear 2030 targets for domestic extraction, processing, recycling, and reduced reliance on single third‑country suppliers.

Echoing the famous refrain “It’s the economy, stupid”, which cut through complexity to pinpoint the decisive factor, the CRMA debate now faces a similar truth: it’s the implementation that will make or break these targets. The challenge is no longer ambition or intent, but whether Europe can translate agreed objectives into timely permits, bankable projects, coordinated regulation, and real industrial deployment.

Two newly released documents, a Policy Paper and Policy Brief developed by eleven Horizon Europe projects including REMHub, examined why industrial deployment of critical raw materials, including rare earths and permanent magnets, is progressing too slowly, and what must change in the remaining years to 2030. The Policy Paper is entitled Unlocking Critical Raw Materials in Europe: Bottlenecks, Challenges, and Prospective Priorities and is  developed from structured stakeholder input at the EU Raw Materials Week 2025 side event “Crossroads of Innovation: Shared Challenges and Joint Solutions in Raw Materials”.

Key barriers to industrial scale‑up of critical raw materials

Across stakeholder groups, industry, research, universities, civil society, and policymakers, the message is consistent: Europe already has many of the technologies needed, but too few survive the transition from pilot stage to industrial operation. The most critical barriers identified include:

• Limited financing for pilot and first‑of‑a‑kind (FOAK) plants, particularly in capital‑intensive areas such as rare earth processing, magnet manufacturing, and advanced recycling.
• Fragmented regulatory practices, especially differing interpretations of waste status and cross‑border transport rules, which slow down circular value chains for rare earth‑bearing waste streams.
• Permitting uncertainty, where timelines and administrative capacity vary widely across Member States despite fast‑track provisions under CRMA.
• Insufficient transparency and traceability, limiting efficient collection and recycling of permanent magnets at end‑of‑life.
• Social acceptance challenges, particularly in primary extraction, where delays linked to community concerns can exceed financial or technical risks.

At the same time, the absence of explicit marketpull instruments or offtake commitments risks delaying deployment, underlining the need for complementary demandside action to anchor investment and enable scaleup. With less than five years to 2030, these implementation bottlenecks represent the most significant threat to achieving CRMA benchmarks.

Rare earths and magnets at the core of CRMA implementation

Rare earth elements and permanent magnets sit at the intersection of multiple CRMA objectives. Compared with many other critical raw materials, they combine exceptionally high strategic importance, strong global supply concentration, limited substitutability, and technically demanding recycling and processing pathways. Also primary extraction and domestic processing remain necessary in the medium term to meet rapidly growing demand.

Forhighlights the importance of:

• De‑risking industrial scale‑up for magnet recycling, separation, and processing technologies. From REMHub’s perspective, de‑risking must also cover investments and business models, as scale‑up is often constrained more by risk allocation and bankability than by technological maturity.
• Mandating product‑level information for devices containing permanent magnets, aligned with Digital Product Passport initiatives and CRMA Article 28. REMHub notes that while such measures will not yield immediate efficiency gains, they are essential for mid‑term impact by enabling much needed efficiency in sorting, and scalable recycling systems.
• Strengthening data and exploration capacity, including interoperable geological data and standardised waste‑stream specifications for rare‑earth‑bearing materials. From REMHub’s perspective, economically viable recovery of secondary raw materials will often depend on multi‑material approaches, requiring aligned technologies, downstream offtakers, and business models, underpinned by standardised data to reduce uncertainty across the value chain.

All three priorities address the same challenge: creating the enabling conditions, data, risk‑sharing, and market clarity, needed to turn technological capability into industrial reality. Without targeted action in these areas, Europe risks remaining dependent on external supply chains despite strong regulatory ambition.

REMHub Digital Platform bridging innovation to policy

For REMHub, these policy conclusions closely align with its mission to connect innovation, implementation, industry, and policy across the rare earth and permanent magnet ecosystem. At the core are critical decision points where investors, industrial partners, offtakers, and public authorities decide whether to move forward with deployment.

Successfully passing these points requires reliable data, predictable permitting and financing conditions, effective risk‑sharing, and credible long‑term demand. This, in turn, depends on stronger links between research and real industrial projects, closer engagement with end‑user companies, long‑term offtake arrangements, and public tools that help shape markets. It also requires better information and traceability for products containing permanent magnets, as well as early and meaningful stakeholder engagement across the value chain.

To support these efforts and the implementation needed to achieve CRMA targets, REMHub is launching a digital platform in autumn 2026 for service providers active in rare earth elements and permanent magnets. The platform is designed to strengthen transparency, coordination, and access to implementation‑relevant capabilities across the ecosystem.