Review Cycle and Updates
The EU Critical Raw Materials Act mandates periodic review and revision of both the critical and strategic raw materials lists. This page explains the assessment methodology, the consultation process, the review timeline, and the history of how the lists have evolved across multiple assessment cycles.
Mandated Review Schedule
The CRMA requires the European Commission to review and, if necessary, update the lists of critical and strategic raw materials at least every four years. This schedule aligns with the EU's broader policy planning cycles and allows sufficient time for the Joint Research Centre (JRC) to conduct the extensive data collection and analysis required for a comprehensive reassessment. The Commission may also initiate an ad hoc review if significant market disruptions, geopolitical events, or technological developments warrant an earlier reassessment.
The four-year cycle represents a slight extension from the roughly three-year cadence that the Commission maintained informally between 2011 and 2023. The longer cycle under the CRMA reflects the greater complexity of the assessment now that the lists carry binding legal consequences. Each review cycle must include a full stakeholder consultation, an impact assessment, and formal adoption through a delegated act, all of which add time to the process compared to the earlier non-binding assessments.
The Assessment Methodology
The European Commission's criticality assessment methodology has been developed and refined by the Joint Research Centre over more than a decade. The current methodology evaluates each candidate material across two primary dimensions: economic importance (EI) and supply risk (SR). Each dimension is scored on a continuous scale, and materials that exceed thresholds on both dimensions are classified as critical.
Economic importance is calculated by mapping each material to its end-use sectors using the NACE industrial classification system, then weighting each sector's contribution to EU gross value added. A material used primarily in high-value-added sectors such as aerospace, semiconductors, and automotive receives a higher EI score than one used predominantly in lower-value-added applications. The methodology also considers the substitution index, which assesses the technical and economic feasibility of replacing the material in each of its major applications.
Supply risk is a composite measure incorporating several factors. The Herfindahl-Hirschman Index (HHI) measures the geographic concentration of global production. This concentration metric is adjusted by the World Governance Indicators (WGI) for each producing country, which assess political stability, regulatory quality, rule of law, and control of corruption. The adjusted HHI is then modified by factors including the EU's import reliance, the existence of trade barriers, and the end-of-life recycling input rate (EOL-RIR), which captures the extent to which secondary materials can offset primary supply needs.
Data Collection and Validation
The JRC maintains an extensive database of material flow data, trade statistics, and production figures that forms the empirical foundation of each assessment cycle. Primary data sources include the European Commission's Eurostat trade database, the USGS Mineral Commodity Summaries, the British Geological Survey's World Mineral Production reports, and the World Mining Data published by the Austrian Federal Ministry of Finance. Production data is cross-referenced across multiple sources to ensure accuracy and completeness.
Substitution data is gathered through targeted consultations with industry experts, academic researchers, and sector-specific associations. The JRC conducts workshops and surveys to assess the current state of substitution technology for each candidate material, considering factors such as the technology readiness level of potential substitutes, the cost premium associated with switching, and any performance trade-offs. This qualitative input is integrated into the quantitative model through a structured scoring framework.
Recycling data is sourced from Eurostat waste statistics, industry reports, and targeted studies commissioned by the JRC. The end-of-life recycling input rate represents the share of EU material demand that is met by secondary (recycled) materials. This metric has proven challenging to calculate accurately for many materials due to gaps in waste tracking data, the complexity of multi-material products, and the difficulty of distinguishing between functional recycling (where the material is recovered in its elemental form) and non-functional recycling (where it is downcycled into lower-value applications).
Stakeholder Consultation Process
Each review cycle includes a formal stakeholder consultation conducted in accordance with the Commission's Better Regulation guidelines. The consultation typically spans 12 weeks and is open to all interested parties, including EU member state governments, mining and processing companies, manufacturers, industry associations, environmental organizations, academic institutions, trade unions, and individual citizens.
The consultation is structured in two phases. The first phase solicits general input on the scope of the assessment, the list of candidate materials to be evaluated, and any changes to the methodology that stakeholders believe are warranted. The second phase presents the preliminary results of the criticality assessment and invites comment on the proposed updated lists. Stakeholders may submit factual corrections, alternative data, methodological critiques, and policy arguments for or against specific material designations.
The Commission publishes a synopsis report summarizing the consultation responses and explaining how stakeholder input was incorporated into the final assessment. In past cycles, stakeholder consultation has led to meaningful changes, including the addition of materials that the quantitative model scored near the threshold and the refinement of substitution indices based on industry-provided technical data.
History of List Evolution
| Assessment Year | Number of CRMs | Notable Additions |
|---|---|---|
| 2011 | 14 | First list: REEs, antimony, cobalt, fluorspar, gallium, germanium, graphite, indium, magnesium, niobium, PGMs, tantalum, tungsten, beryllium |
| 2014 | 20 | Borates, chromium, coking coal, magnesite, phosphate rock, silicon metal |
| 2017 | 27 | Bismuth, hafnium, helium, natural rubber, phosphorus, scandium, vanadium |
| 2020 | 30 | Bauxite, lithium, strontium, titanium |
| 2024 (CRMA) | 34 CRMs + 17 SRMs | Copper, arsenic, feldspar, manganese, nickel; first strategic designation |
From Non-Binding Assessments to Binding Law
The most consequential change in the review process is the transition from non-binding Commission communications to binding legislation. Prior to the CRMA, the critical raw materials list was published as a Commission communication with no direct legal effect. The designations informed policy discussions and prioritized research funding but did not trigger specific regulatory obligations or entitlements.
Under the CRMA, the lists are annexed to the regulation and carry full legal force. Updates to the lists are adopted through delegated acts, a legislative procedure that gives the Commission the authority to amend the annexes subject to oversight by the European Parliament and Council. This procedure ensures that list updates undergo appropriate political scrutiny while avoiding the lengthy ordinary legislative procedure that would delay responses to rapidly evolving supply conditions.
The binding nature of the lists also means that additions and removals have direct economic consequences. A material added to the strategic list becomes subject to the 2030 benchmarks, triggering investment decisions by industry and member states. A material removed from the critical list would lose eligibility for streamlined permitting and strategic project designation. These stakes make the review process more politically sensitive and increase the intensity of stakeholder engagement compared to the earlier non-binding cycles.
Future Review Expectations
The next scheduled review of the CRMA lists is expected to begin in 2027, with publication of updated lists anticipated in 2028. Based on current trends, several developments are likely to influence the next assessment. The continued growth in battery mineral demand may push additional materials toward the critical threshold. Advances in recycling technology could improve the end-of-life recycling input rates for materials such as lithium and rare earths, potentially lowering their supply risk scores. New mining projects in the EU and partner nations, if they achieve commercial production by 2027, could reduce import reliance for materials such as lithium and cobalt.
Geopolitical developments will also shape the next review. If China maintains or expands its export restrictions on critical materials, supply risk scores for affected materials would increase. Conversely, successful diversification through Strategic Partnerships and new projects in Africa, Latin America, and the Arctic could reduce concentration risk. The European Critical Raw Materials Board will play a central role in monitoring these developments between formal review cycles and advising the Commission on whether an ad hoc review is warranted before the scheduled 2028 update.