EU RESourceEU Action Plan – What It Means for Investors and Industry

The European Commission’s RESourceEU Action Plan sets out an accelerated execution framework for the EU’s critical Raw Materials Strategy, building on the Critical Raw Materials Act (CRMA). Its central goal is to reduce strategic dependencies and secure diversified, resilient supply chains for critical raw materials (CRMs) essential to clean tech, digital, defense, and industrial competitiveness. The Plan combines market-based mechanisms, regulatory streamlining, targeted funding, stockpiling, circularity/recycling measures, and international partnerships.

Companies in the EU that supply or depend on crisis-relevant goods – such as CRMs – must increasingly prepare for crisis- and wartime-economy interventions affecting their supply chains and contractual relationships. This makes a proactive Supply Chain Risk Compliance Strategy imperative.

Core objectives and targets

The Action Plan aims to accelerate the CRMA’s existing objectives for the EU’s supply security. Under the CRMA, the EU should – by 2030 – reach the capacity to extract 10%, process 40%, and recycle 25% of the strategic raw materials it consumes, and strategic raw materials sourced from a single third country should not surpass 65% of the EU’s total consumption. While all critical raw materials can benefit from the Action Plan, the Commission emphasizes that the immediate focus is on rare earth permanent magnets, battery raw materials and defense-related raw materials due to their strategic relevance.

Policy instruments and how the EU will deliver

The Action Plan is structured around six pillars: (1.) the establishment of a European Critical Raw Materials Centre, (2.) promoting and accelerating priority projects, (3.) circularity/recycling and innovation, (4.) creating a lasting critical raw minerals market, (5.) single market protection and supply chain resilience, and (6.) partnering with third countries:

European Critical Raw Materials Centre

• The Commission plans to establish a European Critical Raw Materials Centre in 2026, which is supposed to function as the system orchestrator and portfolio manager for EU CRM diversification.
• According to the Commission, it will build market intelligence, steer financing to priority projects, coordinate joint purchasing and strategic stockpiles, monitor project delivery, and facilitate CRM access through demand aggregation and potential price-support mechanisms.
• Legislative proposals are announced to follow to equip the Centre with the necessary legal powers.

Promoting and Accelerating Priority Projects

• The Commission plans to coordinate today’s existing but fragmented funding sources for CRM-related projects, aiming for overall coherence. Within this context, the Commission announces the setting up of a CRM financing hub tasked with coordinating “strategically funding support, [providing] technical assistance to project promoters and national administrations and [accelerating] projects development” along the value chain. The coordinated instruments include: InvestEU, the Innovation Fund, the Battery Booster, and the European Defence Industry Programme (EDIP).
• The Commission expects to mobilize around EUR 2 billion in 2026–2027 within InvestEU. The Innovation Fund will dedicate at least EUR 700 million in 2026 to clean tech manufacturing and CRM supply chains, with an integrated approach that prioritizes projects backed by diversified or EU domestic offtake agreements. The Battery Booster will fund CRMs projects relevant to the battery value chain with up to EUR 300 million. For the EDIP, which addresses the Union’s highly prioritized Security of Supply (SoS) of defence equipment, the Commission plans to work with EU member states to make CRMs funding priorities.
• As part of the so-called “Team Europe approach”– which aims to coordinate development contributions by the EU, its member states, the European Investment Bank (EIB), and the European Bank for Reconstruction and Development (EBRD) – the Action Plan sets the target to mobilize a total of EUR 3 billion within the next 12 months in support of the CRMs value chains.
• In order to accelerate permitting for CRMs projects, the Commission announces that it will revise existing legislation, propose new legislation, provide a guidance document, and generally provide support and guidance to companies. Specifically and among other things, the Commission will put forward a proposal on environmental permitting acceleration which will include provisions on the acceleration of CRMs projects. Moreover, the Commission will publish a guidance document in Q1 2026 on environmental permitting (including mining sector-related aspects) aimed at increasing synergies between the Water Resilience Strategy and the CRMA, thereby enabling easier and faster compliance. The Commission also referenced the announced revision of the REACH regulation and a potential revision of the Carcinogens, Mutagens and Reprotoxic Substances Directive (CMRD), directed at considering operational realities while upholding the highest level of safety and environmental standards.

Circularity/recycling and innovation

• Export restrictions will be proposed by Q2 2026 on rare earth permanent magnet scraps to keep feedstock in the EU; classification of lithium-ion batteries and black mass as hazardous waste in September 2026 will prohibit exports to non-OECD countries after that date, thereby increasing domestic availability for recyclers. The Commission announces that it will propose targeted measures on aluminium (and potentially copper) scrap with the aim of ensuring sufficient access to feedstock for European smelters and recyclers.
• Furthermore, the Commission proposes expanding the list of products under the CRMA containing permanent magnets for which there are labelling requirements directed at providing relevant information for recyclers. The Commission also proposes to include pre-consumer waste in recycled-content declarations (currently, only post-consumer waste is taken into account) to further stimulate secondary materials markets.
• Horizon Europe will launch EUR 593 million in 2026–2027 calls for CRM circularity, new production processes, process efficiency and substitution of CRMs with innovative materials, complemented by EUR 100 million in two European Innovation Council (EIC) Accelerator challenges.

Creating a lasting CRMs market

• The EU Energy and Raw Materials Platform’s Raw Materials Mechanism will enable demand aggregation, matchmaking and joint purchasing for rare earths, battery inputs and defense materials – improving price transparency, enabling SMEs to reach scale, and supporting offtake agreements.
• The Commission will assess to what extent price-floor-based mechanisms can unlock investment in EU processing and upstream extraction.
• A targeted CRMA amendment should, according to the Commission’s proposal, require large companies to carry out risk assessments of their supply chains and – as necessary – diversify their supply chains.
• The Commission and several EU member states will launch a pilot project on stockpiling by early 2026; the European Critical Raw Materials Centre is then meant to integrate the pilot’s activities when carrying out stockpiling operations.

Single market protection and supply chain resilience

• The Commission plans on using the toolbox provided by the Internal Market Emergency and Resilience Act (IMERA) – which will enter into force in May 2026 – to address challenges regarding the EU value chain. This toolbox includes the Commission’s ability to respond to “information requests on production capacities and stocks, supply chains disruptions or shortages” as well as “carry out joint purchases, mandate priority-rated requests and coordinate stockpiling distribution.” The Commission emphasizes that, together with the EU member states, it has already begun to test strategic supply chains and will carry out more joint exercises with the member states specifically on CRMs.
• The Commission also announces that it will integrate the CRMA’s Strategic Projects as “Projects or Programs of Union Interest” under the Foreign Direct Investment Regulation, which is meant to provide further control over CRM-related foreign investment in the EU on security grounds. According to the Commission, Chinese participation will be restricted in the Horizon Europe work program for 2026-2027; the Commission also encourages EU member states to take similar measures within their domestic CRMs funding programs.
• Furthermore, the Commission announces a “robust policy approach”, which includes trade instruments, to react to supply chain disruptions caused by third countries’ use of non-market instruments (such as price manipulation), leveraging the EU’s strengths like access to the Single Market. Through this, the Commission aims to ensure short-term access to CRMs in these scenarios.

Partnering with third countries

• The Action Plan highlights already existing partnerships and agreements with third countries in the field of raw materials and announces to move forward with international cooperation on CRMs. The Commission mentions that, apart from free trade agreements and Clean Trade and In-vestment Partnerships, “15 strategic partnerships on raw materials have been signed to date with resource-rich countries since 2021” and further expansion of the EU’s network is underway.
• According to the Commission, international partnerships seek to be mutually beneficial agreements that incorporate reinforcement of third countries’ capacities beyond extraction, cooperation on ESG standards, research and innovation, and integration of both parties’ value chains by supporting joint projects.
• Recently, a Memorandum of Understanding was concluded with South Africa (November 20, 2025) and negotiations with Brazil are ongoing. The Commission also announces that it will finance CRMs projects via the Ukraine Investment Framework. Finally, the Commission supports and announces to follow up on the G7 Critical Minerals Production Alliance and the G20 Critical Minerals Framework.

Practical implications and next steps for market participants

The near-term calendar is dense: the first matchmaking round is scheduled for March 2026; the CRM financing hub and the new Critical Raw Materials Centre will launch in 2026; export constraints on key secondary material and permitting reforms may follow soon after. Sponsors should align project documentation to EU offtake, ESG and diversification criteria; lock in priority access to the financing hub instruments; and calibrate timelines to CRMA permitting windows.

Companies in the EU that supply or depend on crisis-relevant goods – such as CRMs – must increasingly prepare for crisis- and wartime-economy interventions affecting their supply chains and contractual relationships. One such measure is the instrument of “priority-rated requests”, to be introduced by IMERA as of May 2026, in the event that the Council activates the “internal market emergency mode”. Within the framework of IMERA, this instrument represents a far-reaching interference with the freedom of contract for private companies. Unlike the original proposal set out in the Commission’s draft for IMERA – and in contrast to the more far-reaching “priority-rated orders” now introduced under the new EDIP Regulation, which can be imposed on suppliers of components or raw materials critical to the production of defense products, even against their will – suppliers of crisis-relevant goods under IMERA may still reject such priority-rated requests. However, should they accept these requests, this is likely to result in supply chain disruptions affecting their original customers. Although the European legislator acknowledges that this may give rise to liability concerns, no satisfactory mechanism for resolution is provided: any recourse against recipients of such orders is explicitly excluded. The same legal consequences are expected to apply to both priority-rated requests and priority-rated orders under the EDIP Regulation. Companies that may face disruptions in fulfilling their own delivery obligations due to the diversion of their suppliers of CRMs, should mitigate liability risks. This can be achieved through contractual clauses with customers and by integrating necessary contingency and crisis-response mechanisms into their corporate governance structures – as part of a proactive Supply Chain Risk Compliance strategy.

Downstream operators should conduct supply-chain risk assessments, define diversification pathways, and engage early on joint purchasing to secure volumes and improve pricing certainty. Banks and private credit providers can leverage public de-risking to structure project finance and revenue-backed financing. Anyone active in the field of CRMs is advised to familiarize themselves with the new economic environment early on to secure competitive advantages.