The Dual Challenge of Critical Raw Materials: Advancing the Green Transition Without Compromising Industrial Competitiveness

This article is part of our collaboration with International Policy Review at IE University. Photo Credits: Crédit Agricole

Abstract

This report examines the role of Critical Raw Materials (CRMs) within the context of SDG 12, the UN Sustainable Development Goal aimed at ensuring sustainable patterns of production and consumption. According to the emerging European narrative, CRMs are considered key resources for the ecological transition, as they are essential for the development of renewable technologies, electric mobility, and digitisation. However, their use presents a paradox: although they appear crucial for reducing global environmental impact, the extraction and processing of these materials generate significant environmental harm, conflicting with the sustainability goals of SDG 12. This paradox is further intensified by the phenomenon of outsourcing mining activities, which, although it reduces direct environmental impacts in Europe, shifts these impacts to countries with weaker environmental regulations. This also jeopardises the competitiveness of European industry, which faces protectionist policies from supplier countries, risks of supply disruptions, and potential price shocks. This raises the central question of the report: is it possible to reduce dependence on foreign CRM suppliers and enhance the competitive advantage of European industry without compromising the sustainability principles of SDG 12? To address this question, the report explores potential solutions, including increasing domestic extraction of CRMs in Europe, while considering the negative environmental impacts of mining. Several policy measures are suggested, such as promoting a stronger circular economy, investing in technological innovation, and diversifying supply sources. These actions could help mitigate the paradox, improve the competitiveness of European industry, and make the supply process of critical raw materials more sustainable.

Keywords: Critical Raw Materials (CRM), Green Transition, European Industry sector, Industry competitiveness, SDG 12.

1. Introduction

Sustainable Development Goal 12 (SDG 12) of the United Nations aims to ensure sustainable patterns of production and consumption. Breaking down this broadly inclusive assertion into its main components, SDG 12 primarily seeks to minimize the environmental impact of industrial processes -one of the key objectives of the 2030 Agenda. This goal can only be achieved through the efficient use of natural resources (item 12.2) and the reduction of waste in production (item 12.5), while ensuring that consumers are transparently informed about the sustainability of products (item 12.6).

This approach is essential to ensuring that economic growth remains compatible with the planet’s regenerative capacity.

Discussing sustainable production and consumption today inevitably involves addressing the debate that has emerged, particularly over the past two decades, regarding the management of Critical Raw Materials (CRMs, or critical minerals).

By definition, CRMs are commodities—non-food and non-energy—that possess two key characteristics: they are of strategic importance for the production of technologically sophisticated goods and for managing the ecological transition, and they carry a high supply risk. The European Union has recognized the growing importance of CRMs and has been regularly updating the list of these strategic elements since 2011. The European Commission’s Study on the Critical Raw Materials for the EU of March 2023 (Commission 2020) expands the list of Critical Raw Materials from 30 to 34 and introduces 17 Strategic Raw Materials essential to the ecological and digital transition.

These resources, in fact, have proven to be essential for the development of renewable technologies, electric mobility, and digitization – all central pillars of the ecological transition promoted by the European Green Deal. The paradox, however, lies in the fact that the extraction and processing of these raw materials generate significant environmental impacts, running counter to the principles of SDG 12.

1.1 Why focus on Critical Raw Materials?

In an analysis of SDG 12 progress, one might naturally expect a focus on how production patterns have become more sustainable in recent years or how sustainability regulations have influenced business practices, either improving them or creating new challenges. However, limiting the discussion to these aspects risks providing a partial perspective.

To fully grasp the implications of SDG 12 in the European industry sector, it is essential to address the contradictions that emerge when sustainable production models clash with the industrial and economic needs of European countries. The following sections will explain why the critical raw materials sector in Europe serves as a prime example of this contradiction.

1.1.1 Outsourcing pollution that the European Green Deal had not considered

The Green Deal, a package of policy initiatives launched by the EU in 2019 to drive the Green Transition, was designed to make European industry more sustainable. However, recent debates have highlighted how stringent environmental regulations and high compliance costs have not truly reduced Europe’s environmental impact but have merely shifted it elsewhere. Many companies, in response to rising production costs, have relocated their operations to countries with lower environmental standards. This phenomenon, known as carbon leakage, represents one of the “grey areas” within the directives outlined by SDG 12. A particularly telling example is the case of Critical Raw Materials: rather than developing a sustainable strategy for their management, Europe has become heavily reliant on imports from countries such as China, Turkey and the Democratic Republic of Congo. While this dependence reduces the direct environmental impact of extraction within Europe, it worsens the global one, as extraction and processing supply chains in exporting countries often operate under significantly lower environmental and social standards. In addition, as will be explained later in the report, Europe’s dependence on the importation of these materials from non-European countries significantly undermines the competitiveness of European industry. This dependence exposes Europe to unfair trade practices and protectionist policies from supplier countries, as evidenced by concerns over Chinese overcapacity. Moreover, there is a risk of supply disruptions and potential price fluctuations, which could further destabilize European industrial sectors.

1.1.2 CRM extraction in Europe: a solution or another problem?

Within the ongoing debate on this issue, some argue that, to reduce dependence on foreign suppliers and secure a competitive advantage in the Green transition, the EU should increase the extraction of Critical Raw Materials within its own territory. However, this raises a new problem: mining activities are among the most environmentally damaging. Opening new mines in Europe would lead to greater local ecological impacts, creating a conflict between the goal of making supply chains more sustainable and the reality of a highly polluting mining sector.

1.1.3 The real interests behind the CRM debate

Finally, although increasing local sourcing of Critical Raw Materials is often presented as an essential component of the Green transition and integrated into the Green Deal narrative – enjoying broad political support – some argue that this rhetoric is actually shaped by industrial interests unrelated to, or even at odds with, the EU’s climate goals. Sectors such as aerospace and defense may have opportunistically leveraged the CRMA debate, influencing regulations to promote greater extraction in Europe, regardless of the actual environmental consequences. The emerging risk, then, is that the Green Deal is being instrumentalized to justify resource extraction not for the Green transition, but to serve traditional industrial demands.

In light of the previous points, this report explores how to consistently apply SDG 12 to the Critical Raw Materials sector. The goal is to identify a realistic balance between the need to enhance the competitiveness of European industry and the large-scale adoption of low-impact industrial practices. The central question is: is it possible to reduce dependence on foreign CRM suppliers and enhance the competitive advantage of European industry without compromising the sustainability principles of SDG 12?

To address this question, the following aspects will be analyzed:

The competitive crisis of the European industrial sector, caused not only by a lack of investment in innovation but also by overly strict environmental regulations that increase production costs;
The debate between those who advocate for domestic extraction of CRMs and those who highlight the associated environmental risks;
Potential policies to safeguard European industrial competitiveness while reducing environmental impact, through recycling, increased investment in technological innovation, and diversification of supply sources.

Striking a balance between industrial competitiveness and sustainable production is perhaps the most pressing challenge Europe has faced in recent decades.

This report delves into the crucial debate on Critical Raw Materials in European industry, concluding with policy recommendations that align their management with the objectives of SDG 12, avoiding contradictions that could undermine their credibility and effectiveness in the ecological transition.

2. The Crisis of the European Industry

2.1 Rising costs and falling production

Before delving into the debate on Critical Raw Materials, it is essential to consider the broader context in which this discussion takes place. The European manufacturing industry is currently facing a crisis that has persisted for nearly a decade.

This structural decline—characterized by high energy costs, delays in technological innovation, and regulatory fragmentation—is neither new nor poorly documented.

Europe’s reliance on foreign energy has made energy costs up to three times higher than in the United States and China, undermining the competitiveness of the manufacturing sector. In the automotive industry, which accounts for 6.1% of European employment, supporting 13.8 million direct and indirect jobs, production costs are approximately 30% higher than in China, prompting many automakers to relocate. This offshoring has already led to a 40% reduction in jobs in countries such as Italy and France.

The automotive crisis is mirrored by the steel crisis: due to low demand, high energy costs, and overcapacity outside Europe, European steel production has declined by 30% since 2008, resulting in the loss of nearly 100,000 jobs over the past 15 years.

The slowdown has affected the entire industrial sector: in September 2024, industrial production fell by 2% compared to the previous month and by 2.8% year-on-year. Since 2019, Germany has seen a decline of more than 9% in industrial production, followed by France (-5%) and Italy (-3.5%). Overall, the EU has lost 853,000 manufacturing jobs over the past five years, while the United States (+1.9%) and China (+5.5%) continue to experience growth.

2.2 Europe lags behind in research and innovation

However, the competitiveness of European industry is threatened by another deeply rooted weakness: underinvestment in Research and Development.
In 2021, European companies invested 270 billion euros less in R&D than their U.S. counterparts, where the technology sector leads investment.

In his latest report on European competitiveness, Mario Draghi issued a warning to the European Commission: without a change of course, EU competitiveness is set to collapse. Bureaucracy and fragmented regulations block the transition from innovation to commercialization, stifling industrial growth. Europe’s leading industrial associations (Confindustria, Medef, and BDI) have also raised the alarm: without structural interventions, Europe risks irreversible deindustrialization, undermining its entire economic system.

2.3 The import of Critical Raw Materials is another key issue in the crisis

In addition to energy costs and technological lag, the fragility of Critical Raw Materials’ supply chains represents another risk factor. Since 2011, the EU has expanded its list of strategic materials from 14 to 34 elements, yet it continues to rely heavily on countries outside Europe, especially China, which refines 60% of the world’s lithium, more than half of manganese and cobalt, and 90% of the rare earths critical for green and digital technologies.

3. The Debate on Critical Raw Materials

3.1 CRMs’ increasing importance in the European debate

Ambrosetti’s 2023 study for Erion updates the mapping of key sectors that depend on CRMs: 29 out of 34 are critical for the energy industry, 28 for aerospace, 24 for electronics, 23 for automotive, and 19 for renewable energy.

Despite variations in classification, the core group of CRMs includes elements such as cobalt, graphite, lithium, manganese, nickel, copper, and titanium, as well as rare earths.

These materials are widely used in high-tech and low-carbon products and are increasingly essential for manufacturing batteries, electric motors, and permanent magnets—all key components for managing the ecological transition.

Future demand for CRMs such as cobalt, graphite, nickel, copper, and titanium within the EU is projected to grow exponentially in the coming decades, with estimates indicating that demand will double by 2030.

3.2 Europe’s lack of autonomy in the supply and refining of CRMs

However, Europe is almost entirely dependent on foreign countries for the supply and processing of these essential resources, most of which are imported from non-EU countries, many of them geopolitically unstable.

Italy is the most exposed country, with dependence on non-EU supplies increasing by 22% in one year, reaching 686 billion euros (38% of GDP). It is followed by Germany (33%), Spain (23%), and France (10%). The most affected sectors are energy (dependent on imports for 29 out of 34 CRMs), aerospace (24), automotive (23), and renewables (19).

This situation gives rise to several potential risks: first of all, many of the countries the EU relies on for the supply of CRMs rank poorly in terms of governance. This includes aspects such as political stability, levels of corruption, protection of intellectual property, and the enforceability of contracts. Among the many implications, one stands out in particular: a heightened risk of supply disruptions in importing countries.

There is also the growing possibility that these supplier countries will increasingly impose restrictions on exports, a trend that is already unfolding. Some may even choose to coordinate their actions to reinforce their market power.

China, which controls 65% of global production and most of the refining capacity for these materials, recently imposed export restrictions on germanium, gallium, graphite, and rare earth technologies, limiting European access to materials essential for batteries, microchips, wind turbines, and semiconductors.

Finally, demand for these materials is not only high but continues to grow. The constant rise in demand, combined with the possibility that supply will fail to keep up due to disruptions in the supply chain, leads to high volatility in the prices of imported CRMs.

To mitigate this vulnerability, the European Commission launched the Critical Raw Materials Action Plan in 2020, structured around five key pillars: developing domestic capacity (through the creation of the European Raw Materials Alliance), promoting the circular economy, diversifying global supply sources, strengthening the resilience of supply chains, and restricting CRM imports by EU countries.

In addition, the EU passed the Critical Raw Materials Act in 2023, which imposes a 65% cap on imports from a single country by 2030, requires that 10% of needs be met through domestic extraction and 40% through processing, and sets a recycling target of 15% for CRMs. However, demand for strategic elements such as neodymium and dysprosium is expected to exceed supply as early as 2030, making investment in refining technologies, diversification of supply sources, and development of domestic industrial capacity essential.

Nevertheless, achieving these goals is hindered by insufficient investment, bureaucratic delays, and slow implementation of national strategies. China continues to dominate the refining of many critical CRMs, controlling 60% of the world’s lithium, more than half of global manganese and cobalt production, and 90% of rare earths. In Italy, the National Table for Critical Materials, established in 2021, only became operational in 2022, with limited progress. Difficulties in launching new mining and infrastructure projects further constrain the EU’s ability to achieve self-sufficiency, making supply security an ongoing challenge.

3.3 The hidden paradox of Critical Raw Materials: for whom and for what?

From what has been said so far, it emerges that the European Union is at a crucial crossroads in its strategy to secure supplies of critical raw materials.

Against this backdrop, the Critical Raw Materials Act (CRMA) has been met with an unusual level of political consensus. However, a significant portion of those involved in the CRM debate express doubts about the prevailing narrative.

It has been highlighted that, although CRMs are essential for reducing emissions, deep contradictions emerge behind the rhetoric of their necessity to align with the Green Deal. Indeed, their extraction is notorious for causing severe pollution.

The growing consensus on the need to ensure Europe’s stable supply of minerals critical to the climate transition has restored legitimacy to the mining industry, despite its significant environmental impact and the massive greenhouse gas emissions it generates.

According to these critics, the CRMA, rather than prioritizing materials essential for the climate transition, has been shaped by industrial pressures, particularly from the aerospace and defense sectors – industries with little connection to the energy transition but keen on mining deregulations. The industry lobbied for the metals it was interested in to receive the same public support and environmental exemptions as those genuinely crucial for the climate transition. Some large companies in the sector, such as Airbus, Safran, and ASD, played an active role in all stages of the CRMA legislative process, influencing decisions through meetings with policymakers, events, and often opaque working groups.

The result? The inclusion of metals such as aluminum and titanium on the official list—materials critical to these industries but with a marginal impact on the green transition.

Other criticisms argue that the CRMA grants incentives and environmental deregulations to the mining industry in an overly permissive manner, failing to distinguish between strategic and more controversial uses. It does not impose constraints on the use of extracted raw materials or provide adequate monitoring of environmental impacts. It also authorizes mining projects even in protected areas and on the seabed, neglecting social and ecological consequences.

There is a risk that, under the guise of energy security and the green transition, the EU may grant carte blanche to mining companies and large industrial groups, paradoxically sacrificing its own climate and social ambitions. Without clear criteria and constraints on resource use, the CRMA could make the Green Deal more costly and unpopular, with devastating impacts on communities affected by extraction.

From another perspective, Europe’s race for raw materials risks perpetuating neocolonial dynamics in resource-rich countries, often former colonies. Rather than fostering sustainable development, extraction has historically fueled conflict, corruption, and poverty. Many states reliant on mineral exports remain trapped in the “resource curse,” unable to diversify their economies and provide prosperity for local communities.

4. How to Improve the Competitiveness of European Industry Without Compromising the Principles of SDG 12

The policy framework on which this contribution intends to focus specifically concerns Critical Raw Materials, and the goal would be to meet the growing demand for CRMs while keeping the principles of SDG 12 at the core.

The European Union is not starting from scratch: in recent years, it has introduced a number of regulations and strategies aimed at building a more efficient and sustainable model for the sourcing and use of these materials. However, as highlighted in the previous sections, these initiatives have failed to effectively address the core challenges.

It is therefore essential to ask what the real obstacles are that continue to hinder the EU’s effective management of CRMs, particularly in terms of procurement.

The Critical Raw Materials Action Plan aims to strengthen domestic extraction capacity, promote a circular economy across Europe, and diversify global supply sources. The Critical Raw Materials Act (2023), on the other hand, introduces binding targets: by 2030, each Member State will be required to meet specific thresholds for reducing imports and for the share of materials to be extracted, processed, and recycled within its territory.

Both plans, however, share some structural weaknesses. Five recurring and interconnected issues can be identified that have limited their impact. The following sections will analyze each of these in turn, accompanied by brief policy recommendations aimed at addressing their root causes.

4.1 Promoting in-sourcing, but setting sectoral priorities

It seems well established that the first step to improving the competitive position of European industry is to drastically reduce its dependence on foreign suppliers of CRMs. The Critical Raw Materials Action Plan began to outline a path in this direction, and the Critical Raw Materials Act has provided even more detailed guidance to achieve a significant reduction in imports and to increase domestic production capacity. However, one of the main limitations of both plans in this regard is the absence of clear criteria for setting sectoral priorities: all industries can, in theory, demand access to CRMs without distinction. By contrast, China’s strategy bases part of its competitiveness precisely on the active protection of sectors deemed strategic. For Europe, a relevant example could be the automotive industry.

This lack of selectivity risks generating fragmented and cross-sectoral demand, preventing resources from being directed to supply chains with higher strategic value or greater sustainability. It also opens the door to opportunistic lobbying dynamics. This is precisely what fuels much of the opposition to the opening of new mines in Europe: rather than a generalized criticism of mining per se, it challenges the instrumental use of the Green transition by industrial sectors that have little to do with it but invoke it to justify new mining projects.

To counter this risk, the establishment of an independent body tasked with identifying and ranking the highest-priority industrial projects along the CRMs value chain would be desirable.

At the same time, to avoid abuse by certain sectors, authorized mining projects should be subject to continuous monitoring (made transparent through easily accessible and interpretable data) and demonstrate, within five years, a positive carbon payback – i.e., a favorable balance between emissions avoided through the supported technology and those generated by mining.

Finally, to ensure that access to CRMs is reserved for sectors genuinely committed to reducing their environmental impact, a European system of credit-based permits could be introduced. Companies would acquire credits by developing recycling or substitution technologies and lose them if they fail to meet specific targets for reuse or consumption reduction per unit of output.

4.2 Investment protection

Another major problem is the lack of a common and mandatory Europe-wide system for evaluating investments in industrial projects related to Critical Raw Materials. To date, these assessments remain fragmented and uncoordinated, which contributes to the perception of such projects as excessively risky by investors, particularly due to regulatory uncertainty and lengthy approval processes. In addition, the absence of clear rules increases the risk that funds may be perceived as poorly managed or subject to political interference.

In essence, the current regulatory framework does not offer sufficient safeguards to mitigate the risks associated with these investments.

A virtuous example in this regard comes from Japan, a country like ours that is heavily dependent on imports. Despite limited domestic resources, Japan has responded with a far-sighted and efficient strategy: it has established the Japan Organisation for Metals and Energy Security (JOGMEC), a public agency that strategically coordinates the country’s supply chain. JOGMEC does not leave the responsibility solely to the private sector: it invests directly in mining and refining activities abroad, manages strategic reserves and develops domestic material processing facilities. It also supports the entire supply chain through subsidies, equity investments and debt guarantees, promoting exploration, recycling and resilient supply chains. The European Union could draw inspiration from this model. Reducing administrative burdens and setting clear, context-specific targets for each Member State would be an important step forward. The creation of a joint public-private platform with effective de-risking tools would be a decisive step.

Among these tools, the adoption of a standardized system for investment appraisal would be particularly strategic, helping to reduce uncertainty and make projects more easily comparable. Such a system should integrate criteria related to industrial autonomy, technical and economic feasibility, alignment with national priorities, and environmental and social sustainability.

4.3 Providing incentives for circularity

The Critical Raw Materials Act sets recycling and substitution targets but fails to provide sufficient incentives to achieve them. EU trade policy continues to rely heavily on large-scale imports of cheap, unprocessed raw materials, subject to minimal import tariffs. This, combined with the lack of targeted support for secondary sourcing, ultimately discourages recycling. Additionally, circularity directives are sometimes redundant and, in certain cases, even conflict with one another. As a result, businesses face an unclear regulatory environment and struggle to see tangible benefits in adopting circular solutions or using alternative materials. Consequently, the use of virgin raw materials, particularly imported ones, often remains the most cost-effective option. To address this gap, the regulatory framework should actively incentivize both post-consumer waste recycling and the recycling of production residues. Future amendments should place a stronger emphasis on encouraging investment and providing public support for research in areas such as circularity, design for reuse, and materials substitution.

4.4 Strengthening the enforceability of CRM policies

In addition to the lack of a clear hierarchy among priority sectors and adequate investment incentives, another critical issue with the plan lies in its non-binding nature: it is presented as a roadmap without legal force, rather than as a truly enforceable strategy. The absence of an enforcement mechanism at the supranational level undermines its implementation, which remains slow and fragmented. Ultimately, decision-making power rests with individual Member States, which are responsible for authorizing projects and directing investments. However, this decentralization has so far failed to yield significant results in the management of CRMs.

To overcome this impasse, the establishment of a new independent executive agency at the EU level, equipped with a binding mandate to accelerate the approval of strategic projects—such as refining and recycling plants, and battery and semiconductor supply chains—would be desirable.

This agency should be empowered to activate override clauses if a Member State obstructs an initiative of cross-border relevance or of critical importance to European resilience, provided that the project guarantees a neutral or positive environmental impact in the medium term.

To avoid the bureaucratic paralysis that has thus far slowed down the system, the agency’s primary objective should be to streamline the permitting process. In particular, emergency procedures should be completed within a maximum timeframe of 6 to 12 months.

4.5 Asymmetry of bargaining power between the EU and the Global South on Raw Materials 

This final section steps away for a moment from the question of European industrial competitiveness to turn our gaze outward, towards those countries beyond our borders that have until now been indispensable to us for the supply of Critical Raw Materials. The outsourcing of these resources, in fact, also poses challenges for exporting countries, due to a number of interconnected factors. A structural issue lies in the asymmetry of bargaining power between the EU and raw material-exporting countries, mostly in the Global South. This imbalance often results in agreements that favor European access to cheap resources, at the expense of regulatory sovereignty, environmental protection, and local community rights in partner countries. Among the key factors driving this dynamic is the Investor-State Dispute Settlement (ISDS) mechanism, which allows European companies to directly sue partner governments when environmental policies or local opposition threaten their profits. This fear of litigation often leads governments, especially in developing countries, to avoid adopting or enforcing environmental and social regulations. This hinders sustainable development policies and local value creation: CRM-producing countries such as Namibia and Indonesia, which lack the necessary legal and financial resources, tend to avoid legislation or negotiate from a position of weakness. This asymmetry weakens the ability of these countries to exercise regulatory self-determination, particularly with respect to fundamental issues such as decent work, environmental protection, and consultation with indigenous communities. A potential reform would be to exclude ISDS from Critical Raw Materials chapters in trade agreements, replacing it with a more balanced, multilateral dispute settlement mechanism. This approach should include binding environmental and human rights obligations, local community participation in impact monitoring, and independent assessments of mining projects.

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