[Regulatory Update] EU designates products, components and waste streams subject to critical raw material recovery — giving concrete shape to the CRMA's circular-recovery rules
The CRMA covers not only supply security for critical raw materials but also mechanisms to improve resource efficiency and circularity within the EU. This implementing regulation, adopted in May 2026, sets out concrete rules for that circularity dimension by establishing a list of products, components and waste streams with recovery potential, and marks a milestone showing the CRMA's move into practical resource-circulation implementation. Recovery of critical raw materials from end-of-life products and waste — not just mining and imports — is increasingly being institutionalised as part of the EU's resource policy, making it more important for companies to factor in the recoverability of critical raw materials at every stage of product design, collection and recycling. Rather than the 2024-era framing of "the CRMA has launched," it is more accurate to understand this on a timeline in which the enacted framework is being developed into implementing rules through 2026.
Related Regulation Information
EU Critical Raw Materials Act (CRMA)
The Critical Raw Materials Act (CRMA, Regulation (EU) 2024/1252) is an EU regulation aimed at reducing dependence on external suppliers — particularly excessive reliance on specific countries — for the 34 critical raw materials and 17 strategic raw materials (including lithium, cobalt, nickel, and rare earth elements) needed for clean technology, electric vehicles, digital, and defense industries, thereby strengthening supply chain resilience and security. It sets clear domestic benchmarks for 2030 (10% extraction, 40% processing, 25% recycling, and no more than 65% of any single raw material sourced from a single third country), together with an accelerated permitting process for strategic projects, mandatory supply chain risk assessments (stress tests) for large companies, and disclosure requirements for recyclability and recycled content in products containing permanent magnets (such as neodymium magnets).
See this regulation's full analysis (timeline & business impact)💡 The overview and schedule for the regulation related to this article can also be found on the Regulatory Gateway Database page.
