The European Union is shifting its critical raw materials strategy towards processing and recycling, with recycling accounting for the largest category of projects selected in the European Commission’s latest effort to strengthen domestic supply chains and reduce dependence on external suppliers.
Recycling Leads New Strategic Project Approvals
The European Commission selected 46 new Strategic Projects under the Critical Raw Materials Act (CRMA) in October. The portfolio comprises 19 recycling projects, 11 processing projects, eight extraction projects and eight integrated projects covering multiple stages of the raw-materials value chain.
The distribution highlights a broader change in EU industrial policy. Mining remains essential, but securing critical minerals also requires the capacity to process extracted resources and recover valuable materials from products at the end of their useful lives.
Access to lithium, copper, nickel and rare earths provides limited supply security if these materials must be exported for refining or Europe lacks the technology and infrastructure to recycle them domestically. Processing and recycling capacity therefore play a central role in determining how much of the raw-materials supply chain remains within Europe.
Netherlands, Germany and Poland Expand Recycling Capacity
The latest Strategic Project portfolio includes battery recycling, copper recovery, electronic-waste processing, aluminium recycling and the recovery of rare earths from magnets. The Netherlands received strategic designation for four recycling projects covering batteries, copper, aluminium and printed circuit boards, strengthening its position in the emerging secondary raw materials industry.
Germany’s selected projects combine recycling with mining and refining investments. Among them is AMG’s European Lithium Refining and Recycling Hub in Bitterfeld, which has received Strategic Project status.
In Poland, state-controlled copper producer KGHM plans to convert its Legnica copper operation into an integrated recycling metallurgical facility, connecting primary metal production with the recovery of secondary materials. These investments reflect growing recognition that Europe’s industrial competitiveness depends not only on access to mineral deposits but also on the ability to recover, refine and reuse materials.
CRMA Sets Targets for Extraction, Processing and Recycling
The EU’s Critical Raw Materials Act establishes specific capacity targets for 2030. The bloc aims to extract at least 10% of its annual consumption of strategic raw materials, process at least 40% and recycle at least 25% within the EU.
The legislation also seeks to ensure that no more than 65% of annual consumption of an individual strategic raw material, at the relevant processing stage, depends on a single non-EU country.
These targets are influencing investment decisions by positioning recycling and processing facilities as strategic industrial infrastructure rather than solely as waste-management or circular-economy projects. Strategic designation may also strengthen projects’ access to financing by allowing banks, industrial investors, EU institutions and national governments to consider their contribution to supply security alongside expected commercial returns.
Project Execution Remains the Main Challenge
Despite policy support, Strategic Project status does not eliminate construction and technology risks, exposure to commodity-price fluctuations or competition for suitable feedstock. Developers must still secure reliable supply contracts and demonstrate commercially viable operating models.
Europe’s critical-minerals debate has traditionally focused on whether new mines can secure permits and enter production. The latest CRMA project selection broadens that discussion to include the infrastructure needed to process minerals and recover materials already circulating in the economy. The long-term challenge is to build an integrated European raw-materials supply chain, connecting extraction with processing, recycling and industrial reuse while reducing dependence on external suppliers.
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