With the Critical Raw Materials Act, the “RESourceEU” action plan, and a growing network of strategic projects, the EU is attempting to counteract this trend – with growing ambition, but also with structural gaps.

The EU currently classifies 34 raw materials as critical. Of these, 17 have been placed on a list of strategic raw materials for which demand is expected to grow exponentially and supply bottlenecks are considered particularly likely. The list is updated regularly and forms the basis for all further EU measures in this area.

China’s Export Restrictions as a Wake-Up Call

Europe’s structural dependence on Chinese processing capacities has long been known – yet its practical consequences are only now becoming fully apparent. In recent years, Beijing has deliberately introduced export restrictions on strategically relevant metals:

• Gallium and germanium: Subject to licensing requirements since 2023 – both are central to semiconductors and specialty electronics
• Tungsten, tellurium, bismuth, molybdenum, and indium: Part of Chinese export control measures since February 2025
• Rare earths: Since April 2025, seven of the seventeen rare earths have been subject to a Chinese licensing requirement

In its Special Report 04/2026, the European Court of Auditors describes this as a serious threat to EU supply security.

RESourceEU: The Commission’s Action Plan

In response, the European Commission adopted the “RESourceEU” action plan in December 2025. It relies on three central levers:

• Recycling and circular economy: In spring 2026, export restrictions on aluminum scrap and copper could be introduced in order to keep more secondary raw materials in Europe and make recycling more economically attractive
• Joint purchasing: A newly established European Centre for Critical Raw Materials is intended to consolidate market information, coordinate joint procurement, and act as a portfolio manager for resilient supply chains
• Strategic projects: By the end of 2025, 60 strategic projects had been approved – 47 within the EU and 13 in partner countries such as Ukraine, Greenland, and Canada, with a focus on battery materials such as graphite, lithium, cobalt, and nickel

Ambitious Targets, Structural Gaps

The targets set out in the Critical Raw Materials Act are ambitious: by 2030, the EU is to cover at least 10% of its annual demand for critical raw materials through domestic extraction and 40% through domestic processing. For rare earths, dependence on individual countries is to be reduced from 95% to 42%, and for gallium from 71% to 17%.

However, the European Court of Auditors urges sobriety: many of the approved strategic projects are still at an early stage of development, and offtake agreements are often lacking. As 2030 draws closer, time pressure on new projects is increasingly becoming a problem.

The Critical Gap: Smelting and Processing

In its analysis from October 2025, McKinsey identifies one structural weakness particularly clearly: even a mine developed under European management does little to enhance supply security as long as processing continues to take place in the existing supplier countries. The more smelting and processing capacities Europe builds up itself, the more resilient the industry becomes. Yet at present, these very capacities are in some cases even being dismantled due to insufficient profitability.

For thermal process technology and industrial furnace construction, this represents both a direct challenge and a clear opportunity: anyone seeking to build up European processing capacities for aluminum, cobalt, or rare earths needs modern melting, heat treatment, and refining plants.

Conclusion

Europe has recognized that supply security for non-ferrous metals cannot be achieved through diplomacy and trade agreements alone. The Critical Raw Materials Act, RESourceEU, and the growing list of strategic projects are steps in the right direction. The decisive question, however, is not whether Europe has the right legislation – but whether it will succeed in building up smelting and processing capacities in time, before the next export restriction from Beijing once again throws supply chains off balance.

Further Information and Sources

• EU Council – Regulation on Critical Raw Materials (updated March 2026)

• European Commission – “RESourceEU” Action Plan (December 2025)

• European Court of Auditors – Special Report 04/2026

• GTAI – EU Selects Strategic Raw Materials Projects in Third Countries

• McKinsey Germany – Five Building Blocks of Secure Supply (October 2025)

• Austrian Academy of Sciences – ITA Dossier No. 80 (February 2025)