The Communication on the Clean Industrial Deal: A joint roadmap for competitiveness and decarbonization published on 26 February 2025 (CID), announced that the Commission will carry out a fact-finding exercise aimed at assessing the need for greater industry cooperation in the procurement, recycling, and re-use of key raw materials.
Background
Critical raw materials are vital to the EU's industrial competitiveness and its strategic objectives. This initiative contributes to enhancing the access to and the recycling and re-use of critical raw materials within the EU, building on the objectives of the Critical Raw Materials Act (CRMA). The CRMA underscores the significance of securing a sustainable and diversified supply of critical raw materials. On 25 March 2025, the Commission adopted a list of 47 Strategic Projects to boost domestic strategic raw material capacities.
This fact-finding exercise will also support the Commission’s efforts to promote joint purchasing of critical raw materials, including the system for demand aggregation to be set-up this year under the CRMA. It will focus on the following 14 critical raw materials, namely aluminium, beryllium, cobalt, copper, gallium, germanium, graphite, lithium, manganese, nickel, platinum, rare earth elements (REEs), titanium, and tungsten.
These raw materials are designated critical by the Critical Raw Materials Act, as they are of high importance for the EU economy and face great supply chains risks, due to the fact that extraction and initial processing is done in a small number of third countries. They are also seen as key for a competitive EU industry, including for both clean tech and the green transition (see this International Energy Agency assessment) and defence (see this NATO list).
Call for input
Market participants are invited to indicate specific areas of their business activities as regards the procurement, recycling and re-use of raw materials for which guidance from the European Commission would help their assessment under the EU competition rules of specific instances of cooperation with competitors, with a view to enabling such cooperation. Please send your input to COMP-RAW-MATERIALS@ec.europa.eu by 31 May 2025.
DG COMP will also proactively reach out to key stakeholders during this period. We also invite market participants to engage with DG COMP on a confidential basis about specific cooperation projects. The objective would be to exchange views on how to enable such cooperation to happen in compliance with the EU competition rules. Please contact us at COMP-RAW-MATERIALS@ec.europa.eu also for such confidential discussions.
Depending on the input received, DG COMP may engage with stakeholders in a targeted manner with questionnaires and may also organise a workshop to refine the insights collected on specific raw materials and industries.
As an outcome of this initiative, the Commission may, where appropriate, provide companies with guidance as to the compatibility of specific cooperation agreements in this field with the EU competition rules, such as a policy brief.