The EU is having difficulties securing the supply of the raw materials it needs to meet its energy and climate goals. This is the conclusion of a new report by the European Court of Auditors (ECA). EU action on import diversification is not producing tangible results, bottlenecks hinder domestic production, and recycling is still in its infancy. Against this backdrop, many EU-supported projects are unlikely to succeed in time, the auditors say.
The EU’s transition to renewable energy is heavily reliant on technical equipment such as batteries, wind turbines and solar panels, all of which require critical raw materials such as lithium, nickel, cobalt, copper, and rare earth elements. Most of these materials are currently concentrated in either one or a handful of non-EU countries such as China, Türkiye, and Chile. To address this vulnerability, the EU adopted its Critical Raw Materials (CRM) Act in 2024, with a view to ensuring a long-term secure supply of 26 minerals identified as critical for the energy transition.
“Without critical raw materials, there will be no energy transition, no competitiveness, and no strategic autonomy. Unfortunately, we are now dangerously dependent on a handful of countries outside the EU for the supply of these materials”, said Keit Pentus-Rosimannus, the ECA Member responsible for the audit. “It is therefore vital for the EU to up its game and reduce its vulnerability in this area.”
Securing the supply can be achieved through diversified imports, increased domestic production, and recycling. The CRM Act sets only non-binding targets by 2030, and these apply only to a small number of raw materials, regarded as ‘strategic’ due to their high economic importance and supply risks. It is also unclear how the levels to be reached by 2030 were determined. In addition, there is still a long way to go to meet the targets, the auditors say, and the EU will struggle to secure the supply of the strategic raw materials it needs by the end of the decade.
With the CRM Act, the EU has strived to reduce its dependency on a small number of individual countries. However, efforts to diversify imports have yet to produce tangible results, the auditors note. For instance, the EU has signed 14 strategic partnerships on raw materials over the last five years, seven of them in countries with low governance scores. Imports from these partner countries fell between 2020 and 2024 for around half of the raw materials examined. Some other EU actions are at a standstill, such as the negotiations with the USA which were paused in 2024, while others are yet to materialise, such as the EU-Mercosur agreement with CRM-rich Argentina, Brazil, Paraguay and Uruguay, which has still not been ratified by each EU country.
The CRM Act also envisages that at least 25 % of the EU’s strategic raw materials should originate from recycled sources by 2030. But the outlook is not promising: as things stand, 7 out of 26 materials needed for the energy transition have recycling rates between 1 % and 5 %, while 10 are not recycled at all. Furthermore, most EU recycling targets are not specific to individual raw materials. As a result, they fail to incentivise the recycling of individual materials – especially those that are harder to extract, such as rare earth elements in electric drives or palladium in electronics. They also fail to encourage the use of recycled materials. The auditors highlight that European recyclers suffer from high processing costs, the small quantities available, and technological and regulatory barriers which hinder their competitiveness.
The EU also aims to boost domestic extraction of strategic materials to cover 10 % of its consumption. But the reality is that exploration activities are underdeveloped. And even when new deposits are found, it can take up to 20 years for an EU mining project to become operational. This makes any concrete contribution by the 2030 deadline hard to imagine. Processing capacities – for which the EU aims to reach 40 % of its consumption by 2030 – are shutting down, partly due to high energy costs which can seriously hamper competitiveness. The EU may be trapped in a vicious circle, the auditors warn, where a lack of supply hinders the development of processing projects, which in turn reduces the impetus to secure supply.
Critical raw materials are economically important raw materials for which there is a high supply risk. The most recent list – embedded in the Critical Raw Materials Act – identifies 34 critical materials, 26 of which are needed for key renewable energy technologies and 17 are regarded as strategic raw materials. In the light of the EU’s commitment to reducing net greenhouse gas emissions by at least 55 % by 2030 and achieving net zero by 2050, the role of CRMs is pivotal in order to successfully decarbonise the energy system.
Special report 04/2026, “Critical raw materials for the energy transition – Not a rock-solid policy”, is available to read here.
