EU CRMA Compliance Guide

This guide provides a practical approach to EU Critical Raw Materials Act (CRMA) compliance for companies using strategic raw materials (SRMs) in their products.

Identify Your SRM Exposure

Review your product bill of materials to identify which SRMs you use. The EU CRMA's 17 SRMs include: lithium; cobalt; nickel; manganese; graphite; rare earth elements (neodymium, praseodymium, dysprosium, terbium, etc.); silicon metal; boron; germanium; and others. Map your supply chain to identify where these minerals are sourced and processed.

Conduct Supply Chain Due Diligence

Large companies using SRMs in strategic sectors (clean energy, digital, defence, space) will face enhanced due diligence requirements under CRMA delegated acts. Prepare by implementing the OECD five-step due diligence framework: establish management systems; identify and assess risks; respond to risks; conduct third-party audits; and report annually.

Diversify Your Supply Chain

The CRMA's 65% single-country concentration limit means companies should work to diversify their SRM supply chains. Engage with suppliers in multiple countries, explore recycled content options, and monitor the EU's strategic projects list for new domestic SRM sources.