Large strategic technology companies (i.e. those dealing with mobile electronic devices, data transmission and storage, battery manufacturers or advanced chips) will be required to perform a supply-chain risk assessment on their sourcing of strategic raw materials (SRM) every three years.

Member states will identify the large manufacturers operating on their territory that use SRM to manufacture such technologies by 24 May 2025.

These requirements were set under the Critical Raw Material (CRM) Regulation, which entered into force on 23 May 2024.

The CRM regulation aims to ensure that the EU has access to a secure, diversified, affordable and sustainable supply of critical raw materials, in line with achieving the twin transition.

The regulation sets out additional measures, including:

• objectives in relation to the extraction, processing, and recycling of SRM in the EU;
• the implementation of strategic projects to decrease dependencies and diversify imports of strategic raw materials (i.e. high importance CRM considering their use in strategic technologies needed for the twin transition, such as microchips and batteries); and
• specific rules for products containing permanent magnets (e.g. motor vehicles, light means of transport, cooling generators, heat pumps, electric motors).

To have a closer look at the requirements of the final act, you can read Cullen International's Tracker on the CRM Regulation via the link "Access the full content" or "Request Access" in case you are not subscribed to our Sustainability service.