In recent years, the EU has reshaped its raw materials strategy in response to the energy transition, global supply chain competition, and a geopolitical environment marked by increasing defence concerns. The intersection between climate policy, industrial strategy and security policy has become increasingly apparent, particularly through the adoption of the Green Deal, the Critical Raw Materials Act (CRMA), and most recently the ReArm Europe Plan/Readiness 2030. While the first two frameworks are presented as tools to support the EU’s energy and digital transitions, they also raise important questions about their (growing) linkages to defence and security objectives.
The topic of raw materials for the defence industry lies at the very heart of the intersection of these policies. This means that this topic is linked to an array of controversial issues throughout the value chain of defence equipment. These issues include negative environmental and social impacts of mining activities, governance issues for instance concerning the selection of strategic projects under the CRMA – such as the lack of transparency in this process – but also the easing of transfer controls in relation to defence equipment produced with the raw materials.
In the context of the rearming Europe policy, satisfying the defence industry’s growing need for raw materials for arms production is part of the general boosting of the industry, including increasing defence budgets. This rearming Europe strategy is met with the concern that it is pursued at the expense of other policies, such as peacebuilding initiatives and social policies. Among such concerns is the suspicion that the aim of boosting the defence industry might be pursued under the guise of and progressively supplant the EU’s green ambitions.
This briefing aims to highlight some of the contentious issues surrounding the EU’s raw materials and defence policies.
Overview of relevant EU policies
- The Green Deal
The European Green Deal, launched in 2019, sets the objective of making Europe the first climate-neutral continent by 2050. The transition to renewable energy technologies (solar, wind, batteries, electric vehicles, hydrogen) significantly increases the demand for specific raw materials such as lithium, cobalt, and nickel for batteries, rare earth elements for wind turbines and electric motors, or copper and aluminium for grid infrastructure and electrification.
- The Critical Raw Materials Act (Regulation (EU) 2024/1252)
Adopted in March 2024, the CRMA is the EU’s legislative response to growing concerns about Europe’s dependency on third countries for critical materials needed for the energy and digital transitions, as well as for strategic sectors such as defence and aerospace.
“Critical raw materials” are listed under Annex II of the CRMA. They are deemed “critical” based on their importance for the whole EU economy and the risk that their supply might be disrupted. The list of 34 critical raw materials includes the 17 “strategic raw materials”, which are enumerated separately in Annex I of the CRMA. The CRMA considers those raw materials strategically important that are relevant for specific strategic sectors or technologies, namely “for the energy and digital transition as well as defence and aerospace applications” (Section 2 of Annex I of the CRMA).
The CRMA designates strategic projects to increase the EU capacity to extract, process and recycle strategic raw materials and diversify EU supplies from third countries, with the aim of contributing to the security of the EU’s supply of strategic raw materials.
- ReArm Europe Plan/Readiness 2030
The EU’s ReArm Europe Plan/Readiness 2030, presented in March 2025 by the European Commission, aims at enhancing the Union’s defence capabilities by 2030. The strategy proposes to leverage over 800€ billion in defence spending to strengthen Europe’s defence infrastructure in response to geopolitical threats, mainly the war in Ukraine following the full-scale invasion by Russia and uncertainties over U.S. military support.
The recent Defence Readiness Omnibus reflects the White Paper for European Defence-Readiness 2030 by underlining that the EU’s peacetime regulatory framework must adapt to enable rapid capability development, especially by simplifying legal and administrative frameworks relevant to defence readiness. Among other priorities, it highlights the need to ensure timely access to raw materials critical for defence, addressing supply chain risks and strengthening the European Defence Technological and Industrial Base (EDTIB).
Shifting EU priorities from green to defence?
It is hardly a shocking revelation that the EU’s raw materials policy explicitly aims to support the defence industry and that many raw materials are essential in defence technologies. 26 of the 34 materials of the EU critical raw materials list are used in defence equipment (see table 1). While some raw materials have limited use in defence equipment (e.g. scandium or silicon metal), others are widely used by the aerospace and defence industry (e.g. aluminium, beryllium, copper, graphite, nickel, titanium metal).
However, against the backdrop of the rearming Europe policy, the increased demand for specific raw materials essential for defence technologies may have implications for the EU’s raw materials policy, namely the possible backsliding on the EU’s green ambitions in favour of defence objectives. While more research is needed to determine the exact extent to which raw materials are used by the defence industry in the EU and whether this is an increasing trend at the expense of the energy transition, there are indicators pointing in the direction of such a trend.
One such indicator is that the CRMA narrows down the “critical” raw materials list to the list of “strategic” raw materials that are relevant for the strategic sectors of the energy and digital transition as well as defence and aerospace. Thus, strategic raw materials are, by definition, earmarked for the defence industry and, logically, they are all used in defence equipment (see table 1).
In addition, NATO published a list of “defence-critical” raw materials in December 2024. These raw materials are deemed integral to the manufacture of advanced defence systems and equipment and vital to maintaining NATO’s technological edge and operational readiness. The EU’s strategic raw materials list is essentially congruent with this NATO list: all but one (beryllium) of the NATO defence-critical raw materials are considered strategic raw materials under the CRMA (see table 1). Consequently, the NATO defence-critical raw materials are also widely linked to the current strategic projects under the CRMA: 45 out of the 47 EU-based projects and 11 out of the 13 non-EU projects are tied to minerals that NATO classifies as defence-critical (see table 2).
The fact that a large part of the CRMA list of strategic raw materials corresponds to the NATO list of defence-critical raw materials might suggest that strategic raw materials are especially designated for defence rather than the energy and digital transition.
For some raw materials, it is even possible to identify that they end up especially in defence equipment. A recent study demonstrates that the supply chain of niobium is dominated by a small number of sectors, including the defence industry.
Another indicator is that the defence industry’s need for strategic raw materials is likely to increase. Since strategic raw materials are, by definition, characterised by a supply risk, this growing need might only be satisfied at the expense of the other sectors that the CRMA qualifies as strategic: those linked to the energy and digital transition.
Furthermore, it has been alleged that the aerospace and defence industry’s lobby had a considerable influence on the inclusion of certain raw materials under the CRMA. One example of such reportedly successful lobbying is the recognition of titanium as a critical raw material.
Finally, the sense of the rapidly growing priority of rearming Europe is supported by the impression that the defence industry enjoys a special status across different EU legislative and policy frameworks. Just think about the exemptions for the defence industry built into the EU Corporate Sustainability Due Diligence Directive or the clarifications in the Defence Readiness Omnibus package to allow defence readiness projects to benefit from existing derogations related to overriding public interests for instance under environmental legislation.
While it remains to be demonstrated that these indicators represent a general trend in the EU, this is something that can already be observed in relation to the current US raw material and military policy, with the current administration invoking the Defense Production Act to reinforce US raw material production.
Governance and transparency risks in CRMA strategic projects
A major reason why it is difficult to assess the link between the EU raw materials and defence policy more concretely is that related processes are not very transparent. A matter where this lack of transparency is especially evident – and which might be considered illustrative of the wider EU raw materials and defence policies – is the selection process of strategic projects under the CRMA.
In March 2025, the European Commission, through the CRMA, published the list of 47 strategic projects selected projects within the EU. The 13 selected projects taking place outside of the EU were published on 4 June 2025. These non-EU projects are intended to further diversify and secure the EU’s access to critical and strategic raw materials.
Civil society organisations, research institutes, and members of the European Parliament from across the political spectrum, have increasingly criticised the lack of transparency in how EU strategic projects are selected. Concerns have been raised over the opacity of decision-making processes, limited public consultation, minimal CSO involvement, and the influence of corporate and military lobbying. A 2025 communication by the European Raw Materials Coalition (EURMC) accused the European Commission of bypassing democratic oversight and eroding environmental safeguards under the guise of achieving “strategic autonomy.”
Specific examples from the EU strategic projects list underscore these concerns: in Portugal in the Barroso and Montalegre regions, communities have resisted projects marked by legal irregularities and insufficient resource data; in Sweden, proposed developments threaten Sámi indigenous territories without requiring free, prior, and informed consent (FPIC); in Serbia’s Jadar region, legal challenges and corruption allegations have drawn intense scrutiny over EU involvement; and along the Czech-German border at Zinnwald, only the Czech side of a shared lithium deposit has been designated, raising procedural concerns.
The lack of transparency in project selection, limited community participation, and evidence of environmental and human rights impacts question whether strategic autonomy is being pursued at the expense of the values the EU claims to uphold. A case in point is that the European Commission is alleged to have failed to explain whether the selected projects satisfy the sustainability criteria of Article 6(1)(c) CRMA.
Many of these mining initiatives already pose considerable environmental and social costs, especially for local livelihoods and ecosystems, in the name of the green transition. While these impacts are deeply concerning whatever the ends for which the raw materials are used, civil society’s perception of the EU raw materials policy might deteriorate should it prove true that raw material extraction is redirected toward military objectives, raising fears that defence priorities may ultimately supplant climate and sustainability goals.
As the EU deepens its commitment to securing critical raw materials, the lines between climate ambitions, industrial competitiveness, and defence preparedness are increasingly blurred. While the CRMA is framed as essential for the energy and digital transitions, its entanglement with defence objectives raises concerns among rights-holders and CSOs. To ensure that its green ambitions are not waning behind the ReArm Europe/Readiness 2030 agenda, or to demonstrate in a transparent manner that this is not the case, the EU needs to take these concerns seriously and address them.
FURTHER READING
This briefing was produced with the financial assistance of the European Union. The contents of the editorial is the sole responsibility of IPIS and can under no circumstances be regarded as reflecting the position of the European Union.
