The EU's CRMA Test: 40% Processing in Europe by 2030

The European Critical Raw Materials Act sets three ambitious 2030

benchmarks: 10 percent of annual demand extracted inside the EU, 40

percent processed inside the EU, and 25 percent recycled. Of these, the

40 percent processing target is the most demanding. Whether Europe hits

it will determine how much of the critical-minerals value chain remains

inside the continent — and how much flows to partner countries like

Brazil.¹

The CRMA Benchmarks

The European Critical Raw Materials Act was adopted in March 2024 and

represents the European Union's first comprehensive legislative response

to critical-minerals supply-chain concentration. The Act's three 2030

benchmarks — 10 percent extraction, 40 percent processing, 25 percent

recycling — are intended to rebuild European capability in a set of 34

critical materials that include lithium, cobalt, nickel, graphite, rare

earths, manganese, tungsten, vanadium, niobium and the platinum-group

metals.¹

Alongside the quantitative benchmarks, the CRMA caps single-country

dependency at 65 percent across any stage of the value chain —

extraction, processing or refining. That cap is particularly

consequential because Chinese market share of refining for several

critical minerals currently sits well above 65 percent, which means the

EU is formally committed to reducing Chinese dependence rather than

simply diversifying at the margin.

The Act also creates a Strategic Projects designation that provides

accelerated permitting, priority financing access and coordinated

implementation support. Both EU-internal projects and external

partnerships can be designated under various provisions, creating formal

channels for Brazilian, African and Latin American projects to engage

with European industrial strategy.

Where Europe Stands Today

The gap between current European performance and the 2030 benchmarks is

substantial across most commodities. For rare earths, Europe currently

produces essentially zero mining output, processes less than 5 percent

of its demand, and recycles a negligible share. For lithium, European

mine production is concentrated in a handful of Portuguese and Finnish

operations with modest output relative to demand. For graphite, European

production is similarly marginal, and the continent imports most of its

consumption from China and, increasingly, Mozambique and Madagascar.

Processing performance is particularly weak. European customers have

historically relied on Chinese and, to a lesser extent, Korean and

Japanese refineries to turn imported concentrate into battery-grade

chemicals, separated rare-earth oxides, or specialty alloys. Rebuilding

that processing capability inside Europe requires not just new

facilities but also the technical workforce, chemical plant,

waste-management infrastructure and regulatory frameworks that

historically have not existed for these materials on European soil.

The 40% Processing Challenge

The 40 percent processing benchmark is the hardest of the three.

Extracting 10 percent of demand inside the EU is physically possible

given known European deposits of lithium, cobalt and other commodities —

though expensive and politically contested in some jurisdictions.

Recycling 25 percent by 2030 is demanding but achievable given the

growing end-of-life stock of batteries, magnets and specialty alloys

produced during the 2010s and early 2020s.

Processing 40 percent of demand inside Europe, however, requires capital

commitments measured in tens of billions of euros over a five-year

window. Rare-earth separation capacity, lithium hydroxide refineries,

nickel and cobalt precursor plants, graphite purification and

spheronisation facilities — all of these need to be built, commissioned

and ramped to commercial operation during the remainder of the decade.

Progress during 2024-2025 has been uneven. Strategic Projects have been

designated in Portugal (lithium), Sweden (graphite), Germany

(recycling), France (nickel) and several other member states. Project

economics improved as commodity prices firmed during 2025, and several

major industrial holding companies committed capital to processing

facilities. But the aggregate trajectory remains well short of what the

40 percent benchmark would require.

Strategic Projects Channel

The CRMA's Strategic Projects designation is the primary operational

tool for driving implementation. Projects designated as Strategic

receive priority permitting (aiming for 27 months maximum for extraction

projects and 15 months for processing projects), streamlined

environmental assessment, access to public-sector financing through the

European Investment Bank and national development agencies, and

coordination support from the European Critical Raw Materials Board.

By late 2025, several dozen Strategic Projects had been designated

across the EU. The geographic distribution reflects where credible

projects exist: Portugal for lithium, Sweden and Finland for

battery-chemical processing, Germany for recycling and magnet

manufacturing, Spain and France for specific refining and alloying

projects, Estonia and Slovakia for smaller strategic-processing

initiatives.

Several Brazilian projects have been mentioned in the context of EU

external partnerships, though the formal Strategic Project designation

under the Act is oriented primarily toward intra-EU initiatives. For

Brazilian producers, the engagement is through bilateral agreements,

offtake contracts with European industrial buyers, and informal

coordination with EU industrial strategy rather than through formal

Strategic Project status.

Brazil's Place in the European Plan

The CRMA explicitly envisions third-country partnerships as a key

mechanism for meeting demand that cannot be met from EU-internal supply.

The Brazilian position is strong across several of the critical

materials on the EU list: niobium (CBMM's Araxá), lithium (Sigma and the

broader Jequitinhonha valley), rare earths (Serr