On the proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) 2024/1252

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SHORT JUSTIFICATION

The DEVE Opinion concerns the targeted amendments to the Regulation of the EP and the Council on establishing a framework for ensuring a secure and sustainable supply of critical raw materials (2024/1252), the so-called Critical Raw Materials Act, notably those parts of Article 24 on Company risk preparedness. It transfers from the Member States to the European Commission the identification of large companies covered by the rules under the CRMA, clarification of the aspects to consider for the risk preparedness assessment and mitigation measures, including mapping of the supply chains. In accordance with the proposed amendments, the Commission may request information and clarify further the mitigation measures needed, taking into account information on supply risks, trade flows, potential obstacles to trade in critical raw materials and the shares of reliance on a single third country in the supply chain.

The draft for the DEVE opinion calls for enhanced inter-institutional cooperation to support the Commission in these acts, and to ensure alignment with prior commitments and international agreements. The risk assessment and vulnerability prevention efforts requested from large companies require a conflict-sensitive analysis, and meaningful consultations with stakeholder intervention, notably with local communities and civil society organisations. These are necessary steps to anticipate and address supply chains disruption risks posed by conflicts and crises and thus to secure the Union’s sustainable access to raw materials.

AMENDMENTS

The Committee on Development submits the following to the Committee on Industry, Research and Energy, as the committee responsible:

Amendment 1

Proposal for a regulation

Recital 2

Text proposed by the Commission

Amendment

(2) Access to secure and sustainable critical raw materials is essential for the Union’s objectives of clean and digital transition as set out in the Clean Industrial Deal3 . They are also essential components for the Union’s industries, in all areas including defence. Due to the current geopolitical situation the Union’s supply and security of critical raw materials is put at risk and therefore, the current framework should be strengthened.

(2) Access to secure and sustainable critical raw materials is essential for the Union’s objectives of clean and digital transition as set out in the Clean Industrial Deal3 . They are also essential components for the Union’s strategic autonomy and its industries, in all areas including defence. Due to the current geopolitical situation the Union’s supply and security of critical raw materials is put at risk and therefore, the current framework should be strengthened, taking into account the need for greater resource efficiency and circularity. Global markets for several strategic raw materials are highly concentrated, particularly in the processing stage, which is often dominated by a limited number of third countries, including competing actors. The Union should therefore pursue diversification of supply and strengthen cooperation with reliable partners and preferential trade partners to improve access to critical raw materials and promote fair and transparent markets.

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3 COM(2025) 85 final

3 COM(2025) 85 final.

Amendment 2

Proposal for a regulation

Recital 2 a (new)

Text proposed by the Commission

Amendment

(2a) Due to critical disruption risks posed by conflicts and crises, as well as by environmental hazards, and their consequences on human displacements, the current framework for risk preparedness should be reinforced by conflict and environmentally sensitive risk analyses.

Amendment 3

Proposal for a regulation

Recital 2 b (new)

Text proposed by the Commission

Amendment

(2b) The Commission should promote full transparency and full traceability across the entire supply chain to ensure alignment with the Union’s strategic priorities and engagement in resource-rich partner countries and regions, and to secure the Union’s sustainable access to raw materials. The Commission should promote compliance with all international instruments concerning responsible business conduct, responsible governance and responsible supply chains referred to in Annex III to Regulation (EU) 2024/1252.

Amendment 4

Proposal for a regulation

Recital 2 c (new)

Text proposed by the Commission

Amendment

(2c) The Commission’s risk mitigation strategy for large companies for secure and sustainable supply of critical raw materials should be in line with the Sustainable Development Goals, and should contribute to sustainable economic development, in line with policy coherence for development and Article 208 TFEU. Cooperation with partner countries, in particular low and middle income countries, in particular in Africa, should also contribute to the local development of sustainable processing, refining, manufacturing and recycling and extraction capacities, ensuring that raw materials are not only exported but also transformed locally. The Commission’s strategy should contribute to diversifying supply chains, establishing decent employment and the creation of local industrial capacities and added value, benefiting both the Union and local partners, while respecting their development priorities.

Amendment 5

Proposal for a regulation

Recital 5

Text proposed by the Commission

Amendment

(5) It is essential to strengthen the risk preparedness of the large companies that are identified by the Commission, it is essential that their obligations are strengthened, and therefore large companies should be required to take measures to mitigate their vulnerabilities, including by diversifying their raw material supply chain. The Commission should be able to receive the information regarding their compliance necessary for an effective monitoring and ensure they are prepared in case of supply disruption. The Commission should specify the mitigation measures that large companies should adopt in case of vulnerabilities, it should be able to do so by means of delegated acts.

(5) It is essential to strengthen the risk preparedness of the large companies that are identified by the Commission, it is essential that their obligations are strengthened, and therefore large companies should be required to ensure the traceability of strategic raw materials and to take due diligence measures to identify and mitigate their vulnerabilities, including by diversifying their raw material supply chain and by sourcing from a broader range of reliable partners and strategic partner countries, building on strengthened international partnerships for critical raw materials. Those vulnerabilities include long-term risks that outweigh short-term financial costs, such as disruptions to supply chains caused by civil unrest, which could to a certain extent be mitigated by taking into account impacts on local communities and the environment, including respect for the human rights of women, children and workers. The Commission should be able to receive the information regarding their compliance necessary for an effective monitoring and ensure they are prepared in case of supply disruption. The Commission should specify the mitigation measures that large companies should adopt in case of vulnerabilities, it should be able to do so by means of delegated acts. Where relevant, mitigation measures should be based on meaningful engagement with stakeholders, including with local communities, indigenous peoples and civil society organisations (CSOs), in order to enhance the long-term viability and sustainability of supply chains as well as to take into account economic conditions and development needs of partner countries.

Amendment 6

Proposal for a regulation

Recital 5 a (new)

Text proposed by the Commission

Amendment

(5a) To enhance the resilience of the Union’s supply of critical raw materials, the Commission should bring to the attention of large companies the potential benefits of strategic partnerships, relevant cooperation agreements, including bilateral agreements, and projects, including Global Gateway investment projects relating to critical raw materials in partner countries, with a view to supporting diversification and mitigating supply chain risks, while ensuring that those projects do not fuel conflicts and that negative impacts on the environment and communities are prevented or minimised, including in the permitting phase.

Amendment 7

Proposal for a regulation

Recital 6

Text proposed by the Commission

Amendment

(6) Large companies should, as part of that risk assessment, map where the strategic raw materials they use are extracted, processed and recycled from, and analyse the factors that could affect their supply and assess their vulnerabilities to supply disruptions. In order to have a clear understanding of their vulnerabilities, they should also map the supply chain of the components containing critical raw materials. To reinforce their preparedness large companies should report on their risk assessment to the companies’ board of directors or management board.

(6) Large companies should, as part of that risk assessment, map where the strategic raw materials they use are extracted, processed and recycled from, in order to ensure traceability, and analyse the factors that could affect their supply and assess their vulnerabilities to supply disruptions taking into account the availability of data. Risk assessments should be based on conflict and environmentally sensitive analyses. In order to have a clear understanding of their vulnerabilities, they should also map the supply chain of the components containing critical raw materials. To reinforce their preparedness large companies should report on their risk assessment to the companies’ board of directors or management board.

Amendment 8

Proposal for a regulation

Recital 7

Text proposed by the Commission

Amendment

(7) The Commission should continue to monitor the situation and the risk preparedness of large companies, ensuring their readiness in case of disruption of their supply chains. To that end, and when it decides so, the Commission can request information from large companies on their compliance and mitigation measures as required by this Regulation.

(7) The Commission should continue to monitor the situation, and the risk preparedness of large companies, ensuring their readiness in case of disruption of their supply chains or when incurring irreversible damage to communities or the environment. To that end, and when it decides so, taking into consideration European Parliament resolutions, the Commission can request information from large companies on their compliance and mitigation measures as required by this Regulation.

Amendment 9

Proposal for a regulation

Article 1 – paragraph 1 – point 2 – point d

Regulation (EU) 2024/1252

Article 24 – paragraph 4

Text proposed by the Commission

Amendment

‘4. If significant vulnerabilities to supply disruptions are detected as a result of the risk assessment referred to in paragraph 2, large companies as referred to under paragraph 1 shall take efforts to mitigate those vulnerabilities, including by diversifying its raw materials supply chains, considering secondary raw materials, or substituting the strategic raw materials.’;

‘4. If significant vulnerabilities to supply disruptions are detected as a result of the risk assessment referred to in paragraph 2, including conflict, environmental hazards and disruptions to supply chains caused by civil unrest, large companies as referred to under paragraph 1 shall take efforts to mitigate those vulnerabilities, including by diversifying its raw materials supply chains, considering secondary raw materials, or substituting the strategic raw materials. Where appropriate, mitigation measures shall be based on meaningful engagement with stakeholders, including with local communities, indigenous peoples and civil society organisations (CSOs).’;

Amendment 10

Proposal for a regulation

Article 1 – paragraph 1 – point 2 – point f

Regulation (EU) 2024/1252

Article 24 – paragraph 5a

Text proposed by the Commission

Amendment

‘5a. The Commission may request large companies referred to in paragraph 1 to explain how they comply with the obligations set out in this Article. They shall provide that information no later than 30 days after receiving the request from the Commission.’

‘5a. The Commission, taking into consideration European Parliament resolutions, may request large companies referred to in paragraph 1 to explain how they comply with the obligations set out in this Article. They shall provide that information no later than 30 days after receiving the request from the Commission.’

Amendment 11

Proposal for a regulation

Article 1 – paragraph 1 – point 2 – point f

Regulation (EU) 2024/1252

Article 24 – paragraph 5b – subparagraph 2

Text proposed by the Commission

Amendment

The Commission shall base such risk mitigation measures on an assessment of the available information on supply risks, the trade flows between the Union and third countries, and the potential obstacles to trade in critical raw materials and shall specify the maximum shares of reliance on a single third country in the supply chain of critical raw materials.’;

‘The Commission shall base such risk mitigation measures, where appropriate, on meaningful engagement with stakeholders, including with local communities, indigenous peoples and CSOs and on a conflict-sensitive assessment of supply risks, trade flows, between the Union and third countries, and the potential obstacles to trade in critical raw materials, and shall specify the maximum shares of reliance on a single third country in the supply chain of critical raw materials. The risk mitigation measures shall also display the potential benefits of strategic partnerships, relevant cooperation agreements, including bilateral agreements, and Global Gateway investment projects relating to critical raw materials in partner countries, as well as information on respect for internationally recognised environmental, social and governance standards.’;

ANNEX: DECLARATION OF INPUT

Pursuant to Article 8 of Annex I to the Rules of Procedure, the rapporteur for opinion declares that she included in her opinion input on matters pertaining to the subject of the file that she received, in the preparation of the opinion, prior to the adoption thereof in committee, from the following interest representatives falling within the scope of the Interinstitutional Agreement on a mandatory transparency register, or from the following representatives of public authorities of third countries, including their diplomatic missions and embassies:

1. Interest representatives falling within the scope of the Interinstitutional Agreement on a mandatory transparency register

World Bank Group

European Commission (DG GROW)

European External Action Service

EU-GCC Green Transition Project

Cobalt Institute

LSE Centre for Economic Transition Expertise

EU Raw Materials Coalition

Critical Minerals Institute

2. Representatives of public authorities of third countries, including their diplomatic missions and embassies

The list above is drawn up under the exclusive responsibility of the rapporteur for opinion.

Where natural persons are identified in the list by their name, by their function or by both, the rapporteur for opinion declares that she has submitted to the natural persons concerned the European Parliament's Data Protection Notice No 484 (https://www.europarl.europa.eu/data-protect/index.do), which sets out the conditions applicable to the processing of their personal data and the rights linked to that processing.

PROCEDURE – COMMITTEE ASKED FOR OPINION

Title

Amending Regulation (EU) 2024/1252

References

COM(2025)0946 – C10-0324/2025 – 2025/0385(COD)

Committee(s) responsible

Date announced in plenary

ITRE

19.1.2026

Opinion by

Date announced in plenary

DEVE

19.1.2026

Rapporteur for opinion

Date appointed

Marit Maij

26.2.2026

Discussed in committee

17.3.2026

Date adopted

14.4.2026

Result of final vote

+:

–:

0:

15

10

0

FINAL VOTE BY ROLL CALL BY THE COMMITTEE ASKED FOR OPINION

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