Frequently Asked Questions about Strategic Projects under the CRMA

Please refer to the Guide for Applicants, Section three, for a complete description of the application process steps.  

An application comprises the application form, appropriately filled in and in PDF format created with the help of the online form, and supporting documents to complement and as evidence of the information provided on the application form. After preparing the application, you should submit it following the instructions in the section 3 of the Guide for Applicants, namely

• create an EU login account 
• request the opening of a secure communication channel with the EC  
• submit the application. 

We recommend that you create the login account and request the opening of a secure communication channel with the EC as soon as the call for applications is open (23 May 2024).

All supporting documents should be considered as a means to complement or as evidence of the information provided in the application form. Such information is required by the Critical Raw Materials Act (CRMA). Please refer to the Guide for Applicants for more details about supporting documents. 

Please consult the webpage for strategic projects under the CRMA, the Guide for Applicants, this FAQ section, slides and recordings from the info day. If you don’t find the information you seek or still have doubts, contact us through the functional mailbox: GROW-CRMA-STRATEGIC-PROJECTSec [dot] europa [dot] eu (GROW-CRMA-STRATEGIC-PROJECTS[at]ec[dot]europa[dot]eu).

Please note that questions submitted in the last days before the cut off date may not receive a reply.

All exchanges of information between the applicants and the Commission will be conducted via a secured and encrypted communication channel.  

In addition, the content of each application is treated under strict confidentiality rules. 

Regarding the experts participating in the assessment phase, they will be selected by the Commission following strict rules regarding potential conflicts of interest. The contracts the experts will sign with the Commission also include clauses addressing confidentiality and conflict of interest. Furthermore, the conditions on processing personal data provided in the application, are governed by the data privacy statement included on the application form. 

Yes, a company can submit several applications.

Each application can only address one stage (e.g. extraction or processing). This is due to the different permitting processes in the EU countries and different permitting deadlines. In case of a situation where applicants intend to address different stages (which are linked) in a project, they should prepare different applications (one per stage) indicating their linkage in the project summary field (section one of the application form). Please consult the section 4.1 of the Guide for Applicants for detailed instructions. 

Yes, a specific site location is required and if several locations for the same project exist then they should be indicated in the same application. There are specific fields to indicate the multiple locations. 

Yes, projects that are already in the permitting process or have received permits can apply. You are required to indicate the status of each permit in the application form, in section six addressing project Operation/Permitting status. 

The project should in principle contribute to the 2030 benchmarks included in the CRMA. Please consult the Guide for Applicants for further details. 

The United Nations Framework Classification for Resources (UNFC) classification of strategic projects will be addressed in two-steps. The project promoters are requested to classify the project in accordance with UNFC during the preparation of their application. This initial classification should take less than one day. Following a successful completeness check, the Commission, with the help of UNFC experts, undertakes a review of the project UNFC classification.  

Each application is assessed as submitted. In case of any substantial change in a submitted application after the cut-off date has already passed, the project promoter should inform the Commission via the appropriate designated communication channel and should consider withdrawing the application and possibly submitting an updated one before the following cut-off date. If the project promoter is aware of any meaningful change after submitting the application but before the cut-off date, they should inform the Commission and consider submitting an updated application before the cut-off date. Applications submitted after the cut-off date are not considered for assessment for that cut-off date. 

Yes, there is a possibility to re-apply, respecting the future regular cut-off dates. 

The open call for applications will stay permanently open with regular announcements of cut-off dates. The next cut-off date is foreseen for the 1st Quarter of 2025.  

We will communicate the results of the first cut-off on the CRMA strategic projects call in November or December 2024. 

Project promoters from third countries are eligible to apply for the status of strategic project as defined by the Regulation (EU) 2024/1252 providing that they fulfil the eligibility criteria defined in Article 6 of the Regulation. In particular, the project needs to contribute meaningfully to the security or resilience of the EU supply of strategic raw materials (see Annex 1 of the Regulation). 

In addition, the project should be or become technically feasible and implemented sustainably. Specifically, the applicable legal framework or other conditions in third countries provide assurance that trade and investment related to the project will not be distorted, taking into account, in particular, whether the EU has concluded a Strategic Partnership or a trade agreement containing a chapter on raw materials with the relevant third country, or Overseas Countries and Territories (OCTs), and is consistent with the EU’s common commercial policy. Last, but not least, projects in third countries that are emerging markets or developing economies have to be mutually beneficial for the EU and the third country concerned by adding value to that country. 

In assessing whether a project contributes meaningfully to EU supply security, we will also take into account who controls the undertakings involved in the project. To that end, aspiring projects must also submit in their application detailed information about the control of those undertakings.

Applicants for strategic project recognition under the CRMA must provide comprehensive sustainability information, including environmental and social impacts, governance practices, and supply chain transparency. Evidence must show that the applicant will implement the project sustainably. 

Applicants are also encouraged to include information on any international sustainability schemes their project follows.

This ensures alignment with the CRMA's objectives of promoting sustainable and responsible sourcing of critical raw materials. Refer to section 4.8 guide for applicants for more details.

Having obtained the status of a strategic project under the CRMA allows project promoters to request a meeting of the financing subgroup according to article 16 of the CRMA to discuss and provide advice on how the financing of the project can be completed, taking into account private and public sources of funding. This subgroup brings together relevant national promotional banks, the EIB, EBRD and private financial institutions, among others. 

The status of a strategic project also ensures the possibility for regional and national authorities to make use of funding from the European Development Fund and Cohesion Fund to support the relevant project, in line with the new STEP Regulation. These funds are administered by regional and national authorities and the Commission makes sure that the projects are successfully concluded.

Having obtained the status of a strategic project under the CRMA allows project promoters to request a meeting with the financing subgroup according to article 16 of the CRMA to discuss and provide advice on how to complete the financing of the project, taking into account private and public sources of funding, with a particular focus on the Global Gateway Initiative. This subgroup brings together relevant national promotional banks, the EIB, EBRD and private financial institutions, among others.

Strategic projects in the EU will indeed benefit from a pre-set time frame for permitting. In addition, they can request help to gain access to financing through a subgroup of the CRM Board. This sub-group coordinates the work of EU and national private and public financial institutions to help support the project.

Early exploration stage is not in the scope of the strategic projects under the CRMA. However, if an extraction project also includes targeted exploration and it meaningfully contributes to the benchmarks defined in the CRMA (e.g. the full production foreseen before 2030), then the project is eligible.

The Commission will review and, if necessary, update the list of strategic raw materials by 24 May 2027, and every three years thereafter. Upon the request of the European Critical Raw Materials Board established in Article 35 (the ‘Board’) on the basis of monitoring and stress testing in accordance with that Regulation, the Commission will also review and, where appropriate, update the list of strategic raw materials at any time in addition to the regular reviews.

As the CRMA is a regulation it applies directly in the European Union Member States. Project promoters can therefore apply from the day indicated in the call for applications.

The CRM Board will include high level representatives from EU countries and the European Commission as permanent members, with the European Parliament as an observer. Additional parties may be invited to the meetings as observers if needed.

The assessment of each project application will strictly follow the Commission’s internal rules and CRMA criteria while protecting commercially sensitive information. 

The Commission will provide the CRM Board with its assessment, and the Board will issue an opinion. The Commission will then adopt a reasoned decision, which will be made public, including basic information about each selected project.

A project is considered to make a meaningful contribution if it signicantly enhances the EU’s capacity for extracting, processing, or recycling strategic raw materials. Projects can also contribute to the benchmarks through the production of innovative substitute materials. 

Additional information is available in section 1.3 of the guide for applicants.

Project applications should include evidence that they meaningfully contribute to the EU’s supply security and the 2030 benchmarks.

Relevant studies on expected consumption in 2030 with an EU-scope, such as the  Supply chain analysis and material demand forecast in strategic technologies and sectors in the EU – A foresight study, can be used if applicable. 

This is without prejudice to the Commission’s indicative projections of the annual consumption for each critical raw material, to be published by 24 November 2025.

No specific certification schemes are required. However, if applicable, project promoters should reference any international certification schemes their project follows, describing the aspects related to obtaining the certification or any other third-party assessment as indicated on the application form. Applicants must also summarise the potential environmental and social impacts and mitigation measures. 

For more information, consult sections 1.3 and 4.8 of the guide for applicants. 

The Commission will adopt a single template by 24 May 2027 for certification scheme owners to apply for recognition under the CRMA. Project promoters can use recognised schemes to show compliance with sustainability criteria.

External experts are selected from the Commission’s expert database, established following an open call for expressions of interest. Before they begin their work, they receive a briefing on the content of the relevant parts of the CRMA, the assessment process (including assessment criteria) as well as on their obligations regarding confidentiality, impartiality and conflicts of interest.

Applications are assessed by at least four individual experts whose collective expertise covers technical, financial, and environmental, social and governance (ESG)-related aspects, as well as the United Nations Framework Classification for Resources (UNFC). During their individual assessment, each expert prepares an individual assessment report. After the individual assessment, the Commission may invite all experts who have evaluated the application to meet in a consensus group, to agree on a common position, if needed. The outcome of this assessment is summarised in a consensus report, which is then endorsed by all external experts who contributed to it.

The full assessment procedure is described in section 5.2 of the guide for applicants.