As the European Union works to shore up the security and sustainability of its raw material supply chains, European Commission Executive Vice-President Teresa Ribera has launched a public consultation aimed at promoting cooperation among industry players under EU competition rules.
The move reflects Ribera’s dual mandate as Commissioner for a Clean, Just and Competitive Transition: guiding the bloc’s competition policy through 2029 while co-leading the Clean Industrial Deal, a pillar of the EU’s green and industrial transformation. According to her 2024 Mission Letter, Ribera must “modernise the EU’s competition policy” to enable innovation, resilience, and sustainability in an era marked by geopolitical tensions and unfair subsidy-driven competition.
Announcing the consultation, Ribera invited stakeholders in extraction, processing, and recycling to identify barriers and opportunities for collaboration across the raw materials value chain. “Together, we can build sustainable supply chains and transform challenges into opportunities for prosperity, innovation and resilience,” she stated.
The consultation comes as companies struggle to navigate legal uncertainty around cooperation. While the EU’s 2023 Horizontal Guidelines offer some room for sustainability agreements, they caution that even modest cooperation—such as setting a joint purchase price for recyclable phones—can breach antitrust rules. Meanwhile, the 2022 Vertical Guidelines do little to clarify how sustainability considerations might enable cooperation further down the supply chain.
The legal ambiguity stands in contrast to growing EU policy imperatives. The Draghi Report on European Competitiveness (2024) urges the Commission to ease legal pathways for joint procurement and collaborative production efforts in critical raw materials. Likewise, the Commission’s Clean Industrial Deal communication commits to providing companies with tailored antitrust guidance aligned with EU economic and security priorities.
While the EU’s 2024 Critical Raw Materials Act (CRMA) already outlines strategic public-sector projects to diversify sourcing, the CRMA stops short of addressing the private sector’s role in joint action. In March 2025, the Commission selected 25 Strategic Projects across 14 critical materials—including lithium, cobalt, nickel, graphite, and tungsten—but implementation rests largely with national governments and non-EU partners.
Ribera’s new consultation, therefore, fills a key policy gap. The Commission is expected to initially focus on the 14 raw materials prioritized under the CRMA, particularly those essential to sectors like renewables, digital, aerospace and defence. Based on the feedback, the Commission will consider whether to issue new competition guidance—possibly by 2026—clarifying when and how companies may work together to strengthen critical supply chains without violating EU antitrust law.
