A new policy brief warns that Europe’s ambitious 2030 targets for critical raw materials are under threat, not from a lack of resources, but from a failure to scale industrial operations quickly enough. With less than five years to go, experts are calling for urgent action to de-risk investment and harmonise regulations across the continent.
The delivery gap
A collaborative report from REESOURCE and ten other Horizon Europe projects has highlighted that the EU’s transition to green and digital technologies is currently hampered by significant implementation barriers. Despite the benchmarks set by the Critical Raw Materials Act (CRMA)—which mandates 10% domestic extraction, 40% processing, and 25% recycling by 2030—the window for delivery is rapidly closing.
The brief identifies that the primary risk to these goals is not geological scarcity, but rather “delayed scale-up, fragmented governance, and investment uncertainty”.
Key barriers to industrial scale-up
Stakeholders from across the value chain, including mining companies, research organisations, and SMEs, have identified several critical bottlenecks:
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The “Valley of Death”: Limited access to finance for pilot and first-of-a-kind (FOAK) plants remains the most significant hurdle. Market volatility and price uncertainty frequently stall projects between the research phase and commercial deployment.
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Regulatory Red Tape: Fragmented waste classifications and inconsistent cross-border transport rules for raw materials continue to undermine the efficiency of recycling flows.
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Permitting Delays: While the CRMA introduces “fast-track” timelines, the actual administrative capacity and interpretation varies wildly across Member States, damaging investor confidence.
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Social Acceptance: The report suggests that failing to engage local communities early can lead to delays that “outweigh financial or regulatory barriers combined,” particularly in primary extraction projects.
Recommendations for action
To course-correct, the policy brief recommends moving toward milestone-based funding pathways and introducing mandatory traceability requirements—such as Digital Product Passports—for devices containing rare-earth magnets. Furthermore, it stresses that primary extraction and recycling must be developed in parallel to ensure a resilient European supply chain.
As the 2030 deadline approaches, the focus must shift from legislative design to the “operational delivery” of industrial facilities.
