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The EU identifies critical raw materials by assessing two things: how important a material is to the EU economy and how exposed its supply is to disruption. Under the Critical Raw Materials Act, the Commission applies thresholds to those two scores. It also identifies strategic raw materials using a separate, forward-looking test; those materials are included in the Act’s critical-material list as well. The result is a structured assessment of economic importance and supply exposure—not a prediction that a shortage is about to happen.
How does the EU identify critical raw materials?
The framework is set by Regulation (EU) 2024/1252, the Critical Raw Materials Act. The European Commission assesses materials at EU level using an approach that asks both “critical to what?” and “at risk from what?” A material’s geological rarity, market price, or dependence on one supplier can matter to the analysis, but none of those facts alone defines criticality.
The two-part test is intended to capture different problems. Economic importance measures the consequences of losing access to a material for EU economic activity. Supply risk estimates the exposure of EU supply to disruption. A material may score highly on one dimension without crossing the required level on the other; the framework does not treat the two measures as interchangeable.
The economic-importance test
To estimate economic importance, the Commission maps a material’s end uses to two-digit NACE economic sectors and weights those uses by the value added of the sectors that rely on it. In practical terms, a material used in economically significant manufacturing activities can matter more than one with similar physical scarcity but fewer consequential applications.
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The calculation also accounts for economic substitutability. It considers whether alternatives can provide the required technical functionality and how their costs compare. A theoretical substitute is not necessarily an effective substitute if it cannot perform the needed function or is not economically viable. This adjustment makes the score more informative than a simple tally of uses: it reflects how readily economic activity could adapt if access to the assessed material changed.
The supply-risk test
Supply risk is assessed at the material’s supply-chain bottleneck: extraction or processing, whichever stage presents the greater risk for EU supply. That choice matters. A material may be mined across several countries but depend on a concentrated processing stage, or the reverse. Looking only at the mine or only at a final product can therefore miss where disruption is most consequential.
The assessment examines how concentrated production is and how concentrated the EU’s own sourcing is. It also considers the governance and trade conditions of producing and supplying countries. Import reliance affects how the method weights global producers against the countries from which the EU actually obtains the material. The result is not simply a measure of whether the EU imports a material, nor a count of how many countries produce it.
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Two further factors reduce assessed exposure: end-of-life recycling input and technical substitutes. Recycling can return material from products that have reached the end of their service life; substitution can reduce reliance on the material in relevant applications. These factors are considered alongside concentration, import reliance, governance, and trade conditions rather than replacing them.
What are the thresholds for being classified as critical?
Under the Act, a material qualifies through the ordinary criticality-threshold route when it reaches at least 2.8 for economic importance and at least 1 for supply risk. Both thresholds must be met for that route. These figures are assessment cut-offs, not percentages, probabilities of a shortage, or ratings of how soon a disruption may occur.
The regulation specifies that calculations use an average of the most recent five years for which data are available. It also requires data priority, quality, and availability to be taken into account. A score is therefore based on an evidence window, not a timeless property of a mineral. Changes in sourcing, production, demand, recycling, trade conditions, or substitution can change the underlying assessment.
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What is the difference between critical and strategic raw materials?
Strategic raw materials are identified through a distinct, forward-looking lens. The Commission considers their relevance to strategic technologies—including green and digital technologies, defence, and aerospace—along with expected global demand growth and the difficulty of increasing production. That test asks about future strategic needs and the ability to scale supply, rather than applying only the two criticality scores.
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| Assessment lens | What it measures | How it affects classification |
|---|---|---|
| Criticality thresholds | Economic importance and supply risk, assessed using the methodology in Regulation (EU) 2024/1252. | The material meets this route when its economic-importance score is at least 2.8 and its supply-risk score is at least 1. |
| Strategic-material assessment | Relevance to strategic technologies, expected global demand growth, and difficulty of increasing production. | Strategic materials are included in the Act’s critical-material list, including when they do not meet both criticality thresholds. |
The Commission’s longer-term foresight work complements these assessments but should not be mistaken for the two-axis criticality score. Its 2023 update assessed 15 technologies mapped to five strategic sectors, with demand perspectives for 2030 and 2050. That work informs the forward-looking view of technology and demand; it is not itself a substitute for the supply-risk and economic-importance calculation.
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What does the EU list tell you—and what does it not tell you?
The Commission says its 2023 assessment screened 70 candidate raw materials: 67 individual materials and three groups. It published a list of 34 critical raw materials. Those numbers describe that assessment and list edition; they should not be presented as an immutable count for all time. Earlier assessments also covered different candidate populations: 41 materials in 2011, 54 in 2014, 78 in 2017, and 83 materials represented by 66 candidates in 2020. Differences between editions may reflect changes in scope and methodology as well as changes in supply or economic conditions, so year and method matter when comparing lists.
The Commission’s overview, checked in 2026, gives three examples of concentrated EU supply: China provides 100% of the EU’s supply of heavy rare earth elements; Turkey provides 99% of the EU’s supply of boron; and South Africa provides 71% of the EU’s needs for platinum. These examples concern the specified materials and geographic scope. They illustrate concentration, but they are not complete supply-risk scores and should not be generalized to other materials, including all platinum-group metals.
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How to compare materials or list editions
A useful comparison keeps the assessment year, material form, and geographic scope aligned. A headline statistic from one year or one material stage may not be comparable with another. When assessing the reasons behind a classification, check the underlying dimensions rather than relying on a label alone:
- Economic importance: the score and the end uses and EU economic sectors contributing to it.
- Supply bottleneck: whether the principal exposure is at extraction or processing.
- Concentration: where production is concentrated and where the EU sources the material.
- Import reliance and country conditions: how sourcing patterns, governance, and trade conditions affect exposure.
- Resilience factors: the role of end-of-life recycling input and the technical and economic feasibility of substitutes.
- Strategic status, where relevant: the material’s technology relevance, demand-growth outlook, and difficulty of increasing production.
The European Commission’s overview explains the assessment and publishes list information, while the regulation and its annexes set the legal criteria and methodology. For a material-specific explanation, the broad list alone is not enough: its underlying factsheet or assessment data are needed to establish the particular scores and factors. Do not infer a numerical score from a country-concentration example.
Why the classification can change
Supply chains and economic uses evolve. Production can become more or less concentrated; the countries supplying the EU can change; trade conditions may shift; and new technologies, recycling flows, or substitutes can alter exposure or economic reliance. Demand expectations and the practical difficulty of scaling production also matter to the strategic-material lens. Because the assessment depends on changing conditions and available data, a designation should be read as belonging to a particular assessment and legal list edition.
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