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Have a say! Risks of the EU Critical Raw Materials Act and the problem of strategic projects

Cover image Strategic projects

The EU Critical Raw Materials Act: Acceleration at any cost?

With the EU Critical Raw Materials Act (CRMA), the European Union pursues the goal of securing access to so-called critical raw materials. To this end, selected mining, processing and recycling projects will be classified as ‘Strategic Projects’. These projects benefit from accelerated permitting procedures, shorter deadlines and easier access to public funding.

However, what is sold as a contribution to raw material security poses significant risks to the environment, human rights and democratic participation.

Risks to transparency, environmental and equity rights

Classification as a Strategic Project can lead to time pressure or de facto erosion of environmental assessments, public consultations and local co-determination processes. Particularly in resource-rich regions, there is a risk of exacerbation of existing conflicts, for example by:

  • restricted access to information;
  • shortened participation procedures;
  • high pressure on local authorities and affected communities,
  • limited possibilities for legal protection.

The CRMA thus relies on acceleration rather than diligence – an approach that runs counter to human rights and environmental standards as well as basic democratic principles.

The new PowerShift Guide "Strategic Projects – Making co-determination easy" shows affected communities, local initiatives and civil society what voices they have despite CRMA – and how they can be used.

The guide provides a systematic overview of participation opportunities on:

  • local level (e.g. early information, local procedures);
  • national level (authorisation processes, environmental impact assessments – EIA);
  • EU level (transparency obligations, complaints and legal remedies).

Practical examples show: True participation takes time and transparency.

Based on concrete case studies, including from Portugal, the guide makes it clear:
Effective participation is not a formal act, but requires that data subjects are informed at an early stage, have access to relevant documents and receive sufficient time for examination, exchange and opposition.

Particularly in strategic projects within the CRMA, this is crucial in order to prevent environmental destruction, social conflicts and legal violations.

Conclusion: Raw materials policy needs democracy and care

A sustainable and equitable raw materials policy must not see co-determination, environmental and human rights as an obstacle, but must strengthen them as a prerequisite for social acceptance and long-term security of supply.
The PowerShift Guide makes a concrete contribution to this by making knowledge accessible and showing room for manoeuvre.

More on the topic and international perspectives here.

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