An Analysis of the Impact of Strategic Raw Materials Projects under the Critical Raw Materials Act on Water Resources and Equity
The Critical Raw Materials ActCRMA) to improve Europe's supply of raw materials. To this end, the EU is, among other things, accelerating permitting procedures for ‘strategic projects’ in the extraction of raw materials. The joint study by PowerShift and NABU shows how Fast-Track threatens water protection and participation rights – and how it can protect democratic participation and the environment.
What the EU needs to change
Europe's raw materials policy is facing a double test: Security of supply must not come at the expense of water, nature and democratic participation. The CRMA speeds up – but shortening deadlines and facilitating exceptions threatens legal uncertainty, loss of acceptance and lasting environmental damage. Water is particularly sensitive: Pollution and pressure to use directly affect ecosystems and drinking water supply.
What the study shows
- Fast-Track jeopardizes effective participation
Compressed deadlines and ‘strategic’ status can devalue participation if documents are available late, incomplete or in unusable formats. This creates high conflict and litigation risk dynamics. - Water standards: Strengths – but also gaps
For drinking water, many EU limits are strict. For surface waters, there is a lack of harmonised EU-wide standards for several substances relevant to mining; In some cases, there are no EU or national limit values. - ‘Superior public interest’ as a risk lever
The CRMA may favour future exemptions from the prohibition of deterioration. Without clear barriers, water protection objectives become politically subordinated, with consequential costs for the environment and public budgets. - Tailings & mining waste: EU rules not "best practice"
The EU Extractive Waste rules are considered outdated; Central gap: no ban on upstream tailing dams for new installations. The study recommends an update to global best practice and independent oversight. - Without protective barriers, ‘sacrifice zones’ are created
When transparency, accountability and rights approaches are lacking, raw material regions become sacrificial zones. This undermines the promise of a just transformation and exacerbates social tensions.
What this means in practice
Four cases show how fast-track logics, information deficits and water risks have a concrete impact.
Spain: Mina Doade of Galicia
project splitting and missing cumulative testing along a 12 km belt; Central water risks (including acid mine drainage) remain insufficiently addressed. Authorities demanded studies, some of which were not submitted.
Portugal: Mina do Barroso (Northern Portugal)
In 2023, 1,776 EIA documents should be reviewed in just 10 working days. In 2025, the UN-Aarhus Committee criticised deficits in information and participation. The project was politically approved in 2023 following rejections; Legal action is underway.
Sweden: Sámi rights and CRMA speed
Civil society criticises the fact that accelerated procedures and overriding public interest weaken voice and legal protection. Particularly problematic: insufficient assessment of cumulative effects on reindeer husbandry, culture and livelihoods.
Germany: Tin forest (Saxony)
The study shows implementation and participation gaps compared to high benchmarks (Aarhus/IRMA/Escazú). The CRMA pressure intensifies debates as to whether securing raw materials effectively displaces other protective goods.
What to do politically now
The study makes 17 recommendations. The core is a rights and environmental approach that not only makes permits faster, but also better: transparent, verifiable, with real voice, robust environmental and social audits and secured decommissioning.
5 key points summarized
- Enhance participation: Recognize those affected as rights holders, ensure protection of those engaged.
- Making information usable: provide expert opinions and contracts in an open, machine-readable and comprehensible manner; Finance translations and independent expertise.
- Environmental and Social Impact Assessments (ESIA) without abbreviations: comprehensive, independently verified, including human rights/social consequences, alternatives and cumulative and cross-border effects.
- Prioritise the Water Framework Directive: Water is the basis of human life, not weakening limit values or the prohibition of deterioration; Strengthen monitoring and funding for actions.
- Modern regulation of mining waste: Develop Extractive Waste Directive into a regulation, align with safety-first guidelines, strengthen independent supervision and robust financial collateral.
How the study works
Methodologically, the study combines legal analysis and country gap analyses with international benchmarking: Aarhus as EU baseline, Escazú as standard evolution (including protection of defenders), IRMA as best-in-class standard for mining practice.
Find out more
More on the risks of raw materials policy.
World economy compass – the PowerShift podcast.
PowerShift Action guide for more voice in different languages.
Press & Background
For interviews, audio and data please contact:
Adrian Bornmann
Speaker for press and public relations
Maja Wilke
Policy Officer for Raw Materials Policy
