The Critical Raw Materials Act in brief

Adopted in March 2024, the CRMA is the first European regulation dedicated to securing the supply of critical raw materials. It identifies 34 critical raw materials and 17 strategic raw materials (including antimony, tungsten, cobalt, rare earths, lithium, and gallium) for which the EU is heavily dependent on a small number of third countries.

The regulation sets diversification targets (at least 10% of annual consumption produced in Europe, 40% processed in Europe, and no more than 65% of supplies from any single third country) and imposes due diligence obligations on value chain operators.

What the CRMA specifically requires regarding traceability

The regulation requires companies using strategic raw materials in significant quantities to be able to document the geographic origin of their supplies and assess the risks associated with those origins. This due diligence obligation applies particularly to companies whose products are covered by other European regulations: the Battery Regulation, the Conflict Minerals Regulation, and future regulations on permanent magnets.

In practice, a documentary declaration of origin is insufficient if it is not supported by independent verification. Isotopic traceability provides precisely this independent physical verification.

The Conflict Minerals Regulation (EU 2017/821)

Prior to the CRMA but complementary to it, this regulation requires European importers of tin, tantalum, tungsten, and gold to implement due diligence systems to ensure their supplies do not fund armed groups in conflict zones. It has been in effect since January 2021.

Identifying geographic origin through isotopic signatures is an independent verification tool that strengthens the credibility of due diligence statements, especially for tungsten, whose major global deposits have distinguishable isotopic signatures.

Antimony: A case in point

Antimony is classified as a critical raw material by the EU, the US, and Japan. China accounts for about 70% of global production, and recent geopolitical tensions have led to Chinese export restrictions. Antimony deposits have distinct isotopic signatures depending on their geological context. Isotopic verification of an antimony batch can confirm or refute the declared origin, which is directly relevant to CRMA compliance and supply risk management.

How to integrate isotopic traceability into a compliance system

  1. Identify concerned materials: Map the critical or strategic raw materials used and their annual volume.
  2. Define control points: Choose at which stages of the supply chain isotopic verifications will be performed.
  3. Establish a reference base: For each material and each declared source, obtain and record the reference isotopic signature.
  4. Implement a sampling protocol: Define collection procedures and select accredited laboratories.
  5. Document results: Use the ISOF format to produce enforceable and verifiable analytical certificates.

The state of the regulatory framework

Isotopic traceability is not yet explicitly mentioned in European regulatory texts; the CRMA leaves the choice of verification methods to operators. However, it is recognized as a valid scientific method in specialized literature on due diligence and is used in international legal and arbitration proceedings as proof of origin.

The likely evolution of the regulatory framework points toward the normalization of physical traceability methods. Several European standardization bodies are working on developing standardized protocols for the isotopic verification of critical raw material origins.

Key Takeaways
  • The CRMA imposes traceability obligations on 34 critical raw materials, including antimony and tungsten.
  • Isotopic traceability provides independent physical verification of documentary claims.
  • It is relevant for both the CRMA and the Conflict Minerals Regulation.
  • Its integration into a compliance system follows a step-by-step logic, adaptable to each supply chain.