Article 24 of the Critical Raw Materials Act

Key questions

What does Article 24 of the Critical Raw Materials Act require?

Large companies that manufacture strategic technologies using strategic raw materials must, at least every three years, carry out a risk assessment of their supply chain: map where the strategic raw materials they use are extracted, processed and recycled, analyse the factors that could affect supply, and assess their vulnerability. If they find significant vulnerabilities, they should work to reduce them, for example by diversifying or substituting.

Who has to comply?

Large companies that manufacture strategic technologies in the EU using strategic raw materials. Under the original Act, member states had to identify these companies by 24 May 2025. A 2026 amendment proposal would move the identification to the European Commission.

When did the Critical Raw Materials Act enter into force?

On 23 May 2024. It lists 34 critical raw materials, 17 of them strategic.

What is changing in 2026?

The Commission has proposed amendments under which it would identify the large companies itself, and the companies would carry out the risk assessment within months of being informed and at least every three years, including mapping the components that contain strategic raw materials. The European Parliament adopted its position on 20 October 2026; the final text was still being negotiated at the end of October 2026.

Does it affect suppliers that are not large companies?

Not directly, but large companies need origin and supply information from their suppliers to complete their assessments, so smaller suppliers can expect questions about where their materials come from.