On 9 October the European Commission named 46 more strategic raw materials projects, bringing the total to 106. That sounds like progress, and on paper it is. But a project list is not yet a supply chain, and a stockpile is not yet independence. A new study by the United Nations University reads the raw materials question from the producers‘ side and, in doing so, holds up a mirror to Europe: what the EU claims for itself appears there as the demand of the producing countries. Whether Brussels‘ measures noticeably reduce dependence by 2029 will be decided less in Brussels than in the magnet plants of Estonia and France.
One Hundred and Six Projects
The number carries weight. According to the Commission, the entire portfolio could meet the extraction targets of the Critical Raw Materials Act (CRMA) for lithium, nickel, rare earths, magnesium and tungsten, and, for processing, the targets for lithium and rare earths. For cobalt it would reach 89 percent of the processing target. The 2024 law requires that by 2030 the EU extract ten percent of its consumption of strategic raw materials itself, process forty percent itself, and cover twenty-five percent from recycling. No single third country should supply more than 65 percent at any one stage.
The decisive word is „could“. Of the projects in the first round of 2025, 25 have completed their environmental assessment and 17 hold a construction permit. Strategic project status speeds up permitting but does not automatically bring funding. A list names what is supposed to come into being. A supply chain delivers only once the mine produces, the refinery runs, and a buyer takes the material at a price that sustains the project.
Vulnerability Is Not Dependence
Two things tend to run together in the debate that should be kept apart. Vulnerability describes how hard a supply outage hits. Dependence describes how large the share of a single supplier is. Against vulnerability, stockpiles, joint purchasing and contingency plans help. The RESourceEU action plan of December 2025 starts exactly there: a centre for critical raw materials, a platform for pooling demand, a pilot project for stockpiling. Against dependence, only own or alternative supply chains help, and they take years.
The Commission itself puts the potential of its measures at up to 50 percent less dependence on individual countries of origin by 2029. That is an upper bound of what is possible, not a forecast. I could not verify how the stockpiling pilot actually works. The measures are likely to act mainly where they reduce vulnerability. On China’s share of refining and magnets they are likely to change little over this period. This is a working thesis, so far only provisionally supported.
The Magnet as Test Case
This shows most clearly with rare-earth magnets. According to the Commission, China supplies around 98 percent of EU demand. The Commission’s Joint Research Centre estimates that demand will rise from about 12,000 tonnes in 2020 to about 36,000 tonnes in 2030, driven by electric cars, e-bikes and wind turbines. The new plant of Neo Performance Materials in Narva, Estonia, is expected to cover about ten percent of EU demand, according to the company. The chemicals group Solvay aims to supply around thirty percent of Europe’s demand for processed rare earths for magnets from La Rochelle by 2030. The European Raw Materials Alliance, a grouping of industry and policymakers, has identified investment needs of about 1.7 billion euros, intended to cover roughly twenty percent of demand.
Even in the best case, then, the larger part of magnet demand remains open, and European magnets cost more than Chinese ones. Without secured offtake, even technically convincing projects remain financially vulnerabl…