Brussels, 3 December 2025 – The new ReSourceEU package released today by the European Commission risks militarising mineral policy and weakening the safeguards needed to protect communities, rights and Europe’s long-term resilience.

The European Environmental Bureau (EEB) warns that the EU’s newly announced ReSourceEU plan fails to deliver the investment, accountability and environmental protections required for long-term resilience. The package centres on joint stockpiling, joint procurement, Buy European provisions, demand aggregation and new financial tools designed to secure minerals for defence manufacturing, signalling a clear alignment with the European Defence Industry Programme, the European Defence Fund and Horizon Europe.

For the EEB, this repeats the core mistake of the Defence Omnibus: treating environmental and social protections as expendable in the name of readiness and speed. This push for stockpiling comes at a strikingly contradictory moment, as the EU is also weakening the Corporate Sustainability Due Diligence Directive and the Corporate Sustainability Reporting Directive through the first omnibus, effectively dismantling the very tools that would allow Europe to build genuinely responsible and accountable supply chains. Civil society has already observed growing pressure to accelerate permitting for defence-related mining and processing without proper Environmental Impact Assessments, land-use planning and nature protection. 

The EEB is also deeply alarmed that water protection is being quietly sacrificed, mere months after Commissioner Roswall pressed the need for better implementation of the Water Framework Directive in the Water Resilience. Water law is being quietly dismantled using arguments lifted straight from extractive industrial lobbyists. Their operations cause severe pollution through metal contamination such as mercury; and harmful damages that reshape entire waterways. Yet, despite these well-documented impacts, the sector is pushing for even more “flexibility” so authorities can prioritise new mines and industrial facilities over safeguarding rivers and groundwater. 

We are selling our water protection for the short-term gains of mining interests. The consequences will be devastating for Europe’s freshwater, the ecosystems and all of us that depend on them for our drinking water and our health.– Sara Johansson, Senior Policy Officer for Water at the EEB

The announcement also fails to correct Europe’s structural investment deficit. While the Collission mobilises 3 billion euros and EIB loans to support strategic projects, global competitiors operate on a far larger scale. Since 2020, China has invested over USD 15 billion in overseas battery-metal projects, compared to USD 1.7 billion from EU companies, while more than 14 EU strategic partnerships have yet to produce concrete projects on the ground, which have also raised serious human rights and environmental concerns.

In 2024, NATO published a list of defence-critical raw materials essential for advanced weapons systems. This list largely mirrors the EU’s strategic raw materials designation, meaning NATO defence-critical materials overlap significantly with projects funded under the Critical Raw Materials Act (CRMA). Indeed, 45 of 47 EU-based projects and 11 of 13 non-EU projects target minerals classified as defence-critical by NATO. 

Stockpiling and joint purchasing are central to ResourceEU’s strategy, yet the EEB warns that these measures risk prioritising defence needs over energy transition materials. Given the relative scarcity in global raw material markets and intense competition for rare earths, driven by defence sector demand, minerals for renewable energy and grid modernisation may be deprioritised, potentially undermining the EU’s climate commitments.

“Joint purchasing without due diligence is a political gamble. States will fill warehouses with minerals whose origins have not been properly checked, then decide behind closed doors which sectors get them. The winners will almost certainly be the defence industry, not renewables or batteries. This is bad for communities, bad for rights and bad for climate resilience.” – Diego Marin, Senior Policy Officer at the EEB.

Weakening protections and expanding secrecy will also damage Europe’s credibility abroad, where partner countries consistently stress that strong safeguards and transparent processes are essential for trust and cooperation.

“Security is not achieved by sacrificing the rights and protections that keep Europe stable. A credible mineral strategy must strengthen safeguards, not dismantle them. Civil society, communities and local authorities must remain central actors in any decision that shapes their land, water and future,” Robin Roels, Coordinator of the EU Raw Materials Coalition.

On a positive note, the planned restrictions on the export of permanent-magnet scrap and targeted measures for aluminium, with copper possibly to follow, are a genuinely positive step, helping to keep valuable materials within the EU, boost circularity and strengthen responsibility in Europe’s own supply chains. Strong safeguards and full democratic oversight must guide the implementation of these measures.

The EEB urges the Commission and Member States to:

• Maintain full public access to information and participation, ensuring that no defence justification is used to restrict oversight or expand secrecy in mineral governance.
• Prevent joint purchasing and stockpiling from giving preferential access to the arms industry, at a time when a limited volume of raw materials is available on global markets and multiple sectors, especially renewables and batteries, urgently need supplies.
• Guarantee that mineral governance does not result in the weakening of environmental policies and human-rights due-diligence requirements, which would increase conflict risks and undermine Europe’s credibility.
• Reconsider the announcement to revise the Water Framework Directive and focus instead on closing implementation gaps.
• Manage overall resource demand through promoting genuine circularity by introducing binding targets to reduce Europe’s material consumption. 
• Strengthen high-quality recycling and recovering CRMs from key waste streams such as batteries, end-of-life vehicles, electronics, and construction and demolition waste through the new Circular Economy Act, the revision of the Waste Electrical and Electronic Equipment (WEEE) Directive, or the proposed Regulation on vehicle design and their end-of-life management. 

Europe must avoid a militarised race for minerals and instead build a resilient, rights-based and democratically accountable framework for resource use.