Brussels, 9 October 2026 – As the European Commission announces 46 new ‘Strategic Projects’ under the Critical Raw Materials Act (CRMA) today, the European Environmental Bureau stresses that “strategic” must not mean exempt from due scrutiny. All projects must undergo robust impact assessments and comply fully with EU social and environmental protections. 

The new list of 46 ‘Strategic Projects’ spans 16 EU countries, covering various stages of the raw materials value chain. The EEB, which coordinates the EU Raw Materials Coalition, warns that many of these new projects are located in water-stressed and already environmentally degraded areas.

As Europe seeks to secure supplies of critical raw materials for the energy transition, mining and processing activities pose significant risks to water resources through increased abstraction, pollution and mining waste. These pressures threaten rivers, groundwater and ecosystems that are essential for Europe’s resilience to droughts, floods and water scarcity.

Strategic status is no guarantee of environmental sustainability

Currently, designation as a “Strategic Project” does not guarantee compliance with social or environmental standards. For example, in the first batch of 60 projects, 11 projects received Strategic Project status, despite failing the Commission’s own expert assessment. Additionally, the Commission had rejected all NGO requests for access to the documents and expert opinions from the selection process.

To improve the legitimacy of strategic projects, each project must be assessed on its own merits, including its potential environmental and social impacts.

Strong implementation of EU water law is essential

The EU’s Water Framework Directive (WFD) provides a clear legal framework to protect aquatic ecosystems and manage water resources sustainably. These safeguards must be fully implemented and consistently enforced.

Yet, in the RESource EU Action Plan, the Commission announced a revision of the WFD with the aim to “accelerate access to Critical Raw Materials in the EU”, without conducting any evaluation to assess if this is needed or justified. Mining industry claims that the WFD is blocking projects remain unsubstantiated, with no evidence to show the Directive is causing permitting problems.

Sara Johansson, Policy Manager for Water, EEB, said:

“Europe’s freshwater ecosystems are worth over €11 trillion and are the foundation of Europe’s prosperity and resilience. The European Commission must drop its plans to revise the Water Framework Directive that would grant mining companies a licence to pollute. Pollution costs must be paid by polluters, not the public.”

Transparency and public participation must be guaranteed

The Commission and national authorities should ensure full transparency regarding project assessments and decision-making processes around permitting and approvals. Local communities and Indigenous Peoples must have access to information, opportunities for robust participation, and effective access to justice.

Where public funding supports Strategic Projects, this support must be conditional on robust environmental and human rights safeguards, independent monitoring and effective accountability mechanisms.

Reducing demand must remain part of the solution

Additional recycling projects are a positive step, but the EEB warns that recycling alone cannot deliver Europe’s material security. This requires reducing demand through resource efficiency, reuse, repair, better product design and investment in sustainable public transportation. Together, these tools will allow us to reduce extraction pressures, decrease shaky dependencies, and protect local communities.

Diego Francesco, Senior Policy Officer for Raw Materials, EEB, said:

“Of the first batch of strategic projects, at least one in three mining and processing projects is already late, suspended or dead, and only about a quarter are on track. With this new batch, the obvious question is, what has changed? If the supply push can’t deliver even under these conditions, we hope the EU takes demand reduction and sufficiency seriously, because we cannot permit our way out of a market problem.”

ENDS

Notes to editors:

• The European Commission today announced 46 Strategic Projects under the Critical Raw Materials Act (9 October 2026)

• The Water Framework Directive contains significant flexibilities, as outlined in a recent Guidance document by the Commission. Several Member States have also rejected the need for a revision as the framework already allows the granting of permits for critical raw materials projects.

• The Water Framework Directive requires Member States to prevent deterioration of water bodies and achieve good water status across the EU. The European Commission, in the RESource EU Action Plan announced they will “review and revise” the WFD in Q2 2026 to promote access to CRM in the EU.