While the EU aims to meet Critical Raw Materials Act (CRMA) targets and diversify supply, the current selection process risks ignoring the rights of affected communities and potentially triggering anti-mining protests. The EU must uphold its core values—human rights, international law, and environmental responsibility—in its raw materials policies, particularly within these strategic projects.
Robin Roels, Coordinator of the EU Raw Materials Coalition, raises concerns that the lack of transparency in the process undermines not only democratic oversight but also put into question the EU’s commitments under the Aarhus Convention:
“The opaque selection of Strategic Projects severely undermines public trust in the EU’s critical raw materials strategy. If the EU is serious about a fair and sustainable transition, it must open up this process to genuine scrutiny and ensure that community voices are heard. Civil society, Indigenous Peoples, affected local communities, and independent experts have been largely excluded from the decision-making process, leaving the assessment and prioritisation of projects unclear. Despite repeated requests, the full list of project applicants and the evaluation criteria remain undisclosed.”
Furthermore, the right of Indigenous Peoples to Free, Prior, and Informed Consent (FPIC) is being consistently sidelined. Yblin Román Escobar, Policy Advisor of the SIRGE Coalition said:
“With 54% of energy transition minerals located on or near Indigenous lands, the EU must ensure that Indigenous Peoples’ rights to self-determination and FPIC are fully respected—both within and beyond Europe’s borders.”
Beyond transparency issues, corporate accountability remains a critical issue. Johanna Sydow, head of the International Environmental Policy Division of the Heinrich Böll Foundation said:
“During the negotiations of the legislative process of the Critical Raw Materials Act concerns about too weak human rights and environmental standards were silenced with reference to Corporate Sustainability Due Diligence Directive. However, the Omnibus Package recently proposed by the EU Commission significantly weakens this minimal criteria for imports within the raw materials sector. This is particularly alarming given the sector’s history and poses a long term threat to human and national security. This weakening undermines the EU’s credibility in pursuing high standards.”
Without strong safeguards, Strategic Projects risk enabling human rights abuses, Indigenous rights violations, and environmental harm, especially in regions with weak governance. The EU-Rwanda partnership controversy serves as a stark reminder of the reputational damage caused by bypassing due diligence in mining. The current list appears to prioritise extraction over long-term solutions. Without focusing on material efficiency and demand reduction, the EU risks deepening resource dependency instead of enabling a just, resilient transition.
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