CRMA Corrected: What Changes for Companies Using Critical Raw Materials

Key data

If your company consumes lithium, cobalt, rare earths or other critical minerals to manufacture batteries, solar panels, semiconductors or electric vehicles, the Regulation (EU) 2024/1252, known as CRMA (Critical Raw Materials Act), already defines the rules of the game for the coming years. The official correction published on November 6, 2026 —reference OJ:L_202690953— does not change those rules: it corrects technical and drafting errors in the original text of May 3, 2024.

The key for executives is this: there are no new obligations arising from this correction, but it is the time to verify that the version of the regulation your legal advisory or compliance team is using is the corrected and consolidated version.

What does this regulation establish?

The original CRMA, approved on April 11, 2024 and published on May 3, 2024, creates a European framework to ensure safe and sustainable access to critical raw materials. The correction published now corrects technical or drafting errors detected in that text, without modifying substantive obligations.

The pillars of the CRMA that remain unchanged after this correction are:

• Reference targets ("benchmarks"): 10% of the EU's annual consumption must come from its own extraction, and 40% of processing must be carried out within the EU.
• Supply diversification: no third country can supply more than 65% of any critical raw material to the EU.
• Strategic projects: a certification and support system is created for mining and processing projects considered strategic for the EU.
• Affected raw materials: lithium, cobalt, rare earths and other minerals essential for the energy and digital transition.

The correction also modifies, in technical terms, the references to the four regulations that the original CRMA had already amended: Regulation (EU) 168/2013 (two and three-wheeled vehicles), Regulation (EU) 2018/858 (motor vehicle type-approval), Regulation (EU) 2018/1724 (single digital gateway) and Regulation (EU) 2019/1020 (market surveillance).

Economic and operational impact

This correction does not generate direct new costs. However, it has two relevant operational implications for companies:

• Legal certainty: any contract, compliance audit or due diligence that references the CRMA must do so based on the corrected version. Using the original text with errors can generate interpretative discrepancies.
• Roadmap unchanged: the timelines and obligations of the original CRMA remain in place. Companies that have not yet initiated their analysis of exposure to critical raw materials are falling behind competitors who have already done so.

The real economic impact of the CRMA for affected companies does not come from this correction, but from the underlying regulation: the requirements for supply chain diversification, the need to audit suppliers and the possible reorientation of long-term contracts towards European or allied sources imply management costs and, in some cases, significant procurement costs.

Who does it affect?

• Mining sector: companies engaged in extraction and exploration of critical minerals in European territory or with operations in third countries.
• Manufacturing sector: manufacturers that use lithium, cobalt, rare earths or other critical minerals as inputs (batteries, electric motors, permanent magnets, electronics).
• Technology sector: semiconductor, consumer electronics and telecommunications companies dependent on critical minerals.
• Renewable energy: manufacturers and installers of solar panels, wind turbines and energy storage systems.
• Automotive sector: manufacturers of electric and hybrid vehicles and their component suppliers (also affected by Regulations 168/2013 and 2018/858 amended by the CRMA).
• Legal and compliance advisors: law firms and legal departments managing contracts and audits linked to the CRMA must update their reference documentation.

Practical example

A Spanish battery manufacturer for electric vehicles that purchases lithium and cobalt from Asian suppliers has in its supply contract a regulatory compliance clause that references the "Regulation (EU) 2024/1252 published on May 3, 2024".

Following the correction published on November 6, 2026, the current and consolidated text is the corrected one. If that company faces a due diligence audit or contract negotiation, its advisory must verify that the clauses reference the corrected version and that there are no discrepancies arising from the technical errors corrected.

On the other hand, this company remains obliged to demonstrate —when the CRMA timelines require it— that its supply chain complies with diversification targets: no supplier from a single third country can represent more than 65% of its lithium or cobalt procurement.

What should companies do now?

1. Update regulatory reference documentation: replace any reference to the original CRMA text (May 3, 2024) with the corrected version (OJ:L_202690953, November 6, 2026) in contracts, internal policies and audits.
2. Review the analysis of exposure to critical raw materials: if a mapping of which critical raw materials (lithium, cobalt, rare earths) the company uses and what proportion comes from a single third country has not yet been carried out, start now.
3. Verify compliance with the 65% limit: audit the supply chain to confirm that no supplier from a single third country exceeds that threshold in any critical raw material.
4. Evaluate opportunities in strategic projects: companies in the mining or processing sector should analyze whether their projects can apply for "strategic project" certification under the CRMA, which provides access to institutional support and accelerated processing.
5. Inform the compliance team and external advisors: communicate the publication of this correction so they update their regulatory databases and do not work with the incorrect text.

Official source

Consult complete regulation on official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690953