Europe’s Critical Raw Materials Act: Big Targets, No Mines

Executive Summary

The EU Critical Raw Materials Act (CRMA) entered into force in May 2024 with non-binding 2030 benchmarks that 10% of annual consumption of strategic raw materials be extracted, 40% processed, and 25% recycled domestically, and that no more than 65% of any strategic raw material come from a single non-EU country by 2030. [1][4] Despite this, the European Court of Auditors (ECA) now warns that the EU “risks falling short of key supply targets” because it remains heavily import-dependent and has made only limited progress in scaling mining, refining and recycling capacity. [4][26]

Of 47 strategic projects approved under the CRMA within the EU, only five are fully funded and just 10 have received permits, leaving 37 still in the approval process and an estimated €22.5 billion capital requirement largely unmet. [2][8][9] A further 13 “strategic projects” outside the bloc will need around €5.5 billion to come online. [3] Against this, the ReSourceEU Action Plan provides only €3 billion of immediate EU funding, and the European Investment Bank (EIB) has pledged about €2 billion per year for critical mineral projects. [5][9]

Meanwhile, Europe still obtains 97% of its magnesium, all of its heavy rare earths, 85% of its light rare earths and 98% of its rare-earth magnets from China, while 63% of global cobalt supply comes from the DRC, three-quarters of which historically flowed to China. [19][20][21][22] Disruptions such as the DRC’s cobalt export suspension and quota system, which more than doubled refined cobalt prices to $25/lb by October 2025, and China’s stop-start rare earth export controls underscore the vulnerability of European supply chains in EVs, renewables, and defense. [6][7]

For procurement, trading, and strategy teams, the implementation gap in the EU Critical Raw Materials Act is no longer a regulatory abstraction; it is a concrete supply, price and geopolitical risk likely to intensify from 2026 through 2030.

Immediate action items

• By end of this week: Map Tier 1-2 suppliers against the 47 EU and 13 non‑EU CRMA strategic projects; flag exposure to unfunded or unpermitted assets in lithium, cobalt, nickel, manganese and graphite. [2][3][9]
• Within 30 days: Establish internal price and policy triggers anchored to DRC cobalt quota developments, Chinese export control timelines (through November 2026), and current lithium price levels in Europe and China. [6][7][11][12]
• By end-Q2 2026: Prioritise offtake, pre‑financing or JV discussions with EIB‑backed and CRMA‑designated projects (e.g., Barroso and Cinovec) and leading battery recyclers positioned to meet 2030 recovery targets. [9][10][13][18][24]

Risk / Impact / Timing

Risk	Indicative Impact	Timing Horizon
Failure to meet CRMA 2030 extraction/processing/recycling benchmarks; continued >65% single‑source dependence for key materials	Material cost escalation across EV, storage and defense value chains; multi‑hundred‑million‑euro exposure per large OEM under high‑price scenarios, given projected EU demand of 540,000 t lithium, 418,000 t graphite and 45,000 t cobalt by 2030. [4][14]	Structural risk building through 2026-2030, with lithium market deficits emerging from 2028 under ambitious climate pathways. [17]
Geopolitical disruption from DRC quotas and potential reinstatement or tightening of Chinese export controls	Price spikes as seen in cobalt’s move from $10/lb to $25/lb in 2025, and rapid lithium price swings; risk of physical supply interruptions to EU cathode, magnet, and alloy producers. [6][7][11][12]	Acute event risk 2025–2027 (DRC quotas and China control window to November 2026), with knock‑on contract and inventory implications thereafter. [6][7]
Permitting, social licence and financing delays for EU mining and processing projects	Under‑delivery of CRMA pipeline: only 10 of 47 EU projects permitted and just five fully funded today, limiting new domestic supply despite rising demand and available EIB support. [8][9][18]	Chronic drag on capacity build‑out this decade; most new EU mines beyond 2027 production start, misaligned with 2030 targets. [2][18]

The Problem

The core problem is a widening gap between the EU Critical Raw Materials Act’s ambitions and on‑the‑ground execution in mining, processing, and recycling.

CRMA sets headline 2030 benchmarks that at least 10% of annual EU consumption of each strategic raw material should be mined domestically, 40% processed inside the EU, and 25% sourced from recycling, while no more than 65% of any strategic raw material at any processing stage should originate from a single non‑EU country. [1][4] These targets were designed to reduce the economic and security risks of Europe’s current import dependence. The ECA, however, concludes that the EU “risks falling short of key supply targets under the CRMA because it remains heavily reliant on imports and has made limited progress in scaling domestic production, refining and recycling.” [4][26]

Strategic project delivery is the principal bottleneck. The Commission has granted “strategic” status to 47 projects within the EU and 13 in partner countries, covering lithium, nickel, cobalt, manganese, graphite and other CRMs vital for batteries, renewables and defense. [2][3][18] Yet only five of the 47 EU projects are fully funded, and just 10 have received permits, leaving 37 still somewhere in the permitting or approval pipeline and implying a capital requirement of roughly €22.5 billion just for the EU projects. [2][8][9] The 13 non‑EU strategic projects together require about €5.5 billion in investment before they can begin operations. [3]

Funding tools exist but are modest relative to needs. The ReSourceEU Action Plan announced in December 2025 provides €3 billion in immediate EU funding for alternative CRM supplies and establishes a European Critical Raw Materials Centre. [5] The EIB has committed to around €2 billion per year in financing for critical mineral projects and has begun signing technical assistance agreements with CRM developers such as Andrada Mining and EcoGraf as part of a broader EIB Group financing push. [9][10] Against the €22.5 billion EU project requirement and €5.5 billion for non‑EU projects, this leaves a large reliance on private and third‑country capital. [3][8][9]

Meanwhile, Europe’s exposure to highly concentrated external supply chains remains extreme. China controls around 60% of global rare earth production and about 90% of refining capacity, while the EU sources all of its heavy rare earths and 85% of its light rare earths from China, along with 98% of its rare‑earth magnets. [19] The EU also obtains around 97% of its magnesium from China and relies on Chinese refining for 100% of its rare‑earth permanent magnets. [21][22] On the cobalt side, roughly 63% of global supply is mined in the Democratic Republic of Congo (DRC), and prior to new quotas about 75% of DRC output went to China, reinforcing a dual dependency. [20]

The DRC’s suspension of cobalt exports in early 2025 and subsequent quota system, which limited Q4 2025 exports to 18,125 mt and is projected to reduce DRC cobalt exports 48% in 2026–2027 versus 2024, demonstrates how policy in a single supplier can trigger global price and availability shocks. [6] Refined cobalt prices more than doubled from around $10/lb in early 2025 to about $25/lb by October 2025. [6]

At the same time, EU demand for critical minerals is set to surge. Commission projections indicate lithium demand could rise 12‑fold by 2030 and 21‑fold by 2050, while rare earth demand may increase six‑fold by 2030 and seven‑fold by 2050, driven by electromobility and renewable energy. [22] Fastmarkets estimates that by 2030 the EU will require approximately 540,000 mt of lithium (LCE), 418,000 mt of graphite and 45,000 mt of cobalt annually. [14]

This combination of rapidly growing demand, entrenched dependence on China and the DRC, and under‑delivering domestic project pipelines creates clear downside risk for EU industrial competitiveness and energy transition timelines – particularly for OEMs and defense/aerospace firms that cannot easily relocate production or redesign material inputs.

Current State

The implementation trajectory of the EU Critical Raw Materials Act and related policies from 2024 through early 2026 reveals a pattern: high‑level ambition, growing project pipelines, but slow conversion into bankable, permitted assets and only partial mitigation of external supply risks.

2024–early 2025: CRMA enters into force and first project wave

The CRMA, formally Regulation (EU) 2024/1252, entered into force on 23 May 2024. [1] It set benchmark targets (10% extraction, 40% processing, 25% recycling, maximum 65% single‑country dependence) and introduced accelerated permitting timelines: 27 months for extraction projects and 15 months for processing and recycling projects designated as strategic. [1]

On 25 March 2025, the European Commission approved 47 strategic projects across 13 member states covering mining, processing, and recycling of key materials including lithium, nickel, cobalt, manganese and rare earths. [2][18] These projects require an estimated €22.5 billion in capital investment. [8] The portfolio includes 22 lithium projects, 12 nickel, 10 cobalt and seven manganese assets, indicating a strong focus on battery materials. [18]

At the same time, the EU moved to externalise some of its raw material strategy. By mid‑2025, the Commission had concluded 15 strategic partnerships with resource‑rich countries including Argentina, Australia, Canada, Chile, the DRC, Kazakhstan, Namibia, Norway, Rwanda, Serbia, Ukraine and Zambia, supported by the €300 billion Global Gateway infrastructure investment framework. [23] These partnerships are intended to underpin the 13 non‑EU strategic projects identified later in 2025. [3][23]

Mid–late 2025: External shocks and ReSourceEU

In early 2025, the DRC suspended cobalt exports, moving in October 2025 to a quota system that capped Q4 exports at 18,125 mt and is projected to lower exports by 48% in 2026–2027 compared to 2024. [6] The result was a sharp tightening of the refined cobalt market and a price surge from roughly $10/lb in early 2025 to about $25/lb by October. [6] Analysts estimate that if domestic production does not fall, more than 100,000 mt of cobalt per year could require storage in the DRC due to restricted exports, creating further market distortions. [6]

On 4 June 2025, the Commission recognised 13 additional strategic projects located outside the EU in countries including Canada, Brazil, Ukraine, Kazakhstan, Norway and South Africa, with an estimated capital need of around €5.5 billion. [3] Ten of these are focused on EV and battery materials such as lithium, cobalt, nickel, manganese and graphite. [3] The Commission stated that these non‑EU projects “will contribute to the competitiveness of EU’s industry and in particular sectors such as electromobility, renewable energy, defense and aerospace.” [3]

Domestic project implementation, however, began to encounter the familiar headwinds of permitting complexity and social opposition. In Romania, for example, the Rovina copper‑gold project – the EU’s largest mining development – faced legal challenges from NGOs and community organisations over environmental and social impacts. [18] In the Czech Republic, Jaromír Starý of the Czech Geological Survey argued that the CRMA’s 10% domestic extraction target was unrealistic for some critical raw materials because they are simply not found in sufficient quantities in Europe, stating that “at present it is impossible to say that some of the critical raw materials will be handled in quantities of up to 10% of European consumption.” [16]

On 3 December 2025, the Commission launched the ReSourceEU Action Plan, pledging €3 billion in near‑term funding to secure alternative CRM supplies and establish the European Critical Raw Materials Centre. [5] Executive Vice‑President Stéphane Séjourné framed it as Europe “asserting its independence regarding critical raw materials.” [15] Yet industry voices stressed how far the EU had to go. Anne Lauenroth of the Federation of German Industries noted that “Europe outsourced part of the mining and processing capacity and expertise in the last decades; there was a big underinvestment in these areas.” [15]

On 7 November 2025, China announced a temporary suspension of the second wave of its rare‑earth and critical‑mineral export controls until 10 November 2026, easing immediate fears but underscoring Beijing’s willingness to wield its dominant position. [7][19] China currently accounts for about 60% of global rare earth production, around 90% of refining, and supplies the EU with all of its heavy rare earths, 85% of light rare earths and 98% of rare‑earth magnets. [19]

Early 2026: Auditors’ warning and market tightness

In February 2026, the European Court of Auditors released Special Report 04/2026, concluding that the EU’s diversification efforts and CRMA implementation were unlikely to deliver the targeted supply security on their current trajectory. [4][26] The report argued that the EU “does not monitor the effect of these initiatives on supply” and that “the CRMA’s impact is further weakened by gaps in the underlying data and by targets that are not always supported by robust evidence — limitations that make it harder to track progress and guide investment.” [4]

The auditors highlighted the underdevelopment of domestic processing and refining capacity, noting that European metals and refining facilities have been shrinking and that the lack of technology and unfavorable economics deter new investments. [26] This aligns with broader assessments that EU processing capacity for battery metals and rare earths is significantly lagging CRMA aspirations. [4][19][22]

On the demand and price side, early 2026 data signalled renewed tightness. S&P Global Platts assessed February 2026 CIF Europe lithium carbonate and hydroxide prices in the $17,800–$18,500/mt range. [11] In China, lithium spot prices reached about 159,000 CNY/t as of 11 March 2026, up 112.28% year‑on‑year. [12] Wood Mackenzie forecasts that the global lithium market is heading into a supply crunch much sooner than many expect, with deficits emerging from 2028 under ambitious climate scenarios. [17]

Battery recycling, a pillar of the CRMA’s 25% recycling benchmark, also lags. EU regulations foresee recovery targets of 70% for lithium and 95% for cobalt, lead, nickel, and copper from EV batteries by 2030. [13] Yet the ECA notes “limited progress in scaling domestic production, refining and recycling,” suggesting that current and planned facilities are not yet on a trajectory to meet those recovery targets at scale. [4][26]

Against this backdrop, CRMA‑designated flagship projects such as Savannah Resources’ Barroso lithium project in Portugal – targeting 200,000 t/year of spodumene concentrate by 2027 – and the Cinovec lithium project in the Czech Republic – the EU’s largest hard‑rock lithium resource, targeting a definitive feasibility study by mid‑2025 and EIA submission by end‑2025 – remain in the development phase. [18][24] Their eventual commissioning is crucial to EU battery material self‑sufficiency, but their timelines mean that most new EU lithium supply will materialise only in the latter half of this decade, if projects can overcome permitting and social‑licence challenges. [18][24]

Key Data & Trends

The implementation gap in the EU Critical Raw Materials Act is best understood through four data lenses: the scale of the targets, the shape of projected demand, the status of the project pipeline, and the depth of Europe’s external dependencies.

1. CRMA 2030 benchmarks codify an aggressive reshaping of supply

The CRMA’s non‑binding benchmarks quantify how radically the EU aims to alter its supply structure by 2030. [1][4]

This chart shows the CRMA’s 2030 targets: 10% of annual EU consumption of each strategic raw material to be mined domestically, 40% to be processed within the EU, and 25% to come from recycling. [1][4]

For operators, the key takeaway is that the EU is not merely seeking incremental diversification; it is attempting to re‑anchor a large fraction of supply chains within its borders in less than a decade. Achieving 25% recycling implies massive investment in collection, dismantling and processing infrastructure, aligned with stringent 2030 recovery targets (70% lithium; 95% cobalt, nickel, copper, lead) for EV batteries. [1][13]

2. Demand growth is dominated by lithium and graphite

Projected EU 2030 demand indicates where supply bottlenecks will bite hardest.

Fastmarkets projects that by 2030, the EU will require around 540,000 mt of lithium (LCE), 418,000 mt of graphite and 45,000 mt of cobalt annually. [14]

Strategically, this underscores why CRMA pipelines are heavily weighted towards lithium and graphite assets and why lithium market dynamics (including China’s 112% year‑on‑year price increase as of March 2026) are likely to be the primary driver of battery cost risk for European OEMs. [12][14][17] Cobalt demand growth is smaller in tonnage terms, and some of it may be offset by shifts to cobalt‑free chemistries such as LFP, where China accounts for 70% of the domestic market and 99% of global cathode and cell production. [17][25]

3. Project pipeline: a large portfolio with thin funding and slow permitting

The EU’s 47‑project strategic pipeline appears impressive on paper but is constrained in practice by capital and permitting bottlenecks.

Of 47 EU strategic projects approved under the CRMA, only 10 have permits, 37 remain in the approval process, and just five are fully funded. [2][8][9]

For corporate strategists, this means that most “strategic” projects should currently be treated as optionality rather than firm supply. Anchor customers and financiers will be decisive in determining which projects advance. The EIB’s commitment of roughly €2 billion per year and the EU’s €3 billion ReSourceEU envelope are meaningful but insufficient to de‑risk the full €22.5 billion project slate plus €5.5 billion for non‑EU assets. [3][5][8][9]

Moreover, community and NGO opposition, exemplified by the Rovina project, increase execution risk even for technically sound projects, and may lead to further delays despite the CRMA’s 27‑ and 15‑month permitting caps. [1][18]

4. Structural dependence on China remains extreme

Outside the battery complex, CRMA faces an even steeper uphill battle in rare earths and magnesium, where the EU is almost entirely dependent on Chinese supply.

The EU sources about 97% of its magnesium from China and relies on China for 100% of heavy rare earths, 85% of light rare earths and 98% of rare‑earth magnets. [19][21][22]

This concentration far exceeds the CRMA’s 65% single‑supplier benchmark and leaves Europe acutely exposed to Chinese export policy, environmental inspections, and domestic demand cycles. [4][19][22] European Central Bank economists estimate that over 80% of large European firms are no more than three intermediaries away from a Chinese rare‑earth producer, underlining the depth of embedded dependence. [19]

Given that 34 materials are on the EU’s critical list – including lithium, cobalt, graphite, magnesium, silicon metal, gallium, nickel and rare earths – the combination of limited domestic geology (for some materials), decades of underinvestment in mining and refining, and entrenched third‑country concentration represents a structural challenge rather than a short‑term gap. [15][16][21][22]

Risks & Scenarios

Available evidence supports three broad scenarios for CRMA implementation and Europe’s critical material security to 2030. The research base does not allow for robust quantification of probabilities, so what follows is a structured, qualitative assessment rather than a numerical forecast.

Scenario 1 – Managed shortfall: partial success, structural dependence persists

In this most plausible scenario, the EU makes measurable progress but falls short of its 2030 benchmarks.

Under this path, a subset of the 47 EU strategic projects reaches funding and permitting milestones by the late 2020s, supported by EIB financing and ReSourceEU, with lithium flagships such as Barroso and Cinovec entering production close to or shortly after 2027. [5][9][18][24] Several of the 13 non‑EU strategic projects advance, particularly in jurisdictions with strong governance (Canada, Norway, Australia), contributing additional diversified supply for EV and battery metals. [3][23]

However, permitting delays, social‑licence challenges, and limited private capital appetite mean that many projects slip beyond 2030. The ECA’s concerns about data gaps, weak monitoring of diversification outcomes, and underdeveloped processing capacity remain only partially addressed. [4][26] The EU edges closer to, but does not fully achieve, the 10/40/25 extraction‑processing‑recycling benchmarks, and dependence on China and the DRC remains above the 65% threshold for several key materials, especially magnesium, rare earths and some battery precursors. [19][21][22]

Implications: supply is available but at structurally higher prices and under continued geopolitical risk. OEMs and defense contractors must navigate periodic price spikes (similar to the cobalt surge in 2025 and recent lithium volatility) and carry higher strategic inventories. [6][11][12][17]

Scenario 2 – Escalation: geopolitical shocks collide with implementation delays

In a more adverse scenario, external shocks coincide with under‑delivery of CRMA projects.

This would involve tighter or extended DRC cobalt quotas beyond the 2026–2027 window already projected to cut exports by 48% compared to 2024, reinforcing high cobalt prices and periodically constraining physical availability. [6] Simultaneously, China could reinstate and broaden rare‑earth and critical‑mineral export controls after the current suspension expires in November 2026, potentially covering additional downstream products such as magnets or key battery precursors. [7][19]

Under this scenario, progress on EU mining and refining remains slow: community opposition stalls projects like Rovina, and only a handful of new EU assets reach production before 2030. [18] Recycling capacity scales but fails to hit the 70% lithium and 95% cobalt/nickel/copper targets, limiting the contribution of secondary supply. [4][13][26] Global lithium deficits from 2028 under ambitious climate scenarios materialise, amplifying the effect of supply disruptions on prices. [17]

Implications: This scenario would see recurring, potentially severe supply squeezes in lithium, cobalt and rare earths, with downstream curtailments in EU EV and battery manufacturing, elevated hedging costs, and a greater likelihood of direct state intervention (e.g., strategic stockpiles, export restrictions on EU‑produced technologies).

Scenario 3 – Accelerated adjustment: funding and policy alignment narrow the gap

In a more benign scenario, the EU responds decisively to the ECA’s 2026 warning and accelerates implementation.

Under this path, the Commission strengthens monitoring of diversification outcomes, addresses data gaps, and further streamlines permitting beyond the CRMA’s current timelines. [1][4][26] Additional EU and member‑state capital is mobilised alongside the EIB’s €2 billion per year and existing €3 billion ReSourceEU funding, enabling a larger share of the 47 EU and 13 external projects to achieve bankability and reach construction within the decade. [3][5][8][9]

Battery recycling capacity ramps up more quickly, helping the EU converge towards 70% lithium and 95% cobalt/nickel/copper recovery from EV batteries by 2030, thereby partially insulating the bloc from primary market deficits. [13] Meanwhile, technology shifts – such as increased adoption of LFP chemistries and material thrifting in cathodes and magnets – reduce demand pressure for the scarcest inputs, particularly cobalt and some heavy rare earths. [17][25]

Implications: Even in this optimistic scenario, the EU is unlikely to attain full autonomy; geology, historical underinvestment and entrenched Chinese strength in processing limit the scope for reshoring. [15][19][22][26] But supply risks would be more manageable, price volatility somewhat reduced, and Europe’s bargaining position in global markets improved.

Risk matrix: timing and impact

Across scenarios, two timing axes matter:

• 2025–2027 (acute shock window): Dominated by DRC cobalt quotas, potential re‑tightening of Chinese export controls after November 2026, and emerging lithium market tightness. [6][7][11][12][17]
• 2028–2030 (structural balance window): Determined by how many CRMA strategic projects reach operation, the maturity of recycling infrastructure, and whether demand growth follows the EU’s high‑ambition pathway (12x lithium, 6x rare earths by 2030) or a slower track. [14][17][22]

For risk managers, this suggests focusing near‑term on shock absorption (inventory, flexible offtake, diversification) and medium‑term on structural repositioning (equity stakes, JV refining, and deep recycling integration).

Actionable Intelligence

The following checklists translate the CRMA implementation gap and associated market risks into concrete actions for procurement directors, supply chain strategists, and trading desks.

Do Now (next 4–6 weeks)

• Map exposure to CRMA‑dependent supply – Build a cross‑functional map linking Tier 1–2 suppliers and critical components (cathodes, anodes, magnets, high‑performance alloys) to the 47 EU and 13 non‑EU CRMA strategic projects. Classify each exposure by project status (permitted vs. in approval), funding status, material (lithium, cobalt, nickel, manganese, graphite, rare earths) and geography. [2][3][9][18] Ownership: Strategic sourcing. Deadline: 30 days.
• Anchor risk metrics to current market and policy reference points – Define internal alert thresholds using documented benchmarks: cobalt prices doubling to $25/lb in 2025 under DRC quotas; current lithium CIF Europe prices ($17,800–$18,500/mt); Chinese spot at 159,000 CNY/t; and the current suspension window of Chinese export controls (to November 2026). [6][7][11][12] Ownership: Risk/treasury. Deadline: 2 weeks.
• Re‑paper offtake and supply contracts – Review key raw material and intermediate offtake contracts to ensure pricing and force‑majeure clauses explicitly account for export quota regimes, export controls, and regulatory changes linked to CRMA implementation. Prioritise contracts covering cobalt, lithium and rare earths, where policy risk is already visible. [6][7][11][12][19] Ownership: Legal & procurement. Deadline: Contract review plan within 4 weeks.
• Identify priority recycling and circularity partners – Given the 25% recycling benchmark and 70%/95% recovery targets for lithium and other metals, undertake a shortlisting of EU‑based and allied‑market recyclers with credible scaling plans to 2030. [1][13] Ownership: Sustainability & supply chain. Deadline: Initial longlist in 6 weeks.
• Stress‑test production plans against 2028 lithium deficit scenarios – Use publicly available Wood Mackenzie scenarios to test the sensitivity of your 2028–2032 production plans to lithium supply deficits and price spikes, given EU lithium demand projections. [14][17][22] Ownership: Corporate planning. Deadline: Initial stress test in 6 weeks.

Do in Q2–Q4 2026 (medium term)

• Engage early with strategic projects as an anchor customer – For materials where dependence is most acute (lithium, graphite, rare earths, magnesium), initiate structured dialogues with developers of CRMA strategic projects (e.g., Barroso, Cinovec) and EIB‑backed external projects to explore long‑term offtake, pre‑payment, or equity participation. [3][9][10][18][24] Early commitments can improve project bankability and give buyers preferential access.
• Design a multi‑jurisdiction sourcing portfolio – Leverage the EU’s 15 strategic partnerships (e.g., Canada, Australia, Norway, Namibia, Chile, Argentina, Ukraine) to diversify away from single‑country exposure that violates the CRMA’s 65% benchmark. [4][20][21][22][23] Build procurement scenarios that incorporate a minimum of three non‑EU source regions per critical material at the processing stage.
• Co‑develop refining and processing capacity – The ECA underlines the underdevelopment of domestic processing; consider joint ventures, tolling arrangements or long‑term commitments with emerging refining projects in the EU or allied countries. [4][21][22][26] Focus on battery precursors, rare‑earth separation, and magnesium alloying, where Chinese dominance is strongest. [19][21][22]
• Integrate recycling into procurement strategy – Treat secondary material flows as a strategic “source country.” Map anticipated scrap and end‑of‑life volumes across product lines and align with recycling partners to meet or exceed 2030 recovery targets. [13] For OEMs, include recycled content requirements in supplier scorecards.
• Establish a CRMA implementation taskforce – Create an internal working group to track regulatory updates (including implementing acts, delegated acts and guidance), permitting developments for key projects, and EIB/Global Gateway financing opportunities. [5][8][9][23] This taskforce should feed directly into sourcing and capex decisions.

Do by 2026 and beyond (strategic positioning)

• Take strategic equity stakes in upstream and midstream assets – For large energy, automotive, and aerospace groups, minority equity stakes in CRMA‑aligned projects (both mining and refining) can secure long‑term supply, provide visibility into project execution risk, and align incentives with project financiers and host governments. [2][3][8][9][18]
• Invest in design and material substitution to reduce exposure – Use the 2026–2030 window to scale technologies that reduce dependency on the scarcest inputs: cobalt‑lean or cobalt‑free batteries (e.g., LFP), rare‑earth‑light or rare‑earth‑free motors, and alternative alloys for magnesium‑intensive components. [17][19][21][22][25] This aligns with the observed shift in the critical minerals debate from purely decarbonisation to defense and security concerns. [15]
• Shape permitting and social‑licence frameworks – Engage constructively with EU and member‑state authorities to support predictable, robust permitting regimes that reconcile speed with environmental and social safeguards. [1][18][26] Corporate participation in community benefit schemes and transparent ESG reporting can help reduce the risk of Rovina‑type challenges for projects critical to your supply chain.
• Develop strategic inventories and storage solutions – Given the DRC’s likely need to store over 100,000 mt of cobalt annually under the quota regime, and Europe’s high import dependency, assess the economics and logistics of holding higher critical material inventories, either individually or via shared industry stockpiles. [6][20]
• Integrate CRMA metrics into enterprise risk management – Incorporate CRMA benchmarks (10/40/25 and 65% single‑country limit) as internal risk KPIs for critical materials. [1][4] Regularly report to the board on deviations from these benchmarks in your procurement profile and progress on remediation.

Signals to Watch

To manage CRMA‑related risks proactively, operators should track a focused set of weekly indicators and treat specific thresholds or events as triggers for tactical action.

• Cobalt price and DRC policy trajectory – Monitor refined cobalt prices relative to the October 2025 level of around $25/lb and watch for announcements on adjustments to the DRC’s export quotas, currently projected to cut exports by 48% in 2026–2027 versus 2024. [6] Sustained moves materially above that price, coupled with stricter quotas, should prompt inventory and contract reviews.
• Lithium price differentials (China vs. CIF Europe) – Track Chinese spot prices – 159,000 CNY/t as of 11 March 2026, up 112% year‑on‑year – alongside CIF Europe carbonate and hydroxide prices (~$17,800–$18,500/mt in early February 2026). [11][12] Widening or persistent differentials can signal logistical or policy frictions affecting European buyers.
• Chinese export control announcements – Follow developments regarding the current suspension of China’s second wave of rare‑earth and critical‑mineral export controls, valid until 10 November 2026. [7] Any move to reinstate or broaden controls to magnets or battery precursors should trigger scenario updates and accelerated diversification efforts.
• Permitting milestones for key EU projects – Watch for EIA approvals, mining licences and construction decisions on Barroso, Cinovec and other large CRMA strategic projects, as well as resolution of legal challenges at Rovina. [18][24] Each major permit materially changes the medium‑term supply outlook for specific materials.
• EU recycling capacity announcements and regulation – Track new investment decisions and policy updates related to battery recycling and CRM recovery targets (70% lithium; 95% cobalt, nickel, copper, lead by 2030). [13] Evidence of lagging investment or regulatory delays would strengthen the case for securing primary supply and developing in‑house circular solutions.

Sources

[1] European Parliament – “European Critical Raw Material Act (Regulation EU 2024/1252)” – https://www.europarl.europa.eu/legislative-train/theme-a-europe-fit-for-the-digital-age/file-european-critical-raw-material-act

[2] European Commission – “Commission approves 47 strategic projects under the Critical Raw Materials Act” (Press materials), 25 March 2025 — https://ec.europa.eu/commission/presscorner/detail/en/ip_25_864

[3] S&P Global Commodity Insights (Energy) — “EU identifies 13 new strategic critical mineral projects located outside bloc,” 4 June 2025 — https://www.spglobal.com/energy/en/news-research/latest-news/metals/060425-eu-identifies-13-new-strategic-critical-mineral-projects-located-outside-bloc

[4] S&P Global Commodity Insights (Energy) — “EU faces uphill battle to meet critical raw materials targets – auditors report,” 4 February 2026 — https://www.spglobal.com/energy/en/news-research/latest-news/metals/020426-eu-faces-uphill-battle-to-meet-critical-raw-materials-targets-auditors-report

[5] European Commission — “New measures to secure raw materials and strengthen the EU’s economic security” (ReSourceEU Action Plan), 3 December 2025 — https://commission.europa.eu/news-and-media/news/new-measures-secure-raw-materials-and-strengthen-eus-economic-security-2025-12-03_en

[6] S&P Global Market Intelligence — “DRC cobalt export quotas to support cobalt prices though challenges loom,” October 2025 — https://www.spglobal.com/market-intelligence/en/news-insights/research/2025/10/drc-cobalt-export-quotas-to-support-cobalt-prices-though-challenges-loom

[7] Clark Hill — “China hits pause on rare earth export controls and what it means for supply chains,” 7 November 2025 — https://www.clarkhill.com/news-events/news/china-hits-pause-on-rare-earth-export-controls-and-what-it-means-for-supply-chains/

[8] UNCTAD Investment Policy Monitor — “Streamlines permitting and enhances access to finance for 47 strategic projects under the Critical Raw Materials Act,” March 2025 — https://investmentpolicy.unctad.org/investment-policy-monitor/measures/5127/streamlines-permitting-and-enhances-access-to-finance-for-47-strategic-projects-under-the-critical-raw-materials-act-

[9] Hatch — “47 European Strategic Projects,” blog, 2026 — https://www.hatch.com/About-Us/Publications/Blogs/2026/01/47EUR-Projects

[10] European Investment Bank — “EIB Global backs sustainable critical raw material projects in Africa,” 2026 — https://www.eib.org/en/press/all/2026-050-eib-global-backs-sustainable-critical-raw-material-projects-in-africa

[11] S&P Global Platts / Commodity Insights — Lithium carbonate and hydroxide CIF Europe price assessments, 3 February 2026 — (referenced in S&P coverage) — https://www.spglobal.com/energy/en/news-research/latest-news/metals/020426-eu-faces-uphill-battle-to-meet-critical-raw-materials-targets-auditors-report

[12] Trading Economics — “Lithium” commodity price data, 11 March 2026 — https://tradingeconomics.com/commodity/lithium

[13] Battery Tech Online — “EU boosts EV battery recycling for clean energy transition” — https://www.batterytechonline.com/ev-batteries/eu-batteries/eu-boosts-ev-battery-recycling-for-clean-energy-transition

[14] Fastmarkets — “EU Critical Raw Materials Act: demand outlook and implications,” (EU CRM Act feature) — https://www.fastmarkets.com/metals-and-mining/eu-critical-raw-materials-act/

[15] Fastmarkets — “EU’s critical minerals strategy: €3 billion boost amid industry risks,” December 2025 — https://www.fastmarkets.com/insights/eus-critical-minerals-strategy-e3-billion-boost-amid-industry-risks/

[16] Euronews — “From lithium to rare earths: Europe’s strategy to power its future energy,” 4 June 2025 — https://www.euronews.com/my-europe/2025/06/04/from-lithium-to-rare-earths-europes-strategy-to-power-its-future-energy

[17] Mining.com / Wood Mackenzie — “Lithium demand to top 13m tonnes by 2050 – WoodMac,” — https://www.mining.com/lithium-demand-to-top-13m-tonnes-by-2050-woodmac/

[18] Mining Magazine — “47 European strategic projects announced,” 2025 — https://www.miningmagazine.com/europe/news-analysis/4411420/47-european-strategic-projects-announced

[19] European Parliament Research Service — “EU dependence on critical raw materials,” 2025 briefing (includes rare earths and supply chain analysis) — https://www.europarl.europa.eu/RegData/etudes/ATAG/2025/779220/EPRS_ATA(2025)779220_EN.pdf

[20] Modern Diplomacy — “Congo’s cobalt curbs expose China’s critical metals vulnerability,” 25 February 2026 — https://moderndiplomacy.eu/2026/02/25/congos-cobalt-curbs-expose-chinas-critical-metals-vulnerability/

[21] European Commission — “Critical raw materials” (Single Market Economy) — https://single-market-economy.ec.europa.eu/sectors/raw-materials/areas-specific-interest/critical-raw-materials_en

[22] European Commission — “European Critical Raw Materials Act and Green Deal Industrial Plan” overview pages — https://commission.europa.eu/topics/competitiveness/green-deal-industrial-plan/european-critical-raw-materials-act_en

[23] European Commission — “Raw materials diplomacy and Global Gateway” — https://single-market-economy.ec.europa.eu/sectors/raw-materials/areas-specific-interest/raw-materials-diplomacy_en

[24] Crux Investor — “Europe’s strategic lithium player targeting 2027 production” (Savannah Resources, Barroso Project) — https://www.cruxinvestor.com/posts/europes-strategic-lithium-player-targeting-2027-production

[25] Cobalt Institute — “Cobalt Market Report 2024,” May 2025 — https://www.cobaltinstitute.org/wp-content/uploads/2025/05/Cobalt-Market-Report-2024.pdf

[26] European Court of Auditors — Special Report 04/2026 on EU critical raw materials (processing capacity, data gaps, implementation risks) — https://www.eca.europa.eu/ECAPubli

Materials Dispatch cares about the current lithium cycle because it is reshaping three hard constraints simultaneously: supply security for EV and battery energy storage system (BESS) build‑out, compliance with evolving US/EU rules, and the operational survival of upstream and midstream projects that have already absorbed large capital and political attention. The 2022 spike and subsequent lithium price crash towards 2025 exposed how thinly engineered many supply chains really were: plenty of projects talked about “strategic metal security”; far fewer could ride through a multi‑year downturn without scrambling contracts, workforces, and permitting commitments.

Across procurement cycles and technical due diligence rounds that Materials Dispatch has followed over the last decade, lithium moved from a niche specialty to a central risk item. The combination of lithium oversupply in the mid‑2020s, growing inventories, idled capacity, and a looming ramp in EV and BESS demand has forced a re‑rating of what “security of supply” actually means. The old reflex-lock as much volume as possible, as fast as possible-has collided with negative cash margins, refining bottlenecks in China, and compliance filters such as the US Inflation Reduction Act (IRA) and emerging EU rules on critical raw materials.

• The change: After an extreme upswing in 2022, lithium prices have fallen sharply into what many forecasts describe as a 2025 oversupply trough, with some analyst curves showing surpluses on the order of 100,000+ mt LCE and inventories in the hundreds of thousands of tonnes equivalent.
• What is covered: This briefing focuses on 2025-2026 lithium market balance, lithium price forecast narratives, China lithium refining capacity and dominance, and the survivorship logic across different producer archetypes.
• Operational read‑across: To the extent that forecasts materialise, low‑cost, flexible assets with access to stable refining routes-often via China—look structurally more resilient than smaller or higher‑cost hard‑rock projects dependent on a narrow set of offtakers.
• Scope limits: All forward‑looking volumes, surplus/deficit estimates, and cost bands come from public analyst and industry commentary; they remain inherently uncertain and sensitive to EV/BESS adoption, policy shifts, and project execution.
• Regulatory lens: Geopolitical and compliance filters (IRA, EU critical raw materials initiatives, potential strategic stockpiles) are increasingly as decisive as pure cost in shaping which tonnes matter for supply chains.

FACTS: Market Balance, Price Crash, and Structural Asymmetries

Lithium price crash 2025: from tightness to apparent glut

Public benchmarks and industry commentary agree on one core observation: the lithium price crash into the mid‑2020s is real and steep. Spot prices for lithium chemicals reportedly moved from 2022 highs above the $80,000/mt range to levels below $10,000/mt by around 2025 in some assessments. This collapse is widely attributed to a combination of aggressive supply additions—especially out of Australia and China—and EV demand growth that, while strong, did not match the most optimistic curves that underpinned project sanctioning.

Several analyst houses describe 2025 as a year of clear oversupply, with one widely cited forecast pointing to a surplus around 141,000 mt LCE in 2025, narrowing to about 109,000 mt LCE in 2026, against demand in the vicinity of 1.5 million mt LCE and annual growth in the low teens in percentage terms. Other scenarios are more aggressive, suggesting demand could approach 2 million mt LCE by 2026 if EV and BESS deployments accelerate faster than base case assumptions.

These figures do not represent a single consensus number; they are indicative of the band within which reputable market analyses cluster. Some research groups go further and sketch a potential swing from surplus in 2025 to deficit in 2026, with forecast gaps ranging from a marginal 1,500 mt shortfall to tens of thousands of tonnes of implied deficit in more bullish electrification scenarios.

Inventories, idled capacity, and the “hidden buffer”

One of the striking features of current lithium market discussion is the emphasis on inventory and mothballed capacity as a hidden buffer. Industry commentary describes global inventories on the order of several hundred thousand tonnes LCE—around 350,000 mt is one frequently quoted figure—built up through 2023-2025 as supply growth outpaced real‑time demand.

At the same time, a wave of output cuts and project slowdowns has emerged, particularly among higher‑cost hard‑rock operations and development‑stage assets. Reports of curtailed production from Australian spodumene mines, delays to new greenfield projects, and early‑stage brine or direct lithium extraction (DLE) schemes pushing timelines back by several years are now commonplace in trade and financial press. Some analyses suggest restart lags in the range of 2-5 years for idled or heavily scaled‑back projects, once prices and contract conditions justify reactivation.

China lithium refining capacity and concentration risk

On the midstream side, Chinese dominance in lithium chemical refining remains a central structural fact. Multiple data series place China’s share of global lithium refining capacity around 60 percent, with some forecasts indicating total Chinese refining capacity could exceed 2 million mt LCE per year by the middle of the decade if current expansion plans proceed.

This dominance is not limited to volume. Chinese refiners and integrated battery players have also pushed into lower‑grade or more complex resources, including lepidolite and mica ores, under business cases that many Western analysts label as “unsustainable” at mid‑cycle prices. Yet, in practice, these operations have contributed to the oversupply picture and reinforced China’s ability to shape intermediate product availability and quality, particularly for hydroxide used in high‑nickel cathode chemistries.

Cost bands, survival thresholds, and producer archetypes

Across public cost curves and company disclosures, a rough hierarchy of cost positions emerges. Industry commentary often groups producers into broad bands:

• Low‑cost incumbents – Typically brine‑based producers in South America or highly optimised integrated operations, often cited with cash costs below roughly $5,000–8,000/mt LCE.
• Middle‑of‑the‑pack hard‑rock players – Established spodumene miners with reasonable logistics and/or partial integration, frequently discussed in the mid‑single to low‑double‑digit thousands of dollars per tonne.
• Marginal assets – Smaller, higher‑cost projects, new greenfield developments, or operations with challenging ore bodies, sometimes described with cost structures above $12,000–15,000/mt LCE.

In public debate, survival in a low‑price environment is often equated with staying below the mid‑single‑digit thousands of dollars per tonne, at least on a cash basis, while assets in the high‑teens or above are repeatedly cited as being at risk of curtailment or closure if prices remain depressed. These bands are inherently approximate; each asset’s economics also depend on by‑products, integration, financing structure, and jurisdictional factors.

Company names recur across analyses. Integrated Chinese groups such as Ganfeng Lithium and Tianqi Lithium, diversified Western majors like Albemarle, and brine specialists such as SQM are frequently mentioned as sitting toward the lower end of the global cost curve. On the battery side, CATL is often highlighted as a central node, combining battery manufacturing scale with upstream stakes and long‑term offtake positions. On the more vulnerable side, a cluster of smaller Australian hard‑rock companies, some Canadian and Brazilian developers, and a set of early‑stage DLE projects are repeatedly classified as higher‑risk under prolonged low‑price conditions.

Policy and regulatory overlays

Policy signals are increasingly embedded in lithium market outlook 2026 discussions. Three themes show up consistently:

• IRA and “foreign entity of concern” rules in the United States, which constrain eligibility for subsidies depending on the origin of critical materials and processing.
• EU critical raw materials regulation proposals, including domestic capacity targets and diversification requirements for strategic inputs.
• Strategic stockpile concepts, including open discussion in US policy circles about a potential Strategic Lithium Reserve, although concrete design and timelines remain fluid and not formally codified.

These frameworks do not change the geology or chemistry, but they meaningfully affect which tonnes are considered “usable” for certain end‑uses and so influence offtake decisions, financing, and long‑term planning.

INTERPRETATION: From 2025 Oversupply to a 2026 Pivot

2025 as oversupply trough, 2026 as potential inflection

Read across the major lithium price forecast narratives, a common pattern appears: 2025 is treated as the nadir of oversupply, while 2026 is framed as a pivot year where surplus narrows sharply and could, under certain demand and policy combinations, flip into deficit.

If demand grows in the low‑ to mid‑teens percent annually—as many base‑case EV and BESS scenarios suggest—then even modest project delays and sustained production cuts among marginal assets could erode the currently projected surplus band (around 100,000+ mt LCE). In higher demand trajectories, with BESS and commercial EV segments accelerating faster than anticipated, market balance models start to show deficits on the order of tens of thousands of tonnes by 2026.

The operational reality behind these charts is more important than the exact deficit or surplus number. If high‑cost producers reduce output for multiple years, and if reactivation takes 2–5 years once prices recover, then the system loses optionality. The market can look oversupplied on paper in 2025 while quietly setting up a tight 2026–2028 window where availability of battery‑grade material becomes binding again, particularly for buyers constrained by geography or compliance filters.

Survivors vs casualties: what actually drives resilience

Based on the producer archetypes that keep appearing in public analysis, four variables seem to drive survival through the lithium oversupply and into the next tightening phase:

• Cash cost and all‑in sustaining economics – Assets with cash costs under roughly $5,000–8,000/mt LCE have clear breathing room in a sub‑$10,000 environment, especially if they benefit from integrated refining or by‑products. Projects with costs above $12,000–15,000/mt are repeatedly flagged as exposed if low prices persist.
• Access to processing capacity – Physical mining capacity is not useful without reliable conversion into battery‑grade chemicals. In practice, access to Chinese converters—or equivalent non‑Chinese facilities that meet OEM specifications—has become a decisive differentiator.
• Ability to flex volumes – Operations and corporate structures that can credibly idle, maintain, and restart without destroying balance sheets are better placed to ride out a multi‑year downswing and capture upside when conditions tighten.
• Geopolitical and compliance positioning – Tonnes that qualify for IRA or EU critical raw materials criteria carry strategic weight beyond their immediate economics, especially for North American and European OEM supply chains.

Within this framework, integrated Chinese players combining upstream stakes, large‑scale refining, and captive battery demand appear structurally advantaged in a prolonged downturn: they can run plants to support domestic EV and BESS roll‑out and gradually absorb low‑cost feedstock. Large incumbents in Chile, established hard‑rock producers in Australia with solid balance sheets, and diversified Western majors with significant brine exposure also look more resilient on paper than single‑asset juniors or late‑stage developers.

On the casualty side, smaller hard‑rock miners with thin margins, dependence on a narrow set of Chinese offtakers, and limited access to non‑Chinese refining routes face a harsh environment if prices linger at or below the low end of analyst ranges. Developers that sanctioned projects assuming sustained prices well north of the current levels, particularly in high‑cost jurisdictions or with heavy infrastructure requirements, are similarly exposed.

A two‑tier market: Chinese‑centric vs compliance‑constrained

Another clear pattern in lithium market outlook 2026 discussions is the emergence of a de facto two‑tier system:

• Tier 1 – China‑anchored ecosystem: Dominated by Chinese refiners and battery makers, supplied by a mix of domestic ore, overseas spodumene (notably from Australia), and South American brines, with relatively fewer constraints on Chinese processing content.
• Tier 2 – Compliance‑filtered chains: North American and European OEM‑oriented, increasingly filtered through IRA and EU rules that penalise or disqualify materials with heavy Chinese processing involvement.

If policy trajectories continue along current lines, Western supply chains risk structurally paying a “geopolitical premium” in the sense that they may need to prioritise sources that are both costlier and more complex to scale, in order to maintain regulatory compliance and avoid exposure to sanctions or trade disruptions. Conversely, suppliers that combine low costs with a clean compliance profile—such as certain Chilean brines partnered with Western processors, or new projects in Canada, Australia and Brazil positioned for non‑Chinese refining—gain outsized strategic relevance even if their share of global volume is modest.

Operational and Supply Chain Implications

From a procurement and governance perspective, the lithium oversupply phase is not a comfortable “buyers’ paradise.” Contracting experience around previous cycles suggests that aggressive attempts to squeeze marginal suppliers can accelerate mine closures and project cancellations, eroding future optionality. At the same time, locking into long‑dated, rigid arrangements during a downturn can create stranded obligations if policy conditions or battery chemistries evolve.

In practice, supply chain teams that Materials Dispatch has observed grappling with this cycle tend to re‑prioritise three concrete capabilities:

• Traceable, auditable origin and processing paths – Given IRA‑type rules and growing ESG scrutiny, being able to document mine‑to‑cell pathways for lithium units is becoming a core competence rather than an optional extra.
• Portfolio diversity across cost curves – Combining volumes from low‑cost incumbents, mid‑tier hard‑rock players, and a carefully chosen set of emerging projects can reduce over‑exposure to any single regulatory regime, cost band, or geology.
• Technical adaptability – Cell manufacturing and cathode design that can accommodate a broader range of lithium chemical specifications (within safety and performance constraints) offers more flexibility to switch between hydroxide, carbonate, or alternative forms as regional availability evolves.

Governance teams, for their part, face a more complex mapping problem. It is no longer sufficient to track “lithium tonnes” in aggregate. For risk committees and boards, the relevant questions revolve around which tonnes (by asset, by processor, by jurisdiction) actually end up qualifying for target markets, and how quickly alternative pathways could be mobilised if a specific node—such as a Chinese converter or a South American brine field—were disrupted or rendered non‑compliant by new rules.

WHAT TO WATCH

• Inventory drawdown pace in 2025–2026 – Faster‑than‑expected clearing of the estimated ~350,000 mt LCE inventory buffer would support the thesis of a tighter 2026–2027 market; sluggish drawdown would extend oversupply.
• Announced vs executed production cuts – Real‑world shutdowns, care‑and‑maintenance decisions, and capex deferrals among high‑cost hard‑rock and junior developers will indicate how much latent capacity truly exits the market.
• China lithium refining capacity ramp – The rate at which new Chinese refining capacity (often cited as potentially surpassing 2 million mt LCE/year mid‑decade) actually comes online, and its utilisation levels, will shape global conversion bottlenecks and regional dependence.
• Policy hardening in US and EU – Final IRA guidance on “foreign entities of concern”, EU critical raw materials implementation acts, and any concrete moves toward strategic lithium stockpiles would materially affect which tonnes are effectively bankable for Western OEM chains.
• Battery chemistry trajectories – Shifts between high‑nickel chemistries, LFP, sodium‑ion, and hybrid approaches will alter the precise form and quality of lithium chemicals required, even if total lithium demand continues to rise.
• Project finance signals – Access to debt and equity for lithium projects, especially for higher‑cost or non‑integrated assets, will reveal how much of the notional development pipeline is likely to become real capacity by 2026–2028.

Conclusion

The lithium price crash into the mid‑2020s is not simply a story of excess enthusiasm followed by a hangover; it is exposing deep structural asymmetries between regions, cost positions, and regulatory environments. The next phase, centred around the 2026 horizon, will test whether inventories and idled capacity are a comfortable cushion or a deceptive mirage that delays necessary investment and diversification.

To the extent that current lithium price forecast ranges and surplus estimates hold, low‑cost, well‑integrated producers and processors—many of them anchored in China or long‑established South American brines—look set to emerge from the oversupply period stronger, while a meaningful cohort of higher‑cost juniors and late‑stage projects risks permanent impairment. For supply‑chain, policy, and governance stakeholders, the critical task is less about guessing the exact 2026 price and more about mapping which tonnes are genuinely available, compliant, and restartable at different points along the cycle. Materials Dispatch will continue active monitoring of regulatory and industrial weak signals that will determine how this balance evolves.

Note on Materials Dispatch methodology Materials Dispatch combines systematic monitoring of regulatory texts and guidance from key jurisdictions (including mining, trade, and industrial policy authorities) with continuous review of industry reports, company disclosures, and credible market analyses. These documentary sources are cross‑checked against end‑use technical specifications in batteries, alloys, and chemicals to assess which volumes are truly usable for strategic applications, rather than relying solely on headline capacity or production figures.