The EU Critical Raw Materials Act is the law; the Critical Raw Materials list is one list inside that law. Regulation (EU) 2024/1252 contains a broader list of critical raw materials in Annex II and a narrower list of strategic raw materials in Annex I. In the enacted 2024 text, those lists contain 34 and 17 entries respectively. Strategic materials are also critical, but not every critical material is strategic. The regulation on EUR-Lex is the legal source for the categories and their requirements.
The Act is the law; the critical list is part of it
The phrase “Critical Raw Materials Act” refers to Regulation (EU) 2024/1252, the binding EU framework for the secure and sustainable supply of critical raw materials. The “Critical Raw Materials list” is not a competing act, a separate policy, or another name for the whole regulation. It is the list in Annex II of that regulation.
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The same Act contains a second list: Annex I, which identifies strategic raw materials. The two lists are related but do different jobs. Annex II identifies the wider set of materials that are critical to the EU economy and exposed to supply risk. Annex I marks a smaller group for particular strategic priority. Under Article 4, strategic materials must also be included in the critical list.
That distinction matters when reading a headline or a policy target. A reference to the Act means the complete legal framework, including its rules, benchmarks and review process. A reference to the critical list means the Annex II classification. A reference to the strategic list means the Annex I category within the same law.
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How the two lists compare
| Question | Critical raw materials | Strategic raw materials |
|---|---|---|
| Where it appears | Annex II of Regulation (EU) 2024/1252 | Annex I of Regulation (EU) 2024/1252 |
| Count in enacted 2024 text | 34 materials | 17 materials |
| What the category signals | Economic importance to the EU and comparatively high supply risk | Particular strategic importance to green and digital transitions, defence and aerospace, alongside demand growth and difficulty increasing production |
| Relationship between categories | Includes the strategic materials and other materials meeting the Act’s criticality criteria | A narrower priority category that is included in the critical list |
| Main policy role | Broad identification of materials that matter to the EU economy and face supply risk | Focus for strategic priorities and the Act’s 2030 capacity benchmarks |
The counts refer to the lists as enacted in 2024, not a guarantee that the lists have remained unchanged after later legal updates. The Commission’s overview of the European Critical Raw Materials Act also summarizes the categories and benchmarks.
Why the EU uses both categories
The categories answer different questions. The critical designation asks whether a material is economically important to the EU and whether its supply is risky. Strategic designation adds a sharper policy focus: does the material have particular importance for key technologies and sectors, is demand expected to grow, and would it be difficult to expand production?
Using one broad category and one narrower category lets the Act distinguish general exposure from specific strategic priorities. A material can be important to the EU economy and vulnerable to supply disruption without meeting the separate strategic-importance criteria. Conversely, each material on the strategic list is included in the critical list, so strategic status is not an alternative that replaces critical status.
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In short, the two lists are not two competing rankings in which a material must choose one label. Annex I identifies a narrower strategic subset, while Annex II captures the critical category more broadly. The distinction lets the regulation identify materials that meet criticality criteria without treating every one of them as equally central to the technologies and sectors used to define strategic importance.
How a material becomes strategic or critical
Strategic status focuses on technology, demand and production capacity
The Act assesses strategic importance by considering a material’s relevance to the green and digital transition and to defence and aerospace. The methodology looks at how many relevant strategic technologies use the material, how much those technologies require, and expected global demand. It also takes account of forecast demand growth and the difficulty of increasing production.
So strategic status is not simply a judgment that a substance is scarce or valuable. It reflects the material’s place in specific policy-relevant technologies and sectors, combined with the outlook for demand and supply expansion. The detailed methodology is part of the regulation, rather than an informal ranking based on common usage of the word “strategic.”
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Critical status uses economic importance and supply risk
Criticality is assessed through two indicators: economic importance and supply risk. Article 4 says that an updated critical list must include the strategic materials in Annex I, as well as other materials that meet or exceed the statutory thresholds: a supply-risk threshold of 1 and an economic-importance threshold of 2.8. Annex II sets out the methodology for calculating those indicators.
The numbers are thresholds in the Act’s classification method, not a count of materials, a price measure, or a declaration that a material is currently unavailable. They should be read with the indicators and methodology in the regulation. A familiar description such as “rare,” “expensive” or “in short supply” does not by itself establish that a material is legally critical.
The two methods should not be collapsed into a single test. Strategic assessment considers technology and sector relevance, demand growth and how difficult production would be to expand. Criticality assessment uses economic importance and supply risk, with the stated thresholds applying to materials outside the strategic list. Article 4 also makes the relationship between the categories explicit by requiring strategic materials to be included in the critical list.
For the legal wording and the calculation method, consult Article 4 and Annex II of Regulation (EU) 2024/1252. The Commission also provides a plain-language explanation on its Act overview page.
How to read an entry without overgeneralizing it
The annex wording matters. Some entries are grade-specific, so a casual shorthand can make the list appear broader or more uniform than it is. For example, the relevant entry may specify a material grade, such as battery-grade lithium or graphite, or specify a listed form of rare earth elements. Do not assume that every grade, form or material with a similar everyday name is automatically the same legal entry.
When checking a material, read the entry in its annex and keep three details together:
- Annex and category: determine whether the entry appears in Annex I as strategic, Annex II as critical, or both through the statutory relationship.
- Exact entry wording: retain any grade, form or other qualifier in the name rather than silently broadening it.
- Applicable legal version: note whether you are reading the enacted 2024 text or a later updated list.
This approach prevents a common mix-up: treating an industrial example as the legal category, or treating the word “critical” as a general synonym for scarcity. The annex and the regulation’s criteria control the classification.
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A quick checklist for checking a material
- Start with the legal instrument. Find Regulation (EU) 2024/1252 rather than relying on a news headline or an informal list.
- Check both annexes. Look in Annex I for strategic status and Annex II for critical status; do not treat one list as a substitute for the other.
- Match the wording exactly. Preserve any grade or form specified in the entry, rather than extending the designation to a broader family of materials.
- Check the date and version. The counts of 34 and 17 describe the enacted 2024 text. Verify whether a later legal update has changed the relevant entry before using it as current.
- Separate classification from policy targets. A critical listing does not by itself mean that the strategic-material 2030 capacity benchmarks apply to that material; those benchmarks concern strategic raw materials.
The final distinction is important for readers comparing a particular commodity with a policy objective. “Critical” is the broader classification; the Act’s extraction, processing and recycling benchmarks are framed for strategic raw materials. Use the annex category, not a general impression of importance, to identify which set of provisions is relevant.
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What the Act does beyond listing materials
The Act is more than an inventory. It establishes a framework to strengthen raw-material supply chains, improve preparedness and promote sustainability and circularity. The lists help identify which materials the framework addresses, while the law’s specific measures and benchmarks determine what follows from the classification.
The Commission’s stated aim is to reduce the EU’s dependence on single-country suppliers while developing capacity within the EU and improving resilience. The examples of materials used in batteries, solar panels, wind technologies, space and defence show why the framework spans multiple industries. They do not mean that every listed material is used in every sector or that a particular use alone triggers designation.
The regulation’s legal description of critical raw materials also makes clear that classification is not confined to material in one physical or commercial state. Article 4(1) refers to materials “including in unprocessed form, at any stage of processing and when occurring as a by-product of other extraction, processing or recycling processes.” In other words, the text addresses the listed raw material across processing stages and also when it occurs as a by-product. Readers should not infer from that wording that each form is a separate list entry; the annex entry and Article 4 govern the classification.
Strategic materials have 2030 capacity benchmarks
For strategic raw materials, the Act sets 2030 benchmarks of 10% of the EU’s annual consumption for extraction, 40% for processing and 25% for recycling. The extraction benchmark is qualified by the regulation’s relation to EU reserves. These are capacity benchmarks to be pursued by 2030; they are not statements that the EU has already achieved those levels.
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|---|---|---|
| Extraction | 10% of the EU’s annual consumption | The regulation qualifies this benchmark in relation to EU reserves; it is a capacity target, not a claim about current extraction. |
| Processing | 40% of the EU’s annual consumption | A capacity benchmark for processing strategic materials by 2030. |
| Recycling | 25% of the EU’s annual consumption | A capacity benchmark for recycling strategic materials by 2030. |
The percentages describe the Act’s targets for strategic raw materials, not a separate target for every material or a report of progress so far. The Commission’s summary of the Act states the benchmarks; the regulation provides their legal context.
It is also worth distinguishing the three stages. Extraction concerns obtaining raw material; processing concerns turning it into a usable intermediate or material form; recycling concerns recovering materials from waste or products. The percentages are separate capacity benchmarks, not three interchangeable measures of a single activity. The Act presents them as EU-level capacity aims for strategic raw materials, so they should not be rewritten as proof that a particular mine, processor or recycler has met an individual quota.
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The Commission’s examples help make the policy purpose concrete: lithium, cobalt and nickel are used in batteries, gallium in solar panels, boron in wind technologies, and titanium and tungsten in space and defence. The different uses illustrate why reliable supply can matter across sectors. They do not establish that every material is strategic, nor do they change the distinction between the Annex I strategic category and the wider Annex II critical list.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.When the lists can change
The 34 critical and 17 strategic figures describe the enacted 2024 text. They should not be presented as a permanent count. The Commission must review both lists and, if necessary, update them by 24 May 2027, then at least every three years. The regulation also allows an additional review of the strategic list if the European Critical Raw Materials Board requests one following monitoring and stress testing.
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That review schedule means a reader checking a material for a current business, policy or compliance decision should verify the latest legal text and any later delegated updates, rather than rely only on a summary of the original enactment. The review date is a deadline for the required process; it does not itself mean the annexes will necessarily change on that date.
There are therefore two useful date questions to keep separate: which version of the lists is being counted, and when the next review is due. “34 critical and 17 strategic” describes the enacted 2024 annexes; “by 24 May 2027, then at least every three years” describes the review timetable. A review can leave a list unchanged, so the scheduled review is not the same thing as a guaranteed change in membership.
The EU Publications Office provides a summary of Regulation (EU) 2024/1252. For formal classification and amendments, the regulation on EUR-Lex is the authoritative reference.
A practical way to answer common questions
“Is the Act the same as the critical list?”
No. The Act is Regulation (EU) 2024/1252; the critical list is Annex II within it. Annex I contains the distinct strategic list.
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“How many materials are on the EU critical list?”
The enacted 2024 Annex II contains 34 critical raw materials, while Annex I contains 17 strategic raw materials. Those counts are tied to that enacted text and may be affected by later updates.
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“Why are there two lists?”
The critical list covers economic importance and supply risk. The strategic list narrows attention to materials with particular relevance to the green and digital transitions, defence and aerospace, and factors such as demand growth and difficulty increasing production. Strategic materials are included among critical materials.
“What does the Act require by 2030?”
It sets strategic-material capacity benchmarks of 10% of EU annual consumption for extraction, 40% for processing and 25% for recycling, with the extraction benchmark qualified in relation to EU reserves. These are targets, not achieved outcomes.
The legal text states the relationship succinctly in Article 4(1): “The raw materials, including in unprocessed form, at any stage of processing and when occurring as a by-product of other extraction, processing or recycling processes, listed in Annex II, Section 1, shall be considered to be critical raw materials.” Read alongside the annexes, that wording makes the key point clear: the Act is the framework, and the lists are legal classifications within it.
Frequently Asked Questions
Is the EU Critical Raw Materials Act the same as the EU critical raw materials list?
No. The Act is Regulation (EU) 2024/1252. Its critical raw materials list is in Annex II, while Annex I contains the separate strategic raw materials list.
How many materials are on the EU critical raw materials list?
Annex II of the regulation as enacted in 2024 contains 34 critical raw materials. Annex I contains 17 strategic raw materials. These counts describe the enacted text and could be affected by later legal updates.
Are strategic raw materials also critical raw materials?
Yes. Strategic raw materials are included in the critical category. The critical list is broader and also includes other materials meeting the Act’s economic-importance and supply-risk criteria.
What is the difference between the critical and strategic lists?
Critical status is assessed using economic importance and supply risk. Strategic status focuses on relevance to the green and digital transitions, defence and aerospace, expected demand growth, and difficulty increasing production. The lists therefore have distinct criteria and policy roles.
What does the Act require by 2030?
For strategic raw materials, it sets capacity benchmarks of 10% of EU annual consumption for extraction, 40% for processing and 25% for recycling. The extraction benchmark is qualified in relation to EU reserves. These are targets, not statements of achieved capacity.
When will the EU review the lists?
The Commission must review both lists and, if necessary, update them by 24 May 2027, then at least every three years. The regulation also allows an additional strategic-list review following a request by the European Critical Raw Materials Board after monitoring and stress testing.
The Bottom Line
Bottom line: Regulation (EU) 2024/1252 is the EU Critical Raw Materials Act; its Annex II is the broader critical list, and Annex I is the narrower strategic list. In the enacted 2024 text, the lists contain 34 and 17 entries respectively. Strategic materials are also critical, and the Act sets 2030 capacity benchmarks for strategic materials—not for every material on the critical list. Check the precise annex wording and latest legal version when identifying a material.
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