According to the organisation, the package focuses on joint stockpiling, joint procurement, demand aggregation and financial instruments intended to secure minerals for defence-related manufacturing, reflecting links with the European Defence Industry Programme, the European Defence Fund and Horizon Europe.
The EEB argues that the approach prioritises rapid permitting and procurement without sufficient environmental assessment and due diligence. The organisation notes that these measures follow recent changes to the Corporate Sustainability Due Diligence Directive and the Corporate Sustainability Reporting Directive, which it considers relevant tools for responsible supply chain governance. Civil society organisations report increasing pressure to accelerate permitting for mining and processing projects without comprehensive environmental impact assessments, land-use planning or nature protection measures.
The EEB also states that water protection requirements may be weakened. The organisation refers to discussions on revising elements of the Water Framework Directive to increase flexibility for new mining projects and industrial facilities. According to the EEB, metal contamination and alteration of freshwater systems represent key risks for rivers and groundwater.
The organisation highlights the scale of international investment in battery-metal projects. Since 2020, China has invested more than USD 15 billion in overseas projects, compared with USD 1.7 billion from EU companies. The EEB notes that more than 14 EU strategic partnerships have not yet resulted in operational projects and have raised concerns regarding human rights and environmental impacts.
In 2024, NATO published a list of defence-critical raw materials used in advanced weapons systems. According to the EEB, this list largely overlaps with the EU’s strategic raw materials designation under the Critical Raw Materials Act (CRMA). The organisation reports that 45 of 47 EU-based projects and 11 of 13 non-EU projects funded under the CRMA target minerals classified as defence-critical by NATO.
The EEB warns that stockpiling and joint purchasing may prioritise defence uses over applications in renewable energy and grid modernisation. The organisation refers to limited supply volumes in global markets and competition for rare earth elements.
The EEB states that limited transparency and reduced oversight could affect the credibility of European supply chain initiatives in partner countries. According to the organisation, strong environmental and social safeguards are considered essential for cooperation.
The EEB notes that planned restrictions on the export of permanent-magnet scrap and targeted measures for aluminium scrap, with possible future measures for copper scrap, represent a step towards retaining valuable materials within the EU and supporting circular supply chains. The organisation calls for clear safeguards and oversight in the implementation of these measures.
The EEB calls on the European Commission and Member States to:
- ensure access to information and participation in decision-making processes;
- avoid preferential access to raw materials for defence-related sectors through joint purchasing and stockpiling;
- maintain environmental policies and due diligence requirements in mineral governance;
- refrain from revising the Water Framework Directive and focus on implementation;
- reduce overall resource demand through binding circularity targets;
- strengthen recycling and recovery of critical raw materials from waste streams, including batteries, end-of-life vehicles, electronics and construction waste.
The EEB advocates for a framework for mineral governance based on environmental protection, human rights and democratic accountability.
