Where are the material resources needed to feed Europe’s energy transition?
The raw reality by Ewa Kochańska
One of the latest reports from the European Court of Auditors (ECA) analyses the strategic importance of critical raw materials (CRMs) to the EU’s goals towards climate neutrality – unsurprisingly revealing a too heavy dependence on imports, with supply chains concentrated in a handful of non-EU countries. This situation exposes the bloc to geopolitical risks and trade disruptions, significantly weakening efforts to strengthen its strategic autonomy. Although recent policy initiatives, including the Critical Raw Materials Act, have provided clearer direction, issues related to data, targets, and implementation still need more attention.
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he EU’s objectives of reaching net-zero emissions by the middle of this century and significantly expanding renewable energy by 2030 have rapidly increased the demand for wind turbines, batteries, and photovoltaic panels. As these technologies depend on a small group of key raw materials – including lithium, cobalt, nickel, and rare-earth elements – raw material supply security has become the core of both energy and industrial policy. As consumption rises sharply, ensuring reliable and sustainable access to these materials is emerging as one of the defining challenges of the energy transition. However, ambitions to expand domestic production and improve resource efficiency face persistent structural obstacles. Financial, regulatory, and technological challenges suppress mining, processing, and recycling activities within the EU; permitting procedures are also slow and complex. Circular economy measures and recycling targets offer a pathway to reduce reliance on primary extraction, but market and regulatory constraints hinder their full realisation. Strategy-based projects designed to accelerate progress may ultimately bring about positive outcomes, but they are unlikely to contribute meaningfully before the end of this decade. Before you build, lay the foundation The EU’s approach to securing strategic raw materials sets a clear direction, but its 26 | Baltic Transport Journal | 2/2026
foundation is uneven. Although the policy is based on solid data and clear justification, problems show up in how key materials are identified, how targets are defined, and how progress is measured. The lists of critical and strategic raw materials help prioritise resources needed for the energy transition, but data limitations and methodological issues affect both the selection of materials and the forecasts of future demand. Gaps in trade data and modelling also undermine confidence in the overall picture, meaning the system for identifying and tracking CRMs is still not fully reliable. Similar issues appear in the targets and funding that support the policy. The EU has set benchmarks for extraction, processing, recycling, and import diversification, but it is not always clear how these targets were determined or how they link to broader energy and industrial goals. At the same time, significant EU funding has been allocated to raw materials projects, yet its impact on supply is difficult to measure because funding is spread across different programmes and results are not systematically tracked. ECA’s Critical raw materials for the energy transition report therefore recommends improving data quality, making targets more transparent and better aligned with EU objectives, and monitoring funding more closely to understand whether it is actually strengthening the bloc’s raw materials supply.
Results you can hold The EU remains highly dependent on imports for most of the raw materials needed for the energy transition, and in certain instances, completely dependent. To deal with this, the Critical Raw Materials Act sets a target to limit dependence on any single non-EU country, but current supply patterns show a long path ahead. In some cases, sourcing is still heavily concentrated, particularly at the processing stage, where a few countries dominate key materials such as lithium and rare-earth elements. This leaves supply chains exposed to disruption and underlines the scale of the diversification challenge. Efforts to secure access through trade policy and external cooperation have intensified, but the results are difficult to measure. Free trade agreements and other initiatives should improve access to resources and create more stable conditions for investment, yet there is little evidence so far that they have increased the flow of materials into the EU. Meanwhile, global trade conditions are continually worsening. Among other pressures, export restrictions, licensing systems, and growing geopolitical tensions continue to affect availability, with recent limits on rare-earth exports and the disruption of supplies from Ukraine. As a matter of fact, CRMs are becoming at least some of the reasons for geopolitical aggression, such as the attack on Ukraine, and they have been used as tools