Trade Restrictions on select CRMs

Since 2010, there has been an almost seven-fold increase in trade restrictions levied against the EU27+ on select critical raw materials essential for the green energy transition. The restrictions have also doubled just since the beginning of 2025.

The graphic, which displays import and export trade restrictions levied against the EU27 + Norway, Switzerland, and Iceland, reveals a concerning issue. Since 2010, there has been a 675% increase in policy interventions by producing countries that negatively impact the EU27+ sourcing of the primary minerals aluminium (Al), cobalt (Co), copper (Cu), natural graphite, lithium (Li), manganese (Mn), nickel (Ni), and the rare earth elements (REE). These critical raw materials (CRMs) are particularly important for producing technologies for the digital and green energy transitions and their demand is only expected to increase in the coming years. This escalation in harmful trade restrictions highlights not only a growing need but a significant potential for the EU to move towards diversification of these material value chains. Furthermore, from a broader perspective, advancing circular economy (CE) strategies, including actions ‘before use’ (refuse, rethink, reduce), ‘during use’ (retain, reuse and share, remanufacture), and ‘after use’ (recycle and return), can extend the use of CRMs in circulation and help moderate their future demand¹.

Since 2010, the most common types of restrictions have overwhelmingly been import tariffs, followed to a lesser extent by export and import licensing requirements, and export taxes with import tariffs having become particularly common since the beginning of 2025. For most of these CRMs, the EU has also a >75% import reliance, with only small quantities of some of these materials able to be sourced from member states². Furthermore, the majority of these trade restrictions are coming from two countries, the USA and China, of which the latter the EU is also heavily reliant for several of these CRMs. Given the general lack of mining in the EU, the current global geopolitical dynamics suggests such harmful trade policy interventions towards the EU are likely to continue.

With the observation made from this graphic, it is clear that the EU will need to promote alternative sources and new strategies for these CRMs, if it wishes to relieve the pressures caused by import and export restrictions and its current significant import dependencies. Given the current end-of-life recycling input rate (EoL-RIR) is still very low for most of these CRMs, with only Al, Co, and Cu exceeding 20%³, recycling of these materials alone will not resolve these economic stresses. Implementing CE measures within the EU27+ can help with this. By transitioning to more sustainable CRM practices, that include alleviating demand pressures via behavioural or technology changes, such as the promotion of sustainable lifestyles, investing in substituting CRMs with less critical materials in technologies, and improving recycling and recovery, can already begin to address these issues¹.

The graphic and accompanying data allude to a broader effort by the EU to assess the current state of its CRM value chains, alleviate its import dependencies, all while maintaining economic prosperity and achieving its net zero goals. Like other important minerals heavily used in modern society and its technologies, the EU currently relies on extracting CRMs from virgin mineral ores. Moreover, the CRM value chains are highly complex, with multiple steps occurring outside the EU, from extraction, processing, refining and distribution, where any supply chain disruptions or bottlenecks at any point in this process may further negatively impact eventual EU supply and potentially create unexpected economic fallout.

In an effort to begin to address this, the EU introduced the Critical Raw Materials Act (2024/1252), in force since May 2024. The Act sets benchmarks along the CRM value chain for this diversification. Specifically by 2030, at least 25% of the EU’s annual consumption of CRMs needs to come from recycling⁴. The Act also specifies, that EU countries must now take measures to improve the collection of CRM-rich waste, ensure their recycling into secondary CRMs and investigate the potential for CRM recovery from extractive waste⁴

The severity caused by such increasing trade restrictions from countries the EU is reliant for virgin materials represents a critical opportunity to advance the circular economy principles. For example, it has been previously estimated for aluminium that 1.6 to 1.8 kg of CO₂-equivalent is emitted per kg of virgin aluminium smelted as compared to around 0.5 kg for aluminium recycled⁵. Similarly, recycled minerals such as nickel, cobalt and lithium emit up to 80% less CO₂ than their virgin counterparts⁶. Investments in recycling of CRMs would have immediate benefits towards lowering the EU’s carbon footprint. Furthermore, implementing circular measures for CRM containing EoL products and waste streams, such as market initiatives for product design that support identification and efficient separation of CRM-containing components at the product EoL, landfill bans on waste containing recyclable CRM-enriched wastes, and implementing national CRM stockpile programs that buys secondary CRMs at regulated prices⁷, can already facilitate major strides towards relieving the EU from its import dependencies and easing economic hardships caused by such trade restrictions.

Definition

The metric shows the drastic increase in harmful trade restrictions levied against the EU27 countries sourcing of CRMs.

Methodology

The Swiss-based NGO Global Trade Alert is the world’s premier repository of global policy changes and trusted by governments, international organizations, and leading media brands to provide unbiased, transparent, high-quality data and neutral analysis for more informed decision making.
The data is compiled into an open-source database and displays policy changes affecting the EU27+ global trade and investment. The database query generated a dataset that included harmful policy interventions by implementing jurisdictions (all countries, except the UK) against the EU27 countries, Norway, Switzerland, and Iceland (as impacted jurisdictions).

Once data is generated, it is sorted by the date trade restrictions are implemented and all in force restrictions are summed by year.

The UK was excluded from being either an implementing or an affected jurisdiction as the database does not disaggregate the UK from trade restrictions that were implemented before Brexit.

Metadata

Data source: Global Trade Alert, 2025: https://globaltradealert.org/

Unit: Number of harmful trade policy interventions implemented, still in force; non-cumulative

Temporal coverage: 2010 to present

Geographic Affected Jurisdictions: European Union, Norway, Switzerland, Iceland (EU27+)

Geographic Implementing Jurisdictions: All countries (except EU27+ and UK)

Policy Intervention Types: Export tax, Export ban, Export tariff quota, Export quota, Import ban, Export licensing, requirement, Import licensing requirement, Export-related non-tariff measure, Import-related non-tariff measure, Import tariff quota, Import quota, Import tariff, Internal taxation of imports, Import monitoring, Local supply requirement for export

Literature

(1) EEA. Accelerating the Circular Economy in Europe - State and Outlook 2024; EEA Report 13/2023; European Environmental Agency: Copenhagen, Denmark, 2024. https://www.eea.europa.eu/en/analysis/publications/accelerating-the-circular-economy (accessed 2025-12-05).

(2) European Commission; Directorate-General for Internal Market, I., Entrepreneurship and SMEs; Grohol, M.; Veeh, C. Study on the Critical Raw Materials for the EU 2023 – Final Report; Publications Office of the European Union, 2023. https://doi.org/10.2873/725585.

(3) Joint Research Centre. RMIS - Raw materials’ profiles. RMIS - Raw Materials Information System. https://rmis.jrc.ec.europa.eu/rmp/.

(4) European Commission. European Critical Raw Materials Act; 2023; p 94. https://eur-lex.europa.eu/resource.html?uri=cellar:903d35cc-c4a2-11ed-a05c-01aa75ed71a1.0001.02/DOC_1&format=PDF.

(5) European Aluminium. Vision 2050 - European Aluminium’s Contribution to the EU’s Mid-Century Low-Carbon Road Map; European Aluminium Association, 2020. https://european-aluminium.eu/wp-content/uploads/2022/10/sample_vision-2050-low-carbon-strategy_20190401.pdf.

(6) IEA. Recycling of Critical Minerals; International Energy Agency: Paris, France, 2024; p 163. https://www.iea.org/reports/recycling-of-critical-minerals.

(7) Bergfald, B.; Kristensen, K.; Lystad, H. Recycling of Critical Raw Materials in the Nordics; Nordic Council of Ministers: Copenhagen, Denmark, 2024.

Trade Restrictions on select CRMs

References and footnotes