The European Commission claims to have put in place a solid strategy to ensure the Union has access to the critical raw materials needed for the energy transition, but the ECA’s judgment remains stark: the path is set, the foundations are not. And time, with 2030 approaching, does not play in its favor.
Commission: “Concrete steps forward and strategic vision“
In its official response to the ECA’s special report, the Commission defends the overall framework of the European policy on critical raw materials, calling it a central piece of the Green Deal and the Union’s industrial competitiveness. Brussels highlights the adoption of the Critical Raw Materials Regulation as a turning point: a regulatory framework that aims to reduce external dependencies, strengthen domestic supply, incentivize recycling, and support strategic projects along the entire value chain.
The Commission acknowledges some critical issues-particularly on data quality, funding fragmentation and authorization difficulties-but frames them as problems in the process of being resolved. Improved data collection, refinement of methodologies, more innovative financial instruments and more focused international partnerships are, according to Brussels, the answer already underway.
The Court of Auditors: “Poorly justified goals and uncertain results“
The picture drawn by the European Court of Auditors is decidedly less forgiving. In Special Report 04/2026, the auditors acknowledge that the EU has finally given clear policy direction, but they point out that this strategy rests on an incomplete and, in some cases, fragile foundation.
The central issue is the lack of robustness of data and projections. Lists of critical and strategic commodities are judged to be useful tools, but built on information that is often outdated, deficient and methodologically weak. Even harsher is the judgment on the target values set for 2030: they indicate a direction, but are neither adequately justified nor clearly linked to the Union’s climate and energy goals.
External dependence and diversification: promises rather than results
Another critical issue is import diversification. The Commission claims trade agreements, strategic partnerships and enhanced diplomatic initiatives. But the Court notes that these efforts have yet to produce tangible results in terms of security of supply. In many cases there is a lack of effective monitoring of actual impacts , and partnerships remain more declarations of intent than operational tools.
Dependence on individual non-EU countries remains high for several key materials, from graphite to magnesium via rare earths. A fact that, according to the Court, exposes the Union to geopolitical risks that are anything but theoretical.
Domestic production and recycling: the potential is there, but remains untapped
On domestic production and recycling, the comparison is even more striking. Brussels speaks of growing potential and new industrial opportunities; the Court points to financial, regulatory, and administrative bottlenecks that continue to slow project start-up. Permitting remains slow and complex, funding for extraction and processing is still insufficient, and recycling, while evoked as a strategic pillar, is not supported by binding targets for all critical raw materials.
A convergence only apparent
Commission and Court converge on one point: critical raw materials are a strategic issue for Europe’s future. But they differ sharply on the state of the art. For Brussels, the machine is set in motion and should be allowed to work. For the ECA, without solid data, credible targets and measurable results, the risk is that of a strategy that is ambitious on paper but unable to truly ensure the Union’s strategic autonomy by 2030.
