The European Court of Auditors’ recently published a report on “Critical raw materials for the energy transition – Not a rock-solid policy” in which they identify gaps in critical raw materials policy that, if left unaddressed, can undermine the scale-up of the entire cleantech ecosystem, namely for hydrogen technologies.
For a successful transition, the EU needs growing volumes of critical raw materials. Yet today it faces:
High and persistent import dependencies
Limited progress on diversification
Structural bottlenecks in processing, recycling and financing
Targets that are non-binding, weakly justified, and applied uniformly to very different materials and markets
Hydrogen Europe was part of the stakeholder group providing input and the report ‘s conclusion is clear and worrying: current EU policies are not yet fit for purpose.
In the CRM Act, non-binding targets risk being ineffective, as the underlying methodology remains fragile and should be applied on a material-by-material basis, 10 of which the EU fully depends on, such as platinum group metals (PGMs), essential for hydrogen technologies.
For illiquid markets like PGMs, poorly calibrated measures risk distorting markets, and stockpiling and joint purchasing, although helpful, must be designed carefully.
Additionally, PGMs are not “just another CRM”, they have well-established recycling loops and strong recovery potential, which is not sufficiently reflected in current policies and targets.
When it comes to recycling, Europe currently recycles only around 12% of its capacity on average. Common raw materials that are also key to hydrogen, such as aluminium, copper and others, have a major untapped potential.
