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Supply chain governance as a site of regulatory contestation: The case of the EU Critical Raw Materials Act

Foreign Policy
Governance
Trade
Isabella Strindevall
Stockholm University
Isabella Strindevall
Stockholm University

Abstract

This paper analyses the political contestations and expedited adoption of the European Union’s Critical Raw Materials Act (CRMA), passed by the European Parliament in December 2023, a record nine months after the European Commission’s initial proposal. Situated at the intersection of climate politics and geopolitical competition, the CRMA aims to secure the EU’s critical raw materials supply to meet the demands of decarbonization, digitalization, and strategic autonomy, emphasizing the need to reduce dependence on external suppliers and enhance control over critical raw materials supply chains. Although the CRMA sets ambitious targets for extraction, processing, and recycling, questions remain about how the regulation balances economic priorities with social and environmental concerns. This study investigates how actors within the critical raw materials supply chain leveraged their positions to shape the regulatory process, influencing the final design of the CRMA to reflect their strategic interests. Using qualitative document analysis of the consultation process and interviews with Commission and industry representatives, the study identifies which interests were prioritized, how supply chain dynamics facilitated or constrained influence, and how strategic framing enabled the regulation’s rapid adoption. Theoretically, it applies the advocacy coalition framework to analyze both formal decision-making structures and informal power dynamics. The findings reveal that supply chain actors strategically framed the CRMA debate around geopolitical security of supply rather than reducing demand, steering the regulatory agenda toward upstream control of resources while sidelining more transformative measures to limit overall consumption of critical raw materials. As a result, social and environmental objectives were deprioritized in the final regulation. By situating supply chain governance as a site of regulatory contestation, this study provides insights into the evolving governance of critical raw materials and its implications for future resource policies, particularly in relation to the EU’s broader sustainability commitments under the European Green Deal.