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Policy & Geopolitics · 5 min read

What EU Strategic Project status gives a project, and what it doesn't

Reading the Critical Raw Materials Act's own articles on Strategic Projects: the criteria, the permitting clocks, the public-interest status and the financing help, and the things recognition leaves exactly as they were.

Reviewed by Peter Uppal

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Illustrative artwork: a newly marked lane on a road that still follows the land. Not a facility, equipment or material connected to this project. · Illustration · Osmond Hub

The short version

Under the EU's Critical Raw Materials Act, a project recognised as a Strategic Project in the EU gets a legal ceiling, with stated exceptions, on how long its permitting may take, a public-interest status under named EU nature and water rules, and access to advice on finance and introductions to buyers. On this publication's reading of Articles 15 to 17, the Regulation gives Strategic Projects coordination, advice and introductions, not funding as of right. Recognition does not change the legal requirements that apply to the project, and the Commission can withdraw it.

How a project is recognised

Recognition starts with the project's promoter. Applications are submitted by the project promoter to the Commission(opens in a new tab) (Article 7), which assesses them through an open call with regular cut-off dates, set at least four times a year(opens in a new tab). The Commission must decide within 90 days of acknowledging that an application is complete, and may, case by case and in exceptional cases, extend that by up to 90 days(opens in a new tab). For a project in a third country, the Commission may not approve the application before receiving that country's explicit approval(opens in a new tab).

The test, in Article 6, has five parts, two of which apply only by location. The Regulation asks for a meaningful contribution to the security of the EU's supply of strategic raw materials; technical feasibility within a reasonable timeframe, with expected production volume estimable with sufficient confidence; sustainable implementation; cross-border benefits for projects in the EU; and mutual benefit for projects in third countries that are emerging markets or developing economies(opens in a new tab). Each criterion is assessed against the elements and evidence set out in the Regulation's Annex III(opens in a new tab).

What it gives: a clock

For Strategic Projects in the EU, Article 11 says the permit-granting process may not exceed 27 months for projects involving extraction and 15 months for projects involving only processing or recycling(opens in a new tab), subject to stated extensions and to periods that are not counted; The 27-month permit clock and what it leaves out sets out what counts and what does not. By 24 February 2025 Member States had to set up single points of contact for critical raw material projects generally, each acting as the sole point of contact for a project promoter(opens in a new tab) (Article 9); that duty is not specific to Strategic Projects. On this publication's reading, the permitting time limits apply only to Strategic Projects in the EU; the Regulation sets none for projects in third countries.

What it gives: status

Under Article 10, Strategic Projects are considered to contribute to the security of supply of strategic raw materials in the Union(opens in a new tab). For the purposes of specific EU nature and water rules, namely provisions of the Habitats, Water Framework and Birds Directives and EU restoration law, Strategic Projects in the EU are considered to be of public interest, and may be considered to have an overriding public interest, provided all the conditions in those rules are met(opens in a new tab). The word is "may", and the conditions remain.

National status is conditional in the same way. Strategic Projects in the EU get the status of the highest national significance possible, where such a status exists in national law(opens in a new tab), and disputes about them are treated as urgent if and to the extent that national law provides for such urgency procedures(opens in a new tab).

Status buys an EU project a clock and an introduction. It does not buy it a permit.

What it gives: advice and introductions

Under Article 15, the Commission's activities to crowd in private investment may include providing and coordinating support to Strategic Projects that face difficulties in accessing finance(opens in a new tab), without prejudice to the State-aid rules. Under Article 16, at a promoter's request, a standing subgroup of the Board the Act sets up discusses and advises on how the project's financing can be completed, including through resources from the European Investment Bank Group(opens in a new tab). On offtakes, Article 17 says the Commission must set up a system to facilitate the conclusion of offtake agreements related to Strategic Projects(opens in a new tab), which brings project promoters into contact with potential offtakers(opens in a new tab).

The Commission's own summary is shorter: selected projects benefit from faster permitting, as well as facilitated access to finance and offtakes(opens in a new tab).

What it doesn't give

Recognition does not affect the requirements applicable to the project or its promoter under Union, national or international law(opens in a new tab) (Article 6(3)). It can also be lost. Under Article 7, the Commission may withdraw recognition if a project no longer meets the criteria, or if its application contained incorrect information affecting the criteria, after giving the promoter reasons and a chance to reply; a project that loses recognition loses all rights tied to the status(opens in a new tab). A project that drops out only because the strategic list changes keeps its status for three years(opens in a new tab).

The selections so far

In March 2025 the Commission selected 47 Strategic Projects across 13 Member States, with an expected overall capital investment of €22.5 billion(opens in a new tab); they cover 14 of the 17 strategic raw materials listed in the Act(opens in a new tab). A second group, outside the EU, followed: on 4 June 2025 the Commission recognised 13 projects outside the EU(opens in a new tab). The second call's cut-off date was 15 January 2026(opens in a new tab), and on 9 October 2026 the Commission selected 46 new Strategic Projects(opens in a new tab). By this publication's arithmetic, the Commission's 47 and 46 and the 13 that Covington reports add to 106 Strategic Projects; the Commission itself gives no combined total, and the count does not allow for any withdrawals.

By the Commission's account, as of 9 October 2026, 25 Strategic Projects had completed their environmental impact assessment and 17 had obtained a construction permit(opens in a new tab). The Commission says what it calls Team Europe has mobilised more than €2 billion in financial support since its RESourceEU communication of December 2025, through the Innovation Fund, State aid and the European Investment Bank(opens in a new tab); the release does not tie that sum to Strategic Projects. On buyers, it says several projects have made significant progress towards securing offtake agreements(opens in a new tab).

Related

  • Government Policy
  • Critical Mineral Strategies
  • Regulation
  • Investment Incentives
  • Major Projects

Sources

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