Under the mandate of Critical Raw Materials Act, the European Commission approved in 2025 60 ‘strategic’ extracting, processing, recycling and substitution projects, which are destined to meaningfully contribute to the objectives of the CRMA. Forty-seven projects are to be located within the EU borders and 13 are located outside of the EU.

Business & Human Rights Resource Centre reached out to all promoters of non-EU strategic projects to ask about their policies on human rights and environmental impact assessments. Out of the 13 project promoters, only four responded: Rio Tinto, Jervois Global, Société Le Nickel (Eramet) and Mkango Resources. These responses, along with a web-based research, revealed that:

• No promoter of strategic projects outside the EU currently has both a publicly available human rights policy, and an environmental, human rights and social impact assessments for the proposed project.
• Only the Dumont nickel project in Canada, proposed by Magneto Investments Limited, has a publicly available environmental impact assessment, published in 2015. When it was published, however, local civil society groups complained that health and environmental impacts remain significantly underestimated, given that the project is set to become the country’s largest open-pit mine and a major source of pollutants. The controversial Jadar lithium project in Serbia only has draft environmental and social impact assessments available, which are not official documents in accordance with official procedures.
• Three projects are associated with companies having publicly available human rights policies: Société Le Nickel (Eramet), Rio Tinto and Jervois Global.
• Mkango Resources does not currently have any relevant policies available online, but their response highlights that relevant policies will be published as the project develops towards construction.
• Only two project promoters (Eramet and Rio Tinto) are members of multistakeholder initiatives on responsible mining or supporters of relevant industry standards.