"Selected Strategic Projects: Extraction in the EU", 19 December 2025

The Business and Human Rights Centre recently published the briefing Strategic projects for whom? Challenges and local realities of the European Union's strategic mineral projects, which focuses on the Union’s selected strategic projects under the Critical Raw Materials Act (CRMA) outside the EU. While that focus is understandable, there is also an urgent need to examine the selected strategic projects within the EU—particularly the extraction projects.

In total, 47 strategic projects were selected in Commission Decision (EU) 2025/840 of 25 March 2025. Of these, 22 are extraction projects within the EU. Below is a consolidated overview of each project. For every project, I examine:

• the project's permitting status and whether the permit is publicly available
• whether the project promoter has a publicly available human rights policy, in addition to a publicly available environmental policy
• whether an environmental [and social] impact assessment (ESIA) is publicly available
• whether any human rights or environmental concerns or allegations have been raised
• whether the promoter participates in any mining-related initiatives or standards
• the promoter's profile on the Business and Human Rights Centre platform

I also analyse the Commission’s reply on 26 November 2025 to requests for internal review submitted by in total 16 NGOs under the Aarhus Regulation, including the Commission's assessment of admissibility and substantive grounds. Together, the NGOs requested reviews of the decision to recognise 14 of the 22 examined projects as strategic.

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This review of selected strategic extraction projects in the EU reveals a persistent gap between the transparency and sustainability expectations set out in the CRMA and current practice among project promoters. Only seven of the 22 project promoters have publicly available human rights policies, and none of the project websites provide permitting decisions. While seven projects either publish environmental (and social) impact assessments or refer to relevant government databases, the majority do not. In several of the cases, impact assessment and/or permitting processes are still ongoing. However, several projects that have been operational for years still do not make such documentation publicly available. This raises concerns about compliance with the CRMA requirement for “transparent business practices with adequate compliance policies to prevent and minimise risks of adverse impacts.”

Opposition is present around almost all strategic extraction projects, although the intensity and visibility of conflict vary considerably... Across multiple cases, stakeholders do not only contest project outcomes, but also question the consultation processes themselves, pointing to shortcomings in meeting the standard of meaningful stakeholder engagement set out in the CRMA. ​

Engagement with mining-related initiatives and standards is limited, with only a minority of promoters participating in such schemes. In addition, 12 of the promoters are covered by the Business and Human Rights Resource Centre, signalling the existence of publicly raised human rights concerns linked to the promoter or its activities.

The accessibility of official documentation varies markedly between Member States. In many countries, permits and environmental (and social) impact assessments are difficult to locate despite being formally public information... Taken together, these findings underscore that transparency and meaningful engagement are not merely functions of promoter willingness, but are strongly shaped by the regulatory and administrative environments in which projects are embedded.

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The findings also point to structural constraints within the existing legislative framework. Current EU and national rules do not appear sufficiently robust to capture the full spectrum of risks associated with strategic extraction projects, a limitation that is partly inherent in the scope and design of EU law. In its review of strategic project designations, the Commission clarifies that the substantive assessment of environmental and social impacts is to take place at national level. In practice, this assessment is largely anchored in national legislation transposing the EIA Directive, which does not systematically address all risks. As a consequence, strategic projects may proceed without a substantive assessment of human rights impacts, notwithstanding parallel EU legislation such as the Corporate Sustainability Due Diligence Directive and the Battery Regulation. Moreover, the review mechanism available at EU level—the Aarhus Regulation—does not extend to human rights impacts, further reinforcing the structural separation between environmental and social considerations within the current framework.