The EU’s Critical Raw Materials Act (CRMA) defines mineral value chains as starting with extraction (mining), excluding mineral exploration as a distinct, eligible stage. This creates a governance gap, as member-state capacities vary and private exploration needs EU de-risking. Dr. Nikolaos Arvanitidis, Economic Geologist, provides interesting data to support that without EU-recognised exploration, domestic project pipelines weaken, import dependence persists, and supply resilience becomes unrealistic overall.
Abstract
CRMA defines mineral value chains as starting with extraction (mining), excluding mineral exploration as a distinct, eligible stage. This creates a structural governance gap: exploration drilling, resource classification, metallurgical testing, and pre-feasibility studies cannot be part of EU-recognised Strategic Projects nor access EU-level financing and permit facilitation. The Commission argues that exploration is a national responsibility to be handled by member states and their geological surveys. However, this ignores:
- Unequal national capacities across the EU
- The fact that national surveys focus on early-stage regional mapping, not full-scale exploration, and
- The existence of a private mineral exploration industry and technology developer ecosystem that requires EU-level de-risking.
Without integrating exploration into the official value chain, the EU undermines its own goals of supply resilience, reduces the pipeline of new domestic mining projects, and perpetuates import dependence for critical raw materials. This approach argues for amending the CRMA to include exploration as a recognised stage, creating EU-level exploration financing facilities, and making exploration activities eligible for Strategic Project status. If mineral exploration is excluded, the EU will have to disregard the resilience of value chains. To put it another way, since you cannot mine something you never find, the EU has to fix exploration exclusion.
The EU’s definitional blind spot
The CRMA defines the value chain (Figure 1) as:
- Extraction (mining)
- Processing
- Refining
- End-product
- Precycling and substitution included
Mineral Exploration is not listed as a distinct stage. In practice, this means that Strategic Projects -which receive faster permits and potential access to EU funding (e.g., from InvestEU, Innovation Fund)- cannot have exploration as their primary objective. Exploration can only be a minor, ancillary activity within a project that is already an approved mining or processing project.
Figure 1: The EU’s Critical Raw Materials Act (CRMA) defines mineral value chains as starting with extraction (mining), excluding mineral exploration as a distinct, eligible stage
The Commission’s rationale—and why it breaks down
The Commission’s stated position is:
- Exploration is a pre-competitive, national responsibility
- National Geological Surveys (NGS) can mainly handle early-stage (regional) exploration
- Member states can finance or co-finance exploration via state aid or national budgets.
Where this logic fails, is shown in the Table below.
Figure 2: The exploration stage activities address mineral resources characterisation and provide data and models that enable the submission of a pre-feasibility study and an overall prospect evaluation (https://doi.org/10.1515/geo-2022-0466)
Market reality: Exploration is an industry, not just a precursor
A crucial point to highlight is that there is a mineral exploration industry -junior companies, specialised contractors, technology developers-that operates as a market. These players need:
- Access to Strategic Project status for permit facilitation (e.g., single national contact points, fast-track licensing)
- Access to EU de-risking instruments (grants, loans, guarantees) for drilling and feasibility studies
- Recognition of exploration as a legitimate value-chain stage, especially for brownfield (near-mine) and greenfield (new district) projects.
Without this, the EU is effectively waiting for mining projects to appear as already proven. But without exploration, no new mining appears.
A concrete risk: The EU’s reliance on imports will persist
Consider the timeline:
- A mining project takes 10–15 years from discovery to production
- Exploration takes 3–7 years before a mine can be designed.
If the EU does not support exploration today (2025), then by 2035-2040, there will be no new domestic mining projects beyond the few already in permitting (e.g., Norra Kärr, Cinovec, etc.). The CRMA’s goal of reducing import dependence for 34 CRMs (including lithium, cobalt, REEs) will fail structurally.
What the EU should do
Based on the above analysis, a logical reform would include the following items.
My opinion
The Commission’s current position is legally neat but operationally flawed. It assumes:
- That mineral deposits magically appear at the “mining” stage.
- That private capital is willing to drill in EU countries without EU de-risking.
- That all member states have equal geological survey capacity and budgets.
None of these is true. The result is that the EU will continue to finance recycling and processing (which are low-risk, high-visibility) but neglect the upstream pipeline -precisely where long-term security lies.
A resilient value chain without exploration is like a factory without R&D. You might run for a while on known deposits, but you will run out.
A constructive review for EU policymakers
By excluding exploration from strategic projects, you are not saving money -you are shifting risk to member states that cannot bear it and guaranteeing that EU mining will remain dependent on discoveries made decades ago. The exploration market exists, but it needs EU-level permit facilitation and financing to operate across borders. Without this, the CRMA will fail its own resilience test.
In short, a governance gap is identified that turns an otherwise forward-looking regulation into a self-limiting exercise. The solution is not to keep exploration at the national level, but to Europeanise it with appropriate risk-sharing instruments.
