Public Comment on the European Union Critical Raw Materials Centre

The European Union's dependence on concentrated critical raw material supply chains – above all on China – has shifted from a long-recognised vulnerability to an active crisis. China's 2025 export restrictions on rare earth elements exposed the limits of the EU's existing policy toolkit: benchmarks without enforcement, matchmaking without contracts, and monitoring without purchasing power. The Critical Raw Materials Act and the RESourceEU Action Plan have established the right objectives but lack the institutional capacity to deliver them. This submission argues that the proposed Critical Raw Materials Centre represents a genuine opportunity to close that gap: but only if its founding regulation is built around binding commitment rather than voluntary coordination. Across all four strands, the difference between a Centre that works and one that merely convenes will be determined by legislative design choices made now. This submission, prepared by The SPRING Group, provides analysis and recommendations on joint purchasing, stockpiling, investment support, market intelligence, and governance, with particular attention to transparency, human rights due diligence, and SME access.