Europe is developing a roadmap for providing the EU with critical raw materials: how can Ukraine join?

On May 15, during the EIT Raw Materials Summit, a report of the European Raw Materials Alliance, “Materials for Energy Storage and Conversion: A European Call for Action”, was published.

This report is a logical continuation of the EU Regulation on ensuring a sustainable supply of critical raw materials to the European Union (Critical Raw Materials Act), which emphasises the implementation of concrete and measurable actions by relevant working groups representing key stakeholders from industry, public and private scientific and technical organisations, academia and civil society.

The report provides the first clear road map for addressing the challenges of the entire mineral value chain: from exploration to processing. The focus is on four main strategic areas: materials in solar energy, battery materials, fuel cells and electrolysers, alternative energy storage and conversion – and specific recommendations and actions are prescribed for each.

Key actions outlined in the ERMA report include:

  1. Continue to foster societal acceptance of mining projects across Europe.
  2. Secure raw materials supply by facilitating the opening of new mines
  3. Increase EU recycling capacity through the development of new technologies.
  4. Facilitate the diversification of raw materials supply by mobilising EU diplomacy (i.e., build strong relationships with resource-rich countries).
  5. Strengthen the transparency and sustainability of global solar supply chains, starting with silicon, from extraction to recycling.
  6. Provide a highly skilled workforce across the energy storage and conversion sectors to reduce the most urgent skill gap.
  7. Develop and roll out digital tools to monitor material and waste flows throughout the whole value chain via Industry 4.0 approaches (e.g., IoT, blockchain).

All this, together with the EU Regulation published at the beginning of spring on ensuring the sustainable supply of critical raw materials to the European Union, is intended to guarantee the EU access to those minerals that are critical for the development of the European Union’s economy.

One of the key actions identified in the ERMA report is the development of strategic partnerships with countries rich in natural resources. In this regard, Ukraine occupies a prominent place, because, unlike countries such as Chile, Australia, and the Democratic Republic of the Congo, with which the EU is only planning to sign agreements on strategic partnership, Ukraine is part of Europe – at least geographically, at the moment, which reduces the cost of both time and money required for the delivery of mined minerals to the EU as well as value-added goods, finished products, etc. In addition, Ukraine was one of the first countries with which the EU signed the Memorandum of Understanding on a Strategic Partnership on Raw Materials. As stated in the report, ERMA was the driver of the signing of the Memorandum and the corresponding roadmap of activities on July 13, 2021, between Ukraine and the EU.

Furthermore, ERMA brings together organisations from the public and private sectors covering the entire mineral value chain. Ukraine is also represented in this Alliance – its members are the Ministry of Energy of Ukraine, the State Geological Survey of Ukraine, the Ukrainian Association of Geologists, the Institute of Geology of KNU named after T.G. Shevchenko, as well as two Ukrainian enterprises – “Mine Extraction” LLC, which has a special permit for the extraction of chrome ores from the Kapitanskyi deposit in the Kirovohrad region, and “Zavallivskyi Graphite” LLC, which is a producer of natural graphite from the ores of the Zavalliv deposit, also located in the Kirovohrad region.

ERMA can be joined by any organisation working in the field of mineral resources – a private business, a research institution or an NGO. Participation in such European alliances expands Ukraine’s opportunities to cooperate with the EU and attract investments. According to the State Geological Survey of Ukraine, there are deposits of 22 out of 34 minerals that are on the critical raw materials list of the EU located on the territory of our country. Ukraine is among the top 10 producers of titanium, manganese, zirconium and graphite, and has proven reserves of metals associated with a low-carbon future used in innovative technologies. European investment is what is needed to increase the extraction of minerals critical for the EU and to create supply chains of critical raw materials to the countries of the Union.

To remind, BRDO experts work as part of the EU Project “New Subsoil Code of Ukraine”, the main tasks of which in 2023 are:

  • Support policy dialogue with key relevant institutions in the sector.
  • Analyse the obligations and opportunities of Ukraine as a candidate country for joining the EU in the field of subsoil use and critical raw materials.
  • Identify gaps in Ukrainian legislation to improve industry regulation.
  • Analyse and develop proposals for the improvement of management and regulatory functions in the industry.

In the near future, we will publish the analysis of our experts regarding the compliance of the Law of Ukraine No. 2805 with EU law. The Law of Ukraine “On Amendments to Certain Legislative Acts of Ukraine Regarding the Improvement of Legislation in the Field of Subsoil Use” dated December 1, 2022 (No. 2805-IX) entered into force on March 28, 2023, and creates new rules in the field of subsoil use for the purpose of development and investment attraction.


The project is financed by the European Union and implemented by the Consortium consisting of experts from Projekt-Consult (Germany), MinPol (Austria) and the Better Regulation Delivery Office (Ukraine). This publication reflects the position of the Project and does not necessarily coincide with the position of the European Commission.