The growing global demand for transition minerals, particularly by resource-poor countries in the Global North, is driving a renewed surge in mining across producing regions. This trend risks deepening long-standing inequalities in how the benefits and burdens of extraction are shared. Despite being essential for the clean energy transition, the mining sector continues to be linked with human rights violations, environmental degradation, and threats to human rights defenders. Communities warn that accelerating mineral supply without strong safeguards fuels conflicts and creates further social and ecological harm.
In response to the urgency of securing mineral supply chains, the European Union adopted the Critical Raw Materials Act (CRMA) in 2024. Under this law, the European Commission approved 60 strategic projects in 2025, including 13 located outside the EU. These external projects focus solely on extraction or processing, raising concerns about whether producing countries truly benefit from value addition. A review of the selection process and community perspectives surrounding these projects reveals inconsistent human rights policies, gaps in local engagement, and inadequate mechanisms for ensuring public participation.
Research shows that eight of the 13 non-EU projects are planned in countries with weak governance and elevated corruption risks. Many sites are located in water-stressed or impoverished regions where mining could worsen existing hardships. None of the project promoters have both a publicly available human rights policy and a comprehensive environmental and social impact assessment. Only one project, Dumont in Canada, has published an environmental impact study, and even that assessment has been criticized as outdated and incomplete. Few companies involved are part of responsible mining initiatives or adhere to international standards.
The CRMA’s sustainability criteria call for socially responsible practices, respect for human rights, Indigenous rights, and meaningful community engagement. However, the European Commission has not provided clear explanations of how these criteria were applied during the selection process. This lack of transparency has drawn criticism from civil society and raised questions about potential breaches of obligations under international frameworks such as the Aarhus Convention, which guarantees public access to environmental information and participation in decision-making. Past rulings, such as the case of the Barroso lithium project in Portugal, highlight the importance of public involvement before mining decisions are finalized.
Concerns are already emerging around several proposed project sites. In Madagascar, the Maniry graphite project risks displacing communities in one of the country’s poorest, drought-affected regions. In Norway, the Nussir copper project threatens Sámi land, reindeer herding, and marine ecosystems due to plans for submarine tailings disposal. In South Africa, a rare earth project is planned in a province grappling with poverty and water scarcity. Communities in Malawi, Serbia, Ukraine, and Greenland are also raising alarms about water access, corruption, pollution, and threats to Indigenous livelihoods.
Many project promoters lack essential corporate policies on human rights, impact assessments, and community engagement. Only a few companies, such as Rio Tinto, Société Le Nickel, and Jervois Global, have published human rights commitments, though these firms also have past records of alleged abuses in other operations. Evidence of meaningful engagement with affected communities is limited across nearly all projects, threatening the right to free, prior and informed consent for Indigenous Peoples.
Strategic project status under the CRMA provides significant advantages, including fast-tracked permitting and access to investment support, but these benefits heighten the need for strict human rights obligations. European institutions and financial partners must ensure that strategic projects do not compromise local communities or environmental integrity. Effective oversight and stronger corporate policies are essential, especially in countries with weak regulatory systems.
Ultimately, the CRMA’s strategic projects require greater transparency, rigorous due diligence, and ongoing monitoring. The EU must ensure that mineral supply chains advance justice and shared prosperity rather than reproduce old patterns of exploitation. Building trust through genuine community participation, transparency, and respect for human rights is not only a legal and ethical responsibility—it is crucial for the long-term sustainability of the mineral transition the EU seeks to secure.
