An investigation into the impact of strategic raw material projects under the Critical Raw Materials Act on water resources and stakeholder rights
The Critical Raw Materials Act ( CRMA ) aims to improve Europe’s raw material supply. To this end, the EU is accelerating permitting processes for “strategic raw material extraction projects,” among other measures. A joint study by PowerShift and NABU shows how fast-track approvals threaten water protection and participatory rights – and how the protection of democratic participation and the environment is possible.
What the EU needs to change
Europe’s raw materials policy faces a dual test: security of supply must not come at the expense of water, nature, and democratic participation. The CRMA advocates for speed – but if deadlines are shortened and exceptions made easier, legal uncertainty, loss of public acceptance, and lasting environmental damage are likely. Water is particularly sensitive: pollution and pressure on its use directly impact ecosystems and drinking water supplies.
What the study shows
- Fast-track processes jeopardize effective participation.
Compressed deadlines and “strategic” status can devalue participation if documents are submitted late, incomplete, or in unusable formats. This creates high dynamics of conflict and litigation risk. - Water standards: Strengths – but also gaps.
For drinking water, many EU limits are strict. For surface waters, however, harmonized EU-wide standards are lacking for several mining-related substances; in some cases, there are neither EU nor national limits. - “Overriding public interest” as a risk lever:
The CRMA can favor future exceptions to the prohibition of deterioration. Without clear limits, water protection goals become politically secondary – with consequential costs for the environment and public budgets. - Tailings & Mining Waste: EU Rules Not “Best Practice”
The EU Extractive Waste rules are considered outdated; a key gap is the lack of a ban on upstream tailings dams for new plants. The study recommends an update towards global best practices and independent oversight. - Without safeguards, “sacrifice zones” emerge.
When transparency, accountability, and rights-based approaches are lacking, resource-rich regions become sacrificed zones. This undermines the promise of a just transformation and exacerbates social tensions.
What this means in practice
Four cases demonstrate the concrete effects of fast-track logic, information deficits, and water risks.
Spain : Mina Doade (Galicia)
Project splitting and a lack of cumulative assessment along a 12-km belt; key water risks (including acid mine drainage) remain inadequately addressed. Authorities requested studies, some of which were not submitted.
Portugal : Mina do Barroso (Northern Portugal)
In 2023, 1,776 EIA documents were to be reviewed in just 10 working days. In 2025, the UN Aarhus Committee criticized shortcomings in information and participation. After initial rejections in 2023, the project was approved for political reasons; legal action is underway.
Sweden : Sámi rights and CRMA pace
Civil society criticizes the fact that accelerated procedures and the overriding public interest weaken participation and legal protection. Particularly problematic is the inadequate assessment of cumulative effects on reindeer herding, culture, and livelihoods.
Germany : Zinnwald (Saxony)
The study reveals gaps in implementation and participation compared to high benchmarks (Aarhus/IRMA/Escazú). CRMA pressure intensifies debates about whether resource security is effectively displacing other protected assets.
What needs to be done politically now
The study presents 17 recommendations. At its core is a rights and environmental approach that makes permitting not only faster but also better: transparent, verifiable, with genuine participation, robust environmental and social assessments, and guaranteed decommissioning.
5 key points summarized
- Strengthen participation: Recognize those affected as rights holders, ensure the protection of those involved.
- Make information usable: provide expert opinions and contracts in an open, machine-readable and understandable format; finance translations and independent expertise.
- Environmental and Social Impact Assessments (ESIA) without abbreviations: comprehensive, independently verified, including human rights/social impacts, alternatives, and cumulative and transboundary effects.
- Prioritize the Water Framework Directive: Water is the basis of human life, no weakening of limit values or the prohibition of deterioration; expand monitoring and financing for measures.
- Modernize the regulation of mining waste: Develop the Extractive Waste Directive into a regulation, align it with Safety-First guidelines, strengthen independent oversight and robust financial guarantees.
How the study proceeds
Methodologically, the study combines legal analysis and country gap analyses with international benchmarking: Aarhus as the EU baseline, Escazú as a further development of standards (including the protection of defenders), and IRMA as a “best-in-class” standard for mining practice.
Learn more
More on the risks of commodity policy .
Compass World Economy – the PowerShift Podcast.
PowerShift Action Guide for greater participation in various languages.
Press & Background
For interviews, sound bites and data, please contact:
Adrian Bornmann,
Press and Public Relations Officer;
Maja Wilke,
Raw Materials Policy Officer