What the EU's Critical Raw Materials Act Means for Buyers Looking Outside China

Brussels set a number that nobody in procurement wants to talk about openly. By 2030, no single third country should supply more than 65% of the EU's annual consumption of any strategic raw material. For antimony, tungsten and several others, China is well past that line. Some materials sit closer to 90%.

That's the gap. And honestly, I don't think most EU buyers I've spoken to have a real plan for closing it.

I run GBX Resources out of Gilgit-Baltistan in northern Pakistan. We hold 16 mineral concessions across the Karakoram and the western Himalaya, and over the last 18 months the inbound calls have shifted in a very specific way. Less gold. Less jade. Much more antimony, tungsten, copper, moly. The buyers asking the sharpest questions are German, French and Japanese. The Chinese traders, interestingly, are asking too — they want the same units before anyone else does.

What the CRMA actually demands of buyers

The Act lists 34 critical raw materials and 17 strategic ones. The strategic list is where the teeth are. Antimony went on it. Tungsten was already there. Copper was added as both critical and strategic after a fairly bruising lobbying fight, which tells you how seriously the Commission now treats wire, motors and grid build-out.

The 2030 benchmarks are the part procurement teams need to internalise:

• 10% of annual EU consumption extracted within the EU
• 40% processed within the EU
• 25% recycled within the EU
• And the 65% single-country supply ceiling I mentioned above

Look, the 10% domestic extraction target is aspirational at best. Permitting a new mine in Spain or Portugal takes 12 to 15 years. The recycling target is more realistic for copper, less so for antimony where the scrap pool is tiny. Which leaves the 65% ceiling doing most of the heavy lifting — and that ceiling can only be met by finding new origin countries. Not new traders. New origins.

That's where Pakistan, Central Asia, parts of Africa and a handful of Latin American jurisdictions enter the conversation.

The three metals where the squeeze is sharpest

Antimony. China plus Russia plus Tajikistan account for roughly 83% of global mined supply. China then dominates the trioxide and metal stages. When Beijing announced the September 2024 export controls on antimony, the metal went from around $13,000/t to north of $25,000/t inside a few months. Flame retardants, lead-acid batteries, and — the one the defence buyers care about — armour-piercing ammunition primers and night-vision optics, all of it routes through that bottleneck.

In our Chilas and Astore blocks we're working stibnite-quartz veins in the Kohistan island arc rocks. Hand-sorted ore from surface workings has run 38–54% Sb in lab assays, with vein widths between 0.4 and 1.8 metres. Not a Xikuangshan replacement on its own. But a real, declarable, non-Chinese unit that ships through Karachi or via the Khunjerab–Kashgar corridor depending on the buyer's preference.

Tungsten. China holds about 80% of mined production and an even larger share of APT (ammonium paratungstate) conversion. The EU lost its only operating tungsten mine in Portugal a few years back to care and maintenance. Austria's Mittersill is one of the few Western producers still running at scale. Our scheelite occurrences in the Karakoram batholith contact zones are early-stage — we've got rock chip results between 0.4% and 1.2% WO₃ from skarn float — but the geological setting is exactly the same belt that hosts mineralisation across the border into Xinjiang.

Copper. Different problem. Mining is more diversified globally — Chile, Peru, DRC, Zambia — but smelting and refining isn't. China refines about 45% of the world's copper. For EU buyers who want both non-Chinese mined units and non-Chinese refining, the option set narrows fast. Reko Diq in Balochistan is the headline Pakistani copper story, but our concessions in the Chalt-Thalichi belt sit on similar arc geology with reported chalcopyrite-bornite mineralisation. Early days for us on that one, but the rocks tell a clear story.

What CRMA suppliers actually need to deliver

Here's the thing buyers don't always say out loud. The Act doesn't just want non-Chinese tonnes. It wants non-Chinese tonnes with paperwork. Strategic Project status under the CRMA — which unlocks faster permitting on the EU end and easier financing — requires the project to meet ESG criteria, have a credible offtake pathway, and demonstrate that the supply chain back to the mine gate is auditable.

That last part is where a lot of African and Central Asian suppliers stumble. Mixed-origin material gets blended at the smelter and the chain of custody dies. We've been building our documentation around this from the start because I got it wrong on an earlier shipment in 2022 — sent a parcel to a Gulf trader without origin certification beyond the standard Pakistani export docs, and the end buyer in Europe couldn't use it for CRMA-aligned reporting. Lost the relationship. Won't make that mistake again.

For serious non-China critical minerals sourcing, what an EU or Japanese buyer should be asking a Pakistani counterparty:

• Concession number, lease term, and the Directorate of Mines & Mineral Development reference
• Royalty status and any provincial or federal encumbrances
• Independent assay (SGS Karachi or Bureau Veritas Lahore are the usual ones)
• A logistics route — most of our material moves Karachi port via the N-35 Karakoram Highway, around 1,650 km, roughly 7–9 days truck transit
• Whether the seller has done a CRMA gap analysis on their operation. Most haven't.

Where I think this actually goes

The EU isn't going to hit the 2030 numbers. Nobody serious in Brussels thinks otherwise in private. But the policy direction is locked in, and the procurement contracts being signed today already carry origin diversification clauses that didn't exist in 2022.

The quiet shift I'm watching is that Japanese trading houses — Sumitomo, Mitsui, Marubeni — are moving faster than the Europeans on actual ground-level diligence in Pakistan. They've been here. They've sampled. The Germans are still mostly sending consultants. The French defence-adjacent buyers are somewhere in between.

If you're sitting in a procurement seat in Stuttgart or Lyon or Osaka and antimony is on your bill of materials, the question isn't whether you need a non-Chinese line. The question is who you partner with before the next export-control announcement out of Beijing — and whether you've actually been to the country your supplier is operating in.

How many of you reading this have flown into Skardu?