HomeSectorsAluminium and metals

European Aluminium and metals


How the tracked legislation reaches the sector — 150 measures name it directly, and 69 more reach it through supply chains, procurement or other acts.

Direction
166 burden · 51 benefit
2 unchanged — counted in neither
Status
150 adopted · 26 proposed · 43 mixed
Channel
150 direct · 69 reached
reached via supply chain 8 · procurement 2 · regulatory dependency 59

The platform holds 219 measures for European aluminium and metals: 166 imposing a burden, 51 conferring a benefit, 2 carried over unchanged. Of these, 150 from law in force, 26 from proposals, 43 from a file spanning both; 150 arrive directly, 69 through a channel.

Named in the text

Measures that address aluminium and metals directly

PRM-04Automatic classification as a 'strategic project' contributing to resilience and decarbonisation or resource efficiency, granting access to the priority/streamlined treatment of the future Environmental Assessment Regulation.Promoters of energy-intensive industry decarbonisation projects · BusinessesArt. 6(2) · From entry into forceEntitlementLM-01Have emissions and other data used to calculate a product's greenhouse gas intensity verified by accredited verifiers before it can be classified/labelled as low-carbon.Manufacturers seeking a greenhouse-gas-intensity classification for industrial products · BusinessesArt. 10(2) · Once the underlying delegated acts on classification are adoptedRequirementLM-02Exclude tenders from economic operators owned/controlled by entities in third countries that have no international agreement guaranteeing access, for the lead-market procurement procedures.Contracting authorities and contracting entities · GovernmentsArt. 11(1) · From 1 January 2029RequirementLM-03aApply the Union-origin and low-carbon requirements laid down in Annex II Part I (steel, concrete/mortar, aluminium) and Annex III Part I (electric vehicles) in covered public procurement.Contracting authorities and contracting entities · GovernmentsArt. 11(2) · From 1 January 2029RequirementLM-03bGuaranteed minimum demand share in EU public procurement: at least 25% of steel volume must be low-carbon, at least 5% of concrete/mortar (incl. clinker/cement) must be low-carbon and EU-origin, and at least 25% of aluminium must be low-carbon and EU-origin.Producers of low-carbon and/or Union-origin steel, concrete/mortar and aluminium · BusinessesArt. 11(2); Annex II, Part I · From 1 January 2029OpportunityLM-04May waive the Union-origin/low-carbon procurement requirements where only one supplier exists, no suitable tenders were received, or compliance would be disproportionately costly.Contracting authorities and contracting entities · GovernmentsArt. 11(3) · From 1 January 2029 / [6 months after entry into force]RequirementLM-05Require suppliers to submit a self-declaration or equivalent document demonstrating compliance with the Union-origin/low-carbon procurement requirements.Suppliers of steel, concrete/mortar, aluminium and EV products under EU public contracts · BusinessesArt. 11(4) · From 1 January 2029 / [6 months after entry into force]RequirementLM-06aDesign public support schemes so that the Union-origin/low-carbon requirements of Annex II Part II and Annex III Part II apply to at least 45% of the national budget for Annex II Part II-type schemes and 100% of the budget for Annex III Part II-type schemes.Member States, regional/local authorities and bodies governed by public law · GovernmentsArt. 12(1) · From 1 January 2029RequirementLM-06bCreated demand for low-carbon/EU-origin steel, concrete/mortar and aluminium via publicly-funded renovation, construction and infrastructure support schemes conditioned on using at least 25%/5%/25% qualifying material.Producers of low-carbon and/or Union-origin steel, concrete/mortar and aluminium · BusinessesArt. 12; Annex II, Part II · From 1 January 2029OpportunityLM-08May still run support schemes that do not meet the Annex II/III Part II requirements where compliance would cause significant delay or disproportionate cost.Member States / competent authorities administering public support schemes · GovernmentsArt. 12(3) · From 1 January 2029RequirementSCP-01CBAM applies to processed products made from Annex I goods under inward processing where they are re-exported to Norway or Iceland, bringing those consignments into the CBAM regime.Importers and authorised CBAM declarants of processed products re-exported to Norway or Iceland · BusinessesArt. 1(1)(a), inserting Art. 2(2a) of Regulation (EU) 2023/956 · upon incorporation of the Regulation in the EEA AgreementRequirementSCP-02Comply with the CBAM regime for goods originating in third countries that were previously released for free circulation in the customs territory of an EFTA State that has incorporated the CBAM.Customs declarants importing goods previously released for free circulation in a CBAM-integrated EFTA State · BusinessesArt. 1(1)(b), adding a subparagraph to Art. 2(4) of Regulation (EU) 2023/956 · upon incorporation of the Regulation into the EEA AgreementSimplificationSCP-03Bear responsibility for having documentation proving prior release for free circulation in an EFTA State available at the moment the customs declaration is lodged.Customs declarants relying on the EFTA prior-free-circulation exemption · BusinessesArt. 1(1)(b), adding a subparagraph to Art. 2(4) of Regulation (EU) 2023/956 · upon incorporation of the Regulation into the EEA AgreementRequirementSCP-04A new 'Combined metal products' category enters CBAM scope, pulling downstream steel- and aluminium-containing manufactured goods into the embedded-emissions declaration and certificate-surrender regime for the first time.Importers and authorised CBAM declarants of downstream steel- and aluminium-containing goods · BusinessesArt. 1(21); Annex I, point (2) adding the 'Combined metal products' table to Annex I of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2RequirementSCP-06Comply with CBAM for a good whose inclusion in Annex I is causing severe harm to the Union internal market through serious and unforeseen price effects.Importers of goods withdrawn from Annex I under the safeguard · BusinessesArt. 1(17), inserting Art. 27a of Regulation (EU) 2023/956 · from entry into forceSimplificationDECL-01Include in the CBAM declaration evidence that the imported goods were actually produced at the declared installation and at the declared time of production.Authorised CBAM declarants for goods flagged for supply-chain traceability risk · BusinessesArt. 1(5)(a)(2), adding point (e) to Art. 6(2) of Regulation (EU) 2023/956 · from entry into forceRequirementDECL-02Where a goods/origin combination is designated high-risk for abusive practices and actual emissions are claimed, prove in the declaration that the abuse risk has not materialised.Authorised CBAM declarants claiming actual emissions for high-risk goods/origin combinations · BusinessesArt. 1(5)(a)(2), adding point (f) to Art. 6(2) of Regulation (EU) 2023/956 · from entry into forceRequirementDECL-03Report total embedded emissions per tonne of goods (or per MWh for electricity), and have them verified where actual emissions are supplied by the operator through the CBAM registry.Authorised CBAM declarants · BusinessesArt. 1(5)(a)(1), replacing point (b) of Art. 6(2) of Regulation (EU) 2023/956 · from entry into forceRequirementDECL-05Produce, on request during review of the CBAM declaration, evidence that the imported goods were produced at the installation named in the declaration.Authorised CBAM declarants determining embedded emissions on actual emissions · BusinessesArt. 1(11), inserting Art. 19(2a) of Regulation (EU) 2023/956 · from entry into forceRequirementDECL-06Keep the full underlying records required to calculate embedded emissions, rather than the information actually disclosed to the declarant under Art. 10(7).Authorised CBAM declarants · BusinessesArt. 1(6)(b), replacing Art. 7(5) of Regulation (EU) 2023/956 · from entry into forceSimplificationCALC-01Count the embedded emissions of Annex VIII input materials (precursors) when determining the embedded emissions of the goods.Operators and authorised CBAM declarants calculating embedded emissions · BusinessesArt. 1(6)(a), inserting Art. 7(2a) of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2RequirementCALC-02Apply the complex-goods calculation counting precursors from both Annex I and the new Annex VIII, excluding those from exempted third countries.Operators of installations producing complex CBAM goods · BusinessesArt. 1(22); Annex II, point (2) replacing point 3 of Annex IV of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2RequirementCALC-03For iron and steel, aluminium and combined metal goods, derive the precursor mass from the content of input goods in the finished product rather than from a directly measured mass.Operators of installations producing iron and steel, aluminium and combined metal goods · BusinessesArt. 1(22); Annex II, point (2) replacing point 3 of Annex IV of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2RequirementCALC-05Treat aluminium waste and scrap, other than post-consumer scrap, as a precursor whose embedded emissions count towards the goods.Operators and declarants using aluminium scrap as an input material · BusinessesArt. 1(24); Annex III adding Annex VIII to Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2RequirementCALC-06Bear the mark-up added to default values when declaring downstream goods with complex supply chains.Importers and declarants of listed downstream goods using default values · BusinessesArt. 1(6)(c), adding a subparagraph to Art. 7(7) of Regulation (EU) 2023/956 · from entry into forceSimplificationANTI-01Refrain from practices whose purpose is to gain a benefit by unduly avoiding, wholly or partly, the CBAM financial liability.All actors in the CBAM supply chain · BusinessesArt. 1(3), adding point (35) to Art. 3 of Regulation (EU) 2023/956 · from entry into forceRequirementANTI-02Refrain from artificially adjusting supply chains so that goods qualify for lower default values; doing so is circumvention.Importers, declarants and operators in CBAM supply chains · BusinessesArt. 1(16), adding point (c) to Art. 27(2) of Regulation (EU) 2023/956 · from entry into forceRequirementANTI-03Monitor the CBAM's internal-market impact, warn importers, declarants, competent and customs authorities of high-risk goods/origin combinations, and legislate the conditions for using actual emissions for them.European Commission · GovernmentsArt. 1(5)(c), adding Art. 6(7) to Regulation (EU) 2023/956 · from entry into forceRequirementFIN-01Provide a bank guarantee payable at first demand, sized on the certificates that would have to be surrendered, where the competent authority finds financial capacity is not demonstrated.Applicants and authorised CBAM declarants failing to demonstrate financial capacity · BusinessesArt. 1(9)(a), inserting Art. 17(5a) of Regulation (EU) 2023/956 · from entry into forceRequirementFIN-03From 2028, satisfy the quarterly certificate-holding requirement using only certificates bought in the same year, so certificates carried over from earlier years no longer count.Authorised CBAM declarants · BusinessesArt. 1(13), adding a subparagraph to Art. 22(2) of Regulation (EU) 2023/956 · from 2028RequirementFIN-04Pay the CBAM certificate price as fixed by the fallback rules for weeks with no auction or a single auction.Authorised CBAM declarants purchasing CBAM certificates · BusinessesArt. 1(12)(a), replacing the second subparagraph of Art. 21(1) of Regulation (EU) 2023/956 · from entry into forceRequirementFIN-06Have the documentation evidencing a carbon price paid in a third country certified by a person independent from the authorised CBAM declarant AS WELL AS from that country's authorities.Authorised CBAM declarants claiming a carbon price paid in a third country · BusinessesArt. 1(7)(a)(1), replacing the third sentence of Art. 9(2) of Regulation (EU) 2023/956 · from entry into forceSimplificationFIN-08Apply the Commission's conversion rules when turning a carbon price paid abroad into a reduction in CBAM certificates, including the evidence of actual payment and any deduction of Paris Agreement Article 6 carbon credits.Authorised CBAM declarants claiming a carbon price paid in a third country · BusinessesArt. 1(7)(b)(1), replacing the first subparagraph of Art. 9(5) of Regulation (EU) 2023/956 · from entry into forceRequirementDATA-01An operator may pass verified emissions and carbon-price information not only to an authorised CBAM declarant but to another operator, so verified data can move along the supply chain.Operators of installations in third countries registered in the CBAM registry · BusinessesArt. 1(8)(c), replacing the first sentence of Art. 10(7) of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2EntitlementDATA-02An operator may limit what it hands the declarant to a summary of the registered information, and the declarant is entitled to rely on that summary to discharge its Article 8 verification obligation.Operators of third-country installations and the authorised CBAM declarants they supply · BusinessesArt. 1(8)(d), replacing the second sentence of Art. 10(7) of Regulation (EU) 2023/956 · from entry into forceEntitlementDATA-03Remain responsible for surrendering the correct number of CBAM certificates even where the declaration was built on information disclosed by the operator.Authorised CBAM declarants relying on operator-disclosed information · BusinessesArt. 1(8)(d), replacing the second sentence of Art. 10(7) of Regulation (EU) 2023/956 · from entry into forceRequirementDATA-04Ensure that the conditions laid down for using actual emissions are met for the relevant combinations of goods and origins.Operators of installations registered in the CBAM registry · BusinessesArt. 1(8)(b), adding point (e) to Art. 10(5) of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2RequirementDATA-05A third-country operator may have its installation registered in the CBAM registry not only to support actual-emissions verification but to establish the carbon price it has paid at home.Operators of installations located in third countries · BusinessesArt. 1(8)(a), replacing Art. 10(1) of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2EntitlementCUST-01Communicate import data to the Commission automatically, now including bills of discharge, re-export declarations and equivalent customs documentation, and the importer's identity where there is no EORI number.Customs authorities of the Member States · GovernmentsArt. 1(15)(a), replacing Art. 25(2) of Regulation (EU) 2023/956 · from entry into forceRequirementCUST-02Accept that the CBAM account number entered in the customs declaration fixes which authorised CBAM declarant assumes the obligations for that consignment.Authorised CBAM declarants and importers · BusinessesArt. 1(15)(a), replacing Art. 25(2) of Regulation (EU) 2023/956 · from entry into forceRequirementCUST-04Apply the material and chemical compositions that the Commission fixes by implementing act for Annex I goods.Importers and authorised CBAM declarants of Annex I goods · BusinessesArt. 1(15)(d), adding Art. 25(7) to Regulation (EU) 2023/956 · from entry into forceRequirementGOV-01Base the 2027 assessment due by 30 April 2027 on import data for the goods in both the existing and the newly extended Annex I.European Commission · GovernmentsArt. 1(2), adding a subparagraph to Art. 2a(3) of Regulation (EU) 2023/956 · by 30 April 2027RequirementGOV-02Report to Parliament and Council before 1 January 2028 and biennially thereafter on CBAM's operation, covering carbon leakage, internal-market and price effects, governance, circumvention practices, penalties and per-country emission intensity.European Commission · GovernmentsArt. 1(20), replacing the second subparagraph of Art. 30(6) of Regulation (EU) 2023/956 · before 1 January 2028, then every two yearsRequirementGOV-03State the material composition of each downstream good in the verification report.Accredited verifiers preparing CBAM verification reports · BusinessesArt. 1(23)(b), inserting point (ka) in point 2 of Annex VI of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2RequirementGOV-04Set out in the verification report the quantities of each type of goods produced, the quantification of the installation's direct emissions, how those emissions are attributed across goods, and the energy and emissions flows not associated with those goods.Accredited verifiers preparing CBAM verification reports · BusinessesArt. 1(23)(a), deleting points (g) to (j) of point 2 of Annex VI of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2SimplificationCBAMB-SCP-08A third country or territory may be added to or removed from the Annex III exemption lists by delegated act, including as a consequence of CBAM incorporation into the EEA Agreement, and under urgency where imperative grounds require it.European Commission; importers of goods originating in third countries listed in Annex III · GovernmentsArt. 1(1)(e), replacing Art. 2(11) of Regulation (EU) 2023/956 · from entry into forceRequirementCBAMB-VER-02Use a verifier accredited by a Member State national accreditation body, there being no route to recognition of a third-country accreditation body.Authorised CBAM declarants and third-country operators procuring verification · GovernmentsArt. 1(1)(e), replacing Art. 2(12) of Regulation (EU) 2023/956 · from entry into forceSimplificationCBAMB-DECL-07Report, in the standard declaration format, the detail supporting each total -- per installation and per country of origin -- including the carbon price paid and the default carbon price for the purposes of Art. 9(4).Authorised CBAM declarants · BusinessesArt. 1(5)(b), replacing the first sentence of Art. 6(6) of Regulation (EU) 2023/956 · from entry into forceRequirementCBAMB-ANTI-05Designate, by implementing act, the goods or goods/origin combinations for which traceability evidence must accompany the declaration, and the type of evidence required.European Commission · GovernmentsArt. 1(5)(c), adding Art. 6(6a) to Regulation (EU) 2023/956 · from entry into forceRequirementCBAMB-CUST-05Communicate customs information at the scope, periodicity, timing and by the means the implementing acts prescribe, for the competent-authority flow under Art. 25(3) as well as the customs flow under Art. 25(2).Member State customs authorities and competent authorities · GovernmentsArt. 1(15)(c), replacing the first sentence of Art. 25(6) of Regulation (EU) 2023/956 · from entry into forceRequirementPRM-04A decarbonisation project spanning several facilities on one site may be split, by agreement with the single point of contact, into smaller projects so each fits the permitting time limits.Promoters of energy-intensive industry decarbonisation projects · BusinessesArt. 9(3) · Applies from 29 June 2024EntitlementCBEN-01Build Union capacity towards extracting 10%, processing 40% and recycling 25% of the Union's annual consumption of each strategic raw material by 2030.The Commission and Member States · GovernmentsArt. 5(1)(a) · By 2030RequirementCBEN-02Diversify imports so that no single third country supplies more than 65% of the Union's annual consumption of any strategic raw material by 2030.The Commission and Member States · GovernmentsArt. 5(1)(b) · By 2030RequirementCSP-01A raw materials project meeting all five criteria -- supply-security contribution, technical feasibility, sustainable implementation, cross-border benefit, and mutual benefit for third countries -- is recognised by the Commission as a Strategic Project, which carries the priority permitting track, the financing subgroup and the offtake system.Promoters of critical raw material projects in the Union, third countries and OCTs · BusinessesArt. 6(1) · From entry into force, 23 May 2024EntitlementCSP-02File a Strategic Project application carrying ten items: evidence against the criteria, a UN Framework Classification, a permitting timetable, a public-acceptance plan, ownership and control information, a business plan, a jobs and skills estimate, a post-exploitation environmental restoration plan, an alternative-locations assessment in protected areas, and an indigenous-peoples consultation plan.Promoters applying for Strategic Project recognition · BusinessesArt. 7(1) · From entry into force, 23 May 2024RequirementCSP-03Decide on Strategic Project recognition within 90 days of acknowledging a complete application, give reasons, and notify the applicant, the Board and the territory concerned.The Commission · European CommissionArt. 7(9) · From entry into force, 23 May 2024RequirementCSP-04Strategic Project status, and every right attached to it, is lost where the project stops meeting the Art. 6(1) criteria or was recognised on materially incorrect information.Promoters of Strategic Projects · BusinessesArt. 7(12) · From entry into force, 23 May 2024Entitlement withdrawnCSP-05A project that falls out of the criteria only because the list of strategic raw materials moved keeps its status, and everything attached to it, for three years.Promoters of Strategic Projects affected by an update of Annex I · BusinessesArt. 7(13) · From entry into force, 23 May 2024EntitlementCSP-06Report to the Commission every two years on implementation progress and permitting, on any slippage against the timetable and how it will be recovered, and on progress in financing including public support received.Promoters of Strategic Projects · BusinessesArt. 8(1) · Every two years from the date of recognitionRequirementCSP-07Supply additional information on the project when the Commission asks for it to check that the recognition criteria are still met.Promoters of Strategic Projects · BusinessesArt. 8(2) · From entry into force, 23 May 2024RequirementCSP-08Notify the Commission of changes to the project that affect the recognition criteria, and of any lasting change of control over the undertakings involved.Promoters of Strategic Projects · BusinessesArt. 8(3) · From entry into force, 23 May 2024RequirementCSP-09Run a free-access project website, in a language the local population understands and requiring no personal data to read, carrying at least the environmental, social and economic impacts and benefits of the project, and keep it updated.Promoters of Strategic Projects · BusinessesArt. 8(5) · From entry into force, 23 May 2024RequirementCSPC-01Establish or designate single points of contact, with at most one per administrative level and stage of the critical raw materials value chain, and list them on an accessible website.Member States · GovernmentsArt. 9(1) · By 24 February 2025RequirementCPRM-01Strategic Projects in the Union count as being of public interest or serving public health and safety, and may be treated as of overriding public interest, in the derogations of the Habitats, Water and Birds Directives and of ecosystem-restoration law.Promoters of Strategic Projects in the Union · BusinessesArt. 10(2) · From entry into force, 23 May 2024EntitlementCPRM-02A Strategic Project is given the highest national significance status the Member State's own law provides, and is treated accordingly throughout permitting.Promoters of Strategic Projects in the Union · BusinessesArt. 10(4) · From entry into force, 23 May 2024EntitlementCPRM-03Litigation, appeals and remedies over a Strategic Project's permits are treated as urgent wherever national law has an urgency procedure -- with the promoter required to take part in it.Promoters of Strategic Projects in the Union · BusinessesArt. 10(5) · From entry into force, 23 May 2024EntitlementCPRM-04Complete the permit-granting process for a Strategic Project within 27 months where it involves extraction, or 15 months where it involves only processing or recycling.Member State permit-granting authorities and single points of contact · GovernmentsArt. 11(1) · From entry into force, 23 May 2024RequirementCPRM-05Where the project was already in permitting before recognition, or is an extension of a permitted Strategic Project, finish within 24 months for extraction or 12 months for processing or recycling, counted from recognition.Member State permit-granting authorities and single points of contact · GovernmentsArt. 11(2) · From entry into force, 23 May 2024RequirementCPRM-06Acknowledge completeness of a Strategic Project permit application within 45 days or state exactly what is missing, and on a second pass ask only for evidence completing what was already identified.Single points of contact · GovernmentsArt. 11(6) · From entry into force, 23 May 2024RequirementCPRM-07Publish the permit-granting schedule drawn up by the single point of contact on the project's own free-access website.Promoters of Strategic Projects · BusinessesArt. 11(7) · From entry into force, 23 May 2024RequirementCENV-01Request a scoping opinion on the environmental impact assessment report within 30 days of being notified of Strategic Project recognition, and before filing the permit application.Promoters of Strategic Projects requiring an environmental impact assessment · BusinessesArt. 12(1) · From entry into force, 23 May 2024RequirementCENV-02Where two or more environmental assessment duties arise at once for a Strategic Project, run a coordinated or joint procedure satisfying all of them.Member States · GovernmentsArt. 12(2) · From entry into force, 23 May 2024RequirementCENV-03Issue the reasoned conclusion on a Strategic Project's environmental impact assessment within 90 days of receiving all necessary information and completing consultations.Member State competent authorities · GovernmentsArt. 12(3) · From entry into force, 23 May 2024RequirementCFIN-01A Strategic Project promoter may call in the Board's financing subgroup to work through how to close the project's financing, across private sources, the EIB Group and other IFIs, national instruments and export credit agencies, and Union programmes including Global Gateway.Promoters of Strategic Projects · BusinessesArt. 16(1) · From entry into force, 23 May 2024EntitlementCOFF-01A Commission-run matching system where offtakers bid volumes, qualities, prices and durations and Strategic Project promoters post offers, with the Commission introducing the two sides -- demand-side access a project developer did not previously have.Promoters of Strategic Projects and offtakers of strategic raw materials · BusinessesArt. 17(1)-(4) · From entry into force, 23 May 2024OpportunityCMON-01Identify the key market operators in the critical raw materials value chain on the territory, monitor them through public data and proportionate surveys, report the results, and notify the Commission without delay of major events disrupting them.Member States · GovernmentsArt. 21(2) · From entry into force, 23 May 2024RequirementCMON-02Answer a Member State's monitoring survey with the data already held, and give reasons for any refusal or claim that the data is unavailable.Key market operators along the critical raw materials value chain · BusinessesArt. 21(2), third subparagraph · From entry into force, 23 May 2024RequirementCMON-03A key market operator may refuse a monitoring data request where answering it would disclose trade or business secrets, and is never obliged to generate data it does not already hold.Key market operators along the critical raw materials value chain · BusinessesArt. 21(2), third subparagraph · From entry into force, 23 May 2024EntitlementCSTK-01Report the state of national strategic stocks -- levels in tonnes and as a share of annual consumption, chemical form and purity, five-year evolution, and the rules for release and distribution -- or give a justified notice for withholding it on defence or national security grounds.Member States · GovernmentsArt. 22(1)-(2) · From entry into force, 23 May 2024RequirementCJP-02Stay out of demand aggregation and joint purchasing, as participant, supplier or service provider, where sanctioned under Art. 215 TFEU or owned, controlled by or acting for a sanctioned person.Entities targeted by Union restrictive measures, and entities they own, control or direct · BusinessesArt. 25(6) · From entry into force, 23 May 2024RequirementCEXW-01Produce and file a preliminary economic assessment study of the potential to recover critical raw materials from the extractive waste stored in the facility and from waste being generated, estimating quantities and concentrations and assessing technical and economic recoverability.Operators of extractive waste facilities under Directive 2006/21/EC · BusinessesArt. 27(1)-(3) · By 24 November 2026RequirementCFP-01Publish an environmental footprint declaration for each critical raw material type placed on the market once calculation rules exist for it, naming the responsible person, the material type, the countries and regions of extraction, processing, refining and recycling, the calculated footprint, its performance class, and a link to the supporting study.Anyone placing critical raw materials, including processed and recycled, on the Union market · BusinessesArt. 31(6)-(7) · From adoption of the calculation and verification rules for t…RequirementCFP-02Give customers access to the environmental footprint declaration before they are bound by a sales contract, and display nothing likely to mislead or confuse them about what it says.Anyone placing critical raw materials on the Union market · BusinessesArt. 31(11) · From adoption of the calculation and verification rules for t…RequirementCREC-01A certification scheme owner may have its scheme recognised by the Commission against the Annex IV criteria, with the recognised coverage published in a public register -- and recognition feeds the Art. 6(1)(c) sustainability assessment for Strategic Projects.Governments, industry associations and groupings owning critical raw materials sustainability certification schemes · BusinessesArt. 30(1)-(2) · From entry into force, 23 May 2024EntitlementCREC-02Tell the Commission without delay of any change or update to a recognised scheme bearing on the Annex IV criteria.Owners of recognised certification schemes · BusinessesArt. 30(5) · From entry into force, 23 May 2024RequirementCPEN-01Lay down effective, proportionate and dissuasive penalties for infringements of the Regulation, put them into effect, and notify them and any amendment to the Commission without delay.Member States · GovernmentsArt. 47 · By 24 November 2025RequirementCRMAB-BEN-03Work to moderate the expected increase in Union consumption of critical raw materials below the Art. 44(1) reference projection, through technological progress and resource efficiency.The Commission and Member States · GovernmentsArt. 5(2) · From entry into force, 23 May 2024RequirementCRMAB-SP-10Continue to meet every requirement under Union, national and international law; Strategic Project recognition changes none of them.Promoters of Strategic Projects · BusinessesArt. 6(3) · From entry into force, 23 May 2024RequirementCRMAB-SP-11Run an open call with at least four cut-off dates a year and tell applicants within 30 days of the cut-off whether the application is complete.The Commission · European CommissionArt. 7(3)-(4) · From entry into force, 23 May 2024RequirementCRMAB-SP-12Accept that a single objection by the host Member State ends the application; the Member State must substantiate it before the Board.Promoters of proposed Strategic Projects, and the host Member State · BusinessesArt. 7(8) · From entry into force, 23 May 2024RequirementCRMAB-SP-13Hold the 90-day decision deadline where the application's nature, complexity or size, or the number received, requires longer.Promoters awaiting a recognition decision · BusinessesArt. 7(10) · From entry into force, 23 May 2024SimplificationCRMAB-SP-14Before recognition is withdrawn the promoter gets the Commission's reasons, an opportunity to reply, and a reply the Commission must take into account.Promoters facing withdrawal of Strategic Project recognition · BusinessesArt. 7(11) · From entry into force, 23 May 2024EntitlementCRMAB-SPC-02Facilitate and coordinate the permit-granting process, provide the Art. 18 information, act as the sole point of contact, and help the promoter understand any administrative matter in the process.Single points of contact · GovernmentsArt. 9(3)-(4) · From entry into force, 23 May 2024RequirementCRMAB-SPC-03A promoter can reach the named administrative unit handling its file, and that unit keeps its responsibilities until the promoter has been notified of any change.Promoters of critical raw material projects · BusinessesArt. 9(5) · From entry into force, 23 May 2024EntitlementCRMAB-SPC-04Accept all permit-granting documents in electronic form.Member States and their permit-granting authorities · GovernmentsArt. 9(6) · From entry into force, 23 May 2024RequirementCRMAB-SPC-05Re-run valid studies or re-obtain permits already issued for the same project.Promoters of critical raw material projects · BusinessesArt. 9(7) · From entry into force, 23 May 2024SimplificationCRMAB-SPC-06Give applicants easy access to dispute-settlement information and procedures, including alternative dispute resolution where applicable.Member States · GovernmentsArt. 9(8) · From entry into force, 23 May 2024RequirementCRMAB-PRM-08Carry the permit-granting process out in the most rapid way Union and national law allow -- a duty on the promoter as much as on the authorities.Promoters of Strategic Projects and all authorities concerned · BusinessesArt. 10(3) · From entry into force, 23 May 2024RequirementCRMAB-PRM-09Hold the permitting time limits where the project's nature, complexity, location or size requires longer -- six months more for extraction, three for processing or recycling.Promoters of Strategic Projects · BusinessesArt. 11(4) · From entry into force, 23 May 2024SimplificationCRMAB-PRM-10Decide within 30 days of the developer submitting the required information whether the Strategic Project needs a full environmental impact assessment.Member State competent authorities · GovernmentsArt. 11(5) · From entry into force, 23 May 2024RequirementCRMAB-ENV-04Request the scoping opinion within 30 days of recognition.Promoters whose project was already in permitting before recognition · BusinessesArt. 12(6) · From entry into force, 23 May 2024SimplificationCRMAB-PLAN-01Consider making room for critical raw materials projects in zoning, spatial and land use plans, with priority to built, industrial, brownfield and mined land.National, regional and local planning authorities · GovernmentsArt. 13(1) · From entry into force, 23 May 2024RequirementCRMAB-PLAN-02Combine the strategic environmental and habitats assessments for plans making room for critical raw materials projects, covering water bodies and the marine environment.Member States · GovernmentsArt. 13(2) · From entry into force, 23 May 2024RequirementCRMAB-INF-03Publish every permitting decision in an easily understandable form, with all decisions on one project on one website.Member States and their authorities · GovernmentsArt. 14(2) · From entry into force, 23 May 2024RequirementCRMAB-SP-15Take measures to facilitate timely implementation of a Strategic Project, including help with administrative and reporting compliance and with community involvement.Member States hosting a Strategic Project · GovernmentsArt. 15(2) · From entry into force, 23 May 2024RequirementCRMAB-INF-01Publish online and centrally the points of contact, the permit-granting and related processes, financing and investment services, funding possibilities, and business support services.Member States · GovernmentsArt. 18(1) · From entry into force, 23 May 2024RequirementCRMAB-INF-02Publish centralised online information on how Strategic Project recognition works and what it is worth.The Commission · European CommissionArt. 18(2) · From entry into force, 23 May 2024RequirementCRMAB-EXP-01Draw up and review a national exploration programme covering mineral mapping, geochemical campaigns, geoscientific surveys and reprocessing of existing survey data.Member States · GovernmentsArt. 19(1)-(2) · By 24 May 2025RequirementCRMAB-EXP-02Publish free-access maps of mineral occurrences with UN Framework classification where applicable, and release processed geophysical and geochemical data and large-scale mapping on request.Member States · GovernmentsArt. 19(6) · From entry into force, 23 May 2024RequirementCRMAB-MON-04Publish and keep updated a free-access monitoring dashboard carrying the parameter trends, the supply-risk calculation, and where appropriate mitigation suggestions.The Commission · European CommissionArt. 20(4) · From entry into force, 23 May 2024RequirementCRMAB-MON-05Report new and existing critical raw material projects on the territory, classified under the UN Framework Classification for Resources.Member States · GovernmentsArt. 21(1) · From entry into force, 23 May 2024RequirementCRMAB-MON-06Pass the collated monitoring data to national statistical authorities and Eurostat, and designate the authority responsible for doing so.Member States · GovernmentsArt. 21(3) · From entry into force, 23 May 2024RequirementCRMAB-STK-02Give particular weight, when opining on national stocks, to keeping private operators' incentives to hold their own strategic stocks and manage their own supply-risk exposure.The Commission and the Board · European CommissionArt. 23(4) · From entry into force, 23 May 2024RequirementCRMAB-JP-03Set up and operate an open, transparent demand-aggregation system covering unprocessed and processed strategic raw materials, after assessing the competition impact and setting minimum participation volumes with SMEs in mind.The Commission · European CommissionArt. 25(1)-(4) · From entry into force, 23 May 2024RequirementCRMAB-REP-01Supply information beyond what the reporting provisions listed in Art. 45(1) already require.Economic operators along the critical raw materials value chain · BusinessesArt. 45(1), second subparagraph · By 24 May 2026 and annually thereafterSimplificationFREE-01Place packaging on the market only if it complies with this Regulation.Any economic operator placing packaging on the market · BusinessesArt. 4(1) · New obligation · From 12 August 2026RequirementFREE-03Packaging that meets Arts. 5 to 12 may be placed on the market anywhere in the Union: no Member State may block it, and no additional national sustainability or information requirement may be enforced against it. One compliance route replaces 27.Economic operators placing compliant packaging on the market · BusinessesArt. 4(2) and (3) · new right · From 12 August 2026EntitlementSUB-02Keep the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components at or below 100 mg/kg.Manufacturers and importers of packaging · BusinessesArt. 5(4) · carry over · From 12 August 2026NeutralREC-01Make all packaging recyclable: designed for material recycling, and collectable, sortable and recycled at scale when it becomes waste.Manufacturers of packaging · BusinessesArt. 6(1) and (2) · New obligation · Design for recycling from 1 January 2030 or 24 months after t…RequirementREC-02Assess and grade each packaging unit A, B or C for recyclability; from 2030 do not place packaging below grade C on the market, and from 1 January 2038 do not place packaging below grade B.Manufacturers of packaging · BusinessesArt. 6(3) · Extension · Grade C floor from 1 January 2030 or 24 months after the Art. 6RequirementREC-03Re-comply with design-for-recycling criteria within 3 years each time the Commission adopts or updates them by delegated act.Economic operators placing packaging on the market · BusinessesArt. 6(4), final subparagraph · New obligation · From 12 August 2026RequirementREC-04Pay EPR financial contributions modulated by the packaging's recyclability performance grade.Producers subject to extended producer responsibility · BusinessesArt. 6(8) · New obligation · 18 months after the Art. 6RequirementREC-05Packaging that qualifies as innovative may be sold for up to five years from the end of the year it was first placed on the market even though it does not meet the recyclability requirement -- a run-in period no other packaging gets.Economic operators placing innovative packaging on the market · BusinessesArt. 6(10) · new right · From 1 January 2030EntitlementMIN-01Design packaging so weight and volume are reduced to the minimum necessary for functionality, and document the assessment against the Annex IV performance criteria.Manufacturers and importers of packaging · BusinessesArt. 10(1) and (4) · New obligation · By 1 January 2030RequirementMIN-02Do not place on the market packaging failing the Annex IV performance criteria, or packaging whose features exist only to increase perceived product volume -- double walls, false bottoms, unnecessary layers.Manufacturers and importers of packaging · BusinessesArt. 10(2) · New obligation · By 1 January 2030ProhibitionREU-01Meet all nine reusability criteria before packaging counts as reusable: designed for multiple rotations, emptiable and refillable without damage, reconditionable per Annex VI Part B, labellable, safe to handle, and recyclable at end of life.Manufacturers of reusable packaging · BusinessesArt. 11(1) · New obligation · From 11 February 2025RequirementLAB-01Mark packaging with the harmonised material-composition label, pictogram-based and understandable including for people with disabilities; mark compostable packaging as compostable, not home-compostable and not for disposal in nature.Economic operators placing packaging on the market · BusinessesArt. 12(1) · Extension · From 12 August 2028 or 24 months after the Art. 12RequirementLAB-02Label reusable packaging as reusable, carry a QR code or open digital data carrier giving re-use system and collection-point information and enabling trip and rotation counting, and distinguish reusable from single-use packaging at the point of sale.Economic operators placing reusable packaging on the market · BusinessesArt. 12(2) · New obligation · From 12 February 2029 or 30 months after the Art. 12RequirementLAB-03Do not display labels, marks, symbols or inscriptions likely to mislead or confuse consumers about packaging sustainability, other packaging characteristics, or waste-management options where this Regulation has harmonised the labelling.Economic operators · BusinessesArt. 12(8) · New obligation · From 12 August 2026ProhibitionLAB-04Packaging made or imported before the labelling deadlines may still be sold for three years after those requirements enter into force, so existing stock and pre-printed material do not have to be written off on the deadline.Economic operators holding pre-deadline packaging stock · BusinessesArt. 12(12) · Exemption · From the Art. 12 labelling deadlinesEntitlementLAB-06Make an environmental claim about a packaging property regulated here only where the packaging exceeds the applicable minimum requirement, and state whether the claim covers the unit, part of it, or all the operator's packaging.Economic operators making environmental claims about packaging · BusinessesArt. 14 · New obligation · From 12 August 2026RequirementOPS-01Carry out the Annex VII conformity assessment, draw up the technical documentation and the EU declaration of conformity, and keep both for 5 years for single-use and 10 years for reusable packaging.Manufacturers of packaging · BusinessesArt. 15(2) and (3) · New obligation · From 12 August 2026RequirementOPS-02Keep series production in conformity, tracking changes in packaging design and characteristics and in harmonised standards, common specifications and other technical specifications.Manufacturers of packaging · BusinessesArt. 15(4) · New obligation · From 12 August 2026RequirementOPS-03Give the packaging manufacturer all information and documentation it needs to demonstrate conformity, including the Annex VII technical documentation, in a language the manufacturer easily understands.Suppliers of packaging or packaging materials · BusinessesArt. 16 · New obligation · From 12 August 2026RequirementOPS-04Before placing packaging on the market, verify that the manufacturer carried out the conformity assessment and drew up the technical documentation, that the packaging is labelled under Art. 12 and accompanied by the required documents, and mark your own name, trade name and contact address on the packaging.Importers of packaging · BusinessesArt. 18(1) to (3) · New obligation · From 12 August 2026RequirementOPS-07On request, identify to market surveillance authorities every operator that supplied you with packaging or packaged products and every operator you supplied, retaining the ability to do so for 5 years for single-use and 10 years for reusable packaging.Economic operators · BusinessesArt. 22 · New obligation · From 12 August 2026RequirementRSY-01Ensure a re-use system meeting Annex VI, including a collection incentive, exists in each Member State where you first make reusable packaging available, and document the system's compliance in the technical documentation with written confirmations from system participants.Economic operators first making reusable packaging available in a Member State · BusinessesArt. 26 · New obligation · From 12 August 2026RequirementRSY-02Participate in one or more Annex VI Part A re-use systems, recondition reusable packaging per Annex VI Part B before offering it again, and in closed-loop systems return packaging to an approved collection point.Economic operators using reusable packaging · BusinessesArt. 27 · New obligation · From 12 August 2026RequirementCNF-01Demonstrate compliance with Arts. 5 to 12, 24 and 26 using reliable, accurate and reproducible test, measurement and calculation methods reflecting the state of the art, with results of low uncertainty.Economic operators demonstrating conformity · BusinessesArt. 35 · New obligation · From 12 August 2026RequirementCNF-02No longer required to prove conformity from first principles where a harmonised standard covers the requirement: conformity is presumed, and Art. 37 adds a Commission common-specification fallback where no standard exists or the standard is inadequate.Economic operators demonstrating conformity of packaging · BusinessesArts. 36(1)-(3) and 37 · Reduction · From 12 August 2026SimplificationCNF-03Prove conformity without relying on a national standard: the route by which a notified national standard conferred a presumption of conformity where no harmonised standard existed is not carried over.Economic operators in Member States that had notified national packaging standards · BusinessesArt. 36(1), by omission of the 94/62/EC Art. 9(2)(b) route · Reduction · From 12 August 2026RequirementCNF-04Run the Annex VII internal production control conformity assessment procedure for the Arts. 5 to 12 requirements.Manufacturers of packaging · BusinessesArt. 38 · New obligation · From 12 August 2026RequirementCNF-05Draw up, continuously update and keep the EU declaration of conformity in the Annex VIII model, translated as the Member State of marketing requires, and assume responsibility for the packaging's compliance by drawing it up.Manufacturers of packaging · BusinessesArt. 39 · New obligation · From 12 August 2026RequirementREG-01Register in the national producer register of every Member State where you first make packaging or packaged products available, or where you unpack packaged products without being an end user, supplying the Annex IX Part A information; do not make packaging available at all until registered.Producers of packaging and packaged products · BusinessesArt. 44(2), (4) and (5) · New obligation · 18 months after the first Art. 44RequirementREG-02Report the Annex IX Part B information to the register by 1 June each year for the preceding calendar year, with a lighter Part B point 2 return for producers under 10 tonnes; submit quarterly instead where the Member State requires it for budgetary reasons, and notify changes and cessation without undue delay.Producers, their authorised representatives, or their producer responsibility organisation · BusinessesArt. 44(7) to (9) and (12) · New obligation · Following registration under Art. 44RequirementEPR-01Carry extended producer responsibility for all packaging first made available or unpacked in a Member State, with financial contributions additionally covering the cost of labelling waste receptacles under Art. 13 and of compositional surveys of mixed municipal waste.Producers of packaging and packaged products · BusinessesArt. 45(1) and (2) · Extension · From 12 August 2026RequirementEPR-04A producer whose fulfilment service is suspended for an EPR information failure may challenge that decision before a court in the Member State where the fulfilment service provider is established.Producers whose fulfilment service has been suspended · BusinessesArt. 45(9) · new right · From 12 August 2026EntitlementEPR-05Apply to the competent authority for authorisation to fulfil extended producer responsibility, individually or through a producer responsibility organisation, and notify changes or cessation without undue delay.Producers fulfilling EPR individually, and producer responsibility organisations · BusinessesArt. 47(1) and (4) · New obligation · From 12 August 2026RequirementEPR-06Provide an adequate financial guarantee covering waste management costs owed in the event of non-compliance, permanent cessation of operations or insolvency.Producers fulfilling EPR individually, and producer responsibility organisations · BusinessesArt. 47(6) · New obligation · From 12 August 2026RequirementINF-01Make available to end users information on their role in waste prevention, the re-use arrangements available, their role in separate collection including for packaging containing hazardous products, the meaning of on-pack labels and symbols, and the impact of littering and of discarding packaging in mixed municipal waste.Producers, producer responsibility organisations, or appointed public authorities · BusinessesArt. 55 · New obligation · From 12 August 2026Requirement

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CBAM-01Producers of CBAM-covered goods see their free allocation shrink on a fixed annual CBAM-factor schedule, falling to 0% from 2038, as CBAM replaces free allocation as the carbon-leakage instrument for those goods.Operators of installations producing goods covered by the Carbon Border Adjustment Mechanism · BusinessesArt. 1(15)(b)(i), replacing Art. 10a(1a), second subparagraph of Directive 2003/87/EC · 2026-2038, applies from 30 September 2027SimplificationCBAM-02When new product categories are added to the CBAM goods list, their free allocation also starts phasing down on a set CBAM-factor schedule (97.9% then 95.8%, then the general schedule from 2028).Operators producing goods newly added to CBAM Annex I · BusinessesArt. 1(15)(b)(ii), inserting a subparagraph after Art. 10a(1a), second subparagraph of Directive 2003/87/EC · from the next five-year period following inclusion in CBAM An…SimplificationPRM-01Establish a national single access point through which project promoters submit the single application for industrial manufacturing projects, using the European Business Wallet.Member States · GovernmentsArt. 4(1) · Applies from [1 year after entry into force] per Art. 36RequirementPRM-02Establish a single permit-granting procedure based on a single application covering all permits required for industrial manufacturing projects, coordinated by a designated competent authority.Member States · GovernmentsArt. 5(1)-(2) · Applies from [1 year after entry into force] per Art. 36RequirementPRM-03Acknowledge completeness of a permit application, or request missing information, within a fixed deadline; a further deadline applies to a second request for missing information.Member States' competent authorities · GovernmentsArt. 5(3) · Applies from [1 year after entry into force] per Art. 36RequirementPRM-05Publish, via the Single Digital Gateway national single points of contact, a new information category on permit-granting procedures for industrial manufacturing projects, replacing separate entries.Member States · GovernmentsArt. 33; Annex IV (amending Annex I of Regulation (EU) 2018/1724) · From entry into forceRequirementPRM-07Remove the separate 'Critical raw materials projects' and 'Net-zero technology manufacturing projects' rows from the Single Digital Gateway Annex II catalogue, consolidating them into the unified business-permission entry.Member States · GovernmentsArt. 33; Annex IV, point 2(b) (amending Annex II of Regulation (EU) 2018/1724) · From entry into forceSimplificationAA-01Designate at least one industrial manufacturing acceleration area to cluster industrial manufacturing projects in one or more strategic sectors listed in Annex I.Member States · GovernmentsArt. 25(1) · By [12 months after entry into force]RequirementAA-02Notify the Commission of the designation of an industrial manufacturing acceleration area.Member States · GovernmentsArt. 25(6) · Ongoing from designation of each areaRequirementAA-03Conduct, and review, a comprehensive analysis of the energy needs of each acceleration area and the required energy infrastructure capacity.Member States · GovernmentsArt. 26(c) · Ongoing, milestones 2030/2040/2050RequirementAA-04aPrepare and issue an aggregated baseline permit authorising industrial activities within each designated acceleration area, covering permits required for projects located there.Member States · GovernmentsArt. 27(1)-(2) · After designation of each acceleration areaRequirementAA-04bProject promoters within an acceleration area only need to obtain additional permits that fall outside the scope of the aggregated baseline permit, cutting the permitting burden.Industrial manufacturing project promoters located in acceleration areas · BusinessesArt. 27(3) · After designation of each acceleration areaEntitlementIAAB-AA-06Automatic 'strategic project' status for every industrial manufacturing project sited in an acceleration area, granting priority and accelerated treatment under the future Environmental Assessment Regulation.Promoters of industrial manufacturing projects located within an acceleration area · BusinessesArt. 27(4) · From entry into forceEntitlementLM-06cHouseholds and companies remain eligible for public construction/renovation and motor-vehicle support schemes provided the project uses the qualifying share of low-carbon/Union-origin steel, concrete/mortar or aluminium.Households and companies applying for building renovation/construction or motor vehicle support schemes · HouseholdsArt. 12(1); Annex II, Part II · From 1 January 2029OpportunityGOV-01Carry out a periodic evaluation of the Regulation and its contribution to the internal market's functioning, covering resilience, economic security, decarbonisation and the industrialisation objective.European CommissionArt. 28 · By [2 years after entry into force] and every three years the…RequirementGOV-03Lay down effective, proportionate and dissuasive penalty rules for infringements of the Regulation and notify the Commission of those rules without delay.Member States · GovernmentsArt. 32 · From entry into forceRequirementSCP-05Prefabricated buildings containing steel or aluminium are named in CBAM scope, carrying the embedded-emissions declaration and surrender duty into construction products.Importers of prefabricated buildings containing steel or aluminium · BusinessesArt. 1(21); Annex I, point (2) adding the 'Combined metal products' table to Annex I of Regulation (EU) 2023/956 · applies from 1 January 2028 per Art. 2RequirementELEC-03Accept the standard default value for indirect emissions where the exporting country's actual electricity mix is cleaner than that default.Importers of goods with indirect emissions from lower-carbon third countries · BusinessesArt. 1(22); Annex II, point (5) replacing the second paragraph of point 4.3 of Annex IV of Regulation (EU) 2023/956 · from entry into forceSimplificationCBAMB-ELEC-09Use, as the emission factor for electricity, the weighted average CO2 intensity of all electricity produced in the geographic area, in place of a factor representing the emission intensity of the electricity consumed in producing the goods.Importers and authorised CBAM declarants of electricity and of goods carrying embedded indirect emissions · BusinessesArt. 1(22); Annex II, point (1) replacing point (e) of point 1 of Annex IV of Regulation (EU) 2023/956 · applies from 1 January 2026 per Art. 2RequirementSP-01A manufacturing project meeting any one of the resilience, supply-chain or sustainability criteria is recognised as a net-zero strategic project, which carries the priority permitting track and the public-interest status of Art. 15.Promoters of net-zero technology manufacturing projects in the Union · BusinessesArt. 13(1) · Applies from 29 June 2024EntitlementSP-02File an application for strategic-project recognition containing evidence against the criteria, a business plan evaluating financial viability, and a draft timetable showing when the project contributes to the Union benchmark.Promoters applying for net-zero strategic project status · BusinessesArt. 14(2) · Applies from 29 June 2024RequirementSP-05Projects already backed by the ETS Innovation Fund, an IPCEI, a European Hydrogen Valley or the Hydrogen Bank get strategic-project status on a written request, with no formal application.Promoters of Innovation Fund, IPCEI, Hydrogen Valley and Hydrogen Bank backed manufacturing projects · BusinessesArt. 13(5) · Applies from 29 June 2024EntitlementSP-07Strategic projects count as being in the public interest, and may be treated as of overriding public interest, in the derogations of the Water, Birds and Habitats Directives and of nature-restoration law.Promoters of net-zero strategic projects · BusinessesArt. 15(3) · Applies from 29 June 2024EntitlementCO2-02Deliver an individual share of the Union's 50 Mt/year CO2 injection capacity target by 2030, calculated pro-rata on the entity's share of Union crude oil and natural gas production over 2020-2023, as permitted capacity available to the market.Authorised oil and gas producers above the de minimis production threshold · BusinessesArt. 23(1) · Contribution to be available to the market by 2030RequirementCO2-07Report annually, publicly, on CO2 capture, storage and transport projects in progress, the injection and storage capacity they need, national support measures, capture targets, and cross-border cooperation.Member States · GovernmentsArt. 21(2) · By 30 December 2024, annually thereafterRequirementCO2-10Take the measures needed to open access to CO2 transport networks and storage sites for geological storage, as far as it is economically feasible or where a potential customer is willing to pay.Member States · GovernmentsArt. 22(2) · Applies from 29 June 2024RequirementNZIAB-PRM-07Complete permitting within 18 months where the project's yearly manufacturing capacity is not measured in GW.Member State permit-granting authorities · GovernmentsArt. 9(2) · Applies from 29 June 2024RequirementNZIAB-SP-10A CO2 storage project sited in the Union that contributes to the Art. 20 injection objective and has applied for a storage permit is recognised as strategic -- and so is any capture project and any transport infrastructure project attached to it.Promoters of CO2 storage, capture and transport projects · BusinessesArt. 13(3) · Applies from 29 June 2024EntitlementNZIAB-SP-11A project in a less developed or transition region or a Just Transition Fund territory, eligible under cohesion rules, is recognised as strategic on a written request once the award procedure has run -- with no formal application.Promoters of cohesion-funded projects in less developed and transition regions and Just Transition Fund territories · BusinessesArt. 13(4) · Applies from 29 June 2024EntitlementNZIAB-CO2-11Design every CO2 storage site to operate for at least five years, and run it on fair and open access, transparently and without discrimination.Operators of CO2 storage sites counting towards the Union injection objective · BusinessesArt. 20(2) · Applies from 29 June 2024RequirementNZIAB-CO2-12Publish the data on every area where a CO2 storage site could be permitted, saline aquifers included, to at least the detail the national energy and climate plan guidance asks for.Member States · GovernmentsArt. 21(1)(a) · By 30 December 2024RequirementNZIAB-CO2-13Where no storage projects are in progress, report instead on the plans to decarbonise industry, including cross-border transport to stores in other Member States and CO2 utilisation projects.Member States with no CO2 storage projects in progress · GovernmentsArt. 21(3) · Applies from 29 June 2024RequirementCRSK-01Identify the large companies on the territory that use strategic raw materials to make batteries, hydrogen equipment, renewable generation equipment, aircraft, traction motors, heat pumps, data and mobile equipment, additive manufacturing and robotics equipment, drones, rocket launchers, satellites or advanced chips.Member States · GovernmentsArt. 24(1) · By 24 May 2025RequirementCRSK-02Carry out, at least every three years, a supply-chain risk assessment mapping where the strategic raw materials used are extracted, processed or recycled, analysing what could affect their supply, and assessing the company's vulnerability to disruption.Large companies making batteries, hydrogen, renewable, aerospace, traction, heat pump, electronics, robotics or chip equipment with strategic raw materials · BusinessesArt. 24(2) · First assessment following identification, from 24 May 2025RequirementCRSK-03Obtain supply-chain information from suppliers in order to carry out the risk assessment.Large companies subject to the Art. 24(2) risk assessment · BusinessesArt. 24(3) · From entry into force, 23 May 2024SimplificationCRSK-04Where the risk assessment finds significant vulnerabilities, take mitigating action, including assessing whether supply chains can be diversified or the strategic raw materials substituted.Large companies subject to the Art. 24(2) risk assessment · BusinessesArt. 24(4) · From entry into force, 23 May 2024RequirementCRSK-05Present the risk-assessment report, and the information requests made to suppliers, to the board of directors.Large companies in Member States that exercise the Art. 24(6) option · BusinessesArt. 24(6) · From entry into force, 23 May 2024RequirementCJP-01Undertakings in the Commission's demand-aggregation system may jointly negotiate purchases -- prices and other terms included -- to win better conditions from suppliers or head off shortages, on a transparent basis and within competition law.Union undertakings consuming strategic raw materials · BusinessesArt. 25(5) · From entry into force, 23 May 2024EntitlementCCIR-01Adopt and run national circularity programmes: incentivise resource efficiency, promote re-use and repair, raise collection and processing of critical-raw-material-bearing waste including metal scrap, use recycled content in procurement award criteria or financial incentives, mature recycling technologies, build workforce skills, modulate extended producer responsibility fees, police waste exports, and support Union recycling quality standards.Member States · GovernmentsArt. 26(1) · Within two years of entry into force of the implementing act …RequirementCCIR-02Identify and report separately the quantities of critical-raw-material-bearing components removed from waste electrical and electronic equipment, and the quantities of critical raw materials recovered from it.Member States · GovernmentsArt. 26(5) · First reporting period is the first full calendar year after …RequirementCEXW-03Build a public database of closed and abandoned extractive waste facilities carrying location, extent and waste volume, the operator or successor, and the quantities and concentrations of raw materials held -- backed by permit-file review, geochemical sampling and detailed characterisation.Member States · GovernmentsArt. 27(4), with Art. 27(6)-(7) · Database in place by 24 November 2025, populated by 24 May 2027RequirementCRMAB-RSK-06A large company may take the risk assessment to its own board, with the sources, the risks found and the mitigation planned -- and does not have to unless its Member State requires it.Large companies identified under Art. 24(1) · BusinessesArt. 24(5) · From entry into force, 23 May 2024EntitlementCRMAB-CIR-03National circularity programmes may pay for circularity directly -- discounts, monetary rewards or deposit-refund systems for re-use, and for the collection and treatment of waste from products with recovery potential.Holders and collectors of products and waste with critical raw materials recovery potential · BusinessesArt. 26(3) · From entry into force, 23 May 2024OpportunityCRMAB-EXW-04Put quantities and concentrations, an assessment of technical and economic recoverability, and the estimation methods used into the study.Operators of extractive waste facilities · BusinessesArt. 27(2) · From entry into force, 23 May 2024RequirementFREE-02Do not prohibit, restrict or impede the placing on the market of packaging that complies with Arts. 5 to 12, and do not enforce additional national requirements against compliant packaging.Member States · GovernmentsArt. 4(2) and (3) · New obligation · From 12 August 2026RequirementSUB-01Manufacture packaging so that the presence and concentration of substances of concern is minimised, including in emissions and in waste-management outputs such as secondary raw materials and ashes.Manufacturers of packaging · BusinessesArt. 5(1) · New obligation · From 12 August 2026RequirementLAB-05Ensure harmonised labels enabling separate collection of each material fraction are affixed visibly, legibly and indelibly on all packaging-waste receptacles.Member States · GovernmentsArt. 13(1) · New obligation · From 12 August 2028 or 30 months after the Art. 13RequirementOPS-05Before making packaging available, verify that the producer is registered in the Art. 44 register, that the packaging carries its Art. 12 labelling, and that the manufacturer and importer have marked their identification; do not make it available until any non-compliance is corrected.Distributors of packaging · BusinessesArt. 19(1) to (3) · New obligation · From 12 August 2026RequirementOPS-06Ensure warehousing, handling, packing, addressing and dispatch conditions do not jeopardise the packaging's compliance with Arts. 5 to 12.Fulfilment service providers · BusinessesArt. 20 · New obligation · From 12 August 2026RequirementOPS-08Report the Annex XII Table 3 packaging-waste information to the competent authority annually through the Art. 35(1) electronic registry, and give producers or their producer responsibility organisation everything they need for their own Art. 44(10) reporting.Packaging waste management operators · BusinessesArt. 23 · New obligation · From 12 August 2026RequirementRTG-05Make at least 10% of alcoholic and non-alcoholic beverages available in reusable packaging within a re-use system, rising to an endeavour of 40% from 2040, and ensure own-brand packaged products contribute fairly and proportionately.Final distributors of beverages · BusinessesArt. 29(6) · New obligation · From 1 January 2030RequirementAUT-01Designate competent authorities for this Chapter and for Arts. 6(10), 29(1)-(7) and (9) and 30 to 34, lay down their organisation and the administrative and procedural rules for registration, reporting oversight, EPR supervision, EPR authorisation and information, and notify the Commission by 12 July 2025.Member States · GovernmentsArt. 40 · New obligation · Notification by 12 July 2025RequirementAUT-02Add a dedicated packaging chapter to the Directive 2008/98/EC waste management plan covering Arts. 48, 50 and 52 measures, and a dedicated packaging chapter to the waste prevention programme covering Arts. 43 and 51 measures and litter.Member States · GovernmentsArt. 42 · New obligation · From 12 August 2026RequirementPRV-01Reduce packaging waste generated per capita against a 2018 baseline by at least 5% by 2030, 10% by 2035 and 15% by 2040, and endeavour to reduce plastic packaging waste specifically.Member States · GovernmentsArt. 43(1) and (4) · New obligation · 2030, 2035 and 2040RequirementEPR-02Before allowing a producer to use the platform, obtain its Art. 44 registration details and registration number for the consumer's Member State and a self-certification of EPR compliance, and make best efforts to assess whether that information is complete and reliable.Providers of online platforms allowing distance contracts with producers · BusinessesArt. 45(4) and (6) · New obligation · From 12 August 2026RequirementEPR-03Check the producer's registration and EPR self-certification against an official database or the public register, require correction where the information looks inaccurate, incomplete or out of date, and suspend the service until it is corrected, giving reasons.Fulfilment service providers · BusinessesArt. 45(8) · New obligation · From 12 August 2026RequirementCOL-01Set up return and separate collection covering the whole territory and all packaging waste, open to operators, authorities and third parties and to imported products on non-discriminatory terms; collect design-for-recycling-compliant packaging for recycling and prohibit its incineration and landfill.Member States · GovernmentsArts. 48(1) and (5) · Extension · From 12 August 2026RequirementCOL-02Set mandatory national collection objectives for the Art. 52 materials, consistent with the recycling targets and with the Art. 7 recycled-content requirements.Member States · GovernmentsArt. 49 · New obligation · By 1 January 2029RequirementDRS-01Separately collect at least 90% by weight per year of single-use plastic beverage bottles and single-use metal beverage containers up to three litres.Member States · GovernmentsArt. 50(1) · New obligation · By 1 January 2029RequirementDRS-02Set up deposit and return systems for single-use plastic beverage bottles and metal beverage containers, with a deposit charged at the point of sale, meeting the Annex X minimum requirements.Member States · GovernmentsArt. 50(2) and (11) · New obligation · By 1 January 2029RequirementRCT-01Achieve recycling of at least 65% of all packaging waste by weight by 31 December 2025 and 70% by 31 December 2030, with material lines of 50/55% plastic, 25/30% wood, 70/80% ferrous metals, 50/60% aluminium, 70/75% glass and 75/85% paper and cardboard.Member States · GovernmentsArt. 52(1) · carry over · 31 December 2025 and 31 December 2030NeutralRCT-02Calculate packaging waste generated and packaging waste recycled each calendar year on the Art. 53 rules, exhaustively, adjusted for comparability, reliability and completeness under the Art. 56(7) implementing act.Member States · GovernmentsArt. 53 · New obligation · From 12 August 2026RequirementINF-02Report to the Commission each calendar year on recycling target implementation and reusable packaging, per-capita consumption of each carrier-bag category, the DRS separate collection rate, and the quantities of packaging made available, collected and recycled by category.Member States · GovernmentsArt. 56(1) and (2) · Extension · From 12 August 2026RequirementINF-03Establish harmonised packaging and packaging waste databases carrying the Annex XII data and information on flows, made publicly accessible in a machine-readable, interoperable and re-usable format.Member States · GovernmentsArt. 57 · New obligation · 12 months after the Art. 56RequirementMSV-01Lay down effective, proportionate and dissuasive penalties for infringements, including administrative fines for breaches of Arts. 24 to 29, and notify the Commission of the rules and of any later amendment.Member States · GovernmentsArt. 68 · New obligation · By 12 February 2027RequirementMSV-02Where there is sufficient reason to believe packaging presents a risk to the environment or human health, evaluate it against all relevant requirements, require the operator to take corrective action, and where the operator does not act, prohibit or restrict the packaging or withdraw or recall it.Member State market surveillance authorities · GovernmentsArts. 58 to 60 · New obligation · From 12 August 2026RequirementMSV-03Communicate national non-compliance measures without delay to the Art. 25(1) authorities under Regulation (EU) 2019/1020 so they feed the border risk analysis, and act on formal non-compliance under Art. 62.Member State market surveillance and designated border authorities · GovernmentsArts. 61 and 62 · New obligation · From 12 August 2026RequirementGPP-01Apply the Commission's minimum mandatory green public procurement requirements when awarding contracts where packaging or packaged products represent more than 30% of the estimated contract value or of the value of products used by the contracted services.Contracting authorities and contracting entities under Directives 2014/24/EU and 2014/25/EU · GovernmentsArt. 63 · New obligation · Implementing acts by 12 February 2030, applying to procedures…RequirementDD-01Set up and implement a battery due diligence policy covering the raw materials in the battery and the social and environmental risks in their supply chain.Economic operators placing batteries on the market · BusinessesArt. 48(1) · From 18 August 2027, as amendedRequirement

Where the pressure comes from

Pressure arrives from 5 acts directly, 2 more without ever naming it

Pressure arrives at European aluminium and metals from 5 acts that name it directly, and from 2 more that never do: EU ETS revision, Batteries Regulation.

Industrial Accelerator Act — names the sector in 10 measures, reaches it in 14 more via another act

CBAM extension — names the sector in 40 measures, reaches it in 3 more via another act

Net-Zero Industry Act — names the sector in 1 measure, reaches it in 13 more via another act and supply chain

Critical Raw Materials Act — names the sector in 64 measures, reaches it in 12 more via another act and procurement and supply chain

Packaging and Packaging Waste Regulation — names the sector in 35 measures, reaches it in 24 more via another act and procurement

EU ETS revision — never names the sector; reaches it in 2 measures via another act

Batteries Regulation — never names the sector; reaches it in 1 measure via supply chain

Net position

What the corpus does to this sector, in total

219measures reach this sector · 166 press, 51 relieve or grant
Requirement
163
Simplification
18
Opportunity
5
Entitlement
28
Entitlement withdrawn
1
Neutral
2
In force Proposed or mixed basis

Supply chain and country exposure

What aluminium and metals buys, sells and imports

FIGARO groups steel & alu under one code (C24); these share a profile in this data source.

Inputs come from

What this sector buys

  • mining9.5%
  • wholesale trade7.2%
  • electricity & gas6.6%
  • waste & sewerage5.8%
  • fabricated metal products4.4%
  • land transport4.3%
  • chemicals2.1%
  • retail trade1.7%
  • everything else58.4%

Goods go to

Who buys from this sector

  • fabricated metal products17.8%
  • vehicles9.5%
  • construction9.2%
  • machinery8.9%
  • electrical equipment5.9%
  • furniture & other manufacturing2.5%
  • electronics1.7%
  • machinery repair1.6%
  • everything else43%

Import exposure

21.5% of inputs come from outside the EU

  • rest of world33.9%
  • United States9.9%
  • Norway9.8%
  • United Kingdom7.4%
  • China5.8%
  • Türkiye5.2%
  • Russia4%
  • India3.7%
  • everything else20.3%

basic metals (steel & aluminium) (C24). percent of sector's total inputs (suppliers) / total output (customers); OTHER row carries the remainder to 100. Source: Eurostat input-output data, 2026 edition, 2024 reference year (EU inter-country tables, industry by industry).

Related sectors

Most often caught by the same measure