On June 4, 2025, the European Commission published its first list of Strategic Projects in non-EU countries under the Critical Raw Materials Act (CRMA). The list is intended to support projects that contribute to a more secure and diversified supply of key raw materials. Graphite features prominently, with four projects in Ukraine, Greenland, Kazakhstan, and Madagascar receiving recognition.
The CRMA, adopted earlier in 2024, sets out a framework to strengthen the EU’s access to critical raw materials needed for technologies such as electric vehicles, wind turbines, and batteries. While previous policy efforts focused mainly on domestic supply, this new list extends support to projects located outside the EU, so-called “third countries”, that are considered important for future supply security and aligned with European environmental and governance standards.
The four graphite projects selected are:
- Balakhivka Graphite Deposit in Ukraine, promoted by Pobuzhzhya’s Development LLC, which holds one of the larger known natural graphite deposits in Eastern Europe. The EU has identified this as a potential alternative source to reduce reliance on supply from China and Russia.
- Norgraph a/s and Greenland Graphite a/s, promoted by UK-based GreenRoc Strategic Materials Plc, represent an integrated project spanning Norway and Greenland. These projects offer high-grade flake graphite in regions with close political and regulatory ties to the EU, which could ease integration into European battery and materials value chains.
- Sarytogan Graphite Project in Kazakhstan, operated by Australia’s Sarytogan Graphite Ltd, which claims one of the world’s largest known graphite resources. The deposit is described as containing ultra-high purity graphite suitable for battery-grade applications.
- Maniry Graphite Project in Madagascar, promoted by Evion Group NL. Located in a long-established mining jurisdiction, the project is seen as a potentially important supplier of flake graphite to the European market, especially given growing concerns over concentration of processing capacity in Asia.
Being designated as a Strategic Project under the CRMA does not automatically guarantee funding or commercial success. However, it does offer certain benefits, primarily increased visibility at the EU level and access to support instruments. While fast-track permitting measures only apply within the EU, projects outside the EU may be included in strategic dialogues, receive support in identifying EU offtakers, and become eligible for financing tools such as InvestEU, the Innovation Fund, and the Strategic Technologies for Europe Platform (STEP).
In practical terms, the designation may help project developers secure funding or advance agreements with European buyers, particularly in sectors like batteries where long-term supply agreements are increasingly important. It could also encourage greater cooperation between EU institutions and third-country governments on issues such as infrastructure, ESG standards, and regulatory alignment.
Still, the Strategic label is just one piece of a broader effort to build more resilient supply chains. Whether these graphite projects can meaningfully reduce Europe’s dependence on primarily Chinese supply, which continues to dominate global production and processing, remains uncertain. Much will depend on how quickly the projects can secure financing, navigate permitting, and build the infrastructure needed to deliver consistent, high-quality output. As the EU moves to implement its critical raw materials strategy, the progress of these newly designated projects will be an important signal of what’s possible, and what challenges remain.
The full list of strategic projects in non-EU countries is available in the European Commission’s official decision here.
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