RESourceEU Action Plan: funding opportunities and obligations for industry and investors

With the RESourceEU Action Plan, the European Commission is providing a key industrial policy impetus to secure critical raw materials in Europe. The plan combines billions in funding opportu-nities with new regulatory requirements for companies along the entire value chain. This will par-ticularly affect industry, the recycling sector and the renewable energy sector. The following arti-cle classifies the objectives, funding targets, and regulatory implications of RESourceEU and shows how companies can already prepare themselves.

With the so-called RESourceEU Action Plan, the European Commission (EU Commission) presented a key component of its raw materials and industrial policy on 3 December 2025. The aim is to secure the EU's long-term supply of critical raw materials such as rare earths, lithium, cobalt and other strategic metals. At the same time, the circular economy and recycling capacities in Europe are to be significantly expanded.

According to the EU Commission, by 2030 the EU should be mining at least 10% of its annual consumption of critical raw materials within the EU, processing 40% in the EU, and recycling 25% in order to limit dependencies on individual third countries to a maximum of 65%.

The Action Plan is explicitly aimed at companies along the entire value chain. This includes the extraction and processing of raw materials as well as their industrial use, recycling and disposal. RESourceEU opens up new funding and financing opportunities, but at the same time includes additional regulatory requirements. The Action Plan aims to operatively implement the European Critical Raw Materials Act (CRMA), bundle existing financing instruments and strategically accelerate the implementation of relevant projects. From 2026, a total of around three billion euros in funding is to be made available, primarily from existing EU instruments such as InvestEU, the Innovation Fund and Global Gateway.

The projects being funded

Funding and support will be provided in particular for strategically relevant projects along the raw materials and recycling value chain.

Strategic raw materials projects

The Action Plan focuses on projects for extracting, processing and refining critical raw materials within the EU, as well as for establishing and expanding processing and refining capacities. It also covers projects for diversifying supply chains, including projects in third countries implemented within the framework of EU partnerships.

Recycling and the circular economy

A particular focus of the Action Plan is recycling and the circular economy, with a view to establishing and scaling recycling facilities, particularly for rare earths, permanent magnets and battery raw materials. In addition, measures are being taken to improve the recovery of secondary raw materials from production and end-of-life waste, and to promote innovative technologies for material separation, processing and reuse.

From 2026, exports of rare earth scrap and lithium-ion batteries are to be restricted in order to ensure availability for European recyclers.

Research, innovation and substitution

RESourceEU also addresses the areas of research, innovation and substitution. Support is being provided for developing alternative materials and for researching and developing new recycling and processing technologies.

Through the EU research and innovation programme Horizon Europe, around €593 million is being made available for projects in the areas of circular economy, process innovation and substitution in the period 2026–2027. A further €100 million is earmarked for the EIC Accelerator, which specifically promotes innovative and scalable technology projects.

The companies eligible for funding

The RESourceEU Action Plan is particularly aimed at industrial companies with high raw material requirements, as well as recycling, disposal and processing companies. It is also aimed at project developers in the raw materials and infrastructure sectors, as well as technology and innovation companies.

RESourceEU is particularly interesting for companies in the renewable energy sector, as the expansion of wind, solar and storage technologies highly depends on the availability of critical raw materials, especially rare earths, battery raw materials and special metals. This affects, among others, wind turbines due to the use of permanent magnets (e.g., neodymium, dysprosium) in generators, battery storage systems, grid infrastructure, and power electronics such as transformers, inverters and power semiconductors.

RESourceEU explicitly aims to reduce these dependencies by expanding European processing and recycling capacities. Projects for recovering raw materials from existing plants, recycling old components (e.g., from repowering projects), or for locally processing raw materials can therefore be classified as being of particular strategic relevance.

A prerequisite for funding is that the project in question makes a demonstrable contribution to the EU's security of supply and is compatible with the EU's sustainability and ESG goals.

RESourceEU is also aimed at companies that depend on crisis-relevant raw materials and requires a proactive risk strategy for their supply chains in order to minimise disruptions and liability risks.

The regulatory requirements affecting companies

Besides the funding opportunities, RESourceEU also entails regulatory adjustments. It can be assumed that the criteria for defining eligible strategic projects will be specified in further detail. In practice, this means that there will be increasing requirements for supply chain and sustainability concepts, as well as for demonstrating the social and environmental impact of projects in the context of funding applications.

Companies in the renewable energy sector in particular can also expect sector-specific regulatory implications. These include stricter product labelling and information requirements for components such as generators, batteries and inverters. Stricter requirements for the recyclability and dismantlability of plants are also to be expected, particularly in the context of repowering and decommissioning projects, with target quotas for recyclable assemblies. In addition, there may be restrictions on the export of old plants, components or waste fractions to third countries.

Companies should also be prepared for possible priority-rated requests under the Internal Market Emergency and Resilience Act (IMERA). This instrument allows the EU to request companies to give priority to certain customers in the event of a crisis and may result in short-term interventions in existing supply chains and contractual relationships. These developments may have a significant impact on existing supply, maintenance and disposal contracts in the future and should be legally reviewed in good time.

RESourceEU: What entrepreneurs should do now

Companies should familiarise themselves with the RESourceEU funding and regulatory mechanisms in good time and prepare their projects accordingly. Forward-looking project structuring is crucial if funding opportunities are to be taken advantage of and regulatory risks minimised.

We provide comprehensive legal advice to companies on raw material, processing and recycling projects. This includes, in particular, identifying and structuring eligible projects, assisting with funding and subsidy procedures, implementing new product, recycling and compliance requirements, and providing legal support for repowering, dismantling, recycling and recovery projects.

Please feel free to contact us. We will work together with you to establish whether and in what form your project falls under the RESourceEU Action Plan, how old components can be recycled or reused in a legally compliant manner, and will analyse your supply and disposal contracts with regard to possible export restrictions.

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