EU consultation
11 submissions from 10 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 14 submissions on this file. Shown here: the 11 from organizations. Not shown: 3 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. About this data →
8 submissions from industry (companies and their trade associations) against 2 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 4 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice.
The file, right now
No consultation closing date is recorded for this file.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
Showing 11 of 11 submissions.
· · filed 19 Aug 2025 · source
Further to the ongoing consultation on the draft implementing act of the European Commission setting out the template for the application to be submitted in the context of the recognition of Strategic Projects under the Critical Raw Materials Act (CRMA), the Polish Chamber of Chemical Industry does not provide detailed comments on this document.
Filed in Polish · English published by the European Commission
It is a positive step that the Commission is developing an application template for strategic projects. However, the template reflects a certain level of requirements, and not all requested information can be considered relevant.
The document presents a strategic proposal for integrating the European Trade Indexes Registry (EUTIR) with the EUs framework for recognizing critical raw material projects under Regulation (EU) 2024/1252. It advocates for EUTIR as a decentralized, interoperable digital infrastructure that enhances trust, authenticity, and traceability in cross-border trade.
· · filed 18 Aug 2025 · source
The design of the application template for granting strategic project status is crucial to ensuring transparency, rule of law, and meaningful public democratic participation. As PowerShift, we are concerned that the current draft falls significantly short of these principles. 1.
· · filed 14 Aug 2025 · source
On behalf of Christ&Company and our customers in the recycling industry, we warmly welcome the initiative, the advance publication of the template, and its clear structure. In our view, the following points are important: When evaluating projects, the focus must be on innovation and scalability. In addition, recycling projects, which are often initiated and driven by SMEs, should be given high priority.
· · filed 14 Aug 2025 · source
PRIMIGEA, the confederation representing the interests of the Spanish mineral raw materials sector, submits its observations on the Commission Implementing Regulation establishing a single application template for the recognition of Strategic Projects under Regulation (EU) 2024/1252.
The document provides structured feedback from the DigitalTrade4.EU consortium on the draft Implementing Regulation for strategic project applications under the EUs Critical Raw Materials Act (Regulation (EU) 2024/1252).
· · filed 6 Aug 2025 · source
Critical Raw Materials Act Commission Implementing Act establishing a strategic project application template, August 6th 2025: Iren Group remarks the draft application form reflects an unclear aspect of the applicable critical raw materials regulation (mainly art. 7 of Regulation EU n.
ECOS welcomes the development of a single template for Strategic Project applications under the Critical Raw Materials Act (CRMA) but is concerned that the current draft does not ensure robust environmental and social safeguards. The Strategic Project designation grants projects access to fast-tracking and this must require strong safeguards to maintain public trust and EU credibility.
On behalf of Mecaware, a company developing scalable recycling technologies for critical raw materials, we welcome the Commissions initiative to strengthen Europes strategic autonomy. Based on our experience, we would like to offer constructive input to help ensure the Strategic Project application process is accessible, innovation-driven, and aligned with the CRMA's long-term goals : 1.
Include an item on feedstock quantity and availability, selection, and quality are crucial factors that can significantly impact the reliability and effectiveness of the processes. Unsuitable feedstock materials can pose serious challenges to the feasibility of a companies overall business case. Two topics, availability of suitable materials for the technology and the contracted intake of materials.
Get an email when a new organization files a position here: one email on Tuesdays, only when there is something new. Free with a PolicySpeak website account.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.