Making the Green Premium Work: Policy pathways for critical raw materials

Meeting the EU’s climate and industrial goals requires scaling critical raw material supply while upholding strong ESG standards. 

This report proposes a phased, two-tier strategy. The first tier would harmonize existing frameworks and set minimum market-access requirements – due diligence, traceability and environmental-footprint disclosure – with the option to add performance thresholds such as maximum carbon intensity, including via a targeted CBAM expansion. 

The second tier introduces conditional incentives for frontrunners, using tools like public procurement and price or volume guarantees to reward verified high ESG performance and de-risk investment.