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Requirement · CFP-01

Publish 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 must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 31(6)-(7), in the Critical Raw Materials Act. as of 2026-08-18
  • The act gives its timing as: From adoption of the calculation and verification rules for the material concerned. as of 2026-08-18
  • It names 3 industries by name: Waste, Aluminium and Steel. as of 2026-08-18
  • Compliance is checked by accredited third party, per material type. as of 2026-08-18
Addressee Anyone placing critical raw materials, including processed and recycled, on the Union marketAct Regulation (EU) 2024/1252, consolidated 03.05.2024Article Art. 31(6)-(7)Class Businesses

The rule

New — no predecessor
Trigger

the Commission having adopted calculation and verification rules for that critical raw material

Obligation

Publish 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.

Who is affected

Addressee
Anyone placing critical raw materials, including processed and recycled, on the Union market
Class
Businesses
Sectors
Names Waste and landfill, Aluminium and metals, Steel · Reaches Batteries and solar, Wind, heat pumps, hydrogen, Automotive, Aviation
Applies
From adoption of the calculation and verification rules for the material concerned

Burden drivers

D1 · D2 · D4 — 3 of 7 marks fire on this provision.

Source text

Verbatim

Any natural or legal person that places on the market critical raw materials, including processed and recycled, for which the Commission has adopted calculation and verification rules pursuant to paragraph 1 shall make available an environmental footprint declaration.

View source →

Settled later in secondary legislation. Conditional on a two-step Commission process: a report by 24 November 2025 prioritising materials, then a necessity and proportionality assessment, then calculation and verification rules by delegated act. No material carries this duty until that runs. It does not reach critical raw materials inside intermediate or final products.