Europe's dependence on imports of key mineral resources has long been a subject of debate, as reflected in the EU's Critical Raw Materials Act (CRMA) ( https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=OJ:L_202401252), which identifies a list of 34 critical raw materials, including a subset of 17 strategic raw materials. This list excludes energy raw materials, dominated by metals needed to meet the needs of key modern industrial sectors. To quote the CRMA regulation: "raw materials are considered critical due to their high economic importance and exposure to high supply risks, often caused by the high concentration of supplies from a few third countries (...) demand for them is likely to grow rapidly in the coming decades."

While the diagnosis of heavy dependence on non-EU countries, which are the world's main producers of raw materials, is certainly accurate, the EU's responses and action plans seem long overdue. Currently, China completely dominates the raw materials market, as it is the leading producer of as many as 25 of the 34 critical raw materials , and for some raw materials, it produces over 80% of global production (REE – rare earth elements, germanium, gallium, magnesium, and tungsten). Currently, Europe is only able to meet its current demand for six raw materials: strontium (Spain), arsenic (Belgium), hafnium (France), nickel (Finland), and, importantly, two very important raw materials for the arms industry: copper and coking coal from Polish deposits ( https://set.org.pl/wp-content/plugins/download-attachments/includes/download.php?id=1271) . Other large countries with mining traditions are also entering the race with China, primarily the USA, Canada, Australia and Russia, which is exacerbating the competition for access to deposits around the world.

The CRMA identifies strategic raw materials as "those used in technologies that underpin ecological and digital transformation, or in defense, aerospace, or space applications, and characterized by a potentially significant shortfall in global supply relative to projected demand." The North Atlantic Alliance, specifically its Industrial Advisory Group (NIAG), also developed a list of 12 raw materials critical to NATO's defense and published it last December. This was a continuation of initiatives from the published Defense-Critical Supply Chain Security Roadmap. The initiatives included therein include, among other things, collaboration with allies and industry to determine further actions regarding strategic stockpiling, recycling, and substitutes for strategic defense raw materials. The modern battlefield and evolving military technology depend largely on access to a narrow group of strategic raw materials. These materials are essential for the production of advanced military equipment—from submarines and F-35 fighter jets, through radar systems, to precision-guided munitions. Critical raw materials are irreplaceable due to their unique physical and chemical properties. The NATO list includes: aluminum, beryllium, cobalt, gallium, germanium, graphite, lithium, manganese, platinum, rare earth elements (REE), titanium, and tungsten. The EU's list of strategic is broader and, in addition to beryllium, includes all other raw materials on the NATO list, as well as bismuth, boron, copper, magnesium, nickel, and silicon metal.

A major problem for NATO is that most of these raw materials are extracted or processed outside of Alliance territory, often in countries like China, Russia, or African countries. Dependence on external suppliers creates the risk of supply chain disruptions in the event of geopolitical conflicts , which are unfolding before our very eyes – take, for example, the Chinese government's recently introduced regulations on the export of REE and products containing even negligible amounts of Chinese-made REE. In the context of the growing role of raw materials, it's impossible not to mention Ukraine as a country quite rich in critical and energy resources. Ukraine possesses significant reserves of coal, iron, manganese, graphite, titanium, and likely lithium and REE. This was most likely a significant factor in the Russian attack, and, as recent actions by the US administration have demonstrated, a key factor in American support. According to NATO, the most critical raw materials are graphite (electrodes, in the production of specialized steel, composite materials, lubricants) and aluminum (light structural alloys for aircraft, armored vehicles, missiles), which are crucial for the production of almost every type of weapon ( https://www.nato.int/nato_static_fl2014/assets/pdf/2024/7/pdf/240712-Factsheet-Defence-Supply-Chain-Ro.pdf) . Why were these two raw materials considered to pose the greatest supply risk ? The three largest producers of aluminum in 2024 are China, India, and Russia, while for graphite, China will be the largest producer, followed by Madagascar and Mozambique. It's easy to draw conclusions regarding concerns about the stability of supplies...

What role could Poland play in addressing these alliance challenges? Besides the already mentioned crucial raw materials, namely coking coal (a critical EU raw material), of which Poland has vast reserves of 18.02874 billion tons whose balance reserves are estimated at 56.721 million tons of metallic copper, Poland possesses other raw materials (https://www.pgi.gov.pl/images/surowce/2024/zasoby_i_wydobycie_kopalin_2024.pdf ). From the NATO list of raw materials we have documented deposits that meet the current mining profitability (balance) criteria:

• cobalt in the amount of 181.27 thousand tons (elements co-occurring in Cu-Ag ores)
• gallium in the amount of 0.13 thousand tons (elements co-occurring in zinc and lead ores)
• germanium in the amount of 0.03 thousand tons (elements co-occurring in zinc and lead ores)
• REE in the amount of 30.11 thousand tonnes (elements co-occurring in Cu-Ag ores)
• tungsten in the amount of 238 thousand tons (molybdenum-tungsten-copper ore)

It's worth mentioning that the Myszków molybdenum-tungsten-copper ore deposit, in addition to the tungsten mentioned above, also contains 295,000 tons of molybdenum (a metal also used in the arms industry) and over 800,000 tons of copper. The Myszków deposit has not been mined yet, but given the current geopolitical situation and its abundant resources, I would argue that it's only a matter of time. We also have documented deposits whose resources do not meet current mining profitability criteria and are classified as off-balance. Here, it's particularly worth noting the publicly debated deposits in the Suwałki region: Krzemianka and Udryń , where titanium resources have been estimated at a substantial 97.7 million tons, along with 4.1 million tons of vanadium and 388.2 million tons of iron. Although the abundance of these deposits has raised high hopes for years, the considerable depth (850-2,300 m), potential environmental conflicts, and the presence of more accessible deposits in other regions of the world have prevented any action to begin mining. In the current reality, if resource conflicts continue to escalate and demand for titanium proves crucial for our NATO allies, perhaps conditions will change enough to make an attempt to open these deposits for mining a realistic option.

Implementing CRMA into the legislation of individual member states will introduce regulations that, among other things, will accelerate and simplify administrative and environmental procedures for projects that receive strategic status in the raw materials sector. This represents an opportunity to increase the utilization of domestic deposits and leverage Poland's geological and mining potential. Furthermore, if the EU, in response to NATO's general needs, were to decide to extend environmental incentives to the defense industry and abandon the ETS, we could face a unique opportunity to utilize Polish resources. The use of domestic thermal and coking coal in the steel industry and lower energy prices for the defense industry could attract the Allied defense industry and maximize the country's value chain.