Europe has built four sophisticated policy instruments for its industrial future in the past five years. The Critical Raw Materials Act secures supply of geopolitically scarce minerals and fast-tracks permitting for those designated as strategic. The Net Zero Industry Act builds domestic clean-technology manufacturing capacity. The Clean Industrial Deal addresses decarbonisation in energy-intensive sectors. The Circular Economy Action Plan manages material recovery and recycling. Read them together and a shape emerges: every instrument operates at the top of the mineral stack. The foundational layer (limestone, silica sand, dolomite, kaolin, magnesite, gypsum) the materials that underpin steel, cement, glass, refractories, and carbon capture regardless of whether the end use is green, digital, or defensive, has no equivalent framework.

The scale of what this misses is almost counterintuitive. Industrial minerals extracted in Europe by IMA-Europe member companies alone amount to roughly 180 million tonnes per year, generating €14 billion in value added and representing 82% of all EU mining enterprises. EU aggregates production adds another 3 billion tonnes annually across 26,000 sites and 200,000 workers. The EU’s entire rare earth import dependency (the supply problem the CRM Act was built to solve) amounts to 18,300 tonnes valued at €123.6 million annually. The EU produces zero rare earths domestically. Strategic policy concentrates its attention on the smaller problem by a factor of more than two orders of magnitude.

This is not a bureaucratic gap waiting to be filled. It is the logical endpoint of a methodology; and behind the methodology, an ideology.

Designed not to see

The EU has assessed foundational minerals in every criticality review since 2011. Limestone, silica sand, kaolin, bentonite, magnesite, gypsum, and feldspar appear in the candidate pool in every cycle. Aggregates were added in 2017. All were assessed using the same methodology applied to cobalt and lithium. None crossed the criticality thresholds. The Commission did not fail to look. The problem is what the tool it used to look with is capable of seeing.

The Supply Risk score is built from three interlocking variables: the concentration of global production (an HHI score weighted by governance ratings), actual EU import reliance, and end-of-life recycling rates. When a mineral’s import reliance is near zero (because the EU produces it domestically) the formula assigns virtually no weight to global supply concentration, regardless of how dangerous that concentration may be. Aggregates carry an import reliance of 0.5%. Even if global production of a foundational mineral were controlled by a single hostile state, the methodology would return a near-zero Supply Risk score. The 2020 CRM study stated this plainly Blengini_{2020, pp.15}: for materials where “Member States produce enough primary materials to avoid significant extra-European imports,” current self-sufficiency is treated as a permanent condition. The formula has no mechanism to register permitting bottlenecks, demand surges from re-industrialisation, or the difference between commodity-grade supply and the specialty grades the green transition actually requires.

The magnesite case shows what this looks like in practice. Magnesite was assessed as critical in 2014 European Commission₂₀₁₄. It was de-listed in 2017 European Commission₂₀₁₇ when a revised methodology reduced its supply risk score because EU import reliance was low. Magnesite derivatives (dead-burned and fused magnesia) line every electric arc furnace used in green steel production, every cement kiln, every glass furnace. There is no substitute for magnesia in refractory applications, and no substitute for the refractories themselves Fung_{2025, pp.1,47}. China controls approximately 60% of global magnesite production. Western European magnesia oxide capacity has declined by more than 200,000 tonnes per annum over the past four years. The EU is on track for 35.7 million tonnes per annum of new electric arc furnace capacity by 2030; all of which will consume more magnesia-carbon refractories than the blast furnaces they replace Fung_{2025, p.38}. RHI Magnesita, the world’s leading refractory producer, has been lobbying for re-inclusion on the CRM list since December 2024 Guntschnig₂₀₂₄, its EU lobbying spend rising from the €50,000 range to the €200,000–300,000 band. The argument is straightforward: green steel decarbonisation cannot proceed without secure magnesia supply. This is not a gap waiting to be identified. It is a gap that has been created, documented, and is now visibly producing friction; and the methodology that created it remains in place.

The magnesite case is the clearest evidence of the problem’s structure, but not the only one. High-purity quartz (the feedstock for semiconductor-grade silicon, solar PV glass, and specialist refractories) illustrates a different failure mode: quality blindness. The EU is self-sufficient in general silica sand, consuming about 51 megatonnes per year. The criticality methodology aggregates ultra-high-purity quartz under this heading, producing near-zero import reliance at the category level. In reality, global supply of the highest-purity feedstock (HPQ, >99.99% SiO₂) is overwhelmingly concentrated at a single site: Spruce Pine, North Carolina, where Sibelco controls 70–90% of global supply at the highest purity tiers Mohanty_{2025, pp.8}. In September 2024, Hurricane Helene disrupted Spruce Pine shipments and forced chipmakers to seek emergency alternative sourcing. Sibelco has since announced a $700 million capacity expansion; a market signal, not a policy response. The EU Chips Act and solar manufacturing ambitions are simultaneously accelerating European demand for HPQ at the moment supply is most concentrated and most fragile. The methodology cannot see any of this, because it cannot distinguish between commodity beach sand and aerospace-grade quartz feedstock. The narrowing that converted the 2008 Raw Materials Initiative’s broad coverage into the CRM Act’s geopolitical-scarcity focus was deliberate and methodologically coherent. It has also progressively reduced the policy architecture’s ability to see problems it was not designed to identify.

Assumption of abundance

Neither the methodology nor its limits arose from nowhere. They are the institutional expression of a deliberate choice made across Western Europe over three decades.

Guillaume Pitron names it directly Pitron_{2020, pp.101}: “We believed that by abandoning our heavy industries, we could focus our efforts on high-value-adding manufacturing sectors while maintaining healthy profit margins.” The service-economy pivot did not merely offshore production. It atrophied the institutional capacity to think about industrial inputs as strategic at all. The management practice that operationalised this ideology (just-in-time production and zero-stock outsourcing, institutionalised from the 1960s onward) stripped companies of visibility beyond one tier in either direction of their supply chains. When Thales stated in its 2015 annual report that “given the nature of its business, Thales uses few raw materials” and that its “exposure to raw materials risk is therefore negligible” Pitron_{2020, pp.72}, this was not corporate negligence. It was the accurate output of a management system built to see only what moved through immediate commercial relationships.

The peace dividend made it permanent. In the 1990s, states that had built strategic mineral reserves across the Cold War systematically liquidated them. France sold platinum and palladium stockpiles from Banque de France safes under both left- and right-wing governments Pitron_{2020, pp.72-77}. The US liquidated billions in lithium and beryllium reserves. France’s 1978 Metals Plan (a government-backed mineral exploration programme whose BRGM employees called it a “golden age”) ended in the 1990s and was not replaced. By 2000, exploration had wound down entirely. “We lost an entire industry,” one former participant recalled. “Not to mention our mineral sovereignty.” The three French white papers on defence and national security produced in 1971, 1994, and 2008 made no reference to rare metals supply despite their centrality to military technology Pitron_{2020, pp.76}. The 2013 paper mentioned the term for the first time: “The French DNA is not equipped for a situation of scarcity” Pitron_{2020, pp.78}. It was France (and Europe) that created the conditions of its own scarcity by assuming scarcity was no longer possible. Beijing, in the same period, pursued a different strategy: building reserves while buying up market inventory at distressed prices, and scaling processing capacity for minerals Western economies had ceased to regard as strategically meaningful.

Charles Hyde’s history of British iron production offers a useful corrective to the idea that this pattern is new Hyde_{1977, pp.8}. Limestone functioned as an essential flux reagent in every blast furnace from 1700 to 1870, taken for granted precisely because it was local, cheap, and everywhere. Nobody called it strategic. The industry that built the modern world ran on it without once producing a white paper about its supply chain. Foundational industrial inputs are routinely invisible to the institutions of their time; until the industrial ecosystem around them begins to fray.

The patchwork

What currently covers foundational minerals in European policy is a patchwork, and the patchwork is revealing. The Circular Economy Action Plan addresses them as a waste management problem. The Clean Industrial Deal covers the industries that consume them without touching the minerals themselves. The Net Zero Industry Act covers the clean technologies they feed as inputs to someone else’s supply chain. No instrument asks the relevant question: for each major industrial process European industry is committed to sustaining and decarbonising, is the mineral ecosystem adequate?

The gypsum situation shows how cleanly this misses what is already happening. Germany consumes approximately 10 million tonnes of gypsum per year. Until recently, over half came from flue-gas desulphurisation at coal plants; a byproduct of power-sector pollution controls. As coal plants close, that supply disappears. European FGD gypsum production has declined 18% since 2020. The German Gypsum Association has concluded there will be “no large-scale alternative to natural gypsum in the medium-term future.” Expanding natural quarrying faces permitting resistance: Germany’s reserves lie largely in Thuringia, where extraction into the Harz Mountains meets sustained political opposition. This is a supply cliff created directly by the energy transition, affecting a mineral used as an essential cement retarder. No EU instrument sees it as a strategic concern, because no EU instrument asks the question that would reveal it.

The CEAP’s construction and demolition waste recovery targets are waste management metrics, not industrial strategy. Spent limestone sorbents, steel slag, demolition concrete; these secondary streams are governed by actors with no industrial strategy mandate. Recycling is a complement to a healthy industrial base. It is not a substitute for one you never fully built. “We have gained in buying power what we have lost in buying knowledge,” Pitron writes Pitron_{2020, pp.79}. The knowledge of how to build and maintain a complete industrial mineral ecosystem (from quarry through processing through industrial-grade secondary recovery) is precisely what atrophies when policy treats the foundational layer as a waste management question.

The permitting environment compounds the problem precisely when the demand signal is rising. Without strategic designation, there is no fast-track and no political mandate for permitting reform. In Ireland, aggregate extraction applications subject to appeal average 33 months RPS Group_{2025, pp.26}; longer than the CRM Act’s 27-month target for strategic raw materials. In Greater Dublin, planning was refused for more than half of proposed aggregate extraction volumes between 2017 and 2023 RPS Group_{2025, pp.17}. In England, demand has outstripped new permitted reserves for a decade Mineral Products Association_{2023, pp.2}. Natura 2000 designations (covering 18% of EU land area) require appropriate assessment for any extraction likely to affect a designated site, with no equivalent of the CRM Act’s strategic project override for foundational minerals. UEPG has explicitly warned that CRM fast-tracking may divert regulatory capacity away from industrial mineral permitting, making the gap worse rather than better Aggregates Europe (UEPG)_{2023, pp.1}. The quarry operator facing a Natura 2000 constraint has no mechanism comparable to a strategic project designation. There is no political constituency for an aggregate quarry the way there is for a lithium mine.

A foundational minerals strategy would ask a structurally different question from the one the CRM Act asks; not a longer list of scarce minerals, but a process-anchored analysis. What does the green transition actually demand from the foundational layer? The IEA models battery metals, rare earth elements, and electronics minerals under net-zero scenarios Kim₂₀₂₅. It does not model what the transition requires in limestone for wind turbine concrete foundations (243–413 tonnes per MW) Carrara_{2020, pp.21}, or in high-purity silica for solar glass at EU deployment scale, or in magnesia for EAF refractory linings as green steel scales. No institution has produced this analysis. Where partial analysis does exist, the outlook is not reassuring: feasible cement supply under a Paris-compliant carbon budget is likely to meet only 22–56% of expected global baseline demand in 2050 Watari_{2023, pp.4}. The absence of modelling is itself evidence of the blind spot: you cannot manage a risk you have not measured.

Conclusion

The irony of the current situation is that Europe’s most sophisticated industrial policy instruments have made the foundational layer less visible, not more. By correctly diagnosing geopolitical scarcity as the primary risk in critical minerals, the CRM Act implicitly signals to industry and capital that domestically produced abundant minerals are not a strategic concern. The CEAP confirms it: those materials are a waste management question. Together they produce a coherent institutional message that happens to be incomplete; the base of the industrial stack will sort itself out, because it always has.

For most of the past three decades, that assumption went untested. It is being tested now. The Western re-industrialisation push (the EU’s Clean Industrial Deal, the US Inflation Reduction Act, national onshoring strategies across Europe) assumes the foundational layer will accommodate the demand surge it generates. More cement for offshore wind foundations. More high-purity silica for semiconductor fabs and solar glass. More limestone and magnesia for the steel and refractories that build the infrastructure of the green transition. The US has the same structural blind spot: its critical minerals strategy concentrates on lithium, cobalt, graphite, and rare earths, while the Energy Act of 2020 statutorily excludes “common varieties of sand, gravel, stone, pumice, cinders, and clay” 116th United States Congress_{2020, pp.1383}; categorically, before any technical assessment begins. As analysts at CSIS have noted, “disfavoring certain minerals could inhibit innovation and create shortages down the line” Runde₂₀₂₃.

Industry has begun organising around a gap that policy has not yet named. UEPG has formed an Essential Raw Materials Coalition with Euromines and others specifically to advocate for non-critical minerals excluded from the CRMA. That the coalition exists is itself evidence: industry can see the gap; the instruments cannot.

Hyde’s limestone suggests this pattern has a 300-year history. Pitron’s Europe confirms what happens when the assumption of abundance goes unexamined long enough. The absence of a foundational minerals strategy is not a gap waiting to be filled by the next policy cycle. It is the shape that an ideology leaves when it has been running long enough to feel like common sense; and the re-industrialisation moment is the first serious test of whether that common sense was ever right.