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EU Critical Raw Materials Act 2024/1252

Trace critical raw materials from source to product

Collect multi-tier supplier evidence, trace material flows and share CRM data, without exposing sensitive supply-chain information.

CRM material record

Strategic raw material

NdFeB permanent magnet

Batch MG-0421 · Traction motor

Extraction

Tier 3 supplier · Mine site

Verified

Processing & separation

Tier 2 supplier · Refinery

Verified

Magnet manufacturing

Tier 1 supplier · Recycled content

Requested

Finished product

Your company · Data carrier ready

Know your CRM exposure

Which materials, from where, through which suppliers.

Reuse evidence everywhere

One record for regulators, customers, audits and procurement.

What Circularise covers

CRM traceability is only as strong as its evidence

The label or disclosure is the last step. The hard part is finding critical materials across products and suppliers, and verifying origin and recycled content.

See the workflow

Collect supplier evidence

Structured data and documents from producers, processors, recyclers and component suppliers.

Trace critical material flows

Link materials to sites, batches, transformations and products in an auditable chain of custody.

Share verifiable information

Give customers, auditors and authorities the proof they need. Keep sensitive data private.

Apply evidence across markets

Reuse origin and end-use proof for incentives, trade controls and strategic procurement.

Implementation workflow

From scattered evidence to a maintained CRM data system

Build one ongoing workflow instead of collecting data again for every assessment or request.

  1. 1

    Collect required data

    Map requirements to materials, suppliers and owners, then automate evidence requests.

    ProvenanceProcessingRecycled contentSupply risk
  2. 2

    Connect the material record

    Link evidence, sites, batches and transformations into one auditable record.

    SitesBatchesTransformationsProduct IDs
  3. 3Outputs

    Share the right view

    Publish to each audience while protecting confidential supplier and transaction data.

    Material recordsData carriersAPIsPartner access

CRM data model

Prepare the data before the request arrives

Exact fields depend on the material, product and requirement. The core is the same: clear owners and reliable proof.

Material identity & provenance

One record from raw material to finished product.

CRM / strategic classificationMaterial compositionExtraction, processing & recycling sitesSupplier, batch & product IDs

Supply risk & sourcing evidence

A reliable basis for risk, continuity and sourcing decisions.

Chain-of-custody & verificationSupply concentrationDisruption exposureDiversification & substitutionDue diligence

Product & recovery information

Useful for manufacturers, repairers and recyclers.

Permanent-magnet type, weight & locationRecycled contentFootprint / LCA dataDismantling & safe removalRecovery & recycling

CRM readiness

What to do now

The question to answer

Where does each critical-material data point come from, and can it be verified?

  1. 01

    Confirm your scope

    Identify critical and strategic materials in your products, and which CRMA or customer requirements apply.

  2. 02

    Prioritise upstream evidence

    Start with extraction, processing and recycling data. It is the hardest to reconstruct later.

  3. 03

    Prepare product-level data

    Find products with permanent magnets and assign owners for composition, recycled content and dismantling data.

  4. 04

    Connect systems and access

    Plan ERP, PLM, LCA and procurement integrations, and separate public, customer, auditor and authority access.

  5. 05

    Plan for international trade

    Reuse origin, processing and end-use evidence for sourcing incentives, trade controls and procurement.

Frequently asked questions

What is a CRM Passport?

A practical term for a digital record of critical-material and supply-chain information. The CRMA does not create one universal passport. It sets specific data-carrier requirements for products with permanent magnets, while other information may be needed for risk assessments, recycled-content disclosure, due diligence or connected product passports.

Who is directly affected by the CRMA’s company requirements?

Article 24 applies to identified large companies manufacturing specified strategic technologies with strategic raw materials. Articles 28 and 29 apply to anyone placing covered products with permanent magnets on the EU market. Suppliers often need to provide the underlying material and production data.

Which products are covered by the permanent-magnet requirements?

Article 28 currently covers MRI devices, wind-energy generators, industrial robots, motor vehicles, light means of transport, cooling generators, heat pumps, electric motors (including integrated motors) and specified household appliances. Some exemptions and later dates apply.

Can CRMA information go into an existing Digital Product Passport?

Yes. Where a product already needs a passport under another EU act, Article 28 requires the permanent-magnet information to be included in it. Avoid building a separate data system per regulation.

Is all CRM information publicly accessible?

No. Some recycled-content information must become public. Other data is meant for repairers, recyclers and authorities, and supplier evidence can stay protected through role-based access, selective disclosure or third-party attestations.

Discuss your requirements

Know where your critical materials come from

A 30-minute walkthrough to map your CRM exposure and missing supplier evidence.

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