Reports | Statements
GLI publishes reports, media statements or other documents. The aim is to further public discourse, or appeal to legislators to implement environmental law in a way that leads the general public and associations to better access to courts.
Most of these documents will be in German. Upon request, certain reports may be prepared in English as well. Please contact us to let us know which topic you are interested in.
Commission Decisions designating 60 raw materials projects as "strategic" likely unlawful.
The European Commission’s Decision C(2025) 1904 of 25 March 2025 recognises 47 projects as “Strategic Projects” under Regulation (EU) 2024/1252 (Critical Raw Materials Act). Commission Decision C(2025) 3491 of 4 June 2025 recognizes further 13 projects located outside of the European Union as “strategic”. The Decisions recite that each listed project “fulfil[s] all the criteria provided for in Article 6(1)” of the Regulation, and notes that applications were assessed “with the support of external experts […] in the technical, financial, environmental, social and governance (ESG) dimensions of a
project”. However, the Decision itself contains no explanation of how each project satisfies the sustainability requirements of Art. 6, nor any factual or legal reasoning for granting the strategic status. This omission gives rise to a breach of the Commission’s duty to state reasons and creates legal uncertainty for affected communities, national permitting authorities and companies. The published notice outlines these shortcomings and depicts implications following therefrom for the involved stakeholder groups.
Contesting Mining Projects under the Critical Raw Materials Act
Green Legal Helpdesk publishes guidance on using the Aarhus Regulation to challenge the designation of mining proposals as “Strategic Projects”
Today, the Green Legal Helpdesk, a Green Legal Impact initiative, publishes a set of documents directed at grassroots organizations and communities affected by mining projects, that could be designated as “strategic” by the EU Commission under the Critical Raw Materials Act. This guidance is supposed to inform stakeholders on how to use the Internal-Review-Mechanism under Regulation EC/1367/2006 to challenge this designation.
With the “User Manual – Aarhus Regulation”, we provide an overview of how to launch a Request for Internal Review, explain what it can and cannot do and which criteria applicants must meet. Furthermore, we provide two templates, one for contesting projects that would be realized in the European Union and one for projects in third countries or overseas territories. These templates can serve as a starting point for drafting a Request for Internal Review. Naturally, they have a lot of blank spaces that need to be complemented on a case-by-case basis with a view to the individual facts relevant to a specific mining project. Nevertheless, we believe that having these wireframes can facilitate this process. Green Legal Helpdesk, in collaboration with partner organizations, will conduct a Webinar to guide through these documents and answer questions. This Webinar will be announced separately.