Building a European JOGMEC: The Case for an Autonomous, Market-Facing EU Critical Raw Materials Centre 

Contribution to the European Commission's public consultation on the EU Critical Raw Materials Centre

The European Critical Raw Materials Centre should be an autonomous European body or public-private partnership with its own legal personality outside the European Commission, capitalised through a blend of European Union (EU), member states’ and private money, and run by professionals.

Give the Centre the powers of a market actor 

The Centre should produce centralised market intelligence across materials value chains. The Centre should also be able to act to mitigate supply chain and market risks.

To invest in integrated projects across the value chain, it needs a sizeable multi-annual budget in the tens of billions, equity and debt instruments, loss-absorption capacity and a mandate that tolerates commercial risk rather than one bound by state-aid caution.

To manage strategic stockpiles as something more than a static warehouse, it needs treasury powers: the ability to hedge price and currency risks, to collect fees, and to release and rotate stock without going back to the Commission or the Council for authorisation each time.

To aggregate demand and negotiate credible and useful joint-purchasing terms, the Centre needs the legal capacity to contract on behalf of pooled European buyers and to hold inventory.

Recruit for market experience, as Washington and Tokyo have done, and work through public-private partnerships 

The EU CRM Centre should be inspired by, but not blindly copy, Japan’s approach. It should have a lean, highly skilled in-house team with genuine experience in mining and metals equity and debt, hedging, logistics and commodity trading. 

It should co-invest alongside EU-anchored platforms and funds to achieve strategic outcomes (securing EU-domiciled offtake; building European midstream and refining capacity; diversification away from China) with incentive design favouring deferred- or mission-linked carry.  

The Centre should also take inspiration from Europe’s own past. Europe used to have entities that managed commodity risk, bridging global commodity markets and the needs of European industrial producers but lost this capability. What elements are worth rebuilding in today’s very different climate and what risks should be avoided?: See Germany’s Metallgesellschaft (1881-2000) and SOGEM (1919–2001/02). 

A path to self-financing: price-setting as a revenue model 

EIES recommends that the Centre be designed from inception to reduce its dependence on annual EU budget appropriations by monetising the market functions the Commission already proposes to give it. 

Where the Centre aggregates demand on behalf of European buyers, it should charge a transaction or membership fee and can, over time, act as the reference-price setter for aggregated volumes, much as a clearing house or benchmark administrator earns a margin for providing price discovery the market currently lacks in several CRM segments.

Where it manages strategic stockpiles, it should price releases at a spread over its acquisition cost and market benchmarks, generating a working-capital return rather than treating the stockpile as a pure cost centre.

Where it invests equity or debt into strategic projects, it should retain the upside (carried interest, warrants, offtake rights) as JOGMEC does, so that successful investments replenish the fund rather than reverting entirely to the EU budget.

What sixty years of the Euratom Supply Agency teaches 

The Commission need not look only to Asia: it has run a body with strikingly similar powers since 1958.

The Euratom Supply Agency (ESA) holds an exclusive right under the Euratom Treaty to conclude supply contracts for nuclear materials on behalf of EU users, a right of option to purchase materials produced in Member States, and a statutory duty to monitor the market and publish price indices and quarterly reports.

These are precisely the joint-purchasing, contract-supervision and market-intelligence functions now proposed for the CRM Centre.This is proof that EU primary law already accommodates a body with contracting power over a strategic material.

Recommended structure and next steps 

Of the options on the table, an executive agency attached to the Commission should be excluded: it cannot raise capital, cannot take commercial risk, and cannot pay for market talent.

EIES recommends instead a sui generis European body or public-private partnership with independent legal personality, comparable in spirit to the European Investment Bank rather than to a Commission agency.

It should be capitalised by the EU budget, Member State contributions and private investors as genuine financial partners rather than grant recipients; governed by a board on which the Commission and participating member states sit; and led by an executive team hired on remuneration and mandate terms that can attract the equity, debt, hedging, logistics and trading expertise the four strands of its mandate demand.  

The CRM Centre should set direction, standards and risk appetite, and anchor capital. It should not try to be the deploying entity for every transaction.

Start now with E-MIN 

A body of this kind will take years to legislate, capitalise and staff, and the projects that matter are taking investment decisions now.

EIES recommends launching a European Minerals Investment Network (E-MIN) in the interim, to assess Europe’s needs across critical raw materials and direct public and private funds towards a pipeline of strategic projects.

E-MIN would: 

  • connect, convene and consult institutional investors and private capital, CRM miners and processors and, crucially, anchor industrial investors and offtakers; 

  • create synergies across energy, automotive and defence, linking them with upstream exploration and midstream processing companies; 

  • support supply-chain assessments that identify the components and technologies most at risk and most strategic for the EU; 

  • build the relationships, data and trust the mature Centre will rely on, sharing risks and rewards between public and private actors. 

E-MIN is not an alternative to the Centre. It is the groundwork for it. 

EIES stands ready to support the Commission and the European Initiative for Energy Security's own investment network in developing the governance and financing architecture this model requires. 

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Joint Statement on the Industrial Accelerator Act (IAA)