On March 16, 2023, the European Commission published a proposed Critical Raw Materials Act – a regulation to identify and protect the EU’s supply of critical and strategic raw materials, including key battery metals. The Act would set new EU targets for the extraction, processing, and recycling of strategic raw materials in the EU and grants certain privileges to strategic raw materials projects. This memo outlines key considerations under the proposed Critical Raw Materials Act for developers, processors and investors in critical raw materials.