CRMA maturity · Compliance with Regulation (EU) 2024/1252 on critical raw materials
Your critical and strategic raw material supply, measured against Regulation 2024/1252 and turned into a costed action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
CRMA maturity · Compliance with Regulation (EU) 2024/1252 on critical raw materials
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2024/1252 (Critical Raw Materials Act), applicable since 23 May 2024 assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism, a level, the level above, and the action linking the two, is what turns a finding into a trajectory.
Do you run stress tests on your strategic raw material supply?
- N1
No stress testing. Supply risk is only examined when a disruption actually occurs.
- N2
Sensitivity analyses exist for a few materials, run ad hoc by one team, with no shared method or documented scenarios.
- N3
Strategic materials are stress tested using a written method, with disruption scenarios by origin and by supplier, and conclusions recorded.
- N4
Tests cover all strategic materials in scope, run on a defined frequency, quantify the impact on production, and feed tracked mitigation plans.
- N5
Scenarios are revised in line with list, market and incident developments, results are reported to the management body, and method revisions are tracked.
Action to move from level 2 to level 3
Formalise a one page stress test method (scenarios for losing a country of origin and a supplier failure, time horizon, alert thresholds), apply it to the strategic materials identified in the inventory, and put the review of conclusions on the procurement committee’s agenda for the following quarter.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurementon CRMA.
What this framework covers
Regulation (EU) 2024/1252, known as the Critical Raw Materials Act, establishes a framework to secure the Union’s supply of critical and strategic raw materials. It sets 2030 benchmark targets for extraction, processing and recycling carried out within the Union, along with a cap on dependence on any single third country for each strategic material. It creates a strategic project status with bounded permitting timelines, organises joint purchasing and stockpiling, and requires large companies using strategic materials in determinant technologies to run periodic supply chain risk assessments, reported to the management body.
In practice, the text is hard to steer because it sits across three functions that rarely talk to each other: procurement, operations and compliance. Do you know the actual origin of your strategic materials beyond your tier 1 supplier? Are your disruption scenarios tested, or do they stop at mapping stage? Are your production flows and waste containing critical materials quantified as recoverable volumes, or treated as undifferentiated tonnage? Many organisations hold data scattered across a procurement tool, a risk register and a sustainability report, with no consolidated view.
One confusion comes up often: the regulation does not create a conflict minerals style due diligence regime, and it does not replace Regulation (EU) 2017/821 or the Batteries Regulation. It acts first on European industrial capacity and on knowledge of supply risk. Another point worth clarifying: the annexes distinguish critical raw materials from strategic raw materials, and the risk assessment obligations do not cover the same scope as the capacity targets. The lists are reviewed periodically, which means monitoring needs to be built into a routine rather than run as a one off project.
A compliance audit concludes with a gap or no gap against a requirement. The maturity assessment answers a different question: what level of control do your practices reach on identifying strategic materials, stress testing, circularity and governance, and what specific action moves you up a level. The two complement each other: the assessment prepares the case and prioritises investment, the audit validates it.
In Datamensio, the framework is ready to use. You can adapt it to your sector, extraction, refining, equipment manufacturing or systems integration: the AI adjusts the themes, questions and levels using the CMMI method, or builds a tailored version from your own documents, supplier mapping, procurement policy, sustainability reports.
Reference standard: Regulation (EU) 2024/1252 (Critical Raw Materials Act), applicable since 23 May 2024
The themes assessed
Governance and accountability
Ownership of the critical materials topic by an identified function, management body mandate, coordination between procurement, risk and operations, review frequency.
Identifying critical and strategic materials
Inventory of materials present in products and processes, cross reference with the regulation’s annexes, upkeep during list revisions, scope of determinant technologies concerned.
Supply chain mapping
Traceability beyond tier 1, identification of countries of extraction and processing, measurement of concentration by supplier and origin, data quality and freshness.
Risk assessment and stress testing
Method for assessing supply risk, disruption scenarios, stress tests on strategic materials, measurement of vulnerabilities and response times.
Mitigation strategies and stockpiling
Diversification of sources, long term contracts, qualification of alternative sources, strategic stockpiling policies, participation in joint purchasing.
Substitution and eco-design
Programmes to reduce strategic material content, qualified substitute materials, integration of the criterion into design and product requalification phases.
Circularity and recovery
Knowledge of flows containing critical materials, extractive waste and tailings, collection and recycling contracts, recovery yields, share of secondary material in supply.
Permitting and projects
Preparation of permitting files, single point of contact and regulatory timelines, environmental impact assessment, consultation of communities and interested parties.
Data, reporting and transparency
Collection and consolidation systems, indicators tracked, internal and external reporting, consistency with sustainability reporting and authority information requests.
Regulatory monitoring and improvement
Tracking of implementing acts and list revisions, lessons learned after supply incidents, method updates, comparison of assessments over time.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Is Regulation 2024/1252 subject to certification?
No. It is a directly applicable EU regulation with no dedicated certification body. Enforcement runs through national authorities, strategic project files and risk assessment obligations. The assessment measures the maturity of your practices and prepares you for these milestones, it does not award any certificate.
What is the difference between this assessment and a compliance audit?
An audit checks each requirement and concludes with a gap or a pass. The assessment places each practice on a five level scale and states the action that moves it up a level. It is used to prioritise investment before the audit comes in to validate.
Which companies are covered by the supply risk assessment obligation?
The regulation targets large companies that use strategic raw materials in manufacturing technologies determinant for the energy and digital transitions, defence or aerospace. Beyond that scope, the same questions apply to any manufacturer exposed to concentrated origins, and the assessment remains useful.
How long does the assessment take?
The short version takes about thirty minutes for a procurement or risk manager to complete. The full version, run collaboratively, typically spans one to two weeks: most of the time goes into gathering material origin data from buyers and sites.
Can the framework be adapted to our sector?
Yes. Themes, questions and level wording can all be modified, and the AI generates a version tailored to extraction, refining, equipment manufacturing or recycling based on your documents. You retain ownership of the resulting framework.
How does this assessment relate to the Batteries Regulation or conflict minerals?
These texts cover distinct obligations: recycled content and due diligence for batteries, due diligence on tin, tantalum, tungsten and gold under Regulation 2017/821. The traceability data is largely shared. A cross cutting roadmap consolidates the three assessments without duplicating actions.
Can several sites or business units be compared?
Yes. The same framework is rolled out across multiple entities, with a score per theme and a benchmark between business units as well as against previous assessments. The AI groups gaps into a prioritised roadmap, and the reporting space shares results in the group’s own branding.
Where is the data hosted?
In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.