Permit advice for critical raw materials projects

Critical raw materials are economically important materials that are needed for purposes other than energy or agricultural use. They involve a high supply risk because their availability and production are mainly concentrated in a few countries. 

The following raw materials are considered critical: 

- in unprocessed form, at any stage of processing and when occurring as a by-product of other extraction, processing or recycling processes 

• antimony
• arsenic
• baryte
• bauxite/aluminium oxide/aluminium
• beryllium
• boron
• fluorspar
• phosphorus
• gallium
• germanium
• graphite
• hafnium
• helium
• light rare earth elements
• cobalt
• coking coal
• copper
• lithium
• feldspar
• magnesium
• manganese
• nickel - battery quality
• niobium
• silicon metal
• metals of platinum group
• phosphate rock 
• heavy rare earth elements
• scandium
• strontium
• tantalum
• titanium metal
• vanadium
• bismuth
• Tungsten

The list was updated on 10 January 2025. The European Commission may amend the list. See EUR-Lex for up-to-date information. 

EUR-Lex is linked at the bottom of this page.

A critical raw materials project refers to a project involving

• extracting, processing or recycling critical raw materials and
• planning the establishment of a facility or a significant extension or repurposing of an existing facility 

Extraction

Extraction means the extraction of ores, minerals and plant products from their original source as a main product or as a by-product. 

• Extraction includes mineral occurrences
  • underground
  • under and in water
  • from brine.
• Extraction also includes the production of critical raw materials from plant products, such as trees.

Processing 

• Processing refers to all processes involved in the transformation of raw materials into economically usable forms. 
• These processes include:
  • physical, chemical and biological processes
  • transforming raw materials from ores, minerals, plant products or waste into pure metals or alloys
  • beneficiation, separation, smelting and refining.

Processing does not include working and further transforming metal into intermediate and final goods. 

Recycling

Recycling refers to the reprocessing of waste materials into products, materials or substances.

• Reprocessing may be done for the original purpose or for other purposes.
• Recycling includes the reprocessing of organic material.
• Recycling does not include:
  • energy recovery
  • reprocessing into materials that are to be used as fuels or for backfilling operations. 

The Critical Raw Materials Act (CRMA) of the European Parliament and of the Council entered into force on 23 May 2024.

The purpose of this regulation is to ensure the sustainable supply of critical raw materials in the EU. The regulation supports the economy of EU countries and the reduction of the use of fossil fuels. 

The task of the point of contact authority under the regulation is performed in Finland by the Regional State Administrative Agency for Northern Finland.

The regulation is linked at the bottom of this page.

The point of contact authority coordinates the project permit process and helps the party responsible for a project to understand relevant administrative matters.

The Regional State Administrative Agency for Northern Finland is the national point of contact authority for critical and strategic raw materials projects in Finland.

You can send us questions and documents to [email protected]. 

Please use secure email when sending documents containing confidential or otherwise sensitive information. The maximum size of email messages, including attachments, is 50 MB. Larger files should be compressed or sent in multiple emails. Please remember that any information sent to us by email is at the sender’s risk. 

Send secure email. 

You can also send documents by post to:

Regional State Administrative Agency for Northern Finland
Environmental permits
P.O. Box 6, 13035 AVI

Strategic raw materials are critical raw materials that are of high importance for the EU internal market. They are used in the technologies of the green and digital transition and in defence and aerospace applications. 

The estimated global demand for strategic raw materials is typically higher than their supply. In addition, increasing the production of strategic raw materials is difficult. 

The following critical raw materials are also considered strategic raw materials
- in unprocessed form, at any stage of processing and when occurring as a by-product of other extraction, processing or recycling processes

• bauxite/alumina/aluminium
• boron – metallurgy grade
• gallium
• germanium
• graphite – battery grade
• cobalt
• copper
• lithium – battery grade
• rare earth elements for permanent magnets (Nd, Pr, Tb, Dy, Gd, Sm, and Ce)
• magnesium metal
• manganese — battery grade
• nickel – battery grade
• silicon metal
• platinum group metals
• titanium metal
• bismuth
• tungsten

List updated on 24 February 2025. The European Commission may amend the list. See EUR-Lex for up-to-date information. 

EUR-Lex is linked at the bottom of this page. 

Status as a Strategic Project has the following impacts:

• The overall permit-granting process for the project must be carried out within the time limit laid down in the regulation. 
• The permit applications for the project are given priority by the Regional State Administrative Agency in relation to other permit applications that are compliant with the Environmental Protection Act and the Water Act.
• Matters concerning the project are processed as urgent matters in appeal courts.
• In the consideration of permits, the project can be seen to involve overriding public interest, which may make it possible to deviate from the environmental objectives of water management or the protection of an area belonging to the Natura 2000 network.  

Status as a Strategic Project does not affect the conditions for granting a permit or provisions relating to pollution control. In addition, this status does not impair the level of environmental protection or the quality of the environmental assessments required to carry out the projects.

More information on the status of a Strategic Project, application instructions and the application form are available the European Commission’s website:

• Strategic projects under the CRMA - European Commission

Frequently asked questions:

• FAQ - European Commission

Questions related to the application process can also be sent directly to the European Commission to [email protected].

The calculation of the time limit for the overall permit-granting process starts when the authority processing the matter concludes that the first application contains the required information or when the environmental impact assessment report has been submitted to the authority. The calculation of the time limit ends when the authority issues its decision on the last application. 

We will notify the party responsible for the project of the start and end of the time limit calculation and of any changes.

The time limits for the overall permit procedure for the strategic project are as follows:

• 27 months when the project involves extraction
• 15 months when the project only involves processing or recycling

If a project has already been subject to the permit-granting process before being recognised as a Strategic Project, the total permit-granting process may not exceed: 

• 24 months for projects involving extraction
• 12 months for projects only involving processing or recycling.

If a project requires an environmental impact assessment, the calculation of the time limit for the overall permit-granting process starts once the assessment report has been submitted. If the assessment needs to be supplemented after a consultation, the period between the time limit for delivering the supplement and the delivery of the submission is not included in the duration of the overall permit-granting process. 

No sanctions are imposed on the authorities if the time limits for the overall permit-granting process are exceeded. However, the Finnish State must ensure that the authorities processing the matter have sufficient resources and personnel to process matters within the time limits laid down in the EU regulation. In addition, the authorities responsible for the project and participating in the overall permit-granting process must ensure that the overall permit-granting process is feasible within the determined time limits. 

In exceptional situations, we can extend the time limit for the overall permit-granting process if the nature, complexity, location or size of the strategic project so requires. 

It is possible to extend the time limit before the expiry of the time limits

• by three months if the project relates solely to processing or recycling
• by six months if the project involves extraction.

Grounds for extending the time limit could include unforeseen circumstances giving rise to the need to add to or complete environmental assessments related to the project. 

The authority processing the matter must provide us with its proposal for a time limit extension and the justifications for it.  

If the time limit is extended, we will notify the party responsible for the project in writing. We will accompany the notification with the grounds for the decision and the new end date of the overall permit-granting process. The decision cannot be appealed.

We will prepare a detailed schedule for the overall permit-granting process together with the authorities responsible for the project and participating in the overall permit-granting process. We will prepare the schedule within one month of concluding that the first application is sufficient or of receiving the submitted environmental impact assessment report. The party responsible for the project must publish the schedule on their website. 

We will update the schedule if the end date of the overall permit-granting process changes significantly.

The permits and procedures required for a Strategic Project depend on the type of project. 

Examples of permits and procedures that may be needed to implement a project are listed below.

The permits and obligations required for projects can also be viewed on the Suomi.fi website, linked at the bottom of this page.

In matters related to permit requirements, you can contact the authority processing the matter.

Project applications and documents can be sent to authorities electronically via the Luvat ja valvonta (Permits and Supervision) service and via authorities’ respective e-service channels. The service is developed continuously to better meet the needs of operators and authorities alike. The aim is to offer customers a single e-service channel and streamline cooperation between authorities. 

The Permits and Supervision service is linked at the bottom of this page.

• Project permit for the construction of a high-voltage cable
  • Electricity Market Act (588/2013)
• Permits under the Mining Act
  • Mining Act (621/2011)
• Infringement permit
  • Antiquities Act (295/1963)
• Chemical safety permits and procedures
  • Act on the Safe Handling of Dangerous Chemicals and Explosives (390/2005)
• Obstacle permit
  • Aviation Act (864/2014)
• Building permit for natural and biogas pipelines and storage permit for natural and biogas
  • Government Decree on the Safe Handling of Natural Gas (551/2009)
• Derogation from the prohibition of destruction and degradation of a habitat
  • Nature Conservation Act (9/2023)
• Derogation from the protection of aquatic habitats
  • Water Act (587/2011)
• Permits and procedures under the Construction Act
  • Construction Act (751/2023)
• Permits for the manufacture and storage of explosives
  • Act on the Safe Handling of Dangerous Chemicals and Explosives (390/2005)
• Permit for construction in the Exclusive Economic Zone
  • Act on the Finnish Exclusive Economic Zone (1058/2004)
• Water permit
  • Water Act (587/2011)
• Environmental permit
  • Environmental Protection Act (527/2014)
• Environmental impact assessment 
  • Act on Environmental Impact Assessment Procedure (252/2017)

List updated on 24 February 2025.

The tasks of the authority processing matter of the Strategic Project include

• providing the point of contact authority with information on the current processing stage of a matter concerning the Strategic Project, such as the initiation of the matter and the need to supplement the application or a report. Also when the application contains the required information and a decision has been issued. 
• if necessary, submitting a proposal to the point of contact authority to extend the time limit for the processing of the matter and the reasons for it.
• contributing to the establishment of a schedule for the overall authorisation process for the Strategic Project.