EU Critical Raw Materials Act: Permanent-Magnet Disclosure Requirements

Article 28 covers specified product categories, including certain energy equipment, vehicles, appliances, motors and MRI devices. Its label and data requirements have their own scope and implementation provisions. The 0.2 kg threshold in Article 29 is not a general labelling exemption. Article 28 provides a separate 24 May 2029 application date for MRI devices, motor vehicles and the specified category-L vehicles. Confirm the relevant implementing measures before assigning a date to a particular product.

Article 29(1) concerns the listed products incorporating NdFeB, SmCo or AlNiCo magnets where the aggregate magnet weight exceeds 0.2 kg. The disclosure concerns the shares of neodymium, dysprosium, praseodymium, terbium, boron, samarium, nickel and cobalt recovered from post-consumer waste. Its application trigger is the later of 24 May 2027 and two years after the relevant delegated act enters into force.

That conditional date must be preserved in a compliance plan. It is not an unconditional May 2027 cutover for all products. Article 29(6) separately applies paragraphs 1 and 5 to MRI devices, motor vehicles and type-approved category-L light means of transport five years after the relevant delegated act enters into force. This disclosure clock is distinct from Article 28’s product-information date.

The regulation separates reporting from later measures concerning minimum recycled shares. A capacity benchmark for the EU does not itself impose that percentage of recycled material in every magnet. Do not promise a recycled-content percentage without the applicable methodology and supporting chain-of-custody evidence.

Ask for the magnet family, aggregate magnet weight, composition information needed by the applicable obligation, and the available traceability evidence. State whether a request comes from legislation or the purchase contract. Resolve missing records before agreeing a declaration; a generic supplier certificate cannot establish every element’s recycled share.

The Council position of 4 March 2026 was a negotiating position on an amendment. It was not itself a consolidated trilogue settlement.

Check the enacted text and relevant implementing or delegated acts for the actual placing-on-market date. This review does not assign an unverified universal replacement deadline.

CRMA records do not establish Chinese export clearance. Grade suffixes and F/N/D series labels do not establish composition or export clearance. Classify the actual item and transaction with the exporter, including the parties, end use and route. See the export-control guide. Supplier qualification should identify the contracting supplier, manufacturing entity and exporter.

Check the current certificate for the actual manufacturing entity, address and activity. Agree PPAP level and required reports for the order; a network relationship does not certify every plant or assembly.