How the EU Critical Raw Materials Act reshapes graphite sourcing — and why procurement teams are qualifying European natural flake graphite from Norway's Skaland mine to reduce Chinese export dependency.
The European Commission first designated natural graphite as a Critical Raw Material in 2011. The designation — reaffirmed in the 2023 EU Critical Raw Materials Act (CRMA) — reflects two structural vulnerabilities: the near-total concentration of global graphite mining in China (accounting for over 70% of mined output and over 90% of processed anode-grade material), and graphite's irreplaceable role in the energy transition.
The CRMA establishes a strategic target: by 2030, the EU should be capable of producing at least 10% of its annual consumption of each Critical Raw Material domestically, and should not source more than 65% of any strategic raw material from a single third country. For graphite, both targets require urgent action — and Skaland mine on Senja Island, Norway, is the only operating natural flake graphite mine in the European Economic Area capable of contributing to that supply.
In August 2023, China's Ministry of Commerce announced export licensing requirements for natural graphite, effective December 2023. The controls cover the high-purity and large-flake graphite grades used in battery anode material production — precisely the grades that European battery gigafactories require.
The impact was immediate. Lead times from Chinese suppliers extended from weeks to months as export permit applications accumulated. Several European battery material processors reported qualification delays and began emergency assessments of alternative sources. For procurement teams that had treated graphite as a commodity with reliable Chinese supply, the controls were a strategic wake-up call.
The controls also created a structural asymmetry: Chinese battery manufacturers using domestic graphite face no such restrictions, giving them a cost and logistics advantage that is now a policy concern for EU battery manufacturers competing under the EU Battery Regulation's content requirements.
The CRMA creates both obligations and incentives relevant to graphite procurement. Key provisions include:
Strategic project designation: Mining and processing projects that meet CRMA criteria can apply for accelerated permitting and access to public financing. This improves the investment case for European graphite production and the long-term reliability of domestic supply.
Supply chain auditing: The CRMA's due diligence provisions, aligned with the EU Supply Chain Due Diligence Directive, will require large manufacturers to assess and document the origin and environmental impact of Critical Raw Material inputs. Sourcing from a single European mine with full chain-of-custody documentation simplifies this obligation considerably versus auditing multi-tier Asian supply chains.
EU Battery Regulation Annex X: Separate from the CRMA, the EU Battery Regulation (EU 2023/1542) requires battery manufacturers to provide a battery passport documenting the origin, carbon footprint and supply chain due diligence status of graphite and other critical materials. Natural flake graphite from Skaland comes with mine-to-shipment traceability documentation that directly addresses Annex X requirements.
Skaland mine on Senja Island in Troms county, northern Norway, has operated continuously since 1932 — making it the longest-running natural flake graphite mine in the world outside China. Its geological credentials are exceptional: with an average ore grade of 31% graphitic carbon, it is the world's highest-grade operating natural flake graphite deposit. That ore grade means less material processed per tonne of concentrate, lower energy consumption, and a lower carbon footprint per tonne of finished product than any competing source.
The mine produces six standard grades of natural flake graphite from SGF-80 (≥80% Cg, basic industrial/foundry grade) through SGF-91 (≥91% Cg, refractory grade) to SGF-99 (≥99% Cg, ultra-pure battery anode grade). All production is traceable to a single mine in a single country — Norway — with no sub-contracted processing at unverified third-party facilities.
Norway's near-100% renewable electricity grid further differentiates Skaland's environmental credentials: upstream carbon intensity is approximately 1–2 t CO₂e per tonne of graphite concentrate, compared to 5–10 t for synthetic graphite produced in China using coal-dominated electricity and 3–6 t for typical Chinese natural graphite processing.
For battery material manufacturers, refractory producers and industrial buyers currently sourcing graphite exclusively from China, the risk of supply disruption from export licensing is real and ongoing. Qualification of a European alternative — even as a secondary or backup source — is straightforward with Skaland:
We provide qualification samples, technical datasheets, CoA, REACH documentation and EU Battery Regulation Annex X traceability data to support the full qualification process. Response time to all technical enquiries is one business day. Spot supply and annual contract arrangements are both available.
The EU Supply Chain and EU Battery Regulation compliance case for European natural flake graphite has never been stronger. Contact us to begin qualification.
CAS Number: 7782-42-5 · REACH: Registered · Origin: Skaland Mine, Senja Island, Norway · MOQ: 20 metric tonnes · Incoterms: FCA Skaland / CIF · EU Battery Reg. Annex X: Available on request