UNIFE sets out position on critical raw materials, calling for rail supply industry to be treated as strategic in EU legislation

UNIFE, the European Rail Supply Industry Association, has published a position paper on critical raw materials (CRMs), calling on EU institutions to recognise the rail supply industry as a strategic sector in the European Critical Raw Materials Act (ECRMA) and the planned European Critical Raw Materials Centre (ECRMC).

The October 2026 paper sets out how the sector uses CRMs, the supply constraints it faces and the changes UNIFE wants to the ECRMA, which is under revision. UNIFE says the industry underpins industrial sovereignty and the security of Europe’s critical infrastructure, including military mobility.

Rail’s strategic role and supply chain exposure

UNIFE argues that railways are critical infrastructure, where a single disruption can paralyse passenger and freight mobility. It says the industry provides key technologies for rolling stock, infrastructure and signalling, and that rail freight in the EU carries an estimated 375 billion tonne-kilometres a year. The association adds that Europe must remain at the technological forefront and avoid strategic dependencies on non-secure suppliers controlled by third-country states.

UNIFE has ranked 27 CRM and strategic raw material entries by importance to the sector, led by copper, nickel and bauxite, alumina and aluminium. Copper is essential for catenaries and cables, transformers, traction systems and signalling equipment. Most materials on the list are essential for electrical and electronic equipment across signalling, safety devices and traction. UNIFE stresses that the list is intended to support discussion on strategic criticality and is not a suggestion to extend compliance obligations to additional materials.

UNIFE accepts that CRMs are not the largest cost component of a train, but describes them as an increasing strategic dependency. It says rail uses small quantities because of its size and project-based organisation compared with industries such as automotive, so suppliers never prioritise it. The paper cites the International Energy Agency, which anticipates a 30 per cent copper supply deficit as early as 2030.

CRMs, as identified under the ECRM Act, are not the largest cost component of a train, but they are increasingly a strategic dependency.”

Graphite shortages extend lead times

The paper points to the LEADER 2030 project, funded under the Europe’s Rail Joint Undertaking, as an example of how disruption in upstream raw material markets can quickly translate into delays for manufacturers and operators. Its final report highlights graphite shortages driven by rising defence demand, as materials are redirected from civilian to military uses.

According to the report, lead times for pantographs and certain locomotive components rose from around three months before Russia’s war of aggression against Ukraine to six months in 2024 and approximately nine months in 2025. This resulted in delays of up to 12 months for the delivery of new or refurbished electric trains and locomotives. UNIFE says the European Commission should treat the situation as long term, given the increasing tendency to weaponise supply chains.

UNIFE proposals on ECRMA obligations

UNIFE is critical of the number of delegated acts, which it says leave methodologies, thresholds and timelines to the Commission’s later discretion with limited industry consultation. It notes that the ECRMA revision is open before the delegated acts promised in the first version have been released. The association also wants reporting harmonised with existing EU mechanisms, including the Battery Regulation, ESPR, REACH, RoHS and the Corporate Sustainability Reporting Directive, so that data is reported once and used multiple times.

On labelling, UNIFE requests a de minimis threshold under Article 28, matching the 0.2 kg threshold already applied under Article 29 for permanent magnets. It says signalling products use a considerable number of small permanent magnets sourced through complex international supply chains, and that the administrative burden of collecting detailed information may outweigh the practical benefit.

Under Article 29, UNIFE asks for removal of the requirement to publish the share of recovered materials in permanent magnets, arguing the information is sensitive and could inform competitors, especially from hostile third countries, of a company’s CRM needs and technologies. It also seeks a transition period of at least three years before the deadline, and says Europe lacks sufficient recycled content in permanent magnets to meet the minimum shares required by 31 December 2031.

Joint purchasing and stockpiling through the ECRMC

UNIFE supports a Critical Raw Materials Forum so that downstream industry can be heard, based on the European Parliament’s position approved on 20 October 2026. It wants the ECRMC to facilitate voluntary joint purchasing and demand aggregation, building on demand matching under the Raw Material Mechanism launched in April 2026. With 90 per cent of rail contracts awarded through public procurement, UNIFE says better access to secondary raw materials could support circular procurement.

The association also wants the rail supply industry included in strategic stockpiling, primarily as a response to short-term or emergency shortages such as export controls. On market intelligence, it asks that pooled data remains anonymised and aggregated to protect trade secrets.

UNIFE also suggests the Commission draw on raw material agencies in Japan and South Korea when setting up the centre. The association represents more than 120 European train builders and rail equipment suppliers and brings together national rail industry associations from 13 European countries.