Dear Internal Market, Industry, Entrepreneurship and SMEs,
Dear Raw Materials Unit in DG GROW,

Under the right of access to documents in the EU treaties, as developed in Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents, I am requesting access to the following documents related to the Strategic Projects selected under the Critical Raw Materials Act (Regulation (EU) 2024/1252):

The complete applications submitted by project promoters for Strategic Project status following the first cut-off date (22 August 2024), including annexes and any supporting documentation, as required under Article 7(1).

The methodology and criteria used by the Commission to evaluate and assess these applications in the first assessment round.

The Commission’s internal evaluation and justification provided to the Critical Raw Materials Board under Article 7(6), second subparagraph.

The opinions issued by the Critical Raw Materials Board under Article 7(6), first subparagraph.

While the announcement published on 25 March 2025 includes a list of selected projects with basic identifiers (name, promoter, country), it does not include any information about the criteria applied, the assessment methodology, or the supporting rationale. Given the legal, environmental, and social implications of these decisions, this level of disclosure is insufficient.

I would also like to ask:

Whether the Commission intends to publish the full decisions and related documentation in the Official Journal, or elsewhere — and if so, when this can be expected.

If there is no intention to publish these materials proactively, I would appreciate a clear explanation of the legal grounds for this choice. Since the selection process has concluded, concerns about commercial confidentiality or non-final deliberations no longer appear applicable.

In the interest of transparency, public participation, and in line with the Aarhus Regulation (Regulation (EU) 2021/1767), the requested documents are essential for communities, civil society organisations, and elected representatives to understand and respond to the projects selected for Strategic status. These projects are meant to serve a broad public interest — economic, environmental, and strategic — and must therefore be subject to public scrutiny.

As you will be aware, the Aarhus Regulation provides for internal review mechanisms under Article 10, but any such review presupposes timely access to the relevant documents. To date, multiple access-to-documents requests through various channels — including AsktheEU — have been denied or delayed, making timely engagement increasingly difficult.

Given the urgency of potential legal or administrative challenges, and the fundamental right to access environmental information, I urge the Commission to provide or publish the requested materials without delay.

Many thanks in advance for your attention to this matter. I look forward to your reply.

Yours faithfully,
Robin Roels

Dear [email address],

My postal address is the following:
Mr. Robin Roels, Tweekerkenstraat 14, 1000 Brussels, Belgium

Yours sincerely,
Robin Roels

Dear [email address],

Thank you for your initial reply, which was sent to me via email but not publicly listed on the portal. I would like to reiterate that, under Regulation (EC) No 1367/2006 implementing the Aarhus Convention, I have the right to access environmental information held by EU institutions, including documents related to decisions on projects that have environmental relevance, such as those recognised under the Critical Raw Materials Act (CRMA) as Strategic Projects.

As such, I formally request the following categories of documents:
The application documents of all projects recognised as Strategic Projects under Commission Decision C(2025) 1904,
The criteria, internal guidance, scoring frameworks, and assessment documents used by the Commission to evaluate and select these projects,
Any correspondence, meeting minutes, or internal notes related to the assessment and recognition process.

As I understand it, if no reply is received within five working days, your service will only provide the application documents (603 in total). While access to these applications is necessary, it is not sufficient. In order to ensure transparency and enable proper public scrutiny, it is essential to also receive the Commission’s rationale, criteria, and evaluation documents that underpin these designations.

Given the clear environmental implications of mining and raw materials projects, the application of the Aarhus Convention and Regulation 1367/2006 is undeniably triggered. I therefore ask that you treat this request with the urgency and completeness it requires, and that all relevant documents, beyond the applications, be shared at your earliest convenience.

Ref. Ares(2025)5027296 - 24/06/2025

Yours sincerely,

Robin Roels