Revision of the National Raw Materials Policy - the climate ministry is working on an update

The Ministry of Climate and Environment is working on a document that will identify scarce raw materials for the Polish economy. It also aims to develop a methodology for identifying scarce raw materials and then prepare new lists of strategic and critical raw materials.

Raw material updates and a new list of scarce raw materials

As relayed to PAP, the climate ministry has announced that, as part of the implementation of the National Raw Materials Policy (PSP), a document is being produced Raw material updates - methodology for determining the most important raw materials for the Polish economy with new raw material lists. It will include an overview of scarce raw materials, their importance for the economy and an assessment of the degree of import dependence.

Work on Raw material updates started in 2024 and is still expected to be completed in 2025.The IOC pointed out that the PSP implemented so far was based on data from 2018, so it is necessary:

verification of the current methodology for designating critical and strategic raw materials for the Polish economy and update of the list of raw materials according to the adopted modified methodology.

Among the raw materials classified as scarce in the document will be antimony, germanium, graphite, lithium and manganese. Poland does not have deposits of these, which is why they are all imported at 90 or even 100 per cent. A similar situation also applies to platinum, titanium and vanadium.

According to data from the Polish Economic Institute (PIE) for 2023, our country has 30 so-called critical dependencies in the import of raw materials from China. The consequences of an interruption in their supply could be severe, ranging from an increase in the cost of industrial production to the halting of key industries, especially the automotive, energy and electronics sectors.

Find out more about strategic and critical raw materials >>

What is the National Raw Materials Policy?

It is a document that establishes a strategy for the management and stewardship of all minerals and mineral deposits It refers to the entire value chain of owned resources and is directly linked to the National Environmental Policy 2030 and the Energy Policy of Poland until 2040. The current PSP was adopted by the government on 1 March 2022.

China increases control over rare earth market

Critical raw materials such as lithium, cobalt, graphite and germanium are crucial to the development of modern technologies - from renewable energy and electromobility to electronics and the defence industry. Their availability is becoming increasingly limited and Poland - like other EU countries - is heavily dependent on imports.

Most of the critical raw materials imported in recent years to Poland came from China. It is the Middle Kingdom that is currently regarded as the quasimonopolist in the global rare earths market. Although their deposits are also found in other countries of the world, the only China has the industrial and technological base to extract them. From 2023, however, the Chinese government began to impose restrictions on the export and use of certain raw materials. At the moment, on the list of restrictions already includes 16 items. Furthermore, on 9 October 2025, China made it mandatory for all companies using Chinese rare earth elements in their products to apply for a licence to market these products. Recent reports suggest that applications from arms companies and companies producing dual-use products and technologies are to be automatically rejected.

Turmoil in the global rare earths market has prompted the EU to create a European Critical Raw Materials Act, which is designed to gradually build the raw material independence of Community countries and strengthen the resilience of supply chains by, among other things, strengthening relations with third countries with deposits of rare earth elements.

Poland's strategy against Chinese domination

Restrictions on the import of rare earth elements may also affect Polish industry. For this reason, Poland is taking continuous measures to prevent supply disruptions and the associated significant market shortages. As part of the diversification of supply Poland develops cooperation with countries rich in critical raw materials, such as Mongolia, Kazakhstan, Uzbekistan, Argentina or Ukraine. The aim of these partnerships is to conduct joint geological research and create the conditions for future investment in the extraction and processing of raw materials. The Ministry of the Environment also announces development of a draft law on ensuring the economy's access to critical raw materials and submit it to the Council of Ministers in Q4 2025.

Read also: Government implements EU battery regulation. Find out more about the bill

Not just imports - recycling and domestic deposits as promising sources of critical raw materials

Although our country is largely dependent on imports, it also has a significant copper, coking coal, nickel and platinum resources. Poland accounts for about 27 per cent of EU coking coal supplies and 19 per cent of EU demand for electrolytic copper used for electronics, wires and cables. We are also successfully extracting helium - The Orlen Group recovers this critical resource, as it were, „by the way” of natural gas production. In addition to the deposits being exploited, we also have a number of new deposits that could become an additional source of scarce raw materials in the future. These include ores iron, titanium and vanadium occurring in the Suwałki region, deposits of nickel, gold, tin and arsenic in the Sudetenland and about the deposits of tungsten and molybdenum in Myszków.

Currently The Polish Geological Institute is working on the preparation of a National Programme for the Exploration of Critical Raw Materials (NPSK). The programme, which is expected to be adopted in early 2026, will set out priorities for national geological exploration and potential exploitation directions.

The IOC also points to the importance of recovering raw materials from waste - both from heaps and dumps of mining waste and from waste electrical and electronic equipment and batteries. This waste can become a valuable source of metals, supporting the construction of a closed-loop economy.

Increasing domestic exploration capacity, developing recycling and international raw material partnerships are collectively expected to strengthen Poland's economic security. In an era of increasing competition for access to critical metals and pressure for a green transition, the skilful combination of exploitation, recovery and reuse of materials can become one of the pillars of the country's future raw material independence.

Sources:

1. Poland facing a critical raw materials deficit. The government is working on a document, https://businessinsider.com.pl/gospodarka/ministerstwo-klimatu-prace-nad-lista-deficytowych-surowcow/lsk02w4
2. Odpowiedź na interpelację w sprawie monitorowania gospodarki metali rzadkich, znak: K10INT3248, https://sejm.gov.pl/INT10.nsf/klucz/ATTD6RHXD/%24FILE/i03248-o1.pdf
3. Raw material updates - methodology for determining the most important raw materials for the Polish economy with new raw material lists, https://www.pgi.gov.pl/en/component/chronoconnectivity5/?cont=lists&ccname=projekty&act=view&gcb=1890