The Ungauged Chain — Statecraft

§01 · Occasion and positioning

In the public space of late 2025 and early 2026 two administrative discourses unfold at once, each in its own rhythm and with its own vocabulary, without seeking each other out. One stands in full daylight. Climate debates in the lower house, climate letters from the cabinet, climate passages in successive coalition agreements, climate columns in NRC, Trouw and de Volkskrant, climate protest in the street, climate proceedings before the administrative court and the international courts. Here there is urgency, here there is identity, here is the moral stake of what a society says it wishes to be. The other stands in official corridors. The implementing acts of the Critical Raw Materials Act, the designation of Strategic Projects in two tranches in 2025, the quiet trade notices around Chinese export restrictions on gallium, germanium, graphite, antimony and rare earths between July 2023 and October 2025, the Goods Availability Act of 1952, the Wet beschikbaarheid goederen, activated on 30 September 2025 for the first time since the Cold War for a chip manufacturer in Nijmegen. Here there is execution, here there is material, here is what a society actually does. The two discourses are unequal in staffing, in budget, in visibility and in pace. They are also valued unequally. Climate is urgent and attractive. Raw materials are dull.

The dull makes the urgent possible. No tonne of CO2 avoided in the European emissions trading system was avoided without recourse to a chain that begins in Bayan Obo, Tenke-Fungurume, the Salar de Atacama, Sulawesi or Bayuquan. No European wind turbine turns without permanent magnets of which more than ninety per cent are refined in China.¹ No electric car rolls off a European line without lithium, cobalt and nickel processed into battery-grade material by Chinese, Indonesian or Russian companies. The Climate Act hangs on a chain it does not know, does not manage and does not wish to see. The reason that chain stays invisible is the proxy. CO2 is administratively manageable because it is countable, allocable and tradable. The chain from which it arises has no comparable measuring structure, and it is precisely that absence that has made it disappear from the primary policy discourse.

The dull is also something other than an auxiliary variable for the urgent. It is, apart from its climate function, the actual working of a civilisation on a finite planet. Whoever mines lithium asks water of a drying salt lake. Whoever refines rare earths releases thorium and uranium. Whoever imports cobalt buys into a conflict zone in eastern Congo. Whoever has nickel processed in laterite smelters on Sulawesi accepts deforestation and coastal discharges on a scale to which the European permitting authority would not put its signature. Good stewardship of raw materials is, in a tradition that runs from Brundtland in 1987² through the Rio Declaration to Rockström’s research on planetary boundaries of 2009³ and its recalibration of 2023⁴, an autonomous norm. It is not climate policy in another language. It is what climate policy once also was, before it congealed around CO2 allocation as its sole unit of measure and the broader planetary concern was cut from its register. A European Union that does not know its raw-materials footprint practises no stewardship. It practises the administration of one variable and calls that climate policy.

The thesis of this paper is therefore double. The European architecture suffers from two dissociations at once, an instrumental and an intrinsic one. The instrumental dissociation is that climate ambition does not know its material basis and therefore builds in its own unattainability. The intrinsic dissociation is that the stewardship of raw materials itself, apart from its instrumental contribution to climate targets, no longer figures as an autonomous norm in the policy register. The two dissociations reinforce each other. The first makes raw-materials policy dependent on climate policy and therefore politically adrift on climate waves. When climate urgency falls in the debate, raw-materials policy falls with it. The second means that a raw-materials policy that could stand on its own has no language and no arena in which to conduct itself. The tradition of stewardship left the European institutions at the moment the instrument register closed itself around CO2 arithmetic.

The Critical Raw Materials Act of 11 April 2024 embodies both dissociations.⁵ It codifies the dependency in benchmarks that adjust the existing ratio at the margin: ten per cent domestic mining, forty per cent processing, twenty-five per cent recycling, no more than sixty-five per cent from a single third country per strategic raw material by 2030. And it positions raw-materials policy explicitly as supply to the green and digital transition, not as autonomous planetary stewardship. The word continuity of strategic autonomy conceals that the actual balance of power is left untouched, and that a planetary ethics of raw materials still legible in Brundtland is, in 2024, no longer invoked institutionally. The European Parliament debated the text in an industrial-strategic register. Environmental stewardship appeared in no amendment.

This paper is Nº 06 in Series IV. It demonstrates the meta-mechanism of the series, formulated in Nº 01 as network corruption in Slingerland’s sense, on a file that brings into view, alongside the regulatory axis (EMA, EFSA, ECHA) and the spending axis (EU funds, the audit cascade), the industrial-strategic axis. Here the mechanism is doubly carried. Slingerland’s network mechanics explain the administrative architecture in which the CRMA comes about. The proxy-substitution mechanism explains why that architecture could congeal around CO2 at all rather than around a broader planetary register. The two mechanisms work together: the network supplies the proxy, the proxy renders the network invisible. The paper connects directly to Series III Nº 04, The Optimisation Asymmetry, whose logic returns here at supranational scale, and to Series III Nº 03, Word Continuity, of which ‘strategic autonomy’ becomes the European specimen. It builds on the Statecraft paper Three Files, One Sovereignty Problem of February 2026, which named the three colours of dependency for data infrastructure, and extends that analysis to material infrastructure, with a longer time horizon and a greater deficit of recovery capacity. An English parallel version appears under the title The Ungauged Chain: Raw Materials, the CO2 Proxy and the Absence of Industrial Policy, addressed to the international reader in Brussels, Berlin, London, Washington and Tokyo, where the pattern repeats in its own institutional translation.

The following seven sections develop the thesis. §02 describes the proxy mechanism conceptually and shows how CO2 could become the sole unit of measure in the European architecture. §03 documents the empirics of the congealed chain per strategic raw material, with Chinese market dominance as the consequence of European choices in the period 1990-2015. §04 reads the CRMA as a congealed-outcome instrument. §05 turns attention to defence and the invisible raw-materials footprint of the NATO five-per-cent decision in The Hague. §06 documents the Dutch dispersal of the file across six ministries without integrated ownership. §07 reads the network that keeps the yellow-quadrant avoidance in place. §08 delivers the action perspective in four registers and points forward to the synthesis paper of Series IV Nº 07.

§02 · The proxy and what it conceals

Europe’s climate architecture has been built over twenty-five years around a single variable. Directive 2003/87/EC introduced the emissions trading system on 13 October 2003 as the first large-scale cap-and-trade regime for greenhouse gases, with CO2 equivalents as the sole unit of measure.⁶ The Climate Act of 30 June 2021 fixed the targets at fifty-five per cent reduction by 2030 relative to 1990 and climate neutrality by 2050.⁷ The Fit for 55 package of April 2023 revised the ETS Directive, added a second emissions trading system for buildings and road transport from 2027, and introduced the Carbon Border Adjustment Mechanism, which has been in its definitive phase since 1 January 2026.⁸ The CBAM covers cement, iron, steel, aluminium, fertiliser, electricity and hydrogen, and uses CO2 equivalents as the basis for the levy. It sets no material criteria for the origin of minerals embodied in those products.

The architectural advantage of CO2 as an administrative variable is clear and cannot be ignored. A tonne of CO2 is countable, at an installation, a sector, a member state and ultimately a transaction. A tonne of CO2 is allocable, through the allocation rules that the Effort Sharing Regulation distributes between member states. A tonne of CO2 is tradable, because the emissions cap gives it scarcity and the market gives it a price. No other variable combines these three properties. The Climate Act, the ETS, the ETS2 and the CBAM rest on that combination. What the three properties do not deliver is a measurement of the material chain that produces the countable reduction. A wind turbine that avoids ten thousand tonnes of CO2 in an ETS year does so only because somewhere in a neodymium magnet sit a few kilograms of dysprosium. That dysprosium comes, for more than ninety per cent, from Chinese refining. That share appears in no ETS register and in no Climate Act target. It appears in IEA reports that function in the policy discourse as background reporting, not as a binding ledger.⁹

The mechanism at work here has been named in administrative science since 1975. Charles Goodhart formulated, for the Reserve Bank of Australia, the rule that any observed statistical regularity collapses the moment it is placed under pressure for control purposes.¹⁰ Marilyn Strathern reformulated the same rule in 1997 in its familiar form: once a measure becomes a target, it ceases to be a good measure.¹¹ In Series III Nº 04, The Optimisation Asymmetry, this pattern was documented at municipal and sectoral level, with the BENG norm for housing, the chimney measurement at Vattenfall Diemen and the Drenthe zero-on-the-meter dwellings as material examples in which one measurable variable had cut everything else out of the system. The same pattern works at supranational scale. The European ETS price is the measure, and because it is allocable and tradable it has drawn the whole of administrative attention to itself. What does not fall under the measure disappears from the arena.

What disappears under the measure is, in this case, the chain from which the measure itself must be realised. The World Bank calculated in 2020 that a pathway below two degrees of warming to 2050 requires more than three billion tonnes of minerals and metals for the deployment of wind, solar, geothermal and storage.¹² The IEA calculated in 2024 that in its Net Zero Emissions scenario global demand for lithium increases between 2023 and 2040 by a factor of nine, for graphite by a factor of four, for nickel, cobalt and rare earths by a factor of two, and for copper by fifty per cent.¹³ The Outlook 2025 added that in the Stated Policies Scenario shortfalls of thirty per cent for copper and forty per cent for lithium are already projected for 2035.¹⁴ None of these figures appears in the binding parts of the EU climate package. They appear in scenario documents that offer the policy a frame without changing its instruments.

The intrinsic layer is cut away by that same architecture. The Brundtland Report of 1987 spoke of development that meets the needs of the present without limiting those of future generations, and treated raw-materials stewardship as an autonomous norm alongside emissions reduction.¹⁵ The nine planetary boundaries that Rockström and colleagues published in Nature in 2009, six of which had been crossed by 2023, describe the earth as a system with several correlating critical variables, not one.¹⁶ Climate is one of those nine boundaries, alongside biosphere integrity, biogeochemical cycles, land use, fresh water, ocean acidification, atmospheric aerosols, novel entities and the ozone layer. The institutional translation of that into policy does not exist. The administrative register has not taken the mineral and raw-material flows from the planetary-boundaries analysis on board as an autonomous policy variable. What remains of Brundtland and Rockström reads like a literature review in the contextual introductory chapter of an impact assessment.

The combination of instrumental workability and intrinsic absence is what makes proxy-substitution a dissociative mechanism. CO2 is not false as a unit of measure. It is in fact the most workable proxy the European architecture currently has available. The problem lies in its singularity. CO2 works as the sole measure only on the assumption that everything it does not measure is either unimportant or measured elsewhere. Neither assumption holds. The material chain is constitutive of the objective, and it is not measured elsewhere in binding instruments. The proxy conceals what it hangs on. That concealment is no intention of the architects. It is a property of the architecture itself, on which §03 builds by documenting the chain in its actual materiality.

§03 · The congealed chain

Chinese market power in the chain of critical raw materials has been routinely named in European discourse since 2022 as a given fact. That is misleading in two respects. First, it is no given fact but the residue of twenty-five years of European, American and Japanese choices. Second, its magnitude is usually understated in the discourse. Whoever reads the dependency at raw-material level sees not a single shortfall of resilience but a chain almost every link of which lies outside Europe, and whose refining in almost all cases takes place in China.

Rare earths are the symbolic material. China controls roughly seventy per cent of global mine production and more than ninety per cent of refining capacity for the group as a whole.¹⁷ For the heavy rare earths, including dysprosium and terbium, which are indispensable in permanent magnets for wind turbines, electric cars and military applications, China controlled until 2023 ninety-nine per cent of global processing.¹⁸ The European Union depends on China for one hundred per cent of its heavy rare earths and eighty-five per cent of its light ones.¹⁹ The NdFeB magnets themselves, the compressed end product that sits in every wind turbine and every electric motor, are produced for more than ninety per cent in China.

For graphite the picture is comparable. China supplies more than three-quarters of global mine production and refines more than ninety per cent of the material to battery grade.²⁰ For synthetic graphite, used in most lithium-ion batteries, the Chinese share is above ninety-five per cent. For lithium and cobalt China processes roughly sixty per cent of global output, even though the mining itself lies predominantly in Australia, Chile, Argentina and the Democratic Republic of Congo.²¹ For gallium and germanium, indispensable in radar, electronic warfare, infrared optics and GaN semiconductors, the Chinese share stands at ninety-four and eighty-three per cent of global production respectively.²² For antimony, processed into armour-piercing ammunition, infrared sensors and flame retardants, China supplies almost half of global mining and the great bulk of refining. For nickel the structure is different and therefore more treacherous. Indonesia has taken the lead in refining since 2020, with thirty-seven per cent in 2023, but three-quarters of Indonesian refining capacity is in Chinese hands.²³

These figures appear in separate USGS and IEA reports, in CSIS analyses and in the annual infographics of the Council of the European Union. They do not appear in a European instrument that binds the dependency to an intervention. The CRMA names the lists and sets benchmarks, but it does not tie the figures to a binding reduction pathway as the ETS does for CO2. The dependency has no ceiling, no price and no market. It has only a list.

The present state is no fate; it is congealed residue. Until the late 1990s Mountain Pass in California was the most important rare-earth mine in the world, operated from 1952 to 2002 under Molybdenum Corporation, later Unocal and Chevron.²⁴ The closure in 2002 had environmental reasons, in particular leaks of radioactive wastewater, plus a Chinese price war that made American production commercially unviable. The reopening in 2012 under Molycorp ended in bankruptcy in 2015, again after a Chinese price operation. MP Materials took over Mountain Pass in 2017 and resumed production in 2018, but the same structural factors still apply. In Europe the residue is sharper still. Closures of copper, zinc and aluminium refineries between 1990 and 2015, combined with the NIMBY blockade of new mining sites (eighty-five per cent of European critical-mineral occurrences lie within five kilometres of a Natura 2000 area),²⁵ have detached the Union from an industrial base without any political dispute being conducted about it. The chain moved, and the discourses did not move with it.

The Senkaku incident of September 2010, in which China restricted rare-earth exports to Japan after the detention of a Chinese trawler by the Japanese coastguard, long counted as the key moment of geopolitical supply security in Asia.²⁶ The empirical evidence for a targeted embargo against Japan has proved, in later COMTRADE analyses, less hard than the narrative suggested. What is hard is that Japan after 2010 developed an institutional answer, with JOGMEC as public stockpile manager and strategic investor in mining equity stakes, and that its dependency on China for rare earths fell from ninety per cent in 2010 to sixty per cent in 2023.²⁷ The European Union made no comparable move in the same period. The European Raw Materials Initiative of 2008 produced lists and strategy documents without an operational instrument.

Since July 2023 China has moved from issuer of warnings to active exporter of supply risk. The timeline is legible. On 3 July 2023 MOFCOM announced licensing requirements for the export of gallium and germanium, effective from 1 August.²⁸ On 20 October 2023 followed licensing requirements for synthetic graphite, effective from December. On 21 December 2023 an export ban on technology for NdFeB magnet production. On 15 August 2024 licensing requirements for antimony, effective from 15 September. On 3 December 2024 a de facto export ban to the United States for gallium, germanium, antimony and superhard materials via MOFCOM Notice 2024 No. 46. On 4 April 2025, in response to the Trump tariffs, a licensing requirement for seven rare earths (samarium, gadolinium, terbium, dysprosium, lutetium, scandium, yttrium) via MOFCOM Announcement 2025 No. 18.²⁹ On 9 October 2025 an extension to five further rare earths (holmium, erbium, thulium, europium, ytterbium) plus extraterritorial Foreign Direct Product Rule-like provisions with a 0.1 per cent threshold, published as MOFCOM Notice No. 61.³⁰ On 7 November 2025, after the Xi-Trump accord in Busan, China suspended this extension for one year until 10 November 2026, while the April restrictions remained in force.

These are no incidental restrictions. It is a systematic condensation of an actual market power into a geopolitical instrument. Between July 2023 and October 2025 China announced, in seven waves, export controls that touch European industry in almost every link. The discourse on these controls plays out largely in trade periodicals, in S&P, CSIS and GLOBSEC analyses, and in trade letters to the lower house and the European Council. It does not play out in the primary climate debate. A supply chain restricted in its free transit in October 2025 for twelve rare earths at once directly touches the deliverability of Climate Act targets, and that direct connection is barely visible in the policy conversation.

§04 · The CRMA as a congealed-outcome instrument

The Critical Raw Materials Act is, in its genesis, a correctly functioning piece of Brussels legislation. The Commission published its proposal on 16 March 2023, the political agreement was reached on 13 November 2023, the Council adopted the text on 18 March 2024, and on 11 April 2024 it was signed. Publication in the Official Journal followed on 3 May 2024, and the Regulation entered into force on 23 May 2024.³¹ The CRMA works with two lists. Annex I names seventeen strategic raw materials of vital importance to the transition or to defence. Annex II names thirty-four critical raw materials, including all seventeen strategic ones plus seventeen others such as antimony, barite, beryllium, phosphate rock, vanadium and scandium.

The architectural core of the CRMA sits in Article 5, which fixes the benchmarks for 2030. Ten per cent of annual EU consumption of strategic raw materials must be covered by domestic mining. Forty per cent by domestic processing. Twenty-five per cent by recycling. No more than sixty-five per cent from a single third country per link per strategic raw material. For anyone holding the figures of §03 in mind, the import is immediately legible. Ten per cent domestic mining is no industrial policy; it is a floor that writes ninety per cent dependency into law. Forty per cent processing is more ambitious, but it is filled in through Strategic Project status with accelerated permits (twenty-seven months for mining, fifteen months for processing and recycling) and accelerated access to finance, without an attendant redistribution of public funding or ownership.³² The sixty-five per cent threshold per third country is drafted in a way that allows dependency on China to remain formally below the threshold in European averages, while in specific links (heavy rare earths one hundred per cent, NdFeB magnets more than ninety per cent) it rises far above that threshold.

The Strategic Projects procedure (Articles 6 and 7) came into operation in two tranches in 2025. The first application round closed on 22 August 2024 with one hundred and seventy applications, from which the Commission designated on 25 March 2025 forty-seven projects in thirteen EU member states with a total expected investment of twenty-two and a half billion euros.³³ The material centre of gravity lay on lithium (twenty-two projects), nickel (twelve), graphite (eleven), cobalt (ten), manganese (seven), tungsten (three) and magnesium (one). Bismuth, silicon metal and titanium metal did not feature in the first tranche. On 4 June 2025 followed thirteen projects outside the Union, in Canada, Greenland, the United Kingdom, Norway, Kazakhstan, Serbia, Ukraine, Brazil, Zambia, Madagascar, Malawi, South Africa and New Caledonia, with an expected investment of five and a half billion euros.³⁴ That brings the total to sixty designated projects to date. The second application round closed on 15 January 2026 with one hundred and sixty-one applications, ninety-five inside the Union and sixty-six outside it, with selection expected for the second or third quarter of 2026.³⁵

In these figures sits a considerable achievement. The Union has, in eighteen months, made operational an instrument that produces lists, designates projects and shortens permitting times. At the same time the figures contain the observation this paper wishes to bring into focus. Thirty-five per cent of the designated projects concern lithium and nickel, the two raw materials whose mining lies to a significant degree outside China and which present attractive investment opportunities for European capital markets and geopolitical partners. Heavy rare earths, dependency on which is one hundred per cent, are covered in no project from the first tranche. Permanent-magnet production, dependency on which is more than ninety per cent, is marginally represented in the designated projects. The projects on which the European economy is most dependent are the projects that are hardest to make commercially viable, and they come last in the Strategic Projects procedure. That is no criticism of the Commission. It is a diagnosis of an instrument that works in a green-and-blue register (facilitate, monitor, permit) and structurally leaves outside its reach the yellow quadrant of ownership redistribution, public financing or geopolitically compelled capacity building.

The CRMA’s sustainability criteria reinforce this diagnosis. Article 9 and Annex III contain references to social, environmental and governance safeguards, with an explicit link to the Taxonomy Regulation. The European Court of Auditors observed in its Special Report 04/2026 that the Commission had committed in 2021 to developing sustainable-finance criteria for mining, extraction and processing through delegated Taxonomy acts by the end of 2021, and that four years later those acts still do not exist.³⁶ The yellow-quadrant test reads out precisely in this fact. The binding part of the sustainability structure the CRMA was to hang on its projects is missing, and it is missing in a way for which no one is held responsible.

The RESourceEU Action Plan, adopted on 3 December 2025, adds three billion euros of EU financing to this architecture, to be mobilised within twelve months.³⁷ Three billion euros is, given the twenty-two and a half billion of the first tranche and the five and a half of the second, no small sum in absolute terms. On the scale of the United States’ Inflation Reduction Act investments (estimated at sixty-seven billion dollars for critical minerals between 2022 and 2025) or the Future Made in Australia Act (twenty-two point seven billion Australian dollars) the sum is modest. The issue lies not in the sum itself but in what is done with it. Facilitating and accelerating remain the dominant stance. The yellow intervention is left undone.

The CRMA is thereby a textbook example of what Series III Nº 02 named the congealed outcome as a manifested preference. The current balance of power is treated as a fixed starting point, and the administrative architecture formulates benchmarks that adjust it at the margin under a word (strategic autonomy) that suggests the opposite of what the instrument actually does. The Regulation is no failure. It is a fine piece of work within a register whose boundaries it cannot transcend. Those boundaries themselves are the subject of §07.

§05 · The invisible raw-materials footprint of defence

On 25 June 2025 the allies signed in The Hague a declaration committing them to a spending norm of five per cent of GDP by 2035, divided into at least three and a half per cent for core tasks and up to one and a half per cent for defence and security-related expenditure.³⁸ The declaration was described by Secretary-General Rutte as a transformative leap for collective defence. Spain obtained an exception, with Prime Minister Sánchez setting a ceiling of two point one per cent. The Netherlands, still under a caretaker cabinet at the time of the decision, committed to three and a half per cent core tasks plus one and a half per cent related expenditure, a doubling relative to the 2014 norm agreed in Wales. An interim review is foreseen in 2029. The collective spending pathway between 2025 and 2035 reaches, in all plausible scenarios, into the hundreds of billions, with a doubling of European defence-industrial demand as a consequence.

This doubling touches raw materials in a way that does not figure in the The Hague declaration, barely figures in the Dutch Defence White Paper 2024, and is named in the CRMA discourse only as an incidental occasion. Permanent magnets, mainly NdFeB with dysprosium and terbium and in some applications SmCo, are crucial in missile guidance, in the actuators of the F-35, in radar systems, in the electric propulsion of naval vessels and in unmanned aerial vehicles.³⁹ GaN semiconductors for radar, electronic warfare and satellite technology rest on a gallium substrate. Infrared optics for sensors and target acquisition work with germanium lenses. Ammunition and armour-piercing projectiles contain antimony. Batteries for military applications and for the electrification of the vehicle fleet require lithium, cobalt, nickel and graphite. The CSIS analysis of April 2025 named rare earths as crucial for, among others, F-35 fighter aircraft, Virginia- and Columbia-class submarines, Tomahawk missiles, radar systems, Predator drones and the JDAM bomb series.⁴⁰

The fact that NATO published in December 2024 its own list of defence-critical raw materials, almost identical to the CRMA list of strategic raw materials, with the only difference worth noting being that NATO placed beryllium in the strategic group while the CRMA places it only in the critical list, is not without significance. It shows that the two files, climate and defence, burden the same chain at raw-material level with a now doubled claim. The same dysprosium that sits in a wind-turbine magnet sits in the steering mechanism of a missile. The same gallium that sits in a semiconductor for solar inverters sits in a GaN radar chip. The political conversation about climate and the political conversation about defence are conducted in The Hague, Brussels and Berlin by different ministers, in different Councils, with different delegations. The material conversation is the same conversation.

The United States has recognised this connection since 24 February 2021, when President Biden ordered, through Executive Order 14017, a hundred-day review of American critical-raw-material supply chains. The modernised instruments under Title III of the Defense Production Act were deployed from 2022 to support Talon Metals, MP Materials and Lynas USA. In early 2025 the White House announced Project Vault, a strategic reserve of twelve billion dollars for rare earths, lithium and nickel. Japan has managed, through JOGMEC since 2010, an active reserve architecture combined with equity stakes in foreign mining, among others through a stake in Lynas. South Korea has had, through KORES since the 1970s, a national stockpile institution renewed in 2023 into a thirty-three-mineral strategy. The European Union has, despite World Bank and IEA reports documenting its dependency since 2020 and fifteen years after the Senkaku precedent, no comparable public reserve institution. The Joint Purchasing Mechanism of CRMA Article 25 has indeed been set up, but as of May 2026 it has realised no significant contract volume.

For the Netherlands one episode in this connection is so precisely legible that it must be marked here. On 30 September 2025 the Minister of Economic Affairs, Karremans, activated for the first time since 1952 the Goods Availability Act, the Wet beschikbaarheid goederen, against the chip manufacturer Nexperia in Nijmegen, owned by the Chinese Wingtech group.⁴¹ The justification was recent and acute signals of serious governance failings. The order froze assets, intellectual property, business operations and personnel for one year. The Enterprise Chamber in Amsterdam, in parallel, removed the Chinese CEO Zhang Xuezheng. On 14 October 2025 China responded with an export ban on Nexperia’s Chinese plant. On 19 November 2025 the minister partly suspended the order to restore dialogue with China. The Eurofins-Nexperia-DigiD paper of February 2026 analysed this episode as a demonstration that the Dutch state, under sufficient pressure, is indeed willing to take away foreign control, with instruments from the Cold War toolbox, and that this willingness does not arise from an autonomous Dutch risk analysis but from a combination of American export restrictions and reactive policy.⁴²

The Nexperia episode opens and closes the defence-raw-materials section of this paper. It opens the section because it shows that the Netherlands does, in extremis, have an instrument to reclaim control over critical industrial capacity. It closes the section because it shows that this instrument is deployed only for one chip manufacturer at one location, and not for the broader raw-materials file for which it would be at least as relevant. The Goods Availability Act of 1952 dates from a time when the Dutch state still regarded strategic stockpiling and industrial mobilisation as a regular administrative function. Its deployment in 2025 was reactive and isolated. A Strategic Raw Materials Act that modernises the Goods Availability Act for the whole raw-materials domain, with anticipatory powers, a reserve architecture and a raw-materials impact test, is at present not in preparation.

§06 · The Dutch dispersal

Dutch policy room on raw materials was shaped on 9 December 2022 by the National Raw Materials Strategy of Minister Adriaansens, Minister Schreinemacher and State Secretary Heijnen.⁴³ The letter formulated the aim of increasing security of supply in the medium term, and set out five action perspectives: circularity and innovation, sustainable European mining and refining, diversification, the sustainability of international chains, and the strengthening of knowledge and information provision. The letter was administratively sound and politically almost invisible. On 22 December 2023 followed the first progress report. On 9 September 2024 followed a parliamentary letter on findings from TNO research, signed by Minister Beljaarts under the Schoof cabinet. On 16 December 2024 TNO published the report Processing of critical raw materials in the Netherlands: Towards a plan of approach. On 12 February 2025 the National Materials Observatory was opened, with the task of mapping where the Netherlands is too dependent.

The structure is recognisable in this enumeration as what the Statecraft corpus names performative maturity. There are letters, progress reports, TNO reports and an observatory. What is missing from the structure is a minister with explicit ultimate responsibility for the chain as a whole, a legal toolkit that reaches further than recording and monitoring, and a budget proportionate to the dependency that the ministry’s own reports document. The Dutch raw-materials agenda is spread across six ministries. Economic Affairs and Climate carries the industrial-policy framework and CRMA implementation. Foreign Affairs carries raw-materials diplomacy and the strategic partnerships. Defence knows the NATO targets and the defence requirements, but does not tie them to a raw-materials policy of its own. Infrastructure and Water Management permits mining and refining under the Environment and Planning Act. Agriculture, Nature and Food Quality manages the PFAS restriction that touches battery and magnet chains. Finance sits on the Invest-NL and National Growth Fund instruments. None of the six carries the chain in its entirety.

Under the Jetten cabinet, sworn in on 23 February 2026, the division has been lightly redrawn without the fragmentation being resolved.⁴⁴ Stientje van Veldhoven became Minister for Climate and Green Growth, a minister without portfolio under Economic Affairs and Climate. Jo-Annes de Bat became State Secretary for energy, nuclear energy, mining via the State Supervision of Mines and Groningen gas extraction. Heleen Herbert became Minister of Economic Affairs and carries the primary responsibility for industrial policy and raw materials. Willemijn Aerdts remained State Secretary for the Digital Economy and Sovereignty, with a portfolio covering digital infrastructure, AI standardisation and European digitalisation policy, but no explicit raw-materials component. The coalition (D66, VVD, CDA) included climate passages in its coalition agreement and no comparable passage on the material chain. Interdepartmental coordination runs through working groups without formal powers and without an ultimately responsible minister.

As of May 2026 the Netherlands has no designated Strategic Projects under the Critical Raw Materials Act. The first tranche of 25 March 2025 (forty-seven EU projects) contained no Dutch projects. The second tranche of 4 June 2025 (thirteen projects outside the EU) likewise. The CRMA’s second application round closed on 15 January 2026 with one hundred and sixty-one applications, and at the time of writing it is not known how many Dutch applications are among them. The Minister for Climate and Green Growth did designate, on 26 March 2026, two Dutch Strategic Projects, but those fall under the Net-Zero Industry Act (Regulation (EU) 2024/1735) and concern Sif (offshore wind foundations at the Maasvlakte) and Power2X (eSAF in Rotterdam).⁴⁵ The NZIA and the CRMA work on different lists and different articles. The fact that the announcement was presented in the Dutch press releases as a CRMA success illustrates precisely the mechanism this paper describes. The word continuity of ‘strategic projects’ conceals that the Netherlands has won no position in the mineral links of the chain within the CRMA architecture.

The advisory sector has tried to close this gap without the political level taking up the signal. HCSS published, between 2020 and 2025, a series of reports on critical raw materials, including Securing Critical Materials for Critical Sectors (December 2020), Cobalt Mining in the EU (October 2022), the regional studies for South Holland (July 2024) and North Holland/Flevoland (2025), the report Securing Europe’s Clean Tech Future commissioned by Invest-NL, and Great-power competition and societal stability in the Netherlands on Russian gas, Chinese raw materials and Taiwanese chips. The Advisory Council on International Affairs included no specific raw-materials track in its work programme 2026-2028 of 16 January 2026.⁴⁶ The Netherlands Court of Audit has published no specific study of the National Raw Materials Strategy. The Scientific Council for Government Policy has delivered no substantial report on this specific file in the past five years. On 27 March 2024 Allard Castelein was appointed Special Representative for the Raw Materials Strategy, a function without an executive mandate.⁴⁷ Institutional attention is therefore present, but it is fragmented and without the power to see things through.

The Dutch position in this file is asymmetrical in a way that does not translate into policy by itself. Through ASML the Netherlands supplies the lithography chain on which global chip production rests, which in turn makes the transition possible elsewhere, while it possesses no relevant refining or magnet capacity of its own. Through Tata Steel the Netherlands has a climate agreement that makes basic steel production depend on a hydrogen chain not yet built and resting on raw materials not under control. Through the NATO spending increase the Netherlands has a defence demand that touches in every link the same Chinese market dominance. Through the Nexperia episode the Netherlands has activated the instrument that can, in extremis, lift foreign control over a Chinese owner, and at the same time has no architecture to embed that instrument in a broader doctrine. All of this is handled in six ministries simultaneously in sub-questions, and in none of them in its coherence. At state level there repeats what Series III Nº 06 named form-laundering: institutional attention without the power or the structure that would make it effective.

§07 · The network and the yellow-quadrant avoidance

What was diagnosed in §02 as proxy-substitution and in §04 as a congealed-outcome instrument is carried, at the Brussels level, by a network that fills in exactly the definition of network corruption, in Willeke Slingerland’s sense, from Series IV Nº 01. It is no clique, no cartel, no conspiracy. It is an ecosystem in which formal integrity is maintained per actor, while institutional-relational ties outside formal frameworks become steering, and in which the cumulative outcome works, unintentionally, in the interest of the network itself.⁴⁸

The European Raw Materials Alliance was launched on 29 September 2020 by Vice-President Šefčovič and Commissioner Breton, with the motto that Europe had to pool its forces around raw materials as it had earlier done around batteries.⁴⁹ Its management was placed with EIT RawMaterials, based in Berlin and operating as part of the European Institute of Innovation and Technology. ERMA now consists of more than one hundred and fifty partners and is active in two workstreams: Rare Earth Magnets and Motors, and Materials for Energy Storage and Conversion. On 30 September 2021 ERMA published its Action Plan Rare Earths. The document is recognisable in tone and in conclusions. It recommends far-reaching investments, facilitation measures, experiments with joint purchasing and strategic alliances with third countries. It recommends no yellow interventions. No proposal for public ownership redistribution in the chain, no blocking mechanism against Chinese acquisitions, no compulsory stockpiling at defence level, no active reopening of European mining sites against NIMBY resistance.

The trade associations that worked in Brussels on the making of the CRMA are mainly Eurometaux, Euromines, Eurofer, ACEA and the German VDA. Their presence in Commission expert groups, in consultations of DG GROW and DG CLIMA, and in technical sub-committees of the European Critical Raw Materials Board can be looked up in the EU Transparency Register but is only partly transparent at participant level. Corporate Europe Observatory and the EU Raw Materials Coalition pointed repeatedly, in 2024 and 2025, to the asymmetry between industry representatives and civil-society representatives in the relevant consultation procedures. The EURMC stated, of the first tranche of Strategic Projects of 4 June 2025, that the projects lacked adequate safeguards, transparency and local involvement, with direct risks to human rights, indigenous rights and environmental protection.⁵⁰ The ECA Special Report 04/2026 pointed in addition to the absence of the Taxonomy link that the Commission had imposed on itself four years earlier.⁵¹

This is no scandal and no integrity incident. It is an institutional configuration in which each separate act can be legitimised, and the cumulative outcome does not meet a public-interest test. Eurometaux may lobby for its members. EIT RawMaterials may give priority to its partners. The Commission may seek the politically feasible in its proposals. The Council may bring the text to an agreement. The Parliament may conduct amendments in an industrial-strategic register. Each of those acts is correct. Their sum is an instrument that codifies the dependency and avoids the yellow intervention. With that the Slingerland frame from Series IV Nº 01 lands in its purest form. No broken process, all process. No failing integrity, all integrity. No unintended accumulation of gaps in oversight, but an intended architecture of which the yellow intervention is no part.

The counter-example is legible in other jurisdictions. The Inflation Reduction Act of 16 August 2022 tied the American EV tax credit of seven thousand five hundred dollars to origin requirements for critical minerals from the United States or from countries with a free-trade agreement, with disqualification for sourcing from a Foreign Entity of Concern (China, Russia, North Korea, Iran).⁵² This is a yellow intervention in pure form: a fiscal instrument with geopolitical selectivity that forces the chain to move. The CHIPS and Science Act of 9 August 2022 added fifty-two billion dollars in subsidies and a twenty-five per cent investment credit for semiconductor production. Australia adopted in 2024 the Future Made in Australia Act with twenty-two point seven billion Australian dollars for processing critical minerals, hydrogen and low-carbon iron. Japan built out, through JOGMEC and the Economic Security Promotion Act of 2022, its architecture for stockpiling and investment. South Korea formalised in 2023 its strategy for thirty-three minerals. Saudi Arabia and the United Arab Emirates acquired, in 2023 and 2024, substantial mining stakes through Manara Minerals and Mubadala. In each of these cases the yellow intervention is conducted explicitly: a redistribution of power in the chain through fiscal, ownership or strategic instruments.

The fact that the European Union does not conduct these interventions is not the result of inability or ignorance. The Commission knows the IEA figures, knows the World Bank projections, knows the Chinese export controls in detail and knows the American, Japanese, Australian and Korean instruments. The fact that it is not conducted is the result of an institutional architecture in which the yellow quadrant has lost its entrance. The doctrine of the internal market, the Better Regulation agenda, the unanimity requirement for fiscal files in the Council, the shielded position of member states with respect to their own industrial policy, the absence until recently of a European defence-procurement regime, and the systematic avoidance of ownership discussions within the internal market: these four or five institutional features together seal the yellow quadrant. Strategic autonomy is, within that seal, a form-word, in the sense of Series III Nº 03. It may be uttered precisely because its content has been made institutionally unreachable.

§08 · Action perspective

The action perspective follows the Series IV discipline of four registers. It addresses the question of what the Dutch executing layer can ask of its own remit when it implements CRMA policy, which yellow-quadrant movements lie within Dutch reach, what embedding would be needed to interrupt the reverberation of Brussels network corruption, and which Aiki registers are relevant for officials operating at the Dutch-Brussels interface.

The first register is the question the Dutch executing layer can put to its own remit. At municipal and provincial level, permits for the processing, recycling and reuse of critical raw materials will be a growing file in the coming years. The HCSS reports for South Holland and for North Holland/Flevoland are instruments that help executants make the raw-materials chain legible in their own spatial-economic policy. The provinces, the regional environmental agencies, the Association of Netherlands Municipalities, the Association of Provincial Authorities and the spatial and economic departments of mid-sized municipalities can, on the basis of those reports, include a raw-materials paragraph in their environmental visions and in their business-siting policy. This movement is not itself yellow-quadrant, but it makes the yellow quadrant visible when the time is ripe. Embedding in this layer means that raw-materials legibility does not depend on one director of spatial planning, one economic alderman or one provincial executive, but is anchored in the administrative instruments themselves.

The second register, the yellow-quadrant movements within Dutch reach, calls for an integrated portfolio and an ownership that does not exist in the present cabinet. The paper recommends bringing the raw-materials agenda, in a future cabinet formation, under one coordinating office-holder, with the power to see things through across the six ministries that now handle sub-questions. Concretely this could be a State Secretary for Raw Materials and Strategic Material Autonomy, under Economic Affairs, on the model of the current State Secretary for the Digital Economy and Sovereignty, with an operational service in which chain coordination is lodged, with an explicit mandate over CRMA implementation, over the Goods Availability Act of 1952 for the raw-materials domain, and over the strategic partnerships with third countries where the Netherlands could take a position. This register requires no new regulation in the first phase. It requires that the existing dispersal be converted into integrated ownership.

The second register then calls for two legislative follow-ups. First a Strategic Raw Materials Act that modernises the Goods Availability Act of 1952 for the raw-materials domain, with anticipatory rather than reactive powers, with a doctrine on when and how the instrument is deployed, and with a public reserve architecture on the Japanese and South Korean model. The National Materials Observatory can be built into such an act as a knowledge base, but without an operational mandate it remains an observer. Alongside it, a raw-materials impact test, comparable to the climate test or the Broad Prosperity indicator, that obliges climate, defence and industrial decisions above a threshold to be tied to a transparent raw-materials footprint. Such a test is no blockade. It is an instrument that makes the material conversation before and behind a decision visible. It does for raw materials what the nitrogen test did for deposition, but designed with the mistakes of the nitrogen test in mind: dynamic rather than static, directed at actual dependency rather than at annual averages.

The third register, embedding against the reverberation of Brussels network corruption, calls for institutional arrangements that at first hearing sound administrative but in their working touch the distribution of power. Four interventions come to mind: a compulsory rotation of Dutch representatives in CRMA-relevant Commission expert groups, with disclosure of participation and of industry ties; a test on revolving-door movements between the Permanent Representation, lobby organisations and companies in the raw-materials chain, comparable to what is customary in financial supervision; an active Dutch amendment policy in the Council on the Taxonomy acts that are to realise the CRMA sustainability link and that are, according to the ECA, four years overdue; and a connection of Dutch parliamentary oversight of CRMA implementation through a standing committee that does not follow Economic Affairs alone but monitors chain integration across six ministries.

The fourth register, the Aiki discipline at the Dutch-Brussels interface, calls for something named in the Series IV concept description as personal mastery under pressure. Officials at the Permanent Representation, at the directorates of EZK-Industry, Foreign Affairs-International Economic Relations, Defence-Materiel and Finance-International Affairs, and at the operational posts at Invest-NL, RVO and the National Materials Observatory, operate in a context in which yellow-quadrant avoidance is built into the Brussels architecture. Moving with CRMA implementation is their professional task. Not moving with the yellow-quadrant avoidance built into it is their professional charge. The difference between those two movements is the Aiki discipline of which Series IV Nº 07 speaks further in the synthesis section. It asks of officials that they be at once loyal and critical in the Brussels arena, that they implement what they must implement and at the same time mark what is missing in the implementation. This discipline is present in individual officials. It is not supported by the administrative architecture.

The paper closes on these four registers. It is not complete and it does not pretend that the proposed movements are politically feasible in the short term. It does show that the yellow-quadrant avoidance carrying the present European and Dutch architecture does not remain without consequence. It carries the instrumental dissociation between climate ambition and material basis further. It carries the intrinsic dissociation between mineral stewardship and administrative register further. And it carries the possibility that the European Union will stand, in 2035, with a five-per-cent defence norm and a fifty-five-per-cent climate target against a chain it does not manage. Whoever takes the Nexperia episode seriously reads in its form the possibility of a much larger Nexperia moment, not for one chip manufacturer but for a chain, and not as a reactive emergency measure but as an anticipatory decision. Such a decision costs the yellow quadrant. What it yields is the management of the material basis on which society actually works.

The ungauged chain has no meter and no market. It has people, mines, smelters, refineries, shipping routes, magnet factories and military dependencies. Whoever wishes to handle it administratively must first learn to see it. This paper is an attempt to support that seeing. The choice then to act is not the author’s.

Footnotes

¹ International Energy Agency, Global Critical Minerals Outlook 2025, May 2025. According to this report China controls more than ninety per cent of refining capacity for both graphite and rare earths. See iea.org/reports/global-critical-minerals-outlook-2025.

² World Commission on Environment and Development, Our Common Future, Oxford University Press, 1987, Chapter 2: ‘Towards Sustainable Development’. The report defines sustainable development as development that meets the needs of the present without endangering those of future generations.

³ Johan Rockström et al., ‘A safe operating space for humanity’, Nature 461, 24 September 2009, pp. 472-475. Introduction of nine planetary boundaries. Mineral flows did not appear as an autonomous boundary.

⁴ Katherine Richardson et al., ‘Earth beyond six of nine planetary boundaries’, Science Advances 9, 15 September 2023.

⁵ Regulation (EU) 2024/1252 of the European Parliament and of the Council of 11 April 2024 establishing a framework for ensuring a secure and sustainable supply of critical raw materials (Critical Raw Materials Act). Published in the Official Journal of the EU on 3 May 2024, entered into force on 23 May 2024. See eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202401252.

⁶ Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community.

⁷ Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 (European Climate Law).

⁸ Regulation (EU) 2023/956 of 10 May 2023 (CBAM); Directive (EU) 2023/959 of 10 May 2023 (ETS revision). CBAM in its definitive phase from 1 January 2026.

⁹ International Energy Agency, Global Critical Minerals Outlook 2024, May 2024.

¹⁰ Charles A.E. Goodhart, ‘Problems of Monetary Management: The U.K. Experience’, in Papers in Monetary Economics, Reserve Bank of Australia, 1975.

¹¹ Marilyn Strathern, ”Improving ratings’: audit in the British University system’, European Review 5(3), 1997, pp. 305-321. Strathern’s reformulation holds that a measure ceases to be a good measure the moment it becomes a target.

¹² World Bank, Minerals for Climate Action: The Mineral Intensity of the Clean Energy Transition, May 2020. The report projects more than three billion tonnes of minerals and metals for the deployment of wind, solar, geothermal and storage to 2050. See worldbank.org.

¹³ IEA, Global Critical Minerals Outlook 2024, Net Zero Emissions scenario, projections 2023-2040.

¹⁴ IEA, Global Critical Minerals Outlook 2025, Stated Policies Scenario, projection 2035: thirty per cent shortfall for copper and forty per cent for lithium.

¹⁵ Brundtland Report, cited above.

¹⁶ Rockström 2009 and Richardson 2023, cited above.

¹⁷ IEA, Global Critical Minerals Outlook 2025; USGS, Mineral Commodity Summaries 2025, Rare Earths.

¹⁸ Center for Strategic and International Studies, The Consequences of China’s New Rare Earths Export Restrictions, April 2025. CSIS reports that China accounted, until 2023, for ninety-nine per cent of global refining of heavy rare earths.

¹⁹ Council of the European Union, infographic Critical raw materials, 2025. For heavy rare earths the EU is, according to this table, one hundred per cent dependent on China. See consilium.europa.eu/en/infographics/critical-raw-materials.

²⁰ IEA, Global Critical Minerals Outlook 2025. For both graphite and rare earths China controls more than ninety per cent of refining capacity.

²¹ IEA, Global Critical Minerals Outlook 2025: China processes roughly sixty per cent of global lithium and cobalt.

²² USGS, Mineral Commodity Summaries 2024, Gallium and Germanium. See also GLOBSEC, Critical Materials in the New Geopolitics, December 2024.

²³ IEA, Global Critical Minerals Outlook 2024. Indonesian refining rose from twenty-three per cent in 2020 to thirty-seven per cent in 2023; Chinese control over Indonesian refining capacity at seventy-five per cent according to C4ADS, Refining Power, 2024.

²⁴ History of Mountain Pass: see among others USGS Open-File Report 2025-3038, Global Maps of Critical Mineral Production in 2023, and MP Materials investor disclosures.

²⁵ Ovaskainen et al., Horizon CIRAN project, 2024, cited in Intereconomics 60(5), 2025, ‘Europe’s Critical Raw Materials: Balancing Strategic Needs with Environmental Protection’.

²⁶ For the narrative of the Senkaku embargo see numerous press sources 2010-2012. For empirical nuance: Simon J. Evenett and Johannes Fritz, CEPR/Global Trade Alert, Revisiting the China-Japan Rare Earths dispute of 2010, 2023.

²⁷ Tatsuya Terazawa, ‘How Japan Solved Its Rare Earth Minerals Dependency Issue’, World Economic Forum, 13 October 2023. According to Terazawa, Japanese dependency on Chinese rare earths fell from ninety per cent in 2010 to sixty per cent in 2023.

²⁸ For the full inventory of Chinese export controls 2023-2025 see Global Trade Alert, Chinese export controls on critical raw materials, continuously updated. Z2Data, How China’s Gallium and Germanium Export Ban is Disrupting Supply Chains, for the gallium/germanium tranche.

²⁹ MOFCOM Announcement 2025 No. 18, 4 April 2025. English translation available via the Center for Security and Emerging Technology (CSET), Georgetown.

³⁰ MOFCOM Notice 2025 No. 61, 9 October 2025. For analyses see CSIS, China Imposes Its Most Stringent Critical Minerals Export Restrictions Yet, and Al Jazeera, China tightens export controls on rare-earth metals: Why this matters, 10 October 2025.

³¹ CRMA timeline: proposal 16 March 2023; political agreement 13 November 2023; Council adoption 18 March 2024; signature 11 April 2024; OJ publication 3 May 2024; entry into force 23 May 2024. See also Global Policy Watch, The EU Critical Raw Materials Act enters into force, May 2024.

³² CRMA Article 8 sets permitting times at twenty-seven months for mining and fifteen months for processing and recycling, for recognised Strategic Projects.

³³ European Commission, press release Commission selects 47 Strategic Projects to secure and diversify access to raw materials in the EU, 25 March 2025. See single-market-economy.ec.europa.eu/sectors/raw-materials/areas-specific-interest/critical-raw-materials/strategic-projects-under-crma.

³⁴ European Commission, EU Designates 13 Non-EU Critical Raw Materials Projects as Strategic, 4 June 2025.

³⁵ European Commission, Strategic projects on critical raw materials gain momentum in second selection round, 19 January 2026. One hundred and sixty-one applications, ninety-five EU plus sixty-six non-EU.

³⁶ European Court of Auditors, Special Report 04/2026, Critical raw materials for the energy transition. The Court observes that the Commission committed in 2021 to sustainable-finance criteria for mining, extraction and processing through delegated Taxonomy acts, and that four years later these have not been adopted. See eca.europa.eu.

³⁷ RESourceEU Action Plan, 3 December 2025.

³⁸ NATO, The Hague Summit Declaration, 25 June 2025. The allies commit to five per cent of GDP per year for core tasks and defence and security-related expenditure, by 2035. See nato.int/en/about-us/official-texts-and-resources/official-texts/2025/06/25/the-hague-summit-declaration.

³⁹ For the defence-raw-materials link see Taylor Wessing, China’s Rare Earth Export Controls: Implications for European Defence Companies, June 2025; International Peace Information Service, The EU Critical Raw Materials Act and the defence industry, 2025.

⁴⁰ CSIS, The Consequences of China’s New Rare Earths Export Restrictions, April 2025. According to CSIS, rare earths are crucial for, among others, F-35 fighter aircraft, Virginia- and Columbia-class submarines, Tomahawk missiles, radar systems, Predator drones and the JDAM bomb series.

⁴¹ Government of the Netherlands, press release Minister intervenes at chip manufacturer Nexperia, 13 October 2025. For analysis see Montesquieu Institute, The intervention at Nexperia, and Taylor Wessing, Nexperia international trade wars taking place with Netherlands as the battleground, December 2025.

⁴² Jacob Huibers, Three Files, One Sovereignty Problem: Eurofins, Nexperia, DigiD and the erosion of Dutch control over critical infrastructure, Statecraft, February 2026.

⁴³ Ministry of Economic Affairs and Climate, Parliamentary letter National Raw Materials Strategy, 9 December 2022, Parliamentary Paper 32852-224. See rijksoverheid.nl/documenten/kamerstukken/2022/12/09/nationale-grondstoffenstrategie.

⁴⁴ Government of the Netherlands, Jetten cabinet sworn in, 23 February 2026.

⁴⁵ Ministry for Climate and Green Growth, press release on two Dutch Strategic Projects under the Net-Zero Industry Act (Regulation (EU) 2024/1735), 26 March 2026. Sif Holding (Maasvlakte) and Power2X (Rotterdam). To be distinguished from Strategic Projects under the CRMA, in which the Netherlands has no projects to date.

⁴⁶ Advisory Council on International Affairs, Work Programme 2026-2028, 16 January 2026.

⁴⁷ Government of the Netherlands, Allard Castelein starts as Special Representative for the Raw Materials Strategy, 27 March 2024.

⁴⁸ Willeke Slingerland, Network Corruption: When Social Capital Becomes Corrupted, doctoral thesis, Erasmus University Rotterdam, 2018.

⁴⁹ European Commission, launch of the European Raw Materials Alliance, 29 September 2020. At the launch Šefčovič called for European forces to be pooled, on the model of the earlier EU Battery Alliance. Management placed with EIT RawMaterials. See erma.eu and eitrawmaterials.eu.

⁵⁰ EU Raw Materials Coalition, statement on the announcement of the second tranche of Strategic Projects, 4 June 2025. The coalition pointed to the lack of adequate safeguards, transparency and local involvement, with risks to human rights, the rights of indigenous peoples and environmental protection.

⁵¹ ECA Special Report 04/2026, cited above.

⁵² Inflation Reduction Act of 2022 (Public Law 117-169), passed by the U.S. Congress and signed by President Biden on 16 August 2022. Origin requirements under the Section 30D EV Tax Credit, with disqualification of a Foreign Entity of Concern from 2024.

Colophon

Series IV — The Dissociated Union · De gedissocieerde Unie Statecraft Series IV · Nº 06 The Ungauged Chain · v0.1 editorial draft

Author: Jacob Huibers Publisher: HOUSE OF VIRIDIAN OÜ · Tallinn · Lisbon Contact: jacob@statecraft.nl · statecraft.nl

The Dutch source version appears under the title De ongetelde keten: hoe de CO2-proxy de materiële basis van de transitie buiten het bestuurlijk discours houdt.

Manuscript reference: De Richting van de Beweging: Interim Management in the Public Sector (manuscript in preparation).