106 Strategic Projects. Which ones will actually buy?

On 9 October 2026 the European Commission named 46 more Strategic Projects under the Critical Raw Materials Act. With the 47 projects inside the EU and the 13 outside it that were selected in 2025, the list now holds 106.

Every equipment and technology supplier I speak to has that list. Many treat it as a pipeline: 106 projects, 106 future customers.

It is not a pipeline. It is a label. Some of these projects will buy equipment in the next 18 months. Many will not buy for years. Some never will. The work is telling them apart.

What the label gives a project

Strategic status gives a project three things.

1. Faster permits. Permitting should take no more than 27 months for an extraction project, and no more than 15 months for processing and recycling.
2. One contact point. Each EU country has a single point of contact that tells the project which permits apply and coordinates the authorities.
3. Help finding money. The project gets support in identifying financing: the European Investment Bank, other public lenders, national and EU programmes, and private investors.

Notice what is missing. The label does not come with money. It comes with help finding money, and help finding finance is not finance.

The number that matters

The Commission also reported progress on the first list. Of the projects selected in 2025, 25 have completed their environmental impact assessment, and 17 have obtained a construction permit.

Read that slowly. Around 19 months after selection, most of the first list does not yet have permission to build. A project without a construction permit is rarely placing large equipment orders.

That does not mean the list is weak. Mines and plants take years. It means a supplier who treats every name as a near-term customer will spend most of the sales effort in the wrong place.

The second list is different

The new list leans towards plants rather than mines. Of the 46 projects, 19 are recycling, 11 are processing, 8 are integrated and 8 are extraction.

My reading is that this matters for timing. Processing and recycling projects have the shorter permit limit, 15 months against 27. For suppliers of process equipment, the second list is likely to turn into orders faster than the first. That is an inference, not a promise. Each project still has to clear its own gates.

How to read a Strategic Project

A project moves through a sequence. Each step is public, if you know where to look, and each one tells you how close the orders are.

1. Status. The project is on the list. This is the signal, not the opportunity.
2. Permit. Environmental assessment done, construction permit granted.
3. Money. A grant agreement signed, not just a grant selected. Debt or equity committed.
4. Investment decision. The board commits to build.
5. Engineering. A feasibility study or front-end design completed, an engineering contractor named.
6. Orders. Long-lead equipment first, then the rest.

The specification is written somewhere between steps 3 and 5. That is where a supplier needs to be. Arrive after step 5 and you are usually quoting against a design someone else wrote.

An example

We tested one project from the October list in a sample brief, using only public sources. It is a rare earth processing project in Northern Europe. It has strategic status and has been selected for an EU grant of over EUR 100m. The grant agreement is not yet signed. The investment decision has not been taken. No engineering contractor has been named.

The verdict for a supplier of separation equipment was Wait, but position now. The specification is probably still open, which makes this the right moment to get onto the design basis, and the wrong moment to expect an order. For magnet line equipment, the same project was already late: buying had started months earlier.

One project, two very different answers, depending on what you sell. That is why the list alone cannot tell you where to go.

What I would do with the list

1. Sort by stage, not by headline. Put every project you care about against the six steps above. Most will sit at step 1 or 2.
2. Drop the ones where equipment is already bought, and say so. A clear no frees your team for the projects that can still say yes.
3. Watch for the moves between steps: a grant agreement signed, an investment decision, an engineering contractor named. Each one changes the answer.
4. Be in the room before the engineering contractor is. That is when the specification is still open.

The list is a good place to start. It is not a reason to start everywhere.

Facts as at 30 October 2026. Sources: European Commission, Strategic Projects under the Critical Raw Materials Act, 9 October 2026; Your Europe, Permitting for critical raw materials projects, and Brussels Times, October 2026.