The legal frameworks on either side of the Atlantic are starkly different. Washington treats them as strategic assets, with laws like the Defense Production Act allowing the government to fund domestic mining, steer supply chains and prioritize defense needs in emergencies. The U.S. maintains a national reserve through the Defense Logistics Agency — a federal safety net designed for wartime contingencies. Despite that, it continues to need China.
Brussels, by contrast, has taken a softer path: the Critical Raw Materials Act establishes high-level targets and frameworks, but leaves actual implementation to voluntary coordination among member countries — with no central authority backing enforcement. “We don’t have a state stockpile, unlike with gas or oil,” said Kullik. “This kind of preventive, strategic preparedness — I just don’t see it yet.”
Some lawmakers in Berlin say the EU’s current approach simply doesn’t go far enough.
Vanessa Zobel of the conservative Christian Democrats, a member of the Bundestag’s economic affairs committee, is critical of the EU’s Critical Raw Materials Act, calling it well-intentioned but ineffective. “It names the problem, but gets lost in bureaucracy,” she said. Instead, she argues, national governments need to step in where Brussels hesitates — especially when it comes to defense.
According to Zobel, Germany’s raw materials dependency is a direct threat to national security. “Without secure supply chains, there can be no credible military deterrence,” she said. “Making ourselves this dependent in security-critical areas is reckless.”
While she supports creating national stockpiles, Zobel sees that as only a short-term fix. “A strategic reserve makes sense in times of crisis, but every stockpile is finite,” she said. “If we want true resilience, we have to make structural changes.”
That means reactivating Germany’s own resources. “We’ve been too complacent for too long,” she added, pointing to unused lithium deposits and the political resistance to domestic mining. “Anyone who wants a resilient defense industry must authorize mining sites, approve extraction, and prioritize funding.”
The broader message is that Germany must stop relying on market forces and start thinking like a geopolitical actor. “The Zeitenwende has to show up in our thinking,” she said, referring to former Chancellor Olaf Scholz’s pledge to fundamentally shift Germany’s approach to security and defense after Russia’s invasion of Ukraine. “Everything is political. Everything is strategic.”