For decades, global trade and maritime risk were shaped by the movement of liquid energy, oil, and gas. That model is now changing. In a decarbonised and digital economy, attention has shifted to Critical Raw Materials (CRMs). These are the physical inputs underpinning the energy transition and industrial competitiveness. Lithium, cobalt, rare earth elements, and specialist metals have evolved from niche commodities to strategic cargoes.
For companies exposed to these supply chains, the issue is not simply sourcing. The real question is whether CRM trades remain financable, insurable, and executed as regulation tightens, ESG expectations rise, and voyage legality comes under closer scrutiny. As Europe accelerates its green transition, access to CRMs is reshaping both global trade flows and marine insurance risk landscape. Supply-chain concentration, regulatory fragmentation, and trade legality are now core underwriting and credit considerations, rather than peripheral compliance issues.
This shift is already measurable. IUMI’s 2025 Global Marine Insurance Statistics show growth in battery materials and cleaner fuel cargoes outpacing traditional fossil fuels. This increases accumulation risk at major ports such as Rotterdam. For insurers and lenders alike, the maritime leg is increasingly where these risks manifest.
The 65% Rule and Its Insurance Impact
The EU has reinforced the EU Critical Raw Materials Act through initiatives such as the RESourceEU Action Plan, accelerating strategic projects and reducing reliance on single-source supply chains. At the centre of this framework is the 65% rule, enforced by the European Critical Raw Materials Board since May 2024. It caps reliance on any single non-EU country at 65% of supply at each stage of extraction, processing, or recycling. While designed to support European strategic autonomy, it has direct consequences for project structure, financing, and insurance.
More than 53% of firms cite insurance and regulatory exclusions as a primary barrier to project viability noted WTW’s 2025 Clean Energy Survey. In practical terms, supply-chain concentration has moved beyond trade policy and into the realm of bankability. Many CRMs complicate compliance because producers recover them as co- or by-products of larger mining and refining operations rather than mining them directly. Gallium is typically extracted from bauxite processing streams, while producers recover several heavy rare earth elements alongside base metals. As a result, concentration risk often sits at the processing stage, even where mining activity appears geographically diversified.
From an underwriting perspective, this structural concentration increasingly attracts scrutiny. Lenders and insurers assess whether diversification targets are realistic and resilient across the full lifecycle of a project, rather than whether they simply meet policy thresholds on paper.
Deep-Sea Mining and the Question of Voyage Legality
As demand for CRMs grows, deep-sea mining has moved from theory to execution. In early 2026, the United States introduced measures to fast-track domestic permitting for seabed mineral extraction, even as international governance of seabed resources remains contested.
For maritime operators and insurers, the significance lies in its operational consequences and implications for voyage legality. Most marine insurance policies, including Hull & Machinery and Protection & Indemnity (P&I), require that the insured voyage and underlying trade be lawful. Where legality is disputed or later challenged, coverage uncertainty can arise.
In practice, disputes often stem not from physical loss, but from alleged breaches of policy conditions linked to trade illegality. Vessels extracting or transporting minerals under contested permitting regimes may face heightened scrutiny at ports of call, with detention, delay, or enforcement action quickly escalating into contractual and insurance disputes.
The risk is amplified by the nature of deep-sea cargoes. Polymetallic nodules and similar resources contain mixed mineral assemblages rather than single-element outputs, complicating cargo classification, permitting scope, and port reception requirements. Authorities often raise regulatory questions on arrival, when mitigation options are limited.
Scenario: When Regulatory Uncertainty Becomes an Insurance Issue with CRMs
A bulk carrier is contracted to transport polymetallic nodules from a deep-sea extraction site to a European processing facility. The operator relies on a domestic permitting regime that lacks universal international recognition. On arrival at an EU port, authorities challenge the cargo’s legality and detain the vessel. Charterparty performance breaks down, delay costs mount, and contractual claims follow.
Insurers and P&I Clubs will examine whether the voyage and cargo complied with policy terms, including legality of trade. When legality is contested, insurers may challenge cover or issue it with reservations. What began as a regulatory grey area has now become a commercial and insurance problem. Scenarios of this nature are no longer exceptional and are an emerging feature of CRM trades operating at the edge of evolving regulation.
Managing Risk and Maintaining Financial Seaworthiness
Fast track designation under the EU CRM Act does not eliminate risk. Projects must still demonstrate that their logistics chains, contractual structures, and insurance arrangements can withstand regulatory and lender scrutiny.
Unlike traditional bulk commodities, CRM cargoes often pass through multiple processing, blending, and transformation stages across several jurisdictions. This weakens the link between mine of origin and finished material, increasing friction around ESG verification, sanctions screening, and legality of trade. Insurers, P&I Clubs, and financing institutions routinely examine these issues.
In this environment, early and informed risk assessment is critical. Maritime insurance brokers play a key role in helping clients align sourcing decisions, routing, jurisdictional exposure, and contractual structures with insurance cover and lender expectations. By reviewing mineral provenance, voyage profiles, and applicable regulatory frameworks, brokers can reduce the risk of coverage disputes and improve confidence for insurers and financiers. In higher-risk jurisdictions, political risk insurance may also form part of a broader risk-transfer strategy.
Turning Transition Risk into a Bankable Outcome
Governments are moving quickly to secure access to CRMs and markets are responding. Inevitably, insurance frameworks, contractual standards, and international legal alignment evolve more slowly. It is in this gap that risk accumulates.
Early risk analysis, disciplined sourcing strategies, and fit-for-purpose insurance help prevent delay, dispute, or loss. For CRM supply chains, insurability is increasingly inseparable from bankability.
Maritime insurance underpins the green transition by identifying, pricing, and structuring risk in ways lenders, insurers, and counterparties can support. As CRM supply chains evolve, early engagement with insurance and risk advisers ensure that regulatory ambition translates into projects that are both insurable and financeable.
