The EU Critical Raw Materials Act introduces new product information requirements for permanent magnets used in selected equipment.

Affected products will need a visible label identifying whether they contain permanent magnets and which magnet type is present. Where a covered magnet is used, the product must also carry a digital data carrier providing technical information on the magnet’s location, composition and safe removal.

A separate requirement will make the recycled content of certain larger permanent magnets publicly available.

These obligations are intended to help repairers and recyclers recover strategic raw materials such as neodymium, dysprosium, praseodymium and samarium instead of losing the magnets in mixed metal and electronic waste streams.

The rules do not apply to every product containing a magnet. They also do not yet have one universal application date. Several requirements depend on secondary EU legislation that has not yet been published in final form.

Which law introduces the permanent magnet requirements?

The requirements are contained in Articles 28 and 29 of Regulation (EU) 2024/1252, commonly known as the Critical Raw Materials Act or CRMA.

The Regulation entered into force on 23 May 2024. It establishes a wider framework for securing access to critical raw materials, increasing EU processing and recycling capacity and improving the circularity of products containing strategically important materials.

Articles 28 and 29 focus specifically on permanent magnets. Article 28 introduces the physical label and digital recycling information. Article 29 introduces public recycled-content information and provides the legal basis for future minimum recycled-content requirements.

Does every product containing a magnet fall within scope?

No.

The current Regulation applies only to the product groups expressly listed in Article 28:

• magnetic resonance imaging devices;
• wind energy generators;
• industrial robots;
• motor vehicles;
• light means of transport;
• cooling generators;
• heat pumps;
• electric motors, including motors integrated into other products;
• automatic washing machines;
• tumble dryers;
• microwave ovens;
• vacuum cleaners;
• dishwashers.

A product is not covered simply because it contains a speaker, magnetic closure, sensor or another small magnet.

The wording concerning electric motors is particularly important. Electric motors remain within scope when they are integrated into another product. A manufacturer cannot therefore assume that the obligation applies only to motors sold as standalone components.

The precise classification of products containing integrated motors may require further assessment once the Commission publishes the final labelling format and any corresponding customs classifications. The Regulation empowers the Commission to issue a list of Combined Nomenclature codes and product descriptions to assist customs authorities.

The product list may be expanded

The European Commission proposed an amendment to the Critical Raw Materials Act in December 2025.

Under the proposal, Article 28 would also cover:

• hard disk drives;
• transducers;
• loudspeakers;
• drones for civil use;
• motorised toys.

The proposal would significantly expand the practical reach of the rules into consumer electronics, data storage, audio equipment and smaller motorised products.

However, the amendment remains part of the EU legislative process. These additional product groups should not be treated as part of the binding scope unless and until the amendment is formally adopted and enters into force. Companies producing these products should monitor the procedure and may reasonably begin assessing their magnet data, but they should distinguish proposed requirements from current law.

What must the physical label show?

A covered product must carry a conspicuous, clearly legible and indelible label.

The label must indicate:

1. whether the product contains one or more permanent magnets; and
2. where it does, whether the magnets belong to one of the following types:

• neodymium-iron-boron;
• samarium-cobalt;
• aluminium-nickel-cobalt;
• ferrite.

The obligation therefore covers both positive and negative information. A listed product without a permanent magnet may still need a label confirming that no permanent magnet is incorporated.

A general statement such as “contains magnets” or “contains rare-earth materials” will not necessarily be sufficient. The Regulation requires identification of the applicable magnet category.

The Commission must establish the final format of the label through an implementing act. Manufacturers should therefore not create their own permanent compliance symbol before the prescribed design and presentation rules are known.

When will the label become mandatory?

The Critical Raw Materials Act does not set a fixed general date for the label.

The obligation begins two years after the implementing act establishing the labelling format enters into force.

The Commission was required to adopt that implementing act by 24 November 2025. The original text was subsequently corrected to reflect this date. As of 24 July 2026, no final implementing act establishing the Article 28 label appears to have been published in EUR-Lex.

The two-year transition period has therefore not yet started on the basis of a published final act. The effective application date remains dependent on the eventual adoption and entry into force of the implementing legislation.

Businesses should avoid relying on an assumed 2027 or 2028 deadline. The actual date must be calculated from the final implementing act once it is published.

Which products have a separate application date?

Article 28 provides that its requirements apply from 24 May 2029 to:

• magnetic resonance imaging devices;
• motor vehicles;
• light means of transport that are type-approved category L vehicles.

The relationship between this specific date and the general two-year period linked to the implementing act will need to be considered once the secondary legislation is available.

The Regulation also excludes certain vehicle categories, including special-purpose vehicles, certain components approved through multi-stage vehicle type approval and vehicles produced in small series.

Products primarily designed for defence or space applications are exempt from the Article 28 requirements.

What is the digital data carrier?

Where a covered product contains one or more of the four listed permanent magnet types, it must carry a data carrier on or in the product.

The Regulation does not prescribe the final technical form in Article 28 itself. It could ultimately use a QR code, another machine-readable identifier or a format aligned with the EU Digital Product Passport infrastructure.

The data carrier must be connected to a unique product identifier. That identifier provides access to the required magnet and dismantling information.

The data-carrier obligation begins at the same general point as the label: two years after the labelling implementing act enters into force.

Is this a full Digital Product Passport?

Not necessarily.

The Critical Raw Materials Act refers to a data carrier and unique product identifier. It does not automatically establish a complete standalone Digital Product Passport for every covered product.

The distinction matters because a full product passport under the Ecodesign for Sustainable Products Regulation may include a much wider set of environmental, performance, material and supply-chain information.

Where another EU legal act already requires a product passport for the product, the permanent magnet information must be included in that passport. The company should not create an unnecessary parallel passport solely for Article 28.

Where no other product passport applies, the CRMA data carrier must still provide access to the permanent magnet information required by Article 28.

What information must be available digitally?

The data connected to the unique product identifier must include the identity of the responsible person or company, including its registered name or trademark, postal address and available electronic contact details.

It must also provide information on:

• the weight of each permanent magnet;
• the location of each magnet within the product;
• the chemical composition of each magnet;
• the presence and type of coatings;
• glues used in the magnet assembly;
• relevant additives;
• the steps required to access and safely remove the magnets;
• tools or technologies needed for removal.

This information must be sufficiently precise for repairers and recyclers to locate and remove the relevant components safely.

A high-level statement that a product contains a rare-earth magnet will not satisfy the complete data requirement. Product-level technical data, dismantling instructions and material information will be needed.

A simplified route applies where all magnets are inside motors

Where every permanent magnet in the product is contained exclusively in one or more electric motors, the responsible company can use a simplified information route.

Instead of describing the location and removal of each individual magnet, it may provide information on:

• the location of the electric motors;
• how the motors can be accessed;
• how the motors can be safely removed;
• the sequence of the removal steps;
• the tools or technologies needed.

This reduces the need for final-product manufacturers to provide magnet-level dismantling instructions where the motor can be removed as a complete component.

The simplification does not remove the need to identify the product as containing permanent magnets or to maintain an appropriate data carrier. It changes the level at which certain location and removal information can be provided.

Who can access the information?

Article 28 requires the data to be accessible to:

• repairers;
• recyclers;
• market surveillance authorities;
• customs authorities.

This does not necessarily mean that all technical information must be available without restriction to every consumer or competitor.

The future technical rules may establish different access rights, authentication requirements or data layers. Companies should therefore distinguish the data carrier from the freely accessible recycled-content website required under Article 29.

The Commission is empowered to adopt further rules on the technical design of the data carrier, the unique product identifier, applicable standards, customs controls and integration into market-surveillance registers.

How long must the data remain available?

The responsible company must ensure that the information is complete, accurate and up to date.

It must remain available for at least:

the typical lifetime of the product plus ten years.

This obligation continues even if the responsible company becomes insolvent, enters liquidation or ceases its EU activities.

The company may appoint another natural or legal person to maintain the data on its behalf. This will make the contractual arrangements with passport and data-hosting providers particularly important.

A cloud platform that remains operational only while an annual subscription is paid may not be sufficient unless the agreement addresses business closure, insolvency, data migration and long-term availability.

The information can be organised at model level. Where the magnet data differs between units of the same model, it must instead refer to the relevant batch or individual unit.

Who is responsible for compliance?

The obligation applies to the natural or legal person that places the covered product on the EU market.

The CRMA defines placing on the market as the first making available of a product on the Union market.

Depending on the supply chain, the responsible company may therefore be:

• an EU manufacturer;
• an importer introducing a product from outside the EU;
• a private-label business placing the product on the market under its own commercial structure;
• a system manufacturer integrating an electric motor into a larger product.

The magnet manufacturer or motor supplier will not always be the company legally responsible for the finished-product label and data carrier.

However, the responsible finished-product company will often depend on those suppliers for the necessary technical information. The legal obligation sits at the point of market placement, while the underlying data may be held several tiers further upstream.

Supplier data will be the central compliance challenge

Many existing component specifications do not contain the information required by Article 28.

A conventional motor data sheet may include:

• rated output;
• voltage;
• efficiency;
• dimensions;
• torque;
• operating temperature.

It may not identify:

• the individual magnet weight;
• alloy composition;
• coating type;
• glue or additives;
• post-consumer recycled content;
• dismantling steps;
• batch-level material variations.

Manufacturers and importers should therefore begin mapping products and suppliers before the final label format is published.

Relevant contracts and supplier questionnaires should address the delivery, verification and updating of permanent magnet information. They should also specify how changes to a motor, magnet grade, adhesive or production facility are communicated.

A declaration prepared once at the start of a commercial relationship may become inaccurate if the supplier later changes the magnet specification without notifying the customer.

Does the 0.2-kilogram threshold apply to the label?

No.

The 0.2 kg threshold applies to the separate recycled-content disclosure under Article 29. It is not a general exemption from the Article 28 label and data-carrier requirements.

A listed product containing a small permanent magnet can therefore still require:

• the physical magnet label;
• the digital data carrier;
• location and dismantling information.

The public recycled-content disclosure applies only where the combined weight of the relevant magnets exceeds 0.2 kg.

Companies should not remove small-magnet products from their Article 28 assessment solely because the total magnet weight is below this threshold.

Which magnets are subject to recycled-content disclosure?

Article 29 applies to:

• neodymium-iron-boron magnets;
• samarium-cobalt magnets;
• aluminium-nickel-cobalt magnets.

Ferrite magnets are excluded from the Article 29 disclosure requirement.

Where the combined weight of the applicable magnets in a covered product exceeds 0.2 kg, the responsible company must make the share of specified raw materials recovered from post-consumer waste publicly available.

The current Regulation covers:

• neodymium;
• dysprosium;
• praseodymium;
• terbium;
• boron;
• samarium;
• nickel;
• cobalt.

The information must be made available on a freely accessible website. Customers must be able to access it before being bound by a purchase contract, including in distance-selling situations.

When does the recycled-content disclosure begin?

The date is not yet fixed.

Article 29 states that the disclosure begins on the later of:

• 24 May 2027; or
• two years after the delegated act establishing calculation and verification rules enters into force.

The Commission was required to adopt the delegated act by 24 May 2026. As of 24 July 2026, no final delegated act appears to have been published in EUR-Lex.

The calculation method, verification rules and corresponding conformity assessment procedure therefore remain outstanding. The disclosure obligation cannot be applied reliably until those rules have been finalised and the applicable transition period can be calculated.

Companies should continue collecting supplier information, but they should not invent their own recycled-content methodology and present it as the statutory Article 29 value.

The proposed amendment would also change the recycled-content rules

The Commission’s December 2025 proposal would expand Article 29 from post-consumer waste to both pre-consumer and post-consumer waste.

It would also require separate information on the share of recycled material originating within the EU.

These changes are not yet part of the applicable Regulation.

Until an amendment is adopted, the existing legal text refers to material recovered from post-consumer waste. Businesses should keep current requirements and proposed future requirements clearly separated in product specifications, supplier requests and public communications.

Are minimum recycled-content levels already required?

No fixed minimum percentage currently applies under Article 29.

The initial obligation is a transparency requirement. Companies will disclose the recycled share calculated under the future methodology.

After the calculation and verification rules enter into force, and in any event by 31 December 2031 under the current text, the Commission is expected to adopt delegated acts establishing minimum recycled-content levels.

Different levels may apply to different products, and certain product categories may be excluded. Transitional periods must reflect the difficulty of redesigning products and securing sufficient recycled material.

The future targets will depend on factors including material availability, recycling capacity, technical progress, product performance, environmental benefits and affordability.

Permanent magnet compliance will also affect CE documentation

The CRMA requirements are not limited to a label and online database.

Before placing a product covered by Articles 28 or 29 on the market, the responsible person must ensure that:

• the applicable conformity assessment has been completed;
• the required technical documentation has been prepared;
• an EU declaration of conformity has been drawn up;
• the CE marking has been affixed.

Type-approved vehicles follow their relevant type-approval structure instead of the general Article 33 conformity process.

This means permanent magnet data will need to become part of the product compliance file rather than remaining solely within a sustainability or recycling department.

How do the rules interact with WEEE?

The CRMA requirements complement rather than replace the Waste Electrical and Electronic Equipment framework.

Article 28 expressly preserves the obligation to provide treatment facilities with information under the WEEE Directive.

A company can therefore have parallel duties to:

• register as a WEEE producer in individual countries;
• finance the collection and treatment of electrical equipment;
• report national sales quantities;
• provide treatment information;
• label the product under the CRMA;
• maintain permanent magnet dismantling data;
• disclose recycled content under Article 29.

The responsible company may also differ between regimes. WEEE producer status depends on national market and sales structures, while the CRMA focuses on the entity first placing the covered product on the Union market.

One assessment cannot simply be copied into the other.

What should companies do now?

The precise label and calculation methodologies remain outstanding, but the data requirements in the Regulation are already clear enough to begin preparation.

Companies should first identify whether their portfolio includes a listed product or an electric motor integrated into another product.

For potentially covered products, the next steps are to:

• identify each permanent magnet type;
• establish where the magnets or motors are located;
• obtain magnet and motor weights;
• document composition, coatings, glues and additives;
• prepare safe removal instructions;
• determine whether the 0.2 kg threshold is exceeded;
• identify the legal entity placing the product on the EU market;
• review supplier contracts and change-notification processes;
• plan long-term hosting of the digital information.

The final label artwork and statutory recycled-content values must wait for the relevant secondary acts. The underlying product and supplier data should not.

This is a product data obligation, not an EPR registration

The permanent magnet requirements do not create a new national producer register, collective scheme or recycling fee.

They are EU product compliance and circularity requirements.

Nevertheless, they sit alongside WEEE, battery, packaging and other EPR obligations for many of the same products. A heat pump, washing machine, robot or vacuum cleaner may therefore require both product-level magnet information and country-specific end-of-life registrations.

The central compliance challenge will be coordinating these regimes without confusing their responsible entities, data definitions and application dates.

Viron Compliance supports manufacturers, importers and private-label businesses in mapping EU circular-economy obligations, identifying the responsible legal entities and coordinating permanent magnet requirements with WEEE and other EPR duties across European markets.