The CRMA transformation stage where raw materials are made economically usable, distinct from extraction, recycling, metal working, and finished-good manufacturing.
Processing is where raw-material evidence often changes form, ownership, batch structure, and documentation. The stage boundary matters because processing records can connect upstream extraction to downstream product claims only if inputs and outputs remain traceable.
The EU Critical Raw Materials Act names processing examples and excludes later metal working and transformation into goods. That exclusion should be preserved so refining/separation evidence is not confused with component manufacturing evidence. North America critical-minerals context: U.S. sources use designation/list logic under 30 U.S.C. § 1606 and the Federal Register 2022 list; Canada Income Tax Act section 127.49 uses qualifying material and qualifying mineral activity for a tax-credit context. Keep these source layers separate from EU CRMA critical/strategic raw material and EU conflict-minerals definitions.
Regulation (EU) 2024/1252 establishing a framework for ensuring a secure and sustainable supply of critical raw materials
all physical, chemical and biological processes involved in the transformation of a raw material from ores, minerals, plant products or waste into pure metals, alloys or other economically usable forms, including beneficiation, separation, smelting and refining, and excluding metal working and further transformation into intermediate and final goods
CRMA Article 2 source-specific definition layer.
Reference: Article 2, point 8
Reviewed public draft page. Aligns with CRMA raw-material priority policy: source-bound category boundaries, concrete implementation objects, and evidence-focused commentary.
Implementation records should capture facility record, process type, input/output material, batch or lot, operator, location, source document, conversion factor or yield where relevant, assessment period, and links to extraction, recycling, and downstream product records.
Processing is a transformation evidence node. Inputs, outputs, facility records, and batch/lot links need to stay connected so a material claim can be traced through refining or separation without becoming a vague supplier assertion.