Supply chains · Contracts · Raw materials
Your supplier is nearby. Where do its components come from?
Dependence on China may arise several steps before your regular point of contact.
Case statusResearch closed on 28 September 2026 · check for changes before taking a decision.
01
Critical raw materials enter the picture
The EU Critical Raw Materials Act seeks, among other things, to diversify supply and improve resilience. The Council’s presentation, updated on 13 August 2026, records its entry into force on 23 May 2024. It sets out European benchmarks for 2030: 10% extraction, 40% processing, 25% recycling and a limit of 65% dependence on one third country, within the relevant scope. [1]
These benchmarks concern the Union, and the summary describes them as non-binding. They are not individual purchasing quotas imposed on every small business. The same page discusses a proposed revision and negotiations. We therefore do not present those amendments as already adopted. The full applicable text must be consulted before attributing a particular obligation to a business. [1]
02
Identify a dependency without inventing a prohibition
Dependence on China does not by itself establish that a product is prohibited, a shipment will be blocked or a supplier has breached its obligations. A specific restriction would require verification of its text, scope and any suspensions. This article does not treat any particular Chinese restriction as currently active. The research did not include reading Chinese-language legal texts.
For a buyer, the first difficulty may be documentary. Does the supplier know the component’s origin, the location of processing or only the place of assembly? Can the available records distinguish those stages? We recommend asking these questions for critical items. This is not presented as a universal traceability obligation derived from the regulation. The reliability of an answer matters as much as its apparent detail.
A second source also needs factual examination. It may rely on the same material, processor or industrial equipment. Changing a component may require testing, technical adjustments or a customer’s approval. These are possibilities for operational assessment, not proof that replacement will be impossible or immediately available. A named alternative is only the beginning of the inquiry, particularly where specifications are demanding.
03
The Law Right approach: map one critical dependency
- Start with a product whose absence would interrupt an important activity. Identify critical components and request information the supplier can actually substantiate. Mark origin or a supply stage as unknown when it is undocumented. An incomplete but reliable map helps target the next check. Keep assumptions separate from facts so that a later decision does not quietly turn uncertainty into assurance.
- Clarify information commitments: which changes must be reported, by whom, when and with what records? Then discuss responses to interruption, costs and the time needed to qualify another source. The legal effect of those commitments depends on the contract and applicable law. A useful operational conversation prepares that assessment without replacing it.
- Test the alternative with technical and commercial teams before treating it as secured. Decide which dependencies are acceptable, which call for reserves or another source and who will follow up missing information. European benchmarks provide a collective direction. Your decision needs evidence about your products and an update before commitment; it cannot be made from a general country label alone.
The visible supplier is only the beginning.
The contract identifies your immediate counterparty. Mapping starts here.
Explanatory schematic: illustrative relationships, not a measurement of dependencies or a legal conclusion.Two suppliers offer an assessed alternative only when their critical dependencies have been examined.
