Diversifying Without Autonomy? Kazakhstan, China, and the Limits of the EU Critical Raw Materials Act

The European Union’s Critical Raw Materials Act (CRMA) represents the latest example of the EU’s reactive pursuit of strategic autonomy, informed by lessons from past dependencies on Russian energy and other critical imports. While the Act aims to reduce reliance on China, it continues to reflect an extractivist approach, treating resource-rich partner countries primarily as suppliers rather than fully engaged collaborators. This orientation exposes a structural weakness. The CRMA emphasizes diversification through international partnerships but focuses mainly on securing access to raw materials, without fostering local processing, industrial development, or upstream partner agency. Consequently, the EU’s ambitions for genuine strategic autonomy remain constrained by both structural dependencies and logistical chokepoints. This paper examines Kazakhstan as a single case study to explore these dynamics. Kazakhstan possesses substantial reserves of lithium, cobalt, rare earth elements, uranium, and tantalum, positioning it as a key upstream supplier in global critical raw materials. EU–Kazakhstan relations have intensified since 2022, with enhanced cooperation in the energy and minerals sector. While the EU has articulated strategic objectives through the CRMA, it has also established a strategic partnership with Kazakhstan on raw materials, batteries, and renewable hydrogen, aligned with the Global Gateway strategy and the REPowerEU plan. These initiatives, however, largely concentrate on upstream sourcing, and Kazakhstan’s potential for downstream refining, technological development, and industrial capacity-building remains underexploited. The Dzungarian Corridor, linking Kazakhstan to Chinese refining networks, illustrates a critical chokepoint. Infrastructure constraints and China’s dominance in downstream processing limit the EU’s ability to exercise practical autonomy across the value chain. The study employs a desk-based qualitative methodology, combining systematic analysis of CRMA legislation, EU–Kazakhstan memoranda, trade and partnership agreements, and policy reports, alongside a comprehensive review of secondary literature on Kazakhstan’s mineral sector, global critical raw materials flows, and industrial capacities. This is complemented by supply-chain mapping and comparative assessment of processing capabilities, while explicitly adopting a decentered, partner-country perspective. By recentering Kazakhstan, the analysis reveals how EU-centric policies may overlook local constraints, bottlenecks, and opportunities for industrial development, underestimating the country’s agency in shaping critical raw materials governance. Drawing on a conceptual lens of asymmetric interdependence, the paper argues that while the CRMA advances diversification, it does not guarantee autonomy throughout the value chain. The findings underscore the need for policies supporting local processing, technical cooperation, and equitable industrial engagement, enabling the EU to diversify more effectively while allowing Kazakhstan to leverage its resources for industrial and diplomatic development. By situating Kazakhstan at the center, the paper highlights how structural chokepoints, extractivist policy assumptions, and limited partner engagement collectively constrain EU ambitions, offering a nuanced assessment of the limits of current critical raw materials policy frameworks.