Diversification Without Autonomy: Kazakhstan’s Position in Critical Raw Material Supply Chains Under the EU’s Critical Raw Materials Act

The European Union’s Critical Raw Materials Act (CRMA) marks a significant shift in how the EU seeks to manage strategic dependency in the context of accelerating green and digital transitions. Drawing explicitly on lessons from earlier energy dependencies, the Act frames diversification through international partnerships as the primary response to geopolitical supply risk and as a cornerstone of the EU’s pursuit of “open strategic autonomy.” While this approach has generated growing academic and policy debate about its effectiveness for European supply security, far less attention has been paid to how CRMA-driven governance is experienced by the resource-rich partner countries on which diversification depends. This paper examines EU critical raw materials governance from a partner-country perspective, using Kazakhstan as an analytical lens. Kazakhstan occupies a pivotal position within global critical raw material supply chains, combining substantial upstream resource endowments with limited influence over downstream processing, logistics, and standard-setting. Since 2022, cooperation between the EU and Kazakhstan has intensified through a strategic Memorandum of Understanding on raw materials, batteries, and renewable hydrogen, positioning Kazakhstan as a key partner within the EU’s diversification strategy. Yet this engagement unfolds within value chains characterized by entrenched asymmetries and downstream chokepoints, particularly in processing and transport segments dominated by external actors such as China. The paper advances three interconnected arguments. First, it shows that EU critical raw materials governance remains predominantly access-oriented. While diversification-focused partnerships expand sourcing options for European industry, they offer limited institutional pathways for downstream industrial upgrading or sustained value capture in partner countries. Second, it demonstrates that this governance model reconstitutes rather than overcomes asymmetric interdependence. Kazakhstan’s leverage as a supplier is consistently offset by continued vulnerability in downstream segments of the supply chain, constraining its ability to translate resource endowments into long-term industrial or strategic autonomy. Third, the paper theorizes these outcomes through Ansell and Trondal’s concept of turbulence of scale. It argues that governance solutions designed to stabilize supply and reduce complexity at the EU level generate uncertainty, fragmented demands, and adjustment pressures once externalized across multiple governance levels and global value chains. Empirically, the analysis draws on qualitative examination of the CRMA, EU policy communications, and the EU–Kazakhstan partnership framework, read through their implications for partner-state agency rather than internal EU coherence. The paper concludes that while diversification may reduce supply risk for the EU, it simultaneously externalizes governance complexity to partner states, raising broader questions about the limits of diversification-driven approaches to strategic autonomy in a fragmented global political economy.