The European Green Deal has become the EU’s core blueprint for a net-zero economy. The European Union Deforestation Regulation (EUDR) clearly reflects this effort. Forest commodities must meet requirements concerning deforestation, traceability, and due diligence (EU Green Forum, 2026). However, what happens when we apply the same question to the materials powering Europe’s green transition?
The shift to electric vehicles (EVs) goes hand in hand with critical minerals such as nickel, and Indonesia is a central player in the global nickel supply chain, producing the majority of the world’s nickel (Oluwajomiloju, 2026). The EU considers Indonesia an important partner for securing critical raw materials needed for green transitions, a priority reflected in the EU-Indonesia Comprehensive Economic Partnership Agreement, which aims to strengthen sustainable supply chains for energy and raw materials.
The EUDR seeks to prevent certain commodities associated with deforestation from entering the EU market unless companies can demonstrate compliance with its requirements. Its principle is that environmental harm associated with consumption cannot simply be treated as somebody else’s problem because it occurs outside Europe. Nevertheless, this principle becomes complicated when applied to minerals needed for decarbonization. If environmental destruction embedded in supply chains matters when Europe consumes palm oil, timber, and rubber, why should the environmental and social costs of critical-mineral production be treated differently?
The European Critical Raw Materials Act (CRMA) is designed to secure and diversify the supply of critical minerals essential for the green transition (European Commission, 2023). While the CRMA addresses sustainability and environmental protection, it also emphasizes supply-chain resilience and strengthening the EU’s access to critical raw materials. This creates a different policy context from the EUDR, whose primary objective is to prevent deforestation associated with the consumption of specific commodities.
Why, then, does the EU approach these supply chains differently? The answer lies partly in the different economic and strategic pressures shaping each regulation. The EUDR responds to deforestation by linking the production and consumption to particular commodities, making traceability and compliance central to the regulation. By contrast, the CRMA is a response to the EU’s vulnerability to disruptions in critical-mineral supplies. It seeks to secure access to critical raw materials, diversify supply chains, and strengthen European industrial capacity. Battery-grade nickel is classified as a strategic raw material under the Act due to its importance to the green and digital transitions (European Commission, 2024). This creates a policy tension where the EU must reduce the environmental impact of its consumption while securing the materials required to meet its climate and industrial objectives.
Europe’s dependence on global mineral supply chains and its interest in maintaining access to resources amid growing geopolitical and industrial competition strengthens this tension. Unlike the EUDR’s targeted requirements for specified commodities, the CRMA mainly establishes a framework for securing and diversifying supply and promoting sustainable value chains. Environmental sustainability is part of the CRMA’s objectives, but it operates alongside strategic and economic priorities that may pull in different directions. This raises a question: when stronger environmental safeguards risk complicating access to essential resources, how much weight does the EU give to the communities and ecosystems affected by their extraction?
The consequences of this tension are visible in Indonesia. On Kabaena Island in Southeast Sulawesi, more than 60% of active nickel mining concessions are located within forest areas, while 42.7% of households experienced declining or lost traditional livelihoods (Satya Bumi, 2026). This illustrates how a community living in a region that becomes economically important to the global energy transition has to bear ecological degradation and livelihood insecurity even when their resources become valuable to the green economy. A product’s contribution to decarbonization does not necessarily make the production system behind it just. As Kurniawan et al. (2025) demonstrate, the global decarbonization agenda can accelerate recarbonization and deepen fossil-fuel dependence in mineral-rich countries. Although nickel is essential to the global EV battery transition, its processing in Indonesia has also increased electricity demand and reinforced dependence on coal. This reveals how EVs may reduce emissions, while the production systems behind them generate significant social and environmental costs. A just transition therefore requires attention to distribution, accessibility, and legitimacy, not merely technological or economic outcomes (Ghosh et al., 2025).
Environmental responsibility should extend across the entire value chain. If the EU recognizes its responsibility for the deforestation associated with the commodities it consumes, it must also confront the environmental and social consequences of sourcing materials required for its green transition. This does not mean abandoning decarbonization entirely, but rather recognizing that reducing emissions is not sufficient to make a transition just. As Europe’s climate ambitions depend on livelihoods beyond its borders, the question is not only how the transition can proceed, but also who benefits, who bears its costs, and whose interests shape the terms of that transition.
References
Adebowale Oluwajomiloju. (2026, March 10). Nickel and the electric vehicle revolution: Evaluating Indonesia’s industrial policy and its impact on Global Battery Supply Chains. ResearchGate. https://www.researchgate.net/publication/401836743_Nickel_and_the_Electric_Vehicle_Revolution_Evaluating_Indonesia
EU Green Forum. (2026). Implementing the EU deforestation regulation (EUDR). Green Forum. https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation_en
European Commission. (2023). Critical raw materials act. European Commission. https://single-market-economy.ec.europa.eu/sectors/raw-materials/areas-specific-interest/critical-raw-materials/critical-raw-materials-act_en
European Commission. (2024). Critical and Strategic Materials. European Commission. https://rmis.jrc.ec.europa.eu/critical-and-strategic-materials?
Ghosh, B., Velasco, D., Chakraborty, K., Mguni, P., & Yuana, S. L. (2025). Transformative innovation policy: An analytical review of key methods and challenges. Annual Review of Environment and Resources, 50(1), 593–623. https://doi.org/10.1146/annurev-environ-111523-102251
Kurniawan, N. I., Winanti, P. S., & Cahyati, D. D. (2025). Recarbonization through decarbonization: Nickel extraction and the deepening of fossil fuel dependence in Indonesia. Global Environmental Politics, 25(3), 118–138. https://doi.org/10.1162/glep.a.12
Satya Bumi. (2026, May 21). Pulau Kabaena dalam Angka: Dinamika Sosial, Ekonomi dan Lingkungan Masyarakat dalam Pusaran Pertambangan Nikel. Satya Bumi. https://satyabumi.org/laporan-riset-ekonomi-sosial-kabaena/
Authors fisipol
Published at Megashift Fisipol UGM