Assessment of regulatory requirements and constraints for a combined extraction of heat and minerals – with country overviews

The digital and energy transition in the European Union and worldwide implies an increasing need of raw materials that need to be mined, and provision of Critical Raw Materials (CRM) for the EU is usually linked to import dependency. A potential additional source of CRMs and an alternative to conventional mining could be the exploitation of geothermal reservoirs, as geothermal brines often contain high concentrations of metal ions. The EU-funded ‘CRM-geothermal’ project aims to open up the potentially huge untapped resource of raw materials from geothermal fluids and provide operators and investors with information needed to assess the viability of the approach of co-extraction heat and minerals from geothermal fluids. Every project for the extraction of minerals has to be subject to a PESTEL (political, environmental, societal, technological, economic, legal) analysis to assess its viability. The combined extraction of heat and minerals is no exception even though it would not be a classical mining project with respect to the impacts and legacies it may create. The data for a PESTEL assessment are completed by an assessment of the regulatory schemes across European countries plus Turkey. This report presents on overview over relevant regulations and permitting practices. It also details the countries’ regulatory systems. However, in the majority of countries no specific regulations for combined extraction exist yet. It is concluded that in practice, the regulatory treatment of a given project would depend on what the primary objective of the project is: extraction of heat or extraction of metal value. This document is an extract from CRM-geothermal Deliverable 4.1: Falck, W. E. & Correia, V., The Horizon Europe CRM-geothermal project: Deliverable 4.1 – ESG due diligence of the combined extraction of CRMs and energy, incl. UNFC/UNRMS compatible reporting and policy recommendation, Zenodo, 2025, DOI: 10.5281/zenodo.17235755.