Found while verifying #250's four unread citations against the Official Journal.
The CRM Act was recorded in CITED_NOT_MODELLED as an act that "defines which
materials are critical; it does not govern their disclosure".
That is false, and it is false in the direction that matters most here.
What Art. 28 actually requires
Read from the OJ text of Regulation (EU) 2024/1252, 2026-09-17.
Art. 28(1) — a label, "conspicuous, clearly legible and indelible", on
MRI devices, wind energy generators, industrial robots, motor vehicles, light
means of transport, cooling generators, heat pumps, electric motors "including
where electric motors are integrated in other products", automatic washing
machines, tumble driers, microwaves, vacuum cleaners and dishwashers, stating
whether the product incorporates permanent magnets and of which of four types.
Art. 28(3)–(4) — a data carrier on or in the product, "linked to a
unique product identifier" that provides access to:
- the responsible person's name, trade name or trademark, postal address and
electronic contact;
- "information on the weight, location and chemical composition of all
individual permanent magnets included in the product, and on the presence and
type of magnet coatings, glues and any additives used";
- information enabling access and safe removal of every magnet, including the
sequence of removal steps and the tools required.
Art. 28(6), verbatim:
"For products referred to in paragraph 3 for which a product passport is
required pursuant to another Union legal act, the information referred to in
paragraph 4 shall be included in that product passport."
Art. 28(7) — the person placing the product on the market keeps that
information "complete, up-to-date, and accurate" and available for "a period
at least equal to the product's typical lifetime plus 10 years, including after
an insolvency, a liquidation or a cessation of activity", at model, batch or
unit level, accessible to repairers, recyclers, market surveillance
authorities and customs authorities.
Art. 29 — the share of neodymium, dysprosium, praseodymium, terbium, boron,
samarium, nickel and cobalt recovered from post-consumer waste must be made
"publicly available on a free-access website" where a product's magnets exceed
0,2 kg.
Art. 31 — an environmental footprint declaration.
Why this is more than a wrong inventory reason
A data carrier, a unique product identifier, per-unit information, a retention
period that survives insolvency, an audience of repairers and recyclers, and an
explicit instruction to put the content into the product passport. That is
the shape this workspace builds, written by a different act, and we had it filed
as a list of materials.
#250's own framing was right about the risk: a negative claim asserting the
absence of an obligation across a whole regulation is the hardest kind to hold,
and this one was held by nobody. It is now corrected in the inventory
(32024R1252 is Sourced, with what the articles say). This issue is the
substantive half.
What is not affected
- No product group modelled here is in the Art. 28(1) list. It is an
exhaustive enumeration and smartphones, tablets, batteries, textiles, tyres,
toys, detergents, furniture and mattresses are absent. Nothing is out of
compliance today.
- The shipped schema prose is accurate.
"Critical raw materials per EU CRM Act 2024/1252." sources the list of critical materials, which Annexes I and
II do supply. The false claim lived only in the inventory reason, never in a
published schema — so no erratum is owed.
What to decide
- Whether the CRM Act becomes a modelled instrument. It is not an ESPR
delegated act, so it does not fit the product-group binding shape, but Art.
28(6) makes it passport content wherever a passport is separately required.
- Art. 28(8) is the interaction rule and is worth reading before deciding:
"Where information requirements relating to the recycling of permanent
magnets are established in Union harmonisation legislation for any of the
products listed in paragraph 1, those requirements shall apply to the products
concerned in place of this Article." So an ESPR delegated act can displace it
— which means the answer is per-product-group, not global.
- Art. 28(12) empowers a delegated act listing Combined Nomenclature codes
for the Art. 28(1) products. That connects to the CN-code work already here,
and is a concrete future trigger to watch.
- Dates. Art. 28 applies two years after an implementing act the Commission
was to adopt by 24 November 2026, and from 24 May 2029 for MRI devices, motor
vehicles and category-L vehicles. Art. 29 from 24 May 2027 or two years after
its delegated act, whichever is later.
Provenance
👁️ Read from the OJ consolidated text on EUR-Lex, 2026-09-17, Arts. 28, 29, 31.
The act is not in the local holdings — this is the one #250 was blocked on,
and the block is now lifted. Worth adding to the register with the articles above
so the next reader does not have to go back to the browser.
Found while verifying #250's four unread citations against the Official Journal.
The CRM Act was recorded in
CITED_NOT_MODELLEDas an act that "defines whichmaterials are critical; it does not govern their disclosure".
That is false, and it is false in the direction that matters most here.
What Art. 28 actually requires
Read from the OJ text of Regulation (EU) 2024/1252, 2026-09-17.
Art. 28(1) — a label, "conspicuous, clearly legible and indelible", on
MRI devices, wind energy generators, industrial robots, motor vehicles, light
means of transport, cooling generators, heat pumps, electric motors "including
where electric motors are integrated in other products", automatic washing
machines, tumble driers, microwaves, vacuum cleaners and dishwashers, stating
whether the product incorporates permanent magnets and of which of four types.
Art. 28(3)–(4) — a data carrier on or in the product, "linked to a
unique product identifier" that provides access to:
electronic contact;
individual permanent magnets included in the product, and on the presence and
type of magnet coatings, glues and any additives used";
sequence of removal steps and the tools required.
Art. 28(6), verbatim:
Art. 28(7) — the person placing the product on the market keeps that
information "complete, up-to-date, and accurate" and available for "a period
at least equal to the product's typical lifetime plus 10 years, including after
an insolvency, a liquidation or a cessation of activity", at model, batch or
unit level, accessible to repairers, recyclers, market surveillance
authorities and customs authorities.
Art. 29 — the share of neodymium, dysprosium, praseodymium, terbium, boron,
samarium, nickel and cobalt recovered from post-consumer waste must be made
"publicly available on a free-access website" where a product's magnets exceed
0,2 kg.
Art. 31 — an environmental footprint declaration.
Why this is more than a wrong inventory reason
A data carrier, a unique product identifier, per-unit information, a retention
period that survives insolvency, an audience of repairers and recyclers, and an
explicit instruction to put the content into the product passport. That is
the shape this workspace builds, written by a different act, and we had it filed
as a list of materials.
#250's own framing was right about the risk: a negative claim asserting the
absence of an obligation across a whole regulation is the hardest kind to hold,
and this one was held by nobody. It is now corrected in the inventory
(
32024R1252isSourced, with what the articles say). This issue is thesubstantive half.
What is not affected
exhaustive enumeration and smartphones, tablets, batteries, textiles, tyres,
toys, detergents, furniture and mattresses are absent. Nothing is out of
compliance today.
"Critical raw materials per EU CRM Act 2024/1252."sources the list of critical materials, which Annexes I andII do supply. The false claim lived only in the inventory reason, never in a
published schema — so no erratum is owed.
What to decide
delegated act, so it does not fit the product-group binding shape, but Art.
28(6) makes it passport content wherever a passport is separately required.
"Where information requirements relating to the recycling of permanent
magnets are established in Union harmonisation legislation for any of the
products listed in paragraph 1, those requirements shall apply to the products
concerned in place of this Article." So an ESPR delegated act can displace it
— which means the answer is per-product-group, not global.
for the Art. 28(1) products. That connects to the CN-code work already here,
and is a concrete future trigger to watch.
was to adopt by 24 November 2026, and from 24 May 2029 for MRI devices, motor
vehicles and category-L vehicles. Art. 29 from 24 May 2027 or two years after
its delegated act, whichever is later.
Provenance
👁️ Read from the OJ consolidated text on EUR-Lex, 2026-09-17, Arts. 28, 29, 31.
The act is not in the local holdings — this is the one #250 was blocked on,
and the block is now lifted. Worth adding to the register with the articles above
so the next reader does not have to go back to the browser.