On 24 April 2025, US President Trump signed an Executive Order intended to promote deep-sea mining. The aim is to reduce the US industry's dependence on foreign critical minerals. The executive order directs federal agencies to expedite permits for the commercial seabed mining of resources in US and international waters, primarily to collect polymetallic nodules which are rich in rare metals such as manganese, nickel, copper and cobalt.
Securing the supply of critical minerals is becoming increasingly important also for the EU. The EU aims to increase extraction and processing of these minerals within the EU and to increase recycling rates, especially for metals used in technologies for the future, such as offshore wind turbines and electric vehicles. Germany basically follows this principle. There are no plans yet for commercial mining of polymetallic nodules to improve reliability of supplies.
Germany is a member of the International Seabed Authority (ISA). The ISA Mining Code contains rules and regulations for all mining activities on the deep seabed, from prospecting and exploration to the actual extraction of minerals. The legal requirements for deep-sea mining, however, are still being discussed and negotiated. The ISA has undertaken to develop Regional Environmental Management Plans (REMPs) for all deep-sea regions in which mining activities are carried out or planned. Before individual projects are approved, these plans should be considered when deciding on the implementation of specific projects. Opinions differ as to whether they ought to be mandatory. The purpose of these plans is to strike a balance between deep-sea mining and environmental protection, to close knowledge gaps and identify collateral impacts, and to coordinate deep-sea mining with other permitted activities such as fishing and the laying of submarine cables. In 2012, a REMP was adopted for the Clarion-Clipperton Zone in the Central Pacific with the world's largest polymetallic nodule field. Others are being prepared. There are also negotiations going on to standardise the preparation and the contents of such REMPs. Germany submitted a REMP application in February 2020.
The ISA has reacted negatively to the Executive Order issued by President Trump, stating that any project that is not carried out in accordance with the recognised international framework or attempts to circumvent international law entails legal, diplomatic, economic, security and financial risks. Furthermore, a 'circumvention' of the ISA supervisory authority would violate international law. According to the ISA, the parties to the UN Convention on the Law of the Sea (UNCLOS) - which include Germany - are obliged not to recognise the acquisition or exercise of any rights to minerals extracted from the deep sea by any state, individual or legal entity that does not comply with Part XI of UNCLOS.
Even though the US and the EU have similar interests in terms of reliable supplies of critical raw materials, it remains doubtful whether the EU or Germany will join the US initiative to mine for deep-sea polymetallic nodules in the short term. In the event that polymetallic nodules will be imported to Germany for processing in the future, the question will arise as to whether the extraction has been carried out in accordance with UNCLOS and the ISA requirements, which have been transposed into German national law through the German Seabed Mining Act (Meeresbodenbergbaugesetz).
