Three Regulations, No Common Language: Standardising Process Costing for EU Critical Raw Materials Governance

August 2026, Paper: The European Union has enacted three flagship instruments to govern critical raw materials, decarbonise industrial production, and build digital traceability across battery value chains — the Critical Raw Materials Act (CRMA), the EU Battery Regulation, and the Carbon Border Adjustment Mechanism (CBAM). Each requires process-level economic evidence for core obligations, yet none defines a method for generating evidence that is comparable or auditable across applicants, an absence this paper terms an enforcement gap. This paper maps the collision between these three independently drafted cost-reporting regimes, demonstrates empirically — using a spodumene-to-lithium-carbonate conversion case — why the resulting methodology vacuum is consequential rather than theoretical, and proposes Unit-Process Life Cycle Costing (Unit-Process LCC) as candidate regulatory infrastructure — a reporting grammar built on mandatory separation of physical-intensity and price data around a fixed reference unit. Three integration points carry the governance case: strategic project feasibility assessment for processing and circular-economy recycling routes under the CRMA, battery passport cost provenance under the Battery Regulation, and carbon-cost disclosure aligned with CBAM, with technology-neutral investment appraisal as a fourth, complementary application. Institutional adoption is both feasible and urgent: CRMA approvals, the battery passport delegated act, and CBAM implementation converge within an eighteen-month window in which a shared cost methodology, if adopted now, would materially improve the comparability and defensibility of decisions already being made."