Critical minerals: Technical and policy considerations

For the last few years, critical minerals have been in the news as policymakers and the media highlight the important role critical minerals play in all aspects of the U.S. economy, technology, infrastructure, manufacturing, energy systems and national defense. These discussions focus on how critical minerals are the foundational inputs to everything modern societies build and use. They even play a role in the foods we eat because some fertilizers consist of minerals like phosphates, potash and lime. Many experts predict that the global demand for lithium, copper, rare earth elements, graphite, nickel and other critical minerals will soar in the next decade as countries pursue electrification objectives, build artificial intelligence (AI) data centers that must have massive amounts of always available electricity, and develop high-tech defense equipment built with rare earth magnets and other critical minerals (International Energy Agency, 2025). The U.S. Congress defined minerals for the first time in the National Materials and Minerals Policy, Research and Development Act of 1980, stating: “The term “materials” means substances, including minerals, of current or potential use that will be needed to supply the industrial, military, and essential civilian needs of the United States in the production of goods or services, including those which are primarily imported or for which there is a prospect of shortages or uncertain supply, or which present opportunities in terms of new physical properties, use, recycling, disposal or substitution, with the exclusion of food and of energy fuels used as such.” (30 U.S.C. § 1601(b)(2))Although most critical “minerals” are actually metallic elements rather than minerals, this article will refer to them as “minerals” to conform to the congressional definition and the current critical minerals dialogue. Forty years later, Congress enacted the Energy Act of 2020, which amended the 1980 Act to add the following definition for critical minerals: “The term ‘‘critical mineral’’ means any mineral, element, substance, or material designated as critical by the Secretary under section 7002(c) of the Energy Act of 2020.” (30 U.S.C. 1601(2)(b)(1))The Energy Act of 2020 directs the Secretary of the Interior, acting through the Director of the U.S. Geological Survey (USGS), to identify critical minerals, to develop a Critical Minerals List (CML), and to update the CML at least every three years or more frequently if determined necessary by the Secretary. The USGS published the first CML in February 2022 (USGS, 2022). The 2022 CML identified 50 minerals critical to the U.S. economy and national security. In November 2025, the USGS finalized its 2025 CML (USGS, 2025a, 2025b) to include 60 minerals (Fig. 1), stating: “Critical minerals underpin industries worth trillions of dollars, and import dependence puts key sectors at risk.” In developing the CML, Section 1606(c) of the Energy Act of 2022 directs the USGS to include minerals that: Are essential to the economic or national security of the United States. The supply chain of which is vulnerable to disruption (including restrictions associated with foreign political risk, abrupt demand growth, military conflict, violent unrest, anticompetitive or protectionist behaviors, and other risks throughout the supply chain). Serve an essential function in the manufacturing of a product (including energy technology, defense, currency, agriculture, consumer electronics and health care-related applications), the absence of which would have significant consequences for the economic or national security of the United States. This law also requires the Secretary to consult with the Secretaries of Defense, Commerce, Agriculture, Health and Human Services, and Energy and the U.S. Trade Representative in designating minerals, elements, substances and materials as critical. Policy issues and economic and technical challenges affecting byproduct critical minerals Section 40206(b)(2) of the Infrastructure Investment and Jobs Act/Bipartisan Infrastructure Law of 2021 recognizes that “many critical minerals are only economic to recover when combined with the production of a host mineral” (that is, they are byproducts of primary metals production). The 2025 CML corroborates this congressional finding because 35 of the 60 listed critical minerals are byproducts produced from a host mineral deposit (Federal Register, 2025). Mining companies do not typically recover byproduct minerals, because it is not profitable. Without an economic driver to produce many of the byproduct minerals, the private sector is unlikely to be able to provide these minerals. Additionally, the presence of byproduct critical minerals can create mineral processing complications, and recovering them would require adding costly and otherwise unnecessary circuits to a milling facility. Because the global volumetric demand for some byproduct critical minerals is quite limited, they can be labeled as “mini” and “micro” critical minerals. These minerals have different technical and economic challenges compared to minerals with much higher demand. Many of the mini and micro critical minerals are indispensable components for high-tech and military applications, which means that not having a reliable supply has an outsized, unacceptably adverse impact on our economy, technology and national defense. Table 1 lists some of the mini and micro critical minerals with small annual U.S. consumption and market value. In contrast to the small consumption of the mini and micro critical minerals, some minerals included in the 2025 CML are mega minerals that have an enormous annual demand. For example, according to S&P Global’s recent copper report (S&P Global, 2026), the current global copper demand is 28 Mt/a (31.1 million stpy), which is expected to increase to 42 Mt/y (46 million stpy) by 2040. According to the International Energy Agency’s 2026 Global Critical Minerals Outlook (IEA, 2026), the global annual market size for tantalum, antimony, titanium and magnet rare earths is less than $10 billion. (Note: The IEA defines neodymium, praseodymium, dysprosium and terbium as magnet rare earths.) The global market size for indium, germanium, gallium, tellurium and tungsten is less than $1 billion. Because there is such a broad range in market size and demand for critical minerals, the minerals on the 2025 CML require mineral-specific, custom-tailored policies to reflect their widely divergent demand profiles and economics. There are significant metallurgical challenges associated with recovering many byproduct minerals. This is especially true for rare earth minerals. Because recovering many of the listed byproduct minerals is typically not financially remunerative, the private sector has little incentive to undertake the mineral processing research and development (R&D) work needed to develop effective and economic metallurgical recovery methods. This is especially true for the mini and micro critical minerals for which there is limited demand. To address this challenge, the federal government has recently invested in several critical minerals projects to subsidize metallurgical R&D and to increase future domestic production. These investments in critical minerals processing and downstream manufacturing are filling an R&D gap that was created in part in 1996 when Congress stopped funding the U.S. Bureau of Mines (USBM). Since then, there has been insufficient government-sponsored mineral processing R&D to meet the growing demand for minerals (Fig. 2). The 30-year absence of a coherent federal mining and mineral processing R&D program has created a technical expertise void that has contributed to a steady decline in U.S. mineral production and increased reliance on imported minerals. The USBM’s R&D programs focused on developing breakthrough technologies with broad applications that had the potential to transform industry. In contrast, the federal government’s recent investments in critical minerals projects support specific mineral processing R&D that will develop bespoke solutions that may not be applicable to deposits with different technical characteristics. To develop more broadly applicable mineral processing techniques, the federal government needs to replicate the R&D programs conducted by the former USBM. The Society for Mining, Metallurgy & Exploration’s September 2024 concept paper on “Why the U.S. Needs a National Materials and Minerals Council” (SME, 2024) describes why Congress should reestablish the country’s mining and mineral processing R&D capabilities. Although the statutory authority for the USBM still exists, reinvigorating a federal minerals R&D program similar to the former USBM would require funding through a future appropriations for the Department of the Interior. Alternative critical minerals feedstocks In addition to the federal government’s investments in selected critical minerals projects, the U.S. Department of Energy (DOE) and the USGS have recently issued grants to evaluate previously mined materials (such as waste rock piles, tailings, slag) at operating and closed coal and hard-rock mines. Industrial wastes and other feedstocks may also be sources of critical minerals. The impetus for these studies is the possibility that metals could be recovered from legacy mine wastes. Evaluating the critical mineral content of previously mined materials should be prioritized to focus on the sites with the highest potential for becoming a future source of critical minerals. A detectable presence of one or more critical minerals in mine wastes does not define a viable critical mineral site. Other screening criteria need to be applied to legacy mine wastes to determine their relative potential as a viable critical minerals source. These criteria include the concentration (grade) of the critical minerals, whether known metallurgical processes can recover the metals, existing power and energy infrastructure, and other site-specific factors. From a broad perspective, the highest potential alternative feedstocks include wastes present at copper and other base-metal mines and precious-metals mines that were operated for decades during periods of low commodity prices when cut-off grades were much higher than current grades. Because metallurgical processes and recovery rates have improved over the decades, mine wastes at older mines may be technically and economically viable sources of critical minerals. Potential benefits to investing in and obtaining value from mine-impacted land goes beyond the critical minerals contributions and include extending positive socioeconomic impacts to surrounding communities and achieving environmental improvements. It is reasonable to assume that private-sector mine owners are already evaluating whether reprocessing the mine wastes at their sites is technically and economically feasible. To evaluate the technical and economic feasibility of reprocessing legacy mine wastes, federal decision-makers should consider all technical, environmental and economic criteria. Additionally, mining critics and circular-economy proponents need to realize that reprocessing and recycling alone will not be sufficient to meet current or projected minerals demands. The critical minerals emergency During the last three decades, the United States has steadily drifted away from being self-sufficient for many key minerals, making the nation dangerously reliant on mineral imports from other nations. This decline in self-sufficiency is the result of policies that failed to recognize that minerals are the building blocks of the United States military, manufacturing, infrastructure, technology and economy. Rather than supporting domestic mining and mineral processing, policies focused on outsourcing mining and mineral processing to other countries. U.S. policymakers enacted regulations with costly and unrealistic air emission limits that forced the closure of the country’s smelters and mineral processing facilities and created a complex and time-consuming permitting process fraught with litigation risks. Lawmakers and federal land managers put potentially mineralized lands off-limits to exploration and mining. The United States became overreliant on just-in-time mineral supply chains from across the globe and dismissed the importance of maintaining just-in-case supplies of domestic minerals for the U.S. military and economy. The education of the mining professional was also diminished as the number of U.S. mining schools to shrank from 25 in 1982 to just 14 accredited schools today. In aggregate, these problematic policies created a perfect storm that chilled investment, eventually hollowed out the U.S. mining industry, and produced today’s minerals emergency. At the same time, China seized on the opportunity to capitalize and strategically built a mining and mineral processing empire to become today’s global minerals superpower that uses export restrictions to put a worldwide stranglehold on essential mineral inputs. Recognizing that the steady increase in U.S. mineral dependency — especially minerals and mineral products imported from China — is unsustainable, President Donald Trump declared a national energy and minerals emergency on the inauguration day of his second term. He defined energy to include minerals, established that energy and minerals security are the foundation for national and economic security, and signed two executive orders (EOs) (White House, 2025a, 2025b), on Unleashing American Energy and Declaring a National Energy Emergency, to put the United States back on a path of energy and minerals security. Since then, he has issued many EOs seeking to reduce the nation’s risky minerals import reliance and to increase domestic mining and mineral processing. The administration’s efforts to increase domestic mineral production have identified and reduced regulatory barriers, directed permit streamlining, reviewed the mineral potential of federal lands, mandated more geologic mapping and supported several critical mineral projects. The administration has offered a portfolio of federal investment mechanisms including grants, loans, equity ownership stakes, price floors and offtake agreements that subsidize selected critical minerals projects. These policies and investments represent emergency measures designed to counteract China’s critical minerals export controls and pricing strategies. In the current mineral import reliance environment, minerals that are essential inputs cannot be managed as normal commodities operating in a conventional free-market economy. China’s interference has created shortages of key minerals that have the potential to undermine entire industries, technologies and defense systems that must have these minerals. Examples include the gallium and germanium needed for advanced semiconductor chips, or the rare earths used to manufacture high-tech permanent magnets. The costs of not having these and other minerals pose too great a threat to our economy and national security. The structure of the investments varies from project to project. These investments are designed to help derisk critical minerals projects by giving companies confidence that their investments in developing projects will not be undermined by China suddenly flooding the market or taking other predatory actions to render U.S mineral projects uneconomic. To some degree, the administration’s investments in critical minerals projects mimic the investments that China has been making for years to subsidize critical minerals mining, mineral processing and manufacturing projects worldwide.The administration is also engaging allies to stem China’s minerals hegemony. In February 2026, Secretary of State Marco Rubio invited 54 countries to a Critical Minerals Ministerial to encourage bilateral and multilateral critical minerals agreements, frameworks and partnerships intended to strengthen allied supply chains and reduce dependence on China (U.S. Department of State, 2026). In another move, the administration created a $12 billion Minerals Vault consisting of a $10 billion Export-Import Bank (EXIM) loan and nearly $2 billion in private-sector investment. This independently governed public-private partnership establishes the U.S. Strategic Critical Minerals Reserve that will store essential raw materials in secure facilities across the United States (EXIM, 2026). Minerals not on the CML are important too Although the 2025 CML includes many important minerals, this list does not fully capture the universe of minerals that are essential to modern society. For example, it would be impossible to build infrastructure without lime (calcium oxide) to make cement and construction aggregates that, when combined, form concrete. Similarly, iron ores are essential components of the steel that undergirds buildings, bridges and other essential infrastructure. Gold is another important mineral due to its superior electrical conductivity and resistance to corrosion; its use in computers, communications equipment, spacecraft, jet aircraft engines and other products; and its unique status as a long-term and universal store of wealth (USGS, 2026). Additionally, gold is an important host mineral for several critical minerals. Conclusion Responding to the critical minerals emergency is urgent for the United States’ economic well-being and national defense. Unfortunately, there are no quick or easy solutions due to the numerous complex factors that have created this emergency over the past several decades. These factors include skyrocketing demand for many minerals, China’s export restrictions that have constrainted the mineral supply chains, U.S. domestic and foreign policy considerations, national defense imperatives, and rapidly evolving manufacturing and technology drivers. SME stands ready to assist U.S. policymakers help solve the minerals emergency as efficiently, equitably and quickly as possible. SME members have expertise with the mineral exploration, mining, metallurgical, reclamation and environmental stewardship disciplines pivotal to solving the minerals emergency. We strongly support the objective to responsibly develop our nation’s mineral resources to increase domestic mineral production and reduce the United States’ precarious reliance on foreign minerals. (This is a Society for Mining, Metallurgy & Exploration (SME) Government Relations and Public Affairs Committee (GPAC) paper written by Debra W. Struhsacker and reviewed by Andrea Martin and Courtney Young.) References International Energy Agency (2025) Global Critical Minerals Outlook 2025, https://iea.blob.core.windows.net/assets/ef5e9b70-3374-4caa-ba9d-19c72253bfc4/GlobalCriticalMineralsOutlook2025.pdfU.S. Geological Survey (2022) USGS Releases 2022 List of Critical Minerals, https://www.usgs.gov/news/national-news-release/us-geological-survey-releases-2022-list-critical-mineralsU.S. Geological Survey (2025a) 2025 List of Critical Minerals, https://www.usgs.gov/media/images/2025-list-critical-mineralsU.S. Geological Survey (2025b) Interior Department Releases Final 2025 List of Critical Minerals https://www.usgs.gov/news/science-snippet/interior-department-releases-final-2025-list-critical-mineralsFederal Register (2025) https://www.govinfo.gov/content/pkg/FR-2025-11-07/pdf/2025-19813.pdfHoover Institution (2025) A Multilateral Commercial Stockpile for Critical Minerals, https://www.hoover.org/research/multilateral-commercial-stockpile-critical-mineralsS&P Global (2026) Copper in the Age of AI: Challenge of Electrification, https://www.spglobal.com/en/research-insights/special-reports/copper-in-the-age-of-aiIEA (2026) Global Critical Minerals Outlook 2026, IEA, Paris, https://www.iea.org/reports/global-critical-minerals-outlook-2026SME (2024) https://smenet.blob.core.windows.net/smecms/sme/media/smeazurestorage/pdf/nmmc-concept-paper_final_09_09_24.pdfWhite House (2025a) Unleashing American Energy, https://www.whitehouse.gov/presidential-actions/2025/01/unleashing-american-energy/White House (2025b) Declaring a National Energy Emergency, https://www.whitehouse.gov/presidential-actions/2025/01/declaring-a-national-energy-emergency/U.S. Department of State (2026) 2026 Critical Minerals Ministerial Fact Sheet, https://www.state.gov/releases/office-of-the-spokesperson/2026/02/2026-critical-minerals-ministerialExport-Import Bank of the United States (2026) Week in Review: Project Vault and the U.S. Strategic Critical Mineral Reserve, https://www.exim.gov/news/week-review-project-vault-and-strategic-critical-mineral-reserveU.S. Geological Survey (2026) Gold Statistics and Information, https://www.usgs.gov/centers/national-minerals-information-center/gold-statistics-and-information.

Critical minerals: Technical and policy considerations

Authored by: Debra Struhsacker

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