Highlights

• Ukraine formally classified 11 strategic and 28 critical minerals
• 86 subsoil areas designated for potential development
• The policy aims to:
  • Align with EU and U.S. priorities
  • Attract foreign investment
  • Improve supply chain integration
• Execution challenges remain, including:
  • War-related risks
  • Unclear enforcement timelines

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In a major policy step, Ukraine has formally adopted Resolution No. 845, establishing national lists of strategic and critical minerals. The July 14, 2025, decision aims to align Ukraine’s resource governance with EU and U.S. priorities, attract foreign investment, and deepen supply chain integration—especially for rare earth elements, lithium, graphite, titanium, and other high-demand minerals.

The lists include:

• 11 minerals of strategic importance (e.g., aluminum, uranium, titanium)
• 28 minerals of critical importance, notably rare earths, scandium, lithium, and vanadium

Ukraine has also designated 86 subsoil areas (mineral deposits) for public auction or PSA-based development, aiming to increase transparency and boost investor confidence.

Strong Intentions, Unproven Execution

The classification move is accurate and in line with global best practices. Countries like Australia, Canada, and the U.S. have adopted similar lists. Ukraine is also acting in accordance with Chapter 13 of its Ukraine Facility Plan, mirroring the EU's critical raw materials strategy goals.

However, policy declarations are only the beginning. The real question is whether Ukraine can deliver the legal clarity, environmental oversight, and security guarantees required for Western capital to flow into its extractive sector—especially with a war still ongoing.

What’s Assumed or Omitted

• No clarity on enforcement timelines: How will the subsoil areas be auctioned? When? What protections exist for PSA partners? These remain open.
• The war factor is underplayed: Ongoing Russian aggression poses serious challenges to infrastructure, logistics, and risk insurance—yet the release barely mentions this.
• No detail on ESG framework: International partners expect Ukraine to comply with environmental and labor standards. The piece lacks detail on how this will be monitored, particularly at high-impact sites like the Dobra lithium deposit.

Bottom Line: A Necessary First Step—Now Comes the Proving Ground

Ukraine has abundant mineral wealth, including significant REE and battery metal reserves, and it’s signaling to the world that it’s open for business. But declarations don’t move drill rigs. For Ukraine’s Resolution No. 845 to matter, investors will need not just auctions and maps—but contracts, infrastructure, and confidence.

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