Highlights

• Six new minerals added to the list, including potash and copper.
• The U.S. remains vulnerable to geopolitical supply chain risks.
• The USGS disruption model simulated over 1,200 trade-shock scenarios.
• Rare earth elements identified as the most economically critical.
• Draft highlights gaps in the U.S. mineral strategy:
  • Dependence on China.
  • Lack of concrete domestic production projects.

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The U.S. Department of the Interior (DOI) has released its draft 2025 List of Critical Minerals (opens in a new tab)—54 commodities flagged as essential to America’s economy and security. This update matters: the list guides permitting, stockpiles, tax incentives, and federal investments in mining and processing. For investors, it signals where Washington’s money and attention will flow over the next three years.

What Changed

Six new minerals—potash, silicon, copper, silver, rhenium, and lead—are recommended for inclusion. Arsenic and tellurium are slated for removal. Zirconium was added due to “single-point-of-failure” risk. This draft marks the second major revision since President Trump’s 2017 executive order jump-started the process, and it reflects new modeling advances mandated under the Energy Act of 2020.

The USGS disruption model simulated over 1,200 trade-shock scenarios across 84 minerals and 402 industries. It ranks the top 10 minerals by probability-weighted GDP impact: samarium, rhodium, lutetium, terbium, dysprosium, gallium, germanium, gadolinium, tungsten, and niobium. Rare earths dominate the list, highlighting how exposed defense and clean-tech supply chains remain to geopolitical risk.

What’s Missing

The methodology is a leap forward, but the framing is tilted toward short-term import disruption, not the deeper structural risks:

China dependence

The list quantifies GDP risk but does not foreground Beijing’s near-monopoly in heavy rare earths, gallium, and germanium. Modeling disruption scenarios is useful, but without binding U.S. industrial commitments, the list risks becoming another policy document on the shelf.

Project pipeline reality

The DOI announcement emphasizes “domestic production” yet does not name a single U.S. mine project. Will permitting reform truly accelerate Lynas’ Texas heavy REE plant, MP Materials’ Stage II, or Energy Fuels’ monazite build-out? Silence here is telling.

Stockpile strategy

No clear linkage between the disruption model and Defense Production Act stockpile planning. The National Defense Stockpile remains underfunded compared to the billions modeled in potential GDP hits.

Annual updates

The draft floats moving to yearly technical updates, but absent enforcement, investors will question if Washington can keep pace with fast-moving supply shocks.

Investor Takeaway

The 2025 Critical Minerals List sharpens the economic lens on supply risk and expands the scope to 54 commodities. But until the U.S. pairs lists with shovel-ready projects, funding mechanisms, and enforceable stockpile targets—not to mention workforce and other related factors-- America remains reactive, not proactive. On balance, this is progress wrapped in process—the big test will be whether Burgum’s DOI links the list to actual permits, projects, and capital flows.

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