Critical Minerals List 2025
USGS and DOE Overview

USGS published the final 2025 List of Critical Minerals on November 7, 2025, expanding the count from fifty to sixty. China's Ministry of Commerce, the same day, suspended the rare earth export controls it had imposed a month earlier, then on November 9 extended the suspension to gallium, germanium, antimony, and superhard materials. Xi and Trump had met in Busan on October 30 and lashed tariffs, semiconductor restrictions, and mineral exports into one deal, and the simultaneous November 7 announcements from Washington and Beijing were both sides delivering.

What USGS Recommended Versus What Got Published

The USGS model said add six: potash, silicon, copper, silver, rhenium, lead. Drop two: arsenic and tellurium. Net: 54. The published list has 60.

Metallurgical coal and uranium got in through Section 7002(c)(4)(B) of the Energy Act of 2020, which lets the Secretary of the Interior override the Act's own criteria if another federal agency considers the mineral strategic to national defense. This is significant specifically because the Energy Act excludes fuel minerals and both met coal and uranium are fuel minerals. Uranium was on the 2018 list, pulled in 2022 for that reason, reinstated in 2025 via the override after DOE supplied a supporting letter. The Federal Register filing attributed the recommendation to "the Department of Energy, Department of War, and Department of Agriculture," and the Department of War has been the Department of Defense since 1947.

Arsenic and tellurium: the model said drop them, the final list kept them for "another cycle of refreshed data and modeling." Boron: USGS could not model ferroboron directly, but ferrosilicon, ferrotitanium, and ferrochromium all had Chinese market share between 70% and 80% and hit high GDP numbers, so boron came in on structural analogy. Phosphate was the Agriculture Department's push. Multiple law firms confirmed after publication that minerals absent from the August draft were added after industry and congressional lobbying. The draft solicited comment specifically on met coal and uranium, drew 163 responses, and four minerals not in the draft made the final version: metallurgical coal, uranium, boron, phosphate.

Metallurgical Coal

Every number the USGS model produces flows from an import-disruption premise. Over 1,200 trade disruption scenarios, 84 minerals, 402 industries, all organized around the question of what happens to GDP when imports get cut. The United States is the second-largest metallurgical coal exporter on the planet and supplies most of its own domestic consumption from domestic mines.

Executive Order 14261, April 8, 2025, told the Secretary to evaluate met coal for the list. What the inclusion does is qualify coal projects for federal funding, DPA investment, FAST-41 accelerated permitting. Global steel meanwhile is shifting to electric arc furnaces that use scrap metal instead of coke and do not need metallurgical coal. Most U.S.-mined met coal is exported to foreign steelmakers, and the Sierra Club's industrial campaign lead pointed out that subsidizing met coal production primarily benefits the overseas steelmakers buying those exports.

Until 2025, "critical mineral" meant supply-vulnerable. Met coal is not supply-vulnerable. Its inclusion means "critical" can now also mean "strategically important to a favored industry regardless of supply status," which will invite a longer line of applicants.

Copper and Resolution Copper

Copper is the most defensible new addition on technical grounds: demand around 2.5 million tons, production around 1 million, Arizona about 70% of domestic output. The Biden-era USGS declined to recommend it, and Senators Kelly and Lee introduced the Critical Minerals Consistency Act in February 2025 whose main effect would have been forcing copper onto the list and accelerating permitting for Resolution Copper. USGS's 2025 methodology, running on 2023 data, provided the technical basis.

After the designation, April 2025, Resolution Copper went on the FAST-41 list. March 2026, the Forest Service completed the Oak Flat land exchange.

I want to spend more space on this project than on anything else in this article because it is the single most revealing case of what the critical mineral label actually does once it leaves the Federal Register and enters the physical world.

Resolution Copper holds roughly 40 billion pounds of copper beneath Chi'chil Bildagoteel, a mesa the San Carlos Apache Tribe has used for ceremonies and rites of passage for generations, with the ore body sitting nearly 7,000 feet down and the Forest Service projecting a subsidence crater close to two miles wide and over 1,100 feet deep. Rio Tinto holds 55%, BHP 45%, and they have spent over $2 billion on development and permitting. Rio Tinto's largest shareholder is Chinalco, a Chinese state-owned enterprise holding close to 15% of Rio Tinto's equity, and the project is being advanced under the banner of reducing dependence on foreign adversaries for critical minerals.

Independent mineral appraisers expect the concentrate to ship to Southeast Asia for smelting. Kennecott, the nearest domestic option (also Rio Tinto), is near capacity. There are two copper smelters in the entire United States. China refined roughly 12,000 metric tons of copper in 2024, the U.S. about 890, and the Arizona Mining Association's executive director has said publicly that shipping concentrate overseas has been standard for decades, driven by cost and environmental regulation. So the critical mineral label accelerated permitting, the permitting advanced mining beneath a sacred site, and the ore will most likely leave the country for smelting in Asia, with extraction costs staying in Arizona and smelting economics going offshore, and one of the principal financial beneficiaries of the entire chain being a Chinese state enterprise.

If copper had been listed alongside a parallel initiative to build domestic smelting capacity, or if FAST-41 designation carried a domestic-processing requirement, the picture would look different. Neither of those things happened, and the absence is not an oversight that will be corrected later; it reflects the fact that smelter construction in the U.S. faces the same permitting, environmental, and cost barriers that make it cheaper to ship ore to Asia in the first place. The critical mineral designation accelerates mining but has no mechanism to accelerate the downstream infrastructure that would make the mining strategically useful. This is not a gap that cleverer list management can fix. It is a gap between the analytical framework (which correctly identifies midstream risk) and the policy toolkit (which has no midstream instrument), and it will persist until Congress creates one.

The appraisers who examined the project and concluded the ore would leave the country were hired as part of a land-exchange valuation process that Resolution Copper fought in federal court to keep confidential. The Center for Biological Diversity won a public-records lawsuit to force disclosure. The appraisals had been secret until then. The fact that the ore's likely destination was not part of the public record during the years of debate over the land exchange means that the entire discussion about Oak Flat proceeded without one of the most material facts about the project's economic geography being on the table.

One more thing about Resolution Copper. The average U.S. mine takes 29 years from discovery to production according to S&P Global, and Resolution is already past 20. The project started its U.S. Forest Service permitting process in 2013. The critical mineral designation and FAST-41 placement in 2025 compressed a timeline that had been stalled for over a decade. Senator John McCain inserted a rider authorizing the land swap onto a must-pass defense bill in late 2014. In 2021, Representative Raúl Grijalva introduced a bill to permanently protect Oak Flat from mining; it drew over 100 House co-sponsors and passed his committee but died without a floor vote. Grijalva died in March 2025. The land exchange was completed a year later. The project has been shaped by the deaths, retirements, and electoral defeats of its opponents as much as by any policy decision, and the critical mineral designation landed at the moment when the political obstacles had been cleared by time and attrition rather than by argument.

Uranium

On the 2018 list, off the 2022 list, back on the 2025 list. AI power demand revived the nuclear conversation. One commercial enrichment facility in the country. One conversion facility. Steep import dependence. The legal exposure is the pathway: entered through the notwithstanding clause, not the USGS model, and environmental groups have signaled challenges.

Eight Minerals Where Disruption Helps American GDP

For gold, molybdenum, silicon metal, helium, iron ore, zinc, copper, and nickel at the mining stage, the USGS model produces a positive GDP result from global supply disruption, because prices rise and net exporters collect. Copper is one of those eight and it is on the critical minerals list, because at the refining and fabrication level the import dependence is deep and there are two smelters in the country. The 2025 methodology's processing-stage risk upgrade is what allowed copper to cross the threshold despite the positive mining-level number.

The $2 Million Threshold

Probability-weighted GDP impacts across the 84 assessed minerals range from nearly $4.5 billion to a net increase of $33 million. Inclusion cutoff: net decrease exceeding $2 million, which USGS acknowledged in the report is too low for resource allocation and should be raised by policymakers for that purpose. The floor was set for comprehensive coverage.

The five-tier internal ranking has the discriminating power. Highest: rhodium, gallium, germanium, tungsten, niobium, magnesium metal, potash, samarium, lutetium, terbium, dysprosium, gadolinium, yttrium. Twelve to fifteen minerals. Three orders of magnitude separate the top and bottom of the list.

Canada

Potash is the highest-risk new addition and comes almost entirely from Canada. Between 1989 and 2023, Canada imposed export prohibitions, quotas, or licensing requirements on mineral commodities in 8 separate years, Russia in 6, South Africa in 4. Canada's mineral export volume to the U.S. is so large that a low-probability disruption creates an outsized GDP hit. USGS stress-tested by dropping the Canadian disruption probability from 11% to 1.1% and even at 1.1% the probability-weighted GDP loss was about $41 million, twenty times the inclusion threshold, because potash feeds fertilizer and fertilizer feeds agriculture. Niobium (Brazil), aluminum (Canada), copper (Chile), platinum (South Africa) show the same low-probability-high-impact pattern. Tungsten runs the opposite direction: higher probability via China, smaller footprint.

China remains the primary GDP-loss contributor for 32 of the 50 minerals entering through economic modeling. The new model's contribution is putting dollar figures on ally-supplier risk that previously existed only as a talking point.

USGS and DOE

USGS asks what happens to GDP if supply gets cut today, retrospective, 2023 data, 84 minerals, 402 industries. DOE asks which materials face demand explosions from clean energy deployment over the next 5 to 10 years, prospective, IEA energy models, only materials DOE judges relevant to energy tech. DOE flagged copper and silicon as critical in 2023. USGS, running 2022 methodology on 2015-2018 data, said they were not. Two years apart on copper.

Six minerals on the USGS 2025 list (boron, lead, phosphate, rhenium, silver, uranium) absent from DOE's 2023 list. Electrical steel and silicon carbide on DOE's list, never assessed by USGS (manufactured materials). Uranium excluded from DOE's list (fuel mineral restriction), on USGS's list (notwithstanding clause). DOE added metallurgical coal May 22, 2025, plans a full assessment update in 2026.

USGS drives FAST-41 permitting. DOE plugs into IRA 48C credits and energy incentive programs. A mining company has to track both and determine which version each program references.

45X

Hardcoded to the 2022 list. Not the 2025 list. Copper, silicon, silver, potash, rhenium, lead not eligible for 45X credits until Congress amends the statutory reference, which it has not done. FAST-41 tracks to the current list (permitting benefit is live), 45X does not (tax benefit is not). Thirty-five mining projects had FAST-41 transparency designation as of August 2025.

China

China started restricting gallium and germanium exports in July 2023 and by October 2025 had layered on controls covering graphite, antimony, superhard materials, tungsten, tellurium, bismuth, molybdenum, indium, seven medium and heavy rare earths, rare earth processing equipment, technology transfers, and the activities of Chinese nationals supporting overseas rare earth production. The October 9, 2025 round went qualitatively beyond everything before it because Beijing was reaching past commodities into technology and expertise, and claiming jurisdiction over foreign products containing Chinese-origin inputs.

The April 4, 2025 controls on seven medium and heavy rare earths (samarium, gadolinium, terbium, dysprosium, lutetium, scandium, yttrium) were the ones that bit hardest. Case-by-case export licensing, imposed after Trump's "Liberation Day" tariffs, effectively severing reliable supply to Western defense manufacturers. Six of the seven sit in USGS's highest risk tier.

China holds over 90% of global rare earth processing capacity. Western replacement projects (Serra Verde in Brazil, Lynas in Texas, MP Materials' magnet factory) are racing the November 2026 expiry. Chinese customs data for November 2025 showed exports up 9% month-on-month to 4,343 metric tons after three months of decline, which is a mechanical bounce from the suspension lifting.

The Methodology

The 2018 methodology was qualitative with two quantitative inputs (production concentration, import reliance) and a subjective importance assessment. The 2022 version added a single-point-of-failure criterion and converted importance to numbers but could not compare one mineral's risk to another's in the same units. The 2025 version can: 1,200-plus disruption scenarios, 84 minerals, 402 industries, post-disruption equilibrium from supply-demand elasticities and spare capacity, nonlinear optimization on input-output tables tracing price shocks sector by sector, each scenario weighted by occurrence probability from barrier history, export dependence, political stability. Output: probability-weighted net GDP decrease per mineral in dollars, comparable across all 84 and against other categories of national economic risk.

The model's optimization core uses a computational economics solver (interior-point method, Python optimization library), and the team producing the list is pricing trade disruption rather than classifying mineral deposits. The shift in which discipline owns the "critical" designation has received almost no discussion.

USGS committed to updating at least every two years. DOE plans its next assessment in 2026.