USGS Seeks Comment on 2025 Critical Minerals List to Guide U.S. Mineral Supply Chain Policy

Below we provide more information about the Critical Minerals List, USGS’s methodology and the 2025 draft Critical Minerals List, and issues for comment and next steps. 

Critical Minerals List
Under Section 7002 of the Energy Act of 2020 (Act), the Secretary of Interior, acting through the Director of USGS, is required to maintain a list of critical minerals— defined as any “mineral, element, substance, or material” (excluding, among other things, fuel minerals) deemed essential to U.S. economic or national security, vulnerable to supply chain disruption, and serving an essential role in manufacturing. Specifically, USGS determines which minerals:

• 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, anti-competitive or protectionist behaviors and other risks throughout the supply chain); and
• serve an essential function in the manufacturing of a product (including applications related to energy technology, defense, currency, agriculture, consumer electronics and healthcare), the absence of which would have significant consequences for the economic or national security of the United States.

USGS may also designate critical minerals determined by other federal agencies as “strategic and critical to the defense or national security of the United States.”   

USGS is required to review its list of critical mineral designations and underlying methodology at least every three years. Prior Lists were published in 2018 and 2022.

Per Section 7002 of the Act, USGS published for comment a description of the draft methodology used to identify the minerals proposed for inclusion in the Critical Minerals List, a draft list of proposed critical minerals under the methodology, and an identification of critical minerals from the draft list that are recovered as byproducts and their host minerals.

Methodology and Mineral Commodities Proposed for Inclusion and Removal 
While the methodology for the 2025 Critical Minerals List maintains the framework of that for the 2022 List, it builds upon the 2022 methodology by assessing foreign trade disruptions probabilistically and providing results per mineral commodity in terms of probability-weighted net decreases in U.S. GDP. 

USGS’s methodology for the 2025 Critical Minerals List considers two criteria:

1. an economic effects assessment quantifying the effects of trade disruptions on the U.S. economy as measured by changes to U.S. Gross Domestic Product (GDP). The trade disruption scenarios account for the probability of each scenario’s occurrence. For example, the probability of an export restriction is 100% for scenarios involving China’s trade disruptions of minerals that China has to date targeted for export restrictions or bans while that figure was lower for other minerals China has not to date targeted and for scenarios involving trade disruptions from other countries. The results are presented in terms of changes to U.S. GDP by individual industry (based on an estimate of consumption of the mineral in that industry) and the economy. Minerals with probability-weight net decreases of over $2 million in U.S. GDP on an annual basis are included in the Critical Minerals List. If this threshold is not met with respect to a particular mineral, that mineral is assessed under the second criterion.
2. an assessment of whether the mineral’s U.S. supply chain relied at particular stages on a sole producer that represented a single point of failure.” This criterion is applied to zirconium in which case USGS noted that there is one domestic producer of fused zircon and no domestic producer of zirconium oxychloride, both of which are needed for the production of zirconium metal.       

Based on the criteria described above, for the 2025 Critical Minerals List, USGS recommends adding six mineral commodities (potash, silicon, copper, silver, rhenium, and lead) and removing two (arsenic and tellurium). USGS also reviewed—but did not propose to include—the following minerals: arsenic, cadmium, feldspar, gold, helium, iron ore, mica, molybdenum, phosphates, selenium, strontium and tellurium.

The table below provides the mineral commodities recommended for inclusion in the 2025 Critical Minerals List and the bases for their inclusion under USGS’s methodology for the List.

Source: USGS, August 2025. The methodology breaks down certain mineral commodities in particular forms.

Issues for Comment and Next Steps 
USGS will finalize the list following the public comment period. USGS is seeking input on, among other things: (1) whether other minerals should be added to the 2025 Critical Minerals List, with a justification; and (2) whether updates should move from every three years to annually.

USGS also advised that, in finalizing the list, policymakers across the U.S. government may consider risks other than those assessed in the methodology, such as risks of disruptions from natural hazards, strategic importance of relevant consuming industries, projected demand and national security impacts of disruptions. The comment period provides an opportunity for stakeholders to address USGS’s methodology as well as risks identified above or other risks with respect to particular mineral commodities. 

As noted above, the Critical Minerals List is intended to inform U.S. government policies, strategies, and tools to secure critical mineral supply chains, including “direct investments in mining and resource recovery from mine waste, stockpiles, tax incentives for U.S. mineral processing, and streamlined mining permitting.” As we discuss here, investing in domestic production, including for processing, and streamlining permitting processes are priorities of the Trump administration with respect to mineral supply chains. Also, as we discuss here, the Department of Energy (DOE) has issued notices for the demonstration of the commercial viability of methods for refining and recovering rare earth elements from mine tailings and waste streams and for technologies to recover critical minerals from industrial wastewater.

Relation to Other U.S. Government Lists 
Other agencies maintain priority mineral lists based on their specific mandates:

• The Department of Defense’s Defense Logistics Agency maintains a list of strategic materials. 
• The Department of Energy maintains a list of materials critical for energy, discussed here based on criteria involving importance to energy and supply risk, and has sought input on aligning its list with USGS’s approach.

Conclusion
The 2025 Draft Critical Minerals List represents an important opportunity for stakeholders to influence U.S. supply chain and national security policy. Given its potential to guide investment, permitting, and processing initiatives, active participation in the comment process will help shape how the U. S. government manages critical mineral resources in the years ahead.