The Trump Administration Launches Plurilateral Initiative and a Strategic Reserve to Secure Critical Minerals Supply Chains

Below we discuss these actions, next steps and implications for companies.

Critical Minerals Ministerial
On February 4, Secretary Rubio, joined by Vice President JD Vance, Treasury Secretary Scott Bessent, Interior Secretary Doug Burgum, Energy Secretary Chris Wright and U.S. Trade Representative Ambassador Jamieson Greer, hosted the 2026 Critical Minerals Ministerial, which was attended by representatives from 54 countries and the European Commission. Delegations from the following countries attended: Angola, Argentina, Armenia, Australia, Bahrain, Belgium, Bolivia, Brazil, Canada, Cook Islands, the Czech Republic, the Democratic Republic of the Congo, the Dominican Republic, Ecuador, Estonia, the European Commission, Finland, France, Germany, Greece, Guinea, India, Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Lithuania, Malaysia, Mexico, Mongolia, Morocco, New Zealand, Norway, Oman, Pakistan, Paraguay, Peru, Philippines, Poland, Qatar, the Republic of Korea, Romania, Saudi Arabia, Sierra Leone, Singapore, Sweden, Thailand, the Netherlands, Ukraine, the United Arab Emirates, the United Kingdom, Uzbekistan, and Zambia.

This follows President Trump’s announcement of findings in connection with the investigation under Section 232 of the Trade Expansion Act of 1962 (Section 232) of the national security impacts of processed critical minerals imports. As we discuss in our prior client alert here, President Trump concurred with the findings of the Department of Commerce (Commerce) that imports subject to the investigation threaten national security, citing, among other things, price volatility in critical mineral markets and a decline in critical minerals production, and directed Commerce and the U.S. Trade Representative (USTR) to negotiate agreements or continue current negotiations to address national security threats and to consider “price floors for trade in critical minerals and other trade-restricting measures” as part of such agreements.  

Toward that end, during his remarks, Vice President Vance highlighted the importance of creating competitive critical mineral markets, noting the issue of diverse/domestic investments being undermined by cheap critical minerals flooding the market and proposed “a preferential trade zone for critical minerals, protected from external disruptions through enforceable price floors,” which will entail establishing “reference prices for critical minerals at each stage of production, pricing that reflects real-world, fair-market value.” As we discuss below, additional details regarding the reference prices and implementation are currently being deliberated.

Key Outcomes from the Ministerial:

• The United States signed 11 new bilateral critical minerals frameworks or MOUs with Argentina, the Cook Islands, Ecuador, Guinea, Morocco, Paraguay, Peru, the Philippines, the United Arab Emirates and Uzbekistan. As we discuss here, the Administration has previously signed critical mineral MOUs or frameworks with Australia, Japan, Malaysia, Thailand, Ukraine, Saudi Arabia, Democratic Republic of Congo (DRC) and Pakistan. Generally, many of these MOUs provide for cooperation on investing in projects, streamlining permitting, and establishing high-standard marketplaces with pricing frameworks to provide protection against non-market policies and practices.
• Secretary Rubio announced the creation of FORGE as the successor to the Minerals Security Partnership (MSP), which was established under the Biden administration and brought together various partners to coordinate funding of critical mineral projects. As was the case for the MSP, FORGE will be chaired by the Republic of Korea through June 2026. FORGE partners will collaborate on policies and projects to advance diversification of critical mineral supply chains. According to reports, all MSP partners (namely the United States, Australia, Canada, Estonia, Finland, France, Germany, India, Italy, Japan, Norway, the Republic of Korea, Sweden, the United Kingdom and the European Union) signed onto FORGE.
• The United States, the EU and Japan jointly announced the following:

-Within 30 days, the EU and the United States will conclude an MOU, which will identify areas of cooperation to stimulate demand and diversify supply by identifying and supporting projects in the mineral supply chain, include measures to prevent supply chain disruptions, promote research and development, and share info on stockpiling.

-Japan, the EU and the United States will develop an Action Plan, which could include “exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors, standards-based markets, price gap subsidies, or offtake-agreements.”

• The United States and Mexico announced an Action Plan on minerals. Under the Plan, within 60 days, both parties will “discuss the feasibility and development of coordinated trade policies and mechanisms, including border-adjusted price floors for critical minerals imports, focusing in the first instance on certain select critical minerals to be determined.” The parties will also consult on how price floors as well as other areas of cooperation, such as, among others, trade measures to support a resilient critical minerals marketplace, investment promotion and screening, coordinated stockpiling, and technical and regulatory cooperation, can be included in a plurilateral agreement on trade in critical minerals. The parties will also identify specific projects of mutual interest to the parties or third countries.

The Department of State’s fact sheet also outlined investments in critical mineral projects by various U.S. Government agencies, including the Department of War, EXIM, the Development Finance Corporation, and the Department of Energy. Commerce has also made investments in certain mineral projects where there is a link to semiconductors under the CHIPS and Science Act, and the U.S. Trade and Development Agency also makes investments to support early-stage critical mineral technologies and projects.

Project Vault
On February 2, President Trump announced Project Vault, a public-private partnership, which will store critical minerals in a strategic reserve intended to provide stability of supply to civilian industries in the event of a market disruption. EXIM will utilize its statutory authorities to provide loans to an independent third-party entity to facilitate transactions for Project Vault. Any of the 60 minerals on the 2025 U.S. Geological Survey’s Critical Minerals List (which we discuss here) could be included in the reserve, and the set of minerals ultimately included will be driven by Original Equipment Manufacturers (OEMs), which will provide details regarding critical minerals to be purchased for the reserves, including forms, quantities and grades. Suppliers serving the Vault (including Hartree Partners, Mercuria Americas and Traxys) will purchase the requested material requested by OEMs on behalf of the independent entity governing the Vault. The critical minerals may be sourced from foreign sources utilizing EXIM’s authority to finance material that has offtake for the United States. If material is sourced from a country that has implemented a price floor, the material may be subject to that price floor upon purchases for the reserve for locations in the United States.

The EXIM loan and private capital will be used to fund the purchase and storage of critical minerals for the reserve, and OEMs will make long-term commitments regarding materials to be stored in the reserve and pay a commitment fee to participate. In regular course, OEMs can withdraw up to a certain quantity from the reserve as long as they replenish the material up to their agreed-upon commitment. OEMs can access material in the reserve when specific market conditions (or triggers) are met. This may include, for example, export restrictions or certain market conditions that constrain supply.

Project Vault is distinct from the National Defense Stockpile (NDS) in several respects. Among other things, the NDS is operated by the Department of War’s Defense Logistics Agency and is intended to provide a reserve to support national defense needs; by contrast, Project Vault is a public-private partnership, which is governed independently and intended to provide a reserve to support civilian needs. 

Next Steps and Key Implications for Companies
The initiatives provide significant policy direction from the Administration while a number of details are subject to further negotiations. With respect to price floors, key issues include the reference price or the bases on which the price floors will be set, the initial set of minerals of focus, and implementation of price floors, and the set of countries that will agree to implement price floors. The U.S.-Mexico Action Plan, which will be implemented over 60 days (or by approximately early April 2026) may provide concrete information regarding the bases for the price floors and how they will be implemented, such as via a Minimum Import Price. Also, the pending U.S.-EU-Japan Action Plan, which, as noted above, may include “border-adjusted price floors” or other measures such as “standards-based markets, price gap subsidies, or offtake-agreements” will provide import direction regarding the path forward. Finally, the set of countries that will ultimately implement price floors or other trade-restrictive measures is to be determined. On February 13, 2025, USTR Greer hosted a virtual ministerial with G7⁺countries to “on a potential Agreement on Trade in Critical Minerals.”

With regard to the ongoing negotiations and Project Vault, key issues and opportunities for companies include:

• OEMs have opportunities to participate in Project Vault to avail themselves of the reserve. Participating in Project Vault would involve, among other things, assessing at-risk minerals in an OEM’s supply chain, which could include coordination with suppliers at the appropriate supply chain vertical, which could be at Tier 3 or beyond levels depending on the product.
• OEMs will need to consider the form of material in the reserve and whether that material will need to be further processed before use and coordinate with relevant suppliers.
• Suppliers in the United States and around the world have opportunities to supply OEM-requested material for Project Vault.
• The impact of price floors on the economic viability of projects. For example, price floors could provide protection to producers and investors against risks of price volatility.
• Price floors could potentially lead to increased costs for OEMs. 
• Opportunities under the various bilateral and plurilateral initiatives outlined above for diversifying supply chains or for sourcing or providing feedstock for companies involved in the critical minerals production value chain. This will involve an assessment of capabilities of relevant countries to produce particular minerals and subsequent engagement with the U.S. and ally/partner governments for support and funding opportunities. The appropriate agency or agencies for engagement will depend upon, among other things, the location of the project, the Technology Readiness Level of the project, and the specific request for support.
• Whether coordination between the United States and ally/partner governments under the various initiatives outlined above will include coordination with respect to Project Vault.