The U.S. is moving to secure critical minerals supply chains, following a Section 232 investigation—a law allowing review of imports that could threaten national security. The probe found these minerals are vital for defense and the economy, but price volatility discourages investment and alternative supply chains outside of China. In response, the Trump administration launched the $12 billion “Project Vault” stockpiling program and directed trade agencies to negotiate with allies using tools like price floors, rather than imposing tariffs or import restrictions, to strengthen supply-chain security amid rising geopolitical tensions.

“[The Commerce Department] found that imports threatened national security—but instead of imposing tariffs, the President directed negotiations,” International Trade senior counsel Sahar Hafeez told MINING.com. “The President directed [the United States Trade Representative] and Commerce to negotiate with other countries to address these national security threats and to consider price floors and other trade-restricting measures.”

On the impacts of a border-adjusted price floor, Hafeez, who also co-leads Pillsbury’s Minerals, Metals and Materials practice, pointed out a key question: “What is it based on? What is the reference price?”

“Right now, many of these commodities—particularly where there is significant concentration in China—are priced off Chinese markets,” she said. “So, what becomes the benchmark? We don’t yet know how this would be implemented—whether it would apply to downstream products, or whether we could see changes to rules of origin in trade agreements.”

Hafeez noted that a central focus of the policy is establishing price floors and potentially linking market access to these pricing mechanisms, with the U.S.-Mexico action plan representing the clearest example of how this could work so far.

Looking ahead, she said the key developments to watch are the rollout of the U.S.-Mexico action plan and the upcoming U.S.-EU-Japan action plan, both of which are expected to shed light on how price floors or other mechanisms might be implemented in practice.

“Implementation of the U.S.-Mexico action plan and the forthcoming U.S.-EU-Japan action plan are key—those will tell us what this actually may look like in practice,” she noted.

“Which minerals are prioritized, how a price floor is calculated, and who signs on—those are the critical next steps,” she said. “This is essentially about taking steps to redesign the market architecture for critical minerals.”

To read the full article, click here.