The draft US critical minerals list: Clearer priorities, persistent challenges

Since 2016, the United States has sought to reduce its economic and national security vulnerabilities related to critical minerals, a broad grouping of minerals important for industry and national defense, that the United States is highly import dependent upon and/or that have fragile domestic supply chains. This import dependence renders the US economy vulnerable to supply disruptions, coercion by suppliers, and even natural disasters at home . The US Geological Survey (USGS) publishes a list of the critical minerals it deems vital to the US economy and national security to guide related federal policy decisions, such as on mining investments, tax incentives, and mining permits. In 2022, the USGS listed 50 minerals. The 2025 draft lists 54, including copper, silicon, lithium, and zirconium.

I’ve argued before that the US critical minerals strategy needs clearer priorities . With a revised methodology informing the 2025 USGS draft list, we now have a firm basis for prioritization—with two important caveats: The monetary benchmark for inclusion on economic grounds is too low, and the list does not explicitly consider environmental or national security needs—which are the ultimate goals critical US mineral policy is meant to address.

What are critical minerals, and how do they become “critical”?

Interest in critical minerals—a term that entered the modern lexicon in 2017[1]—rose steadily in the 2020s before exploding in 2025. Associated in the popular imagination with energy transition–intensive materials like lithium, cobalt, and nickel, the term “critical mineral” also covers heavy rare earth elements used in semiconductors and national security applications . More broadly, it refers to minerals for which the United States is highly import dependent and/or susceptible to a single point of failure (SPOF, i.e., one facility closes and the whole supply chain stops) in its US domestic supply chain .

Critical minerals have loomed large in the second Trump administration’s foreign policy: They have been central to trade talks with China and the subject of weaponized Chinese export controls , US attempts to broker peace in the Democratic Republic of Congo , US negotiations to continue supporting Ukraine’s war effort , and Trump’s covetous stance toward Greenland . Through now three congressionally mandated updates, the list has included materials with common uses such as aluminum and others with such rarified uses (such as rhenium) that even specialists may not have heard of them.[2]Critical mineral status matters because it unlocks a suite of US government interventions, including Defense Production Act–related benefits, tax credits for domestic production and refining, and national stockpiling.

The new methodology is a departure from past practice. The 2022 list relied mainly on supply concentration, trade reliance, and import dependence metrics, which flagged minerals as critical if the United States was highly reliant on a small number of suppliers. In contrast, the 2025 methodology models probability-weighted GDP losses from (1,200 different) simulated one-year supply disruptions, producing an explicit economic risk expressed as projected losses to US GDP. It thus moves from static reliance indicators to a scenario-based, impact-driven framework.

The new operational definition of a critical mineral is now one for which a probability-adjusted[3]one-year import supply disruption or domestic SPOF would result in a GDP loss of at least $2 million.

This new methodology is a massive improvement over earlier iterations. It refocuses attention on actual impacts versus theoretical exposure, its probabilistic approach to supply disruptions does not default to worst-case scenarios, and it facilitates cost-benefit analysis. But the resulting list is still overly inclusive and subject to the perennial challenge of accounting for externalities.

The list is too long—but helps establish clear priorities

The $2 million GDP loss estimate cutoff amount is a lot of money in many contexts but not relative to the US economy. US GDP is presently $30.35 trillion a year; a $2 million loss would constitute 7 millionths of 1 percent of annual GDP. For a sense of scale, these are losses typically associated with a medium-sized restaurant fire . There are thousands of such fires in the United States annually, and they are not discussed—even their combined impact—as if they were consequential to the macroeconomy.[5]The table below demonstrates how the 2025 list—currently 54 minerals long—shrinks significantly at higher economic impact thresholds. At amounts exceeding $1 billion, the list comprises just six minerals—samarium, rhodium, lutetium, terbium, dysprosium, and gallium—all of which are small-volume inputs that enable massive downstream industries: defense, semiconductors, medical imaging, and electric vehicles. At amounts exceeding $500 million, the list would comprise nine; at greater than $100 million, just 20.

This distinction is important for prioritizing scarce resources. While the new USGS methodology ranks minerals according to economic risk, most of the legislative and executive perks tied to the “critical” designation—tax credits, accelerated permitting, and Defense Production Act–related benefits—are binary: A mineral is either on the list or it isn’t. That is, for most policy purposes samarium (with an average modeled GDP loss of $4.5 billion) and chromium chemicals ($2 million) are on equal footing. The USGS methodology produces a continuum of criticality; the policy environment treats it as an on/off switch. The 2025 methodology acknowledges this, offering a “statistical risk” categorization ranging from “high” to “elevated” and “moderate” to “limited.” But the “high” category still includes materials (like potash and rhodium) whose economic impacts differ by an order of magnitude.

Accounting for externalities

“Don’t talk price until you’ve established value” is an oft-mentioned key to success in sales. The new methodology establishes the price of disruption but does not consider harder-to-model nonmonetary values.

This challenge is most evident in two areas: renewable energy and national defense. The value propositions of renewable energy and national security far surpass their economic contributions to GDP. The modeled cost of a lithium supply disruption from China is $34 million. But this does not account for the noneconomic benefits of downstream technologies like lithium-ion batteries, which enable us to live mobile-yet-digitally-connected lives and transition to renewable energy.

To the extent that a supply disruption were to slow US clean energy adoption and electric vehicle sales,[6]it would slow adoption of technologies that produced air-quality and health benefits valued at $249 billion (2019–22) and prevented 1,200 to 1,600 premature deaths in 2022 alone. These kinds of considerations do not inform the USGS methodology because the model only accounts for market-mediated GDP losses as represented in input-output tables.

The same logic holds for national security. Two-inch gallium nitride (GaN) substrate—the base layer for building epitaxial semiconductor films used in advanced radar arrays and lasers—may only cost about $1,300 a piece, but the US Navy’s AN/SPY-6 advanced radar system (unit cost approximately $90 million to $100 million) cannot provide its essential function of air and missile tracking without it. Given the importance of these downstream systems, the higher costs would be eaten—demand is price inelastic.

But demand for other systems that depend on critical minerals—like precision-guided munitions, drones, and night vision goggles—is more price elastic. One fewer set of night vision goggles deployed might not sound consequential—but tell that to the spouse of a soldier killed during a nighttime ambush. Focusing narrowly on GDP losses risks misunderstanding the true importance of materials whose principal value is in providing national security or mitigating climate change.

These criticisms seem logically inconsistent: Pricing is good, but pricing doesn’t give us the whole picture. But they point in the same direction: revising the methodology to attempt to price—or at least value—these positive externalities and/or the avoidance of negative ones. A layer of analysis that accounts for health, environmental, and security externalities—using Environmental Protection Agency assessments of avoided mortality and Department of Defense assessments of mission risk, for example—could augment the new (as of 2025) approach.

The 2025 update to the USGS critical minerals list and the methodology underpinning it provide a clear, quantifiable basis for prioritization. But this clarity comes at the cost of undervaluing the noneconomic contributions of these minerals to our shared prosperity, safety, and health. Unless policymakers integrate the noneconomic values of these minerals, we risk a US critical minerals strategy that misses the forest for the trees.

Notes

1. This is true in a technical sense. Dating back to World War I, the United States has monitored a list of “war minerals” to support the war effort. The term "critical mineral" became the standard term used by the USGS in 2017.

2. Global production of aluminum was around 72 million metric tons in 2024; for rhenium, it was 62 MT. One of the densest materials known to humanity, 62 MT of pure rhenium would be about the size of a standard home refrigerator. See USGS mineral commodity summaries for 2025.

3. To account for some scenarios being more plausible and probable than others.

4. The distinction about prices is important because, in theory, a foreign supply shock could result in a net benefit to the US economy if the commodity is exported at higher global prices.

5. It should go without saying that they are still consequential for the communities where they occur and their owners and employees.

6. To be clear, the most significant current threats to US deployment of clean energy are not supply shock related.