Before the end of the year, the US Geological Survey will publish a revised critical minerals list, which will shape defense strategy and stockpiling. The Energy Act of 2020 requires the Department of the Interior to revisit the list every three years, so the upcoming USGS list will be the first update since 2022.
This is a new list for a new administration; it will likely reflect the President’s aims and priorities. Already, President Trump’s executive orders indicate the direction of his critical mineral policy. An examination of possible additions to the USGS list will provide insights into a strategy that is becoming increasingly clear: more targeted interventions across a wider range of materials.
Many of these insights come from the Executive Order 14241, or Immediate Measures to Increase American Mineral Production. In this action, President Trump directed federal agencies to accelerate mineral production using changes in permitting, land usage, and emergency powers. He also ordered that several materials–copper, uranium, potash, and gold–be treated as critical minerals for the purpose of the order.
Few materials have received more attention in the last six months than copper. The President seems to be particularly focused on it: in February, he ordered a section 232 investigation into the national security risks of imported copper. By July, he imposed a fifty percent tariff on semi-finished products and intensive derivative products. Although demand is expected to double by 2030 because of its essential usage in electric vehicles, AI infrastructure, and other industrial uses, it was not included in the 2022 USGS list. That seems likely to change.
EO 14241 also directed that gold be treated as a critical mineral. Although it lacks the widespread industrial usage of copper or lithium, gold is used in small quantities for some commercial and defense technology.
In addition, the order stated that potash be included within the category of critical mineral. The idea of naming potash, the term for a range of potassium-heavy minerals used for fertilizer, is not without precedent. An unpassed bill in March 2024 would have directed USGS to include potash on the critical minerals list alongside phosphate. But potash, unlike the other EO materials, was removed from the USGS list in 2022. And while the US is import-reliant for more than ninety percent of its potash, about eighty percent of those come from Canada.
Uranium, unlike other EO 14241 material, faces a unique hurdle to inclusion on the 2025 USGS list. The text of the Energy Act of 2020 specifies that only non-fuel minerals can be included on the list. However, it is entirely possible that uranium could be included anyway, despite its usage as fuel for the administration’s nuclear power ambitions.
Finally, the One Big Beautiful Bill Act included metallurgical coal as a commodity eligible for a critical mineral tax credit. The production of metallurgical coal, or coal suitable for steelmaking, will merit a 2.5 percent tax credit that terminates in 2029. Much like copper, the inclusion of metallurgical coal aligns with the President’s Section 232 investigation and tariffs on steel. These policies collectively place a heavy finger on the scale for domestic production of steel and the requisite raw materials.
This examination of possible additions to the USGS critical minerals list raises an obvious question: what difference does it make for production if a given material is on the list?
In some ways, the benefits of critical mineral designation have diminished. The OBB Act entirely phases out the 45X tax credit, which offers tax credits equal to 10 percent of mineral production costs, by 2034. However, given the administration’s efforts to accelerate permitting for critical mineral projects, designation could attract the necessary federal approval to jumpstart extraction and production.
These possible inclusions fit within the administration’s mineral strategy: offer support on a case-by-case basis across a wider range of materials. After the success of the MP Materials-DOD deal, the administration has indicated that it will pursue future deals to support mineral production. But the price floor offered for rare earth production (with a global market value of $4 billion) could not possibly be extended to the copper market valued at $300 billion globally. A growing list of critical minerals indicates a growing range of strategies; there is no universal solution to achieve mineral security.
The world has changed over the last three years. Whether USGS includes each of these materials or none of them, the upcoming critical minerals list should reflect those changes.
* Farrell Gregory is a non-resident fellow at the Foundation for American Innovation.
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