Policy & Export Control Tracker

Batteries on EU market must contain minimum percentage of recycled cobalt, lithium, nickel, lead. Specific percentages via delegated acts (expected 2028–2029).

New EV/industrial batteries must contain ≥6% recycled lithium, rising to 12% by 2036.

New EV/industrial batteries must contain ≥6% recycled nickel, rising to 15% by 2036.

Target 500-1,000 tonnes of tantalum reserves (up from <100 tonnes). Defence Production Act invocations under consideration for domestic refining. IRA 30% investment tax credits for critical mineral processing.

All battery recycling must achieve ≥90% cobalt recovery. Current rate ~3% of Li-ion batteries. Drives commercial recycling infrastructure investment.

First assessment of progress toward 10-15% EU refining, 25-30% recycled supply targets. Extended producer responsibility requirements take effect.

Massive VRFB deployment target would require tens of thousands of tonnes of additional vanadium demand, potentially tightening global supply.

Companies >€40M revenue must implement OECD Due Diligence, trace cobalt from mine to manufacturer, undergo third-party audits, and report publicly.

EV batteries containing Chinese-processed graphite will completely lose access to the $7,500 tax credit. Major forcing function for Western anode supply.

First industrial-scale battery-grade niobium production. $80 million investment. If battery applications reach 25% of CBMM revenue by 2030, implies 35,000-40,000 t/yr of battery-grade Nb products.

Modeled on Strategic Petroleum Reserve. Selenium may be included in future stockpile decisions.

Matches US OSHA standard. Increases compliance costs for EU processors and further raises barriers to entry for European beryllium processing.

Reflects tight supply-demand balance and export control uncertainty. Signals sustained structural deficit as demand outpaces supply growth.

1.25 MW VRFB installed in commercial building basement — demonstrating non-flammable VRFB suitability for urban environments where lithium-ion is restricted.

Request for at least one year's supply of ferrovanadium and aerospace-grade V2O5, citing vulnerability of weapons supply chains to China-Russia supply dominance.

Export restrictions imposed (quota/licensing details TBD). Exposes China's vulnerability despite 73% refining — dependent on DRC feed. Spot market tightening.

Bilateral agreement to develop non-Chinese RE processing in Goias. Complements existing Lynas/JARE partnership.

Li-ion and sodium-ion batteries restricted from underground, rooftop, or densely populated building installations. VRFBs remain unrestricted, boosting flow battery demand for urban energy storage.

Directs Commerce Dept to negotiate minimum import prices for critical minerals with trading partners, targeting price volatility that destabilises domestic investment.

Enhanced public reporting requirements for Good Delivery refiners on sourcing from red-flag locations. Strengthens transparency in gold supply chains.

Accelerates CRMA 2030 objectives. Expands magnet recyclability requirements to HDDs, transducers, loudspeakers, and drones.

Third-party validation by major South Korean automaker. First US-produced HREE qualified for magnet use. Targeting 48 t/yr Dy oxide by mid-2027.

Official US critical mineral designation; no indium-specific stockpiling or production programs enacted as of 2026.

25% tariffs applied to Chinese tungsten products (carbides, concentrates, oxides) to counter dependency and spur allied supply chains.

Beryllium maintained on updated list of 60 critical minerals, confirming continued strategic importance.

Temporary relief through Nov 27, 2026. Licensing regime continues. Market uncertainty persists.

Suspends October announcements (57, 61, 62) until 2026-11-10. April 2025 controls remain in effect. Creates temporary but uncertain reprieve.

Selenium acknowledged within institutional supply chain risk assessments. Reinforces strategic classification.

First-time inclusion for Silver, reflecting its vital role in defense, grids, PV, and advanced electronics, plus a 64% US import reliance.

Vanadium designated among 60 critical minerals vital to economic and national security. Unlocks federal support for domestic production, expedited permitting, and potential stockpiling.

Temporary suspension of some export controls, but underlying architecture remains intact. Vanadium not yet directly restricted but risk persists given defense applications.

First domestic US primary vanadium mine since 2020. Received expedited 14-day critical minerals permitting. First production targeted for 2026.

Broadens scope to potentially affect energy, automotive, defence, semiconductor, and data centre sectors globally.

First comprehensive strategy covering domestic extraction, separation, magnet manufacturing, and cooperation with US, Japan, and Australia.

Potential future domestic US source, though development timeline and commercial viability are not yet established.

Controls apply to rare earth items produced outside China if containing >0.1% value ratio of China-origin controlled inputs. Semiconductor end-use screening added.

Disrupts approximately 50% of Myanmar-to-China RE shipments. Direct constraint on global Dy availability, compounding China export controls.

Increased tariffs to 50% for selected countries, affecting Brazilian vanadium products and further constraining non-Chinese supply routes.

Capital investment to meet growing aerospace and defense demand. Addresses capacity constraints approaching maximum utilization.

Multi-billion-dollar deal with equity investment, loans, 10-year price floor (US$110+/kg NdPr), and exclusive 10-year magnet offtake. Largest US government action on RE supply chains.

Enhances domestic refining capacity to reduce import reliance and strengthen defense supply chain resilience.

Historic milestone: first HREE separation outside China. HREE circuit capacity up to 1,500 t/yr mixed HREE, though Mt Weld ore is LREE-dominated (~2-3% HREE).

20% capacity increase for pharmaceutical-grade Se at Rothenbach site. Signals strategic commitment to Se value chain.

Requires special export licences; quotas assigned to approved enterprises. European Dy oxide prices nearly triple within weeks, from ~US$330-380/kg to >US$930/kg by early 2026.

Controls on REE metals, oxides, compounds, targets, and NdFeB magnets containing Dy/Tb. Licensing requirements for export of listed items.

10% tariff on most imports effective April 5, 2025. Affects vanadium product imports and raises costs for US consumers.

Added bureaucratic hurdles to licensing regime. Demonstrated incremental tightening playbook consistent with gallium/germanium precedent.

Requires special government licensing for exports of strategic-grade Mo materials. Creates supply uncertainty for global importers dependent on Chinese refined Mo products.

Official confirmation of China's ban; highlights 100% US import dependency.

Strategic stockpile program modeled on the Strategic Petroleum Reserve. Participation from GM, Boeing, Google. Could support vanadium procurement.

Beryllium listed as 2nd (after aluminium) among materials essential to allied defense industrial capabilities. Elevates coordination on supply security.

Applying USGS methodology, copper's supply risk score rose from 0.334 (2018) to 0.488 (2023), exceeding the 0.40 threshold. Argues copper should be added to the 2025 USGS Critical Minerals List.

Documents 100% US import reliance for finished RE magnets. Recommends accelerated domestic production.

Complete ban on Ga shipments to US. Further tightening of supply for American semiconductor manufacturers.

Complete ban. Prices reach $2,850-3,000/kg (99.999%). US scrambles for alternative sources.

Includes PGMs as Strategic Raw Materials due to their role in emissions control and the emerging hydrogen economy.

Targets 40% domestic processing for strategic raw materials by 2030. 15-month fast-track permitting for critical mineral projects.

Framework for supply chain resilience including extraction and processing benchmarks. CdTe panel recycling mandated under Extended Producer Responsibility (WEEE Directive).

Formal recognition of high supply risk and strategic importance for clean energy and defense. No formal US stockpiling program yet, but DoD discussions ongoing.

Ion-adsorption clay quotas remain constrained. Policy shifting extraction toward Bayan Obo hard-rock mining.

Dysprosium included alongside all rare earths. Triggers Defence Production Act funding eligibility, tax incentives, and streamlined permitting.

Key non-China/Russia primary vanadium producer enters bankruptcy proceedings, reducing Western supply diversity and tightening the non-aligned supply base.

Mandates higher vanadium intensity in reinforcing steel for concrete structures. Could increase annual vanadium consumption by 13,000-15,000 tonnes of vanadium nitride at full enforcement.

Milestone for niobium battery technology commercialization. NTO-anode batteries demonstrated ultra-fast 10-minute charging in electric bus prototype.

Designates cobalt as critical. 2030 targets: 10% EU extraction, 40% EU processing, 25% recycling. Max 65% from single third country.

Copper listed as strategic raw material (not critical, but strategic). 2030 targets: 10% EU extraction, 40% EU processing, 25% recycling. Import dependency capped at 65% from any single third country.

Establishes framework for supply chain resilience. Gallium listed as critical material with extraction and processing targets.

Germanium listed as critical. Targets: 10% extraction, 40% processing, 25% recycling by 2030.

Acknowledging the impossibility of sourcing non-Chinese anodes immediately, the US grants a 2-year grace period for graphite tracing under the FEOC rules.

Lists graphite as a strategic raw material, aiming for 10% domestic extraction and 40% domestic processing by 2030.

Establishes 65% single-source cap by 2030, collection targets for display waste, and investment incentives for EU refining capacity.

Lists lithium as Strategic. Sets 2030 targets: 10% EU extraction, 40% EU processing, 25% from recycling.

Lists rare earths for permanent magnets (Nd, Pr, Tb, Dy, Gd, Sm, Ce) as strategic raw materials. Mandates recycled-content disclosure for magnets >0.2 kg.

Through 2026: restrictions on magnets "melted or produced" in covered nations. From 2027: expanded to "mined, refined, separated, melted, or produced."

Sets 2030 benchmarks: no single non-EU country >65% of EU consumption; 10% domestic extraction; 40% domestic processing; 25% recycling. Directly challenges 92% Brazil dependence for niobium.

Designates tantalum as Critical Raw Material. Targets: 10-15% EU-based refining by 2030, mandatory due diligence for importers >5 tonnes/year, 25-30% secondary supply by 2030. Strategic Projects eligible for fast-track permitting.

Designates tin as a critical raw material. 2030 benchmarks: 10% EU domestic extraction, 40% EU processing, 25% recycling from waste streams. Qualifies tin for strategic stockpiling consideration.

Designates all rare earths including Dy as strategic raw materials. Sets 2030 benchmarks: 10% EU extraction, 40% EU processing, 25% recycling of annual consumption.

Beryllium designated as critical raw material under EU CRMA framework, triggering supply security obligations and strategic project eligibility.

Gallium officially designated as critical raw material with systemic risk to EU value chains.

Requires special permits for exporters of highly sensitive graphite products, including battery-grade spherical graphite. South Korea and Japan heavily impacted.

Indium officially designated as critical raw material with systemic supply risk to EU value chains.

Triggers domestic processing targets, strategic stockpiling, and recycling mandates for listed materials including Mo. 2030 goals: 10% EU extraction, 40% EU processing, 25% recycling.

Confirms niobium's classification as a mineral of high economic importance and supply risk within the EU framework.

Strategic reserve discussions initiated; recycling mandates for CdTe panels; support for European refining capacity (Umicore). EU Horizon Europe allocates >50M euros for substitution research.

Sets targets: 10% domestic extraction, 40% EU processing capacity, and 5% recycling rate by 2030.

Triggered stockpiling behavior and an 18% Tb oxide price spike. Highlighted ongoing geopolitical supply risk.

Periodic delays in export permits. Contributed to supply uncertainty during a period when LME tin was already elevated ($28,000-38,000/tonne range).

Mine closure removes ~330–350 kt copper/year (~1.5% of global supply). Government initiates multi-month closure plan. Highlights governance and social license risks for large copper projects.

Mandatory due diligence for Co, Li, Ni, graphite sourcing. 90% cobalt recovery by Dec 2027. Battery passport by 2027. Minimum recycled content by Aug 2031.

All gallium exports require individual license with 45-day approval process. Immediate supply disruption.

95%+ volume drop in August-September. Supply disruption begins. Prices start climbing.

All indium exports require individual license. Introduced alongside gallium and germanium controls. Affects ~70% of global refined supply.

Disrupted 12-17% of global mine supply feeding Chinese smelters. Contributed to tin price firmness through late 2023 into 2024. Highlighted opacity of Myanmar supply chain.

All Ge exports require individual license application. No immediate price impact.

Establishes due diligence for lithium supply chains, sets minimum recycling efficiency for Li-based batteries (65% by 2025), and ≥50% lithium recovery.

Mandates supply chain due diligence from Aug 2027. Recyclers must recover 95% of nickel by 2031.

Eliminated ~100 tonnes/year of Se capacity. Contributed to 2024 price escalation. Recovery expected 2025-2026.

Formal critical mineral designation enables priority permitting, stockpile funding, and supply chain analysis.

Only near-term North American niobium mine project. NPV $2.8B, IRR 29.2%, 38-year mine life. 75% of FeNb offtake contracted for first 10 years. Financing pending.

30% Investment Tax Credit for solar manufacturing (technology-neutral, covering CdTe) with 10% domestic content bonus. First Solar's US facilities qualify directly.

Case-by-case export approval required for all rare earth shipments. Estimated 280–320 tonnes Tb oxide approved for export in 2023.

Cites 90% supply dependence on China and essential defense applications. IRA allocates >$250M for rare earth mining and processing.

EV tax credit ($7,500) requires 40–80% FTA-sourced critical minerals (2023–2027). Only 8% of refined cobalt is IRA-compliant. Excludes China, DRC, Indonesia.

Sets strict local sourcing requirements for battery components to qualify for the $7,500 EV tax credit, targeting Chinese anode dominance.

50% capacity increase signals long-term demand confidence. Plans to invest $1.7 billion to double sales volume by 2030.

Formal investigation into national security impact of NdFeB magnet imports. Documents qualification barriers and supply chain vulnerabilities.

DOE frames comprehensive NdFeB magnet supply-chain assessment, quantifying concentration risks and substitution difficulty.

Mandatory due diligence for EU importers of tin, tantalum, tungsten, and gold (3TG) from conflict-affected areas. Requires risk assessment, mitigation, third-party audits, and annual reporting.

Full compliance required. National competent authorities (e.g., Germany's BAFA) begin customs enforcement. Estimated 60-80% compliance among traders by 2024-2025.

EU importers of 3TG minerals above volume thresholds must conduct OECD-aligned supply chain due diligence. Applies to smelters and refiners, not just end-users. Reinforces ITSCI certification demand.

Confirms Mo criticality for EU economy. Lays groundwork for CRMA domestic processing and stockpiling targets.

Banned export of raw laterite ore, forcing tens of billions in foreign direct investment into domestic smelters.

Beryllium OEL set at 0.6 μg/m³ (effective 2021) transitioning to 0.2 μg/m³ (July 2026). Increases compliance costs for EU processors.

Federal recognition of Mo supply risk. Triggers priority review of mining permits and supply chain assessments for domestic Mo operations.

Formal recognition of niobium's strategic importance and 100% US import dependence. Triggers inclusion in defense stockpile reviews.

Permissible exposure limit reduced tenfold from 2.0 μg/m³ to 0.2 μg/m³. Phased compliance imposed significant capital costs, discouraging new entrants.

Global treaty requiring countries with significant ASGM to develop National Action Plans to reduce mercury use. ~46 ASGM countries covered. Targets: 37% reduction by 2025, 70% by 2030.

Requires all EU mineral importers to conduct supply chain due diligence per OECD Guidance. Broader scope than Dodd-Frank (not limited to public companies). National authorities may block non-compliant imports.

Chronic exposure limits set at 4.6 ug/L (lentic) and 6.5 ug/L (lotic). Increased compliance costs for miners and refiners.

Five-step framework adopted by ~40 countries. ITSCI and RMI audits serve as primary implementation tools for tantalum. Non-binding but widely referenced by Dodd-Frank and EU regulation.

Triggered 2011 rare earth price crisis (Dy oxide >US$400/kg). WTO ruling forced removal of export quotas but demonstrated willingness to use RE supply as leverage.

Forced consolidation of Indonesian smelting. Created 12-18 month global supply tightness. LME tin prices rose ~15-20%. Established precedent for Indonesian resource nationalism in tin.

Requires Good Delivery refiners to implement OECD-aligned due diligence against human rights abuses, conflict financing, money laundering, and mercury use. Multiple iterations since.

Began restricting ion-adsorption clay mining — the primary HREE-enriched source. Progressive tightening has continued ever since.

Restored domestic high-purity Be metal production. Designed to produce up to two-thirds of output for defense/government end uses.

CdTe panels exempted from cadmium restrictions because Cd is hermetically sealed and proven recycling pathways exist. Exemption remains in force; political consensus favors maintaining it for decarbonization.

Five-step framework for risk-based due diligence covering mines, traders, refiners, and downstream companies. Becomes the reference standard for EU and LBMA rules.

Requires SEC-registered companies to disclose 3TG sourcing from DRC and 9 surrounding countries. Annual Form SD filings mandatory. Compliance costs $100K-$1M+ per large company. ~6,000-8,000 companies covered.

US-listed companies must report on DRC-origin tin, tantalum, tungsten, and gold. Drives adoption of ITSCI certification and supply chain traceability for DRC cassiterite.

Electronics industry transitions to SAC solder alloys (96.5% Sn). Tin demand for solder increases structurally by ~15-20%. Sets global standard adopted by China RoHS 2.0 and other jurisdictions.

Federal funding for construction of Elmore, Ohio refinery to restore domestic high-purity beryllium metal production capability lost in 2000.

First national Se supplementation programme. Dietary Se intake tripled and plasma levels approximately doubled within three years. Global model for biofortification.

Formal recognition of defense dependency on beryllium. Triggers public-private partnership investments under Defense Production Act Title III.

60 strategic projects approved from 170 applications in 2024 (first round). Includes processing and recycling projects. Fast-track permitting for designated projects.

Potential 10,000-15,000 t/yr of new capacity outside Brazil. Would meaningfully diversify supply if financed and built, but timelines remain uncertain.

Tighter vehicle emissions regulations sustain high PGM loadings in autocatalysts, keeping demand robust despite EV penetration.

Classified as critical due to high economic importance and extreme supply risk, triggering mapping and strategic funding.