November 6, 2025

The Draft US Critical Minerals List

The Draft US Critical Minerals List

Since 2016, the United States has taken strategic steps to reduce its economic and national security vulnerabilities that stem from an overreliance on imports of critical mineral materials essential to advanced manufacturing, clean energy, and defense technologies. Informed by growing geopolitical tensions and the rise of clean energy and digital technologies, these minerals have become a focal point of U.S. industrial and foreign policy. The U.S. Geological Survey (USGS), the federal body tasked with assessing critical mineral risks, released a draft of its updated Critical Minerals List in 2025, expanding the count from 50 in 2022 to 54.

The draft list, guided by a new and improved methodology, offers a clearer picture of mineral supply risks and prioritizes them based on modeled economic impact. However, while it represents progress in evaluating economic dependencies, it still faces significant challenges, especially in accounting for the environmental and national security externalities these minerals embody.

A Shift Toward Economic Impact Assessment

The 2025 USGS Critical Minerals List marks a methodological departure from earlier iterations. Previous assessments mainly relied on static metrics such as global supply concentration and U.S. net import reliance to determine which minerals should be considered critical. These metrics flagged minerals that had high exposure to supply risk but did not always reflect the full scope of their strategic importance.

Now, the USGS employs a scenario-based, economic risk assessment approach. Analysts modeled 1,200 one-year disruption scenarios for 84 mineral commodities, incorporating variables like trade disruption probabilities, price elasticity, market concentration, and U.S. industry dependencies. The result is a probability-weighted estimate of GDP loss due to supply disruptions. Any mineral that could cause an annualized GDP loss greater than $2 million or whose domestic supply chain is reliant on a single producer (a “single point of failure,” or SPOF) qualifies for critical status.

This approach provides a more dynamic and nuanced understanding of mineral vulnerabilities. For the first time, stakeholders can now rank minerals not just on how exposed the U.S. is to foreign suppliers, but on the magnitude of expected economic disruption if access to these minerals were suddenly curtailed.

New Additions, New Concerns

The new methodology led to the addition of six minerals, potash, silicon, copper, silver, rhenium, and lead, to the Critical Minerals List, and the removal of arsenic and tellurium. The inclusion of copper, in particular, was notable given its broad use in electrical and industrial infrastructure, but its previous exclusion from earlier lists.

Still, the updated list remains long, 54 entries, and potentially too inclusive. The $2 million GDP loss threshold sets a relatively low bar for inclusion. To put this into perspective, such an economic disruption represents only about seven millionths of one percent of the current U.S. GDP ($30.35 trillion), comparable to the economic cost of a medium-sized restaurant fire. These small risks, while potentially harmful to specific sectors or regions, do not meaningfully threaten the macroeconomy.

Tiered Risk, Uniform Benefits

Notably, the USGS modeling distinguishes minerals by the magnitude of their economic impact. Those with probability-adjusted GDP losses exceeding $1 billion include:

These minerals are essential to sectors ranging from defense and semiconductors to electric vehicles and medical imaging. At this scale, any disruption could significantly ripple through tech-driven supply chains and national defense procurement.

Despite these distinctions, U.S. policy still treats all critical minerals equally in key administrative channels. Whether a mineral is expected to impose $4.5 billion in GDP losses (as in samarium’s case) or $2 million (as in low-ranking chromium chemicals), eligibility for benefits like tax credits, Defense Production Act resources, and strategic stockpiling is identical. This binary treatment fails to reflect the true range of economic and strategic importance captured in the USGS's new modeling.

Accountability for Non-Economic Value

While the new methodology marks a step forward in using data and modeling to inform policy, it falls short in accounting for the non-economic externalities at stake. Critical minerals underpin technologies vital for national security and the environmental domains that extend beyond what GDP figures can fully capture.

For example, while disruption in lithium supply may be modeled to cause just $34 million in economic losses, such a shortfall could delay deployment of electric vehicles and lithium-ion battery storage critical to clean energy. Between 2019 and 2022, clean energy gains contributed to improved air quality and health outcomes in the U.S., saving up to 1,600 lives per year and generating an estimated $249 billion in societal benefits. These benefits, however, do not register in GDP-based supply risk analyses.

Similarly, gallium nitride substrates costing about $1,300 each are essential to advanced radar systems like the U.S. Navy's AN/SPY-6 (which costs around $90 million per unit). Their disruption may seem like a small economic loss, but it's a large strategic one. The same underscores the nuanced role minerals play in military readiness: technologies like night vision goggles or guided munitions don’t carry high material costs, but their utility in national defense is invaluable.

Policy Recommendations

To bridge the gap between economic modeling and broader strategic priorities, U.S. policymakers should consider overlaying the current GDP-based analysis with estimates of environmental, public health, and national security externalities. Cost-benefit ratios from agencies like the Environmental Protection Agency and Department of Defense, which assess avoided mortality and mission risk, could provide a richer, multidimensional framework.

In addition, Congress and the executive branch must move toward a tiered designation system for critical minerals, one that recognizes not just whether a mineral is important, but how important it is. Such a move would facilitate smarter allocation of investment, subsidies, permitting fast-tracks, and stockpiling decisions, not to mention R&D funding for mineral substitutes.

Conclusion

The 2025 USGS Critical Minerals List and its updated methodology offer a more precise measure of economic exposure than ever before. By quantifying modeled GDP losses and integrating probabilistic supply chain scenarios, the list represents a valuable technical foundation for critical mineral policy. Yet, as the U.S. seeks to build resilient supply chains and reinforce its clean energy and defense ambitions, it must embrace more than just economic risk. Without incorporating national security and environmental externalities into prioritization frameworks, the U.S. risks mistaking the scale of the minerals’ value and missing the forest for the trees.

Cole Morace

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