How the USGS Critical Minerals List Is Made

Legislative Foundation

The legal basis for the USGS critical minerals list is the Energy Act of 2020, specifically Section 7002, which defines a critical mineral as a non-fuel mineral or mineral material that is essential to the economic or national security of the United States, has a supply chain vulnerable to disruption, and serves an essential function in the manufacturing of a product the absence of which would have significant consequences for the economy or national security. The Act explicitly excludes fuel minerals such as coal, oil, natural gas, and nuclear fuels, as well as minerals for which the Secretary determines there is no significant risk of supply disruption.

The Act requires the Secretary of the Interior to publish an updated list at least every three years, though interim revisions may be issued when warranted by significant changes in supply conditions. Each update must be published in the Federal Register, include a public comment period, and undergo interagency review involving the Department of Defense, the Department of Commerce, the Department of Energy, and the Office of the U.S. Trade Representative.

The Quantitative Screening Framework

At the heart of the USGS methodology is a quantitative screening framework that evaluates each candidate mineral across two primary dimensions: supply risk and disruption impact. The supply risk assessment considers factors including the geographic concentration of global production, the concentration of U.S. import sources, the political stability of producing nations, the availability of recycled material, and the existence of strategic stockpiles. The disruption impact assessment evaluates the mineral's importance to the U.S. economy based on the value of downstream industries that depend on it, the availability of substitutes, and the time required to develop alternative sources.

The USGS uses the Herfindahl-Hirschman Index (HHI) to measure production concentration, applying it to both global mine production and U.S. import sources. A higher HHI indicates greater concentration and therefore higher supply risk. This index is weighted by the Worldwide Governance Indicators published by the World Bank, which assess the political stability and regulatory quality of each producing nation. The combined metric produces a supply risk score for each candidate mineral.

On the disruption impact side, the USGS estimates the economic value at risk by mapping each mineral to its downstream manufacturing sectors using input-output models derived from the Bureau of Economic Analysis. This analysis quantifies the dollar value of U.S. GDP that depends on the availability of each mineral. Minerals with high economic value at risk and limited substitutability receive higher disruption impact scores.

Data Sources and Inputs

The USGS draws on an extensive array of data sources to populate its screening model. Primary production data comes from the USGS Mineral Commodity Summaries, which compile annual statistics on global mine production, reserves, and U.S. import and export volumes. Trade data is sourced from the U.S. Census Bureau and the International Trade Commission. Recycling rates and substitutability assessments are developed through consultation with industry experts, academic researchers, and national laboratories.

Geopolitical risk assessments incorporate the World Bank's Worldwide Governance Indicators, the Fund for Peace's Fragile States Index, and the Office of the Director of National Intelligence's assessments of supply chain threats. The Department of Defense provides classified and unclassified assessments of minerals essential to defense applications, which inform the disruption impact scoring for defense-critical minerals such as beryllium, tungsten, and rare earth elements.

The USGS also evaluates forward-looking demand projections developed by the International Energy Agency, the Department of Energy, and private sector forecasters. These projections are particularly important for emerging technology minerals such as lithium, cobalt, gallium, and germanium, where demand is expected to increase substantially over the coming decade due to the energy transition and semiconductor expansion.

The Scoring and Threshold Process

Each candidate mineral receives a composite criticality score derived from the weighted combination of its supply risk score and disruption impact score. The USGS establishes a threshold above which a mineral is considered critical. This threshold is not a fixed number but is calibrated based on the distribution of scores across all evaluated minerals, ensuring that the designation captures minerals with genuinely elevated risk profiles rather than applying an arbitrary cutoff.

The scoring model assigns greater weight to supply risk than to disruption impact, reflecting the legislative emphasis on supply vulnerability. However, a mineral with an extremely high disruption impact score can qualify even with a moderate supply risk score, and vice versa. This ensures that both dimensions of criticality receive appropriate consideration.

Interagency Review

Before publication, the draft list undergoes interagency review. The Department of Defense assesses the list against its own strategic material requirements. The Department of Energy evaluates the implications for energy transition programs and clean energy manufacturing goals. The Department of Commerce considers trade policy and export control dimensions. The U.S. Trade Representative reviews the list for consistency with ongoing trade negotiations and bilateral mineral agreements.

This interagency process ensures that the final list reflects the full spectrum of national interests, not just geological or economic considerations. In past review cycles, interagency input has led to the addition of minerals that scored near the threshold but were deemed essential by specific agencies. Nickel, for example, was added in 2022 following strong advocacy from the Department of Energy, which emphasized its critical role in next-generation battery chemistries.

Public Comment and Final Publication

The Energy Act of 2020 requires that the draft list be published in the Federal Register for a public comment period, typically 30 to 60 days. During this period, mining companies, industry associations, environmental organizations, academic researchers, state and tribal governments, and individual citizens may submit comments. The USGS reviews all comments and publishes a response document addressing substantive concerns.

The public comment process has produced meaningful changes in past review cycles. Industry stakeholders have successfully argued for the inclusion of minerals that the quantitative model initially scored below the threshold, providing supplementary data on supply chain vulnerabilities not captured in the standard datasets. Environmental organizations have raised concerns about the permitting implications of critical mineral designations, prompting the USGS to clarify that designation does not exempt projects from environmental review requirements.

Following the public comment period and any resulting revisions, the final list is published in the Federal Register and takes immediate effect. The USGS simultaneously publishes the complete methodology documentation, scoring results, and response to public comments, ensuring full transparency in the designation process.

Review Cycle and Updates

The Energy Act mandates that the list be reviewed at least every three years, establishing a regular cadence of assessment and update. The USGS has indicated that it intends to maintain this triennial cycle, with interim updates reserved for extraordinary circumstances such as new export restrictions by major producing nations, significant supply disruptions, or the emergence of previously unrecognized supply chain vulnerabilities.

The review cycle begins approximately 18 months before the scheduled publication date, allowing sufficient time for data collection, model updates, interagency review, and public comment. This timeline means that the USGS is effectively in a continuous state of assessment, updating its data models and monitoring global supply conditions between formal review cycles.

The triennial review process also allows the USGS to remove minerals from the list if their supply risk profiles have improved sufficiently. This could occur if new production capacity comes online in geopolitically stable regions, recycling rates increase substantially, or viable substitutes are developed and commercialized. To date, no mineral has been removed from the list once added, but the mechanism exists and the USGS has indicated it will apply it when warranted.