How the USGS Critical Minerals List Is Made

The U.S. critical minerals list is made in three legal steps set by section 7002 of the Energy Act of 2020: the Secretary of the Interior publishes a draft methodology and draft list for public comment, then publishes a final methodology and list within 45 days after the comment period closes, and reviews both at least every three years. USGS did the technical work for the 2025 list with two tests: an economic model of foreign trade disruptions and a check for a sole domestic producer.

What steps turn the law into a list?

The steps below follow the statute and show what happened in the 2025 cycle. USGS carries out the analysis, but the Secretary of the Interior makes the designation.

How does the 2025 economic model work?

The economic model estimates how much a foreign supply disruption would cut U.S. output. USGS used an input-output model of the U.S. economy with a nonlinear optimization routine. Post-disruption prices and quantities come from price elasticities of supply and demand, and each scenario is a year-long foreign trade disruption in which any excess production capacity elsewhere is taken into account. The model runs over 1,200 scenarios for 84 mineral commodities and reports the change in U.S. GDP for 402 industries and for the economy as a whole.

Each scenario is weighted by its probability, so a likely small disruption counts for more than an unlikely large one. Across the 84 commodities the probability-weighted results ranged from a net GDP decrease of nearly $4.5 billion to a net increase of $33 million. USGS grouped the commodities into risk classes with the Jenks natural breaks method and recommended for the list every commodity with an annualized probability-weighted net GDP decrease above $2 million.

What is the single-point-of-failure test?

The single-point-of-failure test checks whether a commodity's domestic supply chain depends on one producer. USGS recommends a commodity for the list when only one domestic producer exists, because the loss of that producer would leave no domestic source. The notice gives no further detail on how the test was applied, so the full report is the place to look for it.

How do agencies and the public change the result?

Agency advice and public comment changed the 2025 list in four visible ways. The Department of War argued for keeping arsenic and tellurium, which the draft had proposed to drop. The Department of Energy recommended metallurgical coal and uranium and the Department of Agriculture recommended phosphate, citing food security. USGS could not model ferroboron, so boron was added on the strength of modelled results for silicon, titanium and chromium ferroalloys, where China has similar market control. The notice names the Secretary's consultation duty with the Secretaries of Defense, Commerce, Agriculture, Health and Human Services, and Energy.

How does the USGS method differ from the EU method?

The USGS method models the damage a disruption would do to U.S. GDP, while the EU method scores each material on two indices and applies fixed thresholds. In the EU, a raw material is critical when its supply risk is at least 1 and its economic importance is at least 2.8, with supply risk built from supply concentration weighted by governance indicators, import reliance, recycling and substitution. The EU review cycle page sets out that method in full, and the comparison page shows how the two approaches change the lists.

Frequently asked questions

Who decides which minerals go on the USGS critical minerals list?

The Secretary of the Interior decides, acting through the USGS Director. The Energy Act requires consultation with other agencies, and the Secretary can also designate a mineral that another federal agency has found strategic and critical to defense or national security.

What criteria does a mineral have to meet to be critical?

A mineral must be essential to economic or national security, have a supply chain vulnerable to disruption, and serve an essential function in manufacturing a product whose absence would have significant consequences. The Energy Act sets these three criteria, and USGS turns them into a model-based test.

How often is the USGS critical minerals list reviewed?

The Energy Act requires a review at least every three years. USGS says the 2025 list will be updated at least every two years, and the Federal Register notice says "not less than biannually". The earlier lists appeared in 2018 and 2022.

Can public comments change the list?

Public comments can change the list, and in 2025 they did. The Department of the Interior received 163 comments on the August 2025 draft, covering 62 minerals, and the final list kept arsenic and tellurium that the draft had proposed to drop. The notice credits new data, public feedback and interagency recommendations for the additions.

Sources

Read on October 12, 2026. Figures on this page come from these documents; where a number is an estimate, the source says so.

1. 30 U.S.C. 1606 (Energy Act of 2020, section 7002)
2. USGS Open-File Report 2025-1047: Methodology and technical input for the 2025 U.S. List of Critical Minerals. Nassar and others; abstract read, version 2.0 of 15 April 2026
3. Federal Register: Final 2025 List of Critical Minerals (7 November 2025). Read through the Federal Register text file
4. USGS: Interior Department releases final 2025 list of critical minerals
5. Regulation (EU) 2024/1252, Article 4 and Annex II. Used for the EU comparison