#CriticalMminerals: licensing, tariffs, and the new supply-chain risk
Critical minerals are no longer just industrial inputs. They are now strategic assets treated by governments as both economic infrastructure and national security leverage. Critical minerals sit inside everyday objects like smartphones, hairdryers, vacuums, and electric vehicles, but also inside missile guidance systems and power grids.
U.S. law reflects that broadened view. The Energy Act of 2020 defines “critical minerals” as minerals or materials that are essential to U.S. economic or national security, have supply chains vulnerable to disruption, and perform an essential manufacturing function such as that their absence would carry significant consequences.
In practice, that definition is sweeping. anchor battery supply chains. Gallium and germanium support semiconductors and other high-tech uses. Rare earth elements such as neodymium and dysprosium underpin permanent magnets found in electric vehicles, wind turbines, and defense applications.
As companies diversify away from concentrated suppliers, a second-order risk emerges. Some alternative sources sit in higher-risk jurisdictions, where governance, labor, or conflict-linked concerns are more acute.
This is where “critical minerals” and “conflict minerals” begin to overlap in practice. Even when the commodity is available, shipments can be disrupted by forced-labor enforcement, sanctions exposure, or traceability requirements imposed by customers, regulators, or financiers. A sourcing shift meant to reduce geopolitical risk can accidentally import compliance risk.
What this means for companies
For importers, manufacturers, and downstream buyers, the near-term imperative is operational. It is to build a compliance-and-procurement posture that assumes volatility.
Practical steps include:
•Map exposure: Identify where critical minerals enter production, either directly or embedded through subcomponents.
•Classify and document early: For controlled inputs, assume licensing and end-use information will be required, and build documentation upstream with suppliers.
•Contract for delay: Treat licensing and customs holds as foreseeable risks and allocate them clearly in contracts.
•Diversify with diligence: Diversification plans should include conflict minerals/forced-labor screening and traceability, not just alternate countries of origin.
•Monitor policy signals: Lists, proclamations, and export controls notices are increasingly early warning systems for trade risk.
For U.S.-based processors and refiners, the new critical minerals objectives may allow for new opportunities, with the Administration’s focus on domestic capacity expansion creating favorable conditions for investment in U.S.-based processing and refining operations. Companies aligned with U.S. supply-chain security objectives may find enhanced opportunities for partnerships and government support.
Conclusion
Critical minerals have become trade’s hard currency. They are not just priced, but negotiated; not just mined, but regulated; and not just shipped, but screened.
For businesses, the lesson is that in the critical minerals economy, supply chains are no longer merely commercial. They are strategic, and trade policy is being built to match.
Read more at: https://www.reuters.com/legal/legalindustry/critical-minerals-licensing-tariffs-new-supply-chain-risk–pracin-2026-01-29/










