US Critical Minerals Policy: What the Capital Has Actually Deployed and What Is Still a Press Release

The US has thrown authorised capital at the critical minerals problem across DOE, DOD, the Development Finance Corporation, EXIM, and more executive orders than any single analyst can track. The result includes 21 bilateral agreements, a new allied trading bloc called FORGE, and Project Vault, a strategic reserve backed by a US$10 billion EXIM loan. Sounds impressive until you examine how much has actually left the building. The Defense Production Act sunsets in September 2026. EXIM needs reauthorising. And China still controls 60-97% of processing across the minerals that actually matter.

The Architecture on Paper: FORGE, Project Vault, and the Critical Minerals List

The USGS quietly expanded the Critical Minerals List from 50 to 60 minerals in November 2025, adding copper, silver, lead, silicon, rhenium, boron, potash, metallurgical coal, phosphate, and uranium. That single expansion changes the eligibility map for hundreds of billions in federal financing across IRA tax credits, DPA Title III programmes, and DOE loan facilities. Copper’s addition alone potentially unlocks financing pathways that were previously unavailable to the world’s most strategically critical energy transition metal.

FORGE, the Forum on Resource Geostrategic Engagement, was announced at the February 2026 Critical Minerals Ministerial in Washington alongside 54 participating countries. It replaces the Minerals Security Partnership and is designed to create a preferential trading zone for critical minerals with reference prices that act as price floors, enforced through adjustable tariffs. The explicit objective is to counter Chinese dumping of below-market minerals that undercuts Western production economics.

Project Vault combines the US$10 billion EXIM loan with approximately US$2 billion in private capital to create a strategic minerals stockpile covering all 60 minerals on the USGS list, modelled on the Strategic Petroleum Reserve. Manufacturers including GE Vernova, Clarios, and Boeing have expressed support. Commodity firms Hartree Partners, Traxys North America, and Mercuria agreed to participate.

What Has Actually Been Deployed Versus What Remains Committed Capital

The gap between authorised capital and deployed capital is the critical distinction. Legislative authorisation is not capital in the ground. Project commitments are not operating facilities. A US$10 billion EXIM loan for a strategic reserve requires procurement, storage, logistics, and governance before a single tonne of material sits in a US warehouse. The DoD’s July 2025 deal with MP Materials is a real public-private commitment with executed commercial terms, but MP Materials’ new 10,000 tonne per annum magnet facility is not expected to commission until 2028.

The policy cliff corridor that runs from September 2026 through December 2027 concentrates multiple authority expirations simultaneously. The DPA Title III authority, which has been the primary legal basis for DoD critical minerals investments, sunsets in September 2026 without reauthorisation. EXIM’s own reauthorisation timeline creates a parallel uncertainty window. Multiple authorities expiring within a 15-month period creates a legislative risk that project developers and investors need to price into their capital allocation frameworks.

This is the kind of analysis we publish daily in The Drill Down. Subscribe HERE for free.

The Processing Monopoly That Capital Cannot Solve Quickly

China controls 60-97% of processing across the minerals that make the list. The IEA confirmed China is the top refiner for 19 of 20 strategic minerals, with an average processing share of 70%. For heavy rare earths, graphite, and gallium, the concentration approaches 90-100%. The USGS expansion of the Critical Minerals List and the authorised federal capital pool are necessary conditions for building alternative supply chains. They are not sufficient conditions.

Building a separation facility, magnet plant, or battery-grade processing refinery takes 3-7 years from commitment to commissioning, requires equipment supply chains that are themselves concentrated in China or dependent on Chinese inputs, and demands specialised process expertise that has been accumulated in China over three decades of deliberate industrial policy. Capital solves the financing constraint. It does not solve the knowledge, equipment, and process expertise constraints that sit beneath it.

The policy framework being built is the right framework. The timeline mismatch between political cycles and industrial development is the structural risk that neither press releases nor authorised capital can close on its own.

A Five-Layer Durability Framework for Federal Instruments

Not all federal instruments carry the same durability. Executive orders that are reversed on day one of a new administration sit at the top of the fragility spectrum. Followed by unfunded authorisations with no appropriation behind them. Then budget allocations that require annual reauthorisation. Then executed public-private partnerships with committed commercial terms and offtake agreements. At the base, operational projects with deployed capital, commissioned facilities, and producing output that cannot be reversed regardless of the next administration’s policy preferences.

The most durable instruments in the current US critical minerals architecture are the MP Materials DoD partnership (executed commercial terms, committed capital), the Project Vault reserve structure (committed EXIM loan, private counterparties signed), and the bilateral agreements where partner countries have already allocated their own capital to specific projects. Executive orders and the FORGE framework are real policy signals. Their durability depends on reauthorisation, sustained appropriations, and execution capacity that outlasts the current administration.

This analysis is from The Drill Down, a daily briefing on critical minerals, junior mining, and capital markets. Join 2,900+ investors and operators who read it before the market opens. Subscribe HERE.