# Critical Minerals

## 60 Minerals on the U.S. Critical List. 34 in the EU. Do You Know Where Yours Come From?

Critical minerals compliance demands origin-level traceability across your entire supply chain—with sourcing restrictions tightening from both the U.S. and EU simultaneously. The USGS list expanded to 60 minerals in 2025. The EU CRMA enforces supply chain mapping and diversification targets. DFARS sourcing restrictions bar procurement from China, Russia, North Korea, and Iran.

Certivo automates critical minerals traceability from supplier origin declarations to customer and regulatory evidence packages.

### Regulation Overview

**Jurisdiction**  
United States (USGS/DFARS/Section 232) and European Union (CRMA)

**Regulatory Body**  
USGS / DoD (U.S.); European Commission / DG GROW (EU)

**Regulation Number**  
Energy Act of 2020 (U.S.); Regulation (EU) 2024/1252 (EU CRMA)

**Effective Date**  
USGS list updated November 2025; EU CRMA in force since May 23, 2024

**Official Source**  
[USGS Critical Minerals](https://www.usgs.gov/programs/mineral-resources-program/science/what-are-critical-minerals-0)

**Key Threshold**  
Origin traceability to mining, refining, and separation stages

## Key Components / Sub-Frameworks

- **Obligation**  
Guides federal strategy, investment, stockpiling, and procurement restrictions

- **USGS Critical Minerals List**  
60 minerals essential to U.S. economy and national security

- **DFARS § 4872**  
DoD sourcing restrictions on covered materials

- **EU CRMA**  
Supply chain mapping, risk assessments, 2030 diversification targets

- **Phased restrictions**  
2027–2031 on additional minerals and advanced batteries

## What Are Critical Minerals Regulations?

Critical minerals regulations are a converging set of U.S. and EU frameworks designed to secure supply chains for minerals essential to national security, energy transition, and advanced manufacturing. For supply chain compliance teams, the primary obligation is proving mineral origin, tracking sourcing against restricted-country lists, and demonstrating supply chain diversification.

The U.S. USGS 2025 Critical Minerals List contains 60 minerals—10 more than the 2022 list. DFARS sourcing restrictions under 10 U.S.C. § 4872 bar DoD contractors from procuring covered materials from China, Russia, North Korea, and Iran. The FY 2026 NDAA expanded these restrictions to additional minerals and introduced new battery-related prohibitions tied to foreign entities of concern.

The EU Critical Raw Materials Act identifies 34 critical and 17 strategic raw materials, with 2030 targets for domestic extraction (10%), processing (40%), and recycling (25%). Companies must map supply chains, conduct risk assessments, and ensure no more than 65% of any strategic material comes from a single third country.

Critical minerals compliance requires origin-level data—mine site, refiner, country of processing—from every supplier tier. When lists expand or restrictions tighten, your entire portfolio requires reassessment.

## Key Compliance Requirements

### Who Must Comply  
- U.S. DoD prime contractors and subcontractors at all tiers procuring covered materials  
- Importers of critical minerals and processed mineral products into the U.S.  
- EU manufacturers and importers of products containing strategic raw materials  
- Companies in EU battery, EV, wind, and clean tech supply chains  
- Defense and aerospace suppliers subject to DFARS flowdown requirements  
- Companies subject to EU CRMA supply chain risk assessment obligations

### Key Thresholds  
- **60 minerals**  
2025 USGS Critical Minerals List scope  
- **65%**  
Maximum single-country sourcing for EU strategic raw materials  
- **10% / 40% / 25%**  
EU 2030 targets for domestic extraction / processing / recycling  
- **2027**  
DFARS expanded sourcing restrictions take full effect

## Core Obligations

1. `DFARS Sourcing Compliance`  
   `Verify covered materials are not sourced from restricted countries at mining, refining, and separation stages`  
   `DEADLINE`  
   `Ongoing; expanded restrictions effective 2027`

2. `EU CRMA Supply Chain Mapping`  
   `Map extraction, processing, and recycling origins of strategic raw materials`  
   `DEADLINE`  
   `Ongoing; first Commission progress report 2026`

3. `EU CRMA Risk Assessment`  
   `Conduct supply chain risk assessments and report vulnerabilities`  
   `DEADLINE`  
   `As directed by European Critical Raw Materials Board`

4. `Section 232 Compliance`  
   `Comply with tariff requirements on processed critical mineral imports`  
   `DEADLINE`  
   `Ongoing; tariffs active on copper and other minerals`

5. `FEOC Battery Restrictions`  
   `Ensure advanced batteries do not contain materials from foreign entities of concern`  
   `DEADLINE`  
   `Phased: 2028–2031 under FY 2026 NDAA`

## Managing critical minerals compliance alongside related regulations eliminates duplicate supplier requests. Certivo validates one submission against multiple frameworks.

## Industries Most Impacted  
- **Electronics Manufacturing**  
  Your Pain Point  
  Rare earth elements, gallium, germanium in semiconductors and displays

- **Automotive Manufacturing**  
  Your Pain Point  
  Lithium, cobalt, nickel, graphite in EV batteries; DFARS flowdown for defense vehicles

- **Aerospace & Defense**  
  Your Pain Point  
  DFARS § 4872 sourcing restrictions; titanium, tungsten, rare earths in defense systems

- **Industrial & Heavy Equipment**  
  Your Pain Point  
  Manganese, chromium, vanadium in specialty steels; global supply chain complexity

- **Energy & Infrastructure**  
  Your Pain Point  
  Copper, silicon, lithium for grid and renewable energy; Section 232 tariff exposure

- **Medical Devices & Equipment**  
  Your Pain Point  
  Platinum, palladium, rare earths in imaging and surgical devices

- **Pharmaceuticals & Biotech**  
  Your Pain Point  
  Phosphate, specialty chemicals; BIOSECURE Act driving Chinese supplier de-risking

- **Semiconductor & High-Tech**  
  Your Pain Point  
  Gallium, germanium subject to Chinese export controls; silicon newly on USGS list

## Frequently Asked Questions  
### What minerals are covered by U.S. critical minerals regulations?  
The 2025 USGS Critical Minerals List contains 60 minerals essential to U.S. economic and national security, including lithium, cobalt, rare earth elements, copper, silicon, graphite, and uranium. DFARS sourcing restrictions apply to a subset of these minerals, barring DoD procurement from China, Russia, North Korea, and Iran at the mining, refining, and separation stages. Certivo validates supplier origin data against the complete USGS list and all DFARS restricted-country requirements.

### What are the penalties for non-compliance with critical minerals sourcing restrictions?  
Under DFARS, non-compliant materials can result in contract termination, debarment, and False Claims Act liability. Under the EU CRMA, Member States must establish penalties by November 2026 for violations of reporting, monitoring, and supply chain mapping obligations. Sanctions may include administrative fines and withdrawal of strategic project status. Section 232 tariff violations carry standard customs penalties.

### How does Certivo handle dual U.S. and EU critical minerals compliance?  
Certivo collects origin-level supplier data once and validates it simultaneously against the 60-mineral USGS list, DFARS restricted-country requirements, EU CRMA's 34 critical and 17 strategic raw materials, and the 65% single-country sourcing cap. CORA maps mineral origins to both jurisdictions and generates separate compliance evidence packages for U.S. and EU requirements from a single data set.