Restoring American mineral dominance with a US critical minerals action plan

Improving critical minerals security has been a bipartisan point of focus across all recent administrations, going back to the Obama administration, including executive orders, legislation, and policy interventions such as the World Trade Organization’s trade actions. Over time, these interventions have progressively become more granular and targeted. Nevertheless, progress in the past decade toward achieving resource security has been slow.⁶ More than 15 federal agencies are currently engaged in activities and programs aimed at increasing the United States’ mineral security,⁷ but these initiatives have at times overlapped or lacked effective coordination. As the US government considers anew how to strengthen America’s economic and national security, many industry stakeholders are calling for a more cohesive and coordinated approach to critical minerals development to accelerate results.

The Trump administration has made critical minerals security a key component of its energy-focused strategy, evident by no fewer than five recent executive orders (EOs) seeking to address the American deficiency in the mining industry.⁸ These executive orders lay the groundwork for a comprehensive approach to increasing US mineral production, including accelerating and streamlining permitting, reconsidering certain regulations, mobilizing additional financing, and opening up federal lands and military bases for mining and processing. To assist in ongoing efforts to develop a national critical minerals strategy, we’ve defined an approach to pairing such a strategy with a targeted action plan. Based on Deloitte’s experience advising most federal agencies focused on this issue, we’ve identified and prioritized time-sequenced actions to advance the goals defined under the Jan. 25, 2025, “Unleashing American Energy” EO and in a subsequent, forthcoming national strategy.

Priority 1: Foster a domestic renaissance for mining and processing critical minerals

Advanced development of the critical minerals industry in the United States, including mining, processing, and downstream manufacturing, has been hindered by numerous factors: complex and unpredictable regulatory and permitting processes; weak project economics stemming from anti-competitive market manipulations by foreign actors with resulting price instabilities; a shortage of trained mining and mineral processing professionals; and the lack of risk-tolerant, patient capital to support extended exploration and project development timelines. Reviving the domestic critical minerals industry requires a targeted and time-sequenced approach addressing constraints to project development and accelerating private sector investment in the domestic market.

EO 14241 (Immediate Measures to Increase American Mineral Production, March 20, 2025) sets out several actions to accelerate the permitting and financing of domestic production and processing, including identifying priority mineral production projects for which expedited procedures could be applied; clarifying the treatment of waste rock, tailings, and mine waste disposal; and identifying and implementing measures to prioritize mineral production on federal lands. Priority actions defined below would support the effective use of these measures and related EOs.

Action 1(a): Accelerate federal loan, equity, and grant financing to expand primary domestic critical mineral production (medium complexity, high impact, one to two years to implement). Expanding domestic critical minerals production and processing will require significant public and private investment in capital and innovation. Given the relatively high risk and upfront costs of mining investments, expanded use of public finance can play an increasingly catalytic role in mobilizing private investment. This can be achieved by mitigating risk, lowering the cost of capital, and defraying startup and transaction costs.

The US government can leverage and expand existing financing platforms to rapidly deploy funding to expand primary domestic mineral production. This includes the Department of Energy’s Loan Programs Office and the Department of Defense’s Defense Production Act (DPA) funding. EO 14241 delegates authority to the secretary of defense and the chief executive officer of the US International Development Finance Corporation (DFC) to utilize DPA funding to this end via the DFC.

To supplement such plans, the US government could also expand funding authority within certain programs (such as the Industrial Base Analysis and Sustainment Program) and modify exposure limits to enable agencies to cofinance future domestic financing requirements with US financial institutions. In support of these efforts, consideration should be given to increasing available funds, streamlining processes, and reassessing as well as clarifying sourcing restrictions and exceptions.¹⁰

Action 1(b): Accelerate the secondary processing of critical minerals (byproducts) that are associated with existing domestic primary production (medium complexity, high impact, two to four years to implement). Several critical minerals can be obtained as byproducts of domestic primary production, including selenium in copper production, gallium from aluminum refining, germanium from zinc smelting, and bismuth in copper and lead smelting. However, the upfront capital costs and limited market sizes for the byproducts often prevent the secondary processing of these minerals.

The US government could accelerate the development of secondary processing capacity for critical mineral byproducts by identifying priority-associated minerals and providing catalytic grants, concessionary project loans, and guaranteed offtake agreements to existing primary producers or interested third parties. Such efforts could include the coordinated development of centralized or regional processing hubs where co-located primary production could promote efficiencies.

Action 1(c): Reduce costs and lead time for developing domestic mining and processing capacity by streamlining permitting and regulations, and ensuring that proper environmental safeguards are in place (high complexity, high impact, two to four years to implement). According to S&P Global, it takes nearly 29 years to build a greenfield mine in the United States, the second-longest timeline in the world.  As a result, only three new mines have commenced operations in the United States since 2002, and only 10 are currently in development.

In the United States, numerous federal, state, and local authorities are involved in permitting and regulatory review, often with their own applications, data requirements, and processes. To address this, the US government agencies responsible for permitting and regulatory reviews at the federal level (for example, the Department of Interior’s Bureau of Land Management, the US Forest Service, the US Army Corps of Engineers, and the Environmental Protection Agency) could work with state and local authorities to align on a common standard for data collection and information-sharing. This could enable project developers to provide all necessary data and information in one place and format where all regulatory agencies could access the data they require.

Deloitte implemented a similar approach at the Federal Energy Regulatory Commission, which shifted to the use of eXtensible Business Reporting Language (XBRL) and refined required data fields so that industry and other data users could automate the submission, extraction, and analysis of electronic quarterly reports. At the state level, the federal government could leverage, or replicate, the Interstate Oil and Gas Compact Commission (IOGCC) to convene and streamline state-level regulations and policies for minerals development on state and private land. The IOGCC played a key role, working with the federal government, in addressing government and public concerns associated with hydraulic fracturing and horizontal drilling to realize the shale oil and gas revolution, which made the United States the world’s largest producer of oil and gas. Identifying opportunities to reduce or remove overlapping responsibilities and requirements, and using time-bound, predictable approval processes and sustainability measures could significantly accelerate permitting and regulatory reviews, as well as oversight.

Action 1(d): Expand primary domestic exploration on federal lands through co-funding, the augmentation of precompetitive geoscience data, and the use of existing artificial intelligence and machine learning tools (high complexity, high impact, two to four years to implement). Exploration is a critical first step in increasing domestic critical mineral production, but many junior exploration companies lack access to adequate financing to enable broad, industry-led, early-stage exploration. The Department of Defense’s Manufacturing Capability Expansion and Investment Prioritization office, which has provided financial support to domestic exploration projects like nickel exploration in Minnesota and cobalt exploration in Idaho, provides an example of how to incentivize and mitigate risks for domestic critical minerals exploration. The US government could also invest in improving the quality, availability, and standardization of precompetitive geoscience data to be used by industry to more efficiently and effectively identify exploration targets, similar to what has been done as part of Canada’s Critical Minerals Geoscience and Data initiative.

As Deloitte’s 2025 Tracking the Trends report on mining and metals notes, precompetitive geoscience data includes all geological, geophysical, geochemical, and other types of data created and curated through federal, state, and territory government geological surveys and made available to the public. When analyzed by skilled geoscientists with the assistance of rapidly improving artificial intelligence and machine learning models, this data can significantly improve the identification of potential critical mineral resource deposits and stimulate exploration activity across geographies and essential mineral commodities.

Action 1(e): Build the mining workforce of the future by creating tailored workforce development and training programs, and leveraging artificial intelligence tools (medium complexity, high impact, more than four years to implement). With a rapidly retiring US mining workforce and ongoing AI work transformation, both public and private sectors can take immediate action to develop the US mining workforce of the future. The federal government can work with national laboratories and leading geology and engineering academic institutions to help expand relevant curricula and support apprenticeship programs. Such efforts could focus both on traditional, four-year academic programs and certifications in targeted areas (such as welding and mine safety).

Workforce development and training programs can be designed to reflect the way mining and processing work will be done in the decades ahead, relying on the significant use of machine learning, agentic AI, and more across operations, including for predictive and prescriptive maintenance, data entry and analysis, standards reporting, process design and optimization, and capital project design. Reskilling, upskilling, and training current and incoming workers on AI tools and best practices will enable organizations to maximize workforce productivity. For more details, see trend 7 in Deloitte’s 2025 Tracking the Trends report on mining and metals.

Action 1(f): Increase investment in R&D to improve mining and processing efficiency, productivity, and innovation through new technology and artificial intelligence (medium complexity, high impact, more than four years to implement). Expanding R&D funding in critical mineral mining and processing through the DPA or via the Department of Energy labs or other channels could drive efficiency, productivity, and innovation in the sector. R&D focused on reducing the usage and protection of water resources during processing and waste management, especially tailings storage facilities, can help improve the sustainability of mining projects and mitigate local community concerns regarding potential negative project impacts. This could include reducing the cost of dry-stacking tailings and improving water recycling capabilities. Increased R&D investment will also help draw new talent into the industry by encouraging higher education institutions to put more resources behind their mining and minerals programs, expand program and course offerings, and attract more young professionals into the sector.

Priority 2: Strengthen international cooperation and expand US access to critical mineral reserves and processing capacity abroad

The United States has a considerable natural resource endowment. However, it possesses less than 1% of the world’s reserves of some key critical minerals, such as graphite, nickel, and cobalt, making it essential that the United States supplements domestic extraction and processing with a dependable and secure supply of critical minerals from diverse partners, including large, developed producers like Canada, Australia, and some countries in South America and Africa.

The Trump administration has already signaled that access to critical minerals will be a core component of its foreign affairs strategy. As the new administration seeks to advance these objectives, several key initiatives could enhance the value proposition of US investments and cooperation abroad, and support US-led industry development in allied countries that host supply-constrained minerals like cobalt, nickel, lithium, and REEs. US investments in foreign projects would largely be commercial in nature, based on appropriate equity or debt ownership by US institutions. This would further ensure projects are operated economically, are environmentally sound, and are managed in the interest of US national security.

Action 2(a): Expand the role and use of existing multilateral arrangements to identify, prioritize, and support strategic critical minerals projects in allied countries that have the potential to serve the US market (medium complexity, high impact, one to two years to implement). Managing and counterbalancing China’s dominance of the critical minerals market will require well-coordinated collective action among industry and the governments of countries looking to secure critical mineral supply chains. The Mineral Security Partnership (MSP) is an example of such a multilateral initiative. The MSP was formed in June 2022 to “[accelerate] the development of diverse critical minerals supply chains in cooperation with industry and other governments, support strategic projects, and encourage investment throughout the value chain by reputable mining companies.”¹¹ Members include Australia, Canada, Estonia, Finland, France, Germany, India, Italy, Japan, Norway, the Republic of Korea, Sweden, the United Kingdom, the United States, and the European Union (represented by the European Commission).¹² As of September 2024, the MSP had supported 32 projects, including 19 upstreaming mineral and mining extraction projects, 15 midstream processing projects, and three recycling and recovery projects.¹³

The critical minerals czar could oversee a multilateral initiative like this, with the US government serving a role as secretariat. This approach could provide for a centralized management and oversight capability that enables and activates the full suite of capabilities of public and private sector partners in support of identified projects. It could also improve the quality and quantity of projects in the pipeline, and more effectively identify, support, and monitor projects in the pipeline. Further, the US government could put into operation existing (or similar, new) arrangements like the MSP as a transaction-driven public-private partnership body similar to Power Africa and more closely align the policy, funding, technical assistance, and diplomatic tools of the United States and its allies with the resources and expertise of private sector firms, including mining and mineral companies, processors, investors, and technical and advisory firms. In the near term, for example, the MSP could expand the pipeline of strategic projects and establish additional processes to support project application reviews, due diligence, and prioritization, after which prioritized projects could become eligible for various technical and financial assistance from the body’s members.

Action 2(b): Expand the capabilities of US institutions to accelerate investment in strategic upstream and midstream critical minerals projects abroad, including via reauthorization of the US DFC and expansion of authority for (and FY27 reauthorization of) the US Export-Import Bank (EXIM) (low/medium complexity, high impact, one to two years to implement). Efforts of America’s development finance institution, the DFC, to mobilize financing abroad to address US critical mineral security have been limited to date.¹⁴ This is partly due to restrictions in authorities, policies, and procedures governing income thresholds and equity scoring.

Given ongoing efforts around the DFC’s reauthorization, there is a unique, short-term opportunity to enhance the DFC’s authorities, tools, and processes to enable it to help drive American critical minerals security for many years to come. Specifically, legislation governing its reauthorization could:

• Expand the DFC’s authority to invest in and support projects in middle- and high-income countries if projects advance US access to critical minerals and other national security interests.¹⁵
• Broaden the DFC’s technical assistance authority not only to support feasibility studies (similar to the US Trade and Development Agency) but also to enhance the viability and impact of projects (for example, local workforce development programs and support to foreign governments to expedite project development) to reflect the new US foreign assistance landscape.
• Increase the DFC’s exposure limits for specific sectors to allow the agency to meet the size and scope of investment needed for critical minerals mining and processing projects.
• Simplify requirements and processes for equity investments, including revising the equity risk scoring methodology to allow DFC to deploy equity funding more effectively.
• Create a critical minerals enterprise fund, managed or overseen by the DFC, that can invest in, finance, and de-risk critical minerals projects in high-priority partner countries.

Expansion of EXIM’s authority to more broadly utilize tailored financial instruments, including via its China and Transformational Exports Program and its Supply Chain Resilience Initiative, could complement the above and accelerate the financing of highly strategic critical minerals production and processing projects to serve the US market. Such expansion could be considered as part of its fiscal year 2027 reauthorization.

Action 2(c): Support and fund geological field exploration efforts and data initiatives to accelerate early-stage resource identification in partnership with allies and host governments (low complexity, high impact, two to four years to implement). Similar to the US exploration support efforts discussed earlier, the US government could (in coordination with partners as appropriate) fund further exploration and data management programs to advance the collection, aggregation, and analytical review of precompetitive geoscience data in partner countries and accelerate on-the-ground exploration activities. As part of this program, the US government could develop an accelerator platform that identifies and supports early-stage critical mineral exploration and technology companies, and facilitates collaboration with large-scale industry participants that become partners and co-financiers with US financing institutions (for example, the US DFC). Such an accelerator could be modeled similarly to the BHP XPLOR program, which provides funding, technical and commercial coaching, training, industry connections, and potential follow-on investment for selected innovative, early-stage mineral exploration companies.

A specific focus of this effort could also be assessing and analyzing project tailings facilities for critical trace metals that were previously uneconomical or had an unknown value. The ability to develop these resources in some international jurisdictions may require regulatory or even legislative reforms and the management of potential negative environmental and social impacts. Leveraging the collective resources, connections, and expertise of industry and government partners will foster a strong ecosystem of support for exploration and innovation in the global critical minerals industry and help critical mineral exploration companies succeed.

Action 2(d): Accelerate the development and financing of strategic midstream processing facilities in allied countries (high complexity, medium impact, more than four years to implement). Building on lessons learned from US investment in and development of domestic secondary processing capacity, the US government could use domestic financing institutions, including the US DFC and EXIM Bank, to advance the development and US-led financing of mineral processing facilities in allied countries. Where the domestic on-shoring of processing capacity is less feasible, such efforts could support value chain integration consistent with US foreign policy interests and enhance the value proposition for allied nations to improve international cooperation with the United States. This should include, where possible, connecting such capacity with US manufacturers and end users.

Priority 3: Mitigate risk and foster a well-functioning critical minerals market

Long project development timelines, high capital expenditure requirements, market control or influence over market prices, and the potential for supply disruptions amplify critical mineral value chain risks. Various efforts and tools could improve value chain resilience and enable the United States to utilize its purchasing power and funding resources to mitigate the risk of market disruptions, stabilize supply and demand, and catalyze investment in the sector.

Action 3(a): Complete a detailed mapping of priority critical mineral value chains and develop a real-time monitoring system to identify short-term vulnerabilities and risks (high complexity, medium impact, one to two years to implement). To tailor and effectively deploy US government interventions, a robust, real-time understanding of where there are value chain vulnerabilities is critical. Building off the data and analysis already undertaken by the Department of State, US Geological Survey, and other agencies, the US government should work with allied partners to conduct a detailed mapping of high-priority critical mineral value chains and develop a regularly updated value chain data and monitoring system with a real-time dashboard that can enable the minerals czar, relevant agencies and partners, and value chain participants to make informed decisions and take targeted action to mitigate risks and vulnerabilities.

Action 3(b): Expand the purpose and use of the National Defense Stockpile (NDS) for critical minerals based on their near-term demand profile; supply risk; and criticality for key defense, technology, and other civilian applications to help stabilize the market during supply disruptions (high complexity, medium impact, one to two years to implement). The current NDS reserve has shrunk to historic lows. According to the Department of Defense’s FY2023 stockpile assessment, the NDS had reserves to meet only about 38% of military needs and less than 10% of essential civilian needs in the event of a base-case military conflict scenario.¹⁶ Significant future investments could be made to expand the national reserve of critical minerals to bring the NDS up to the levels necessary to promote domestic supply security and to provide the commercial industry with a tool for reducing the risks associated with market disruptions.

The US government, led by the Department of Defense, could collaborate closely with private sector stakeholders to develop a forecast for critical mineral needs across defense and commercial applications, and determine appropriate reserve levels. In addition to federal appropriations to fund the replenishment of the NDS, the Department of Defense could mobilize additional funding by selling options to private sector firms to draw on non-defense critical mineral stockpiles using Dutch auctions or other competitive means. Notably, some minerals are more appropriate and effective to stockpile than others, as dictated by their relative market size, near-term demand profile, market value, and diversity of supply sources. Efforts to expand the stockpile should also prioritize those minerals for which stockpiling can generate meaningful security in the event of market disruption, with cost efficiencies considered.

Action 3(c): Identify and deploy time-limited and targeted priority incentives (for example, tax incentives, purchase guarantees, and price floors) to address upfront capital cost issues and mitigate price disruptions (high complexity, medium impact, two to four years to implement). High upfront capital costs and the risk of market price fluctuations, including those caused by market manipulation, can discourage investment in new domestic critical minerals production and processing, and delay project completions. Targeted incentives and risk mitigation approaches could potentially include:

• Tax incentives benefit domestic critical mineral producers, such as production tax credits, which can reduce the risk of developing new domestic production or processing operations and accelerate access to financing; such incentives could be time-limited and designed by the Treasury Department in coordination with appropriate members of the NEDC and other federal agencies.
• Purchase guarantees and price floors could serve as a US government backstop to commercial agreements in the event of market disruptions that leave domestic producers without near-term customers; price floors have been used strategically in the agriculture industry to promote market stability and support domestic producers.