Critical-minerals policy timeline

Graphite · Sep 22, 2026 · freshness floor Aug 13, 2026

US antidumping and countervailing duty investigations on Large Diameter Graphite Electrodes from China and India (2026, live)

Announced (stale)stale future scheduled effective date

Boundary note first: large diameter graphite electrodes are furnace electrodes for steelmaking, and this Factbook does not track them as a chain stage. The case is recorded because it is the live US trade action on graphite products following the active anode material case's conclusion without orders; because the merchandise is defined by graphitization, with country of origin determined by the country of graphitization; and because it may enter under HTSUS 3801.10.5090 and 3801.90, the same subheadings that active anode material may enter under. Resonac Graphite America and Tokai Carbon GE petitioned on 24 February 2026; the ITC made affirmative preliminary injury determinations on 10 April 2026; Commerce made preliminary affirmative countervailing duty determinations on 30 July 2026 at 103.49 percent for China (adverse facts available) and 3.68 to 6.99 percent for India; the antidumping preliminary determinations were postponed to no later than 22 September 2026.

Graphite, Lithium · Aug 27, 2026 · freshness floor Aug 13, 2026

BIS DPAS Directive Allocation Order — domestic sales requirement for black mass (2026)

Effective (stale)stale future scheduled effective date

A temporary final rule under Defense Production Act section 101 requires U.S. persons selling black mass — shredded lithium-ion battery scrap whose cathode material may contain lithium and whose anode material may contain graphite — to allocate 100 percent of monthly sales to U.S. persons from 27 August 2026, unless BIS grants an adjustment or exception. The order directly governs a shared graphite/lithium recycling feedstock; it restricts where black mass can be sold, not how it is processed.

Germanium · Jul 10, 2026 · freshness floor Aug 18, 2026

Belgian consideration of Umicore germanium prefinancing

Announced announced

The Belgian Council of Ministers agenda for 10 July 2026 lists Umicore germanium prefinancing. The public primary page gives no amount, guarantee terms or executed-agreement evidence, so this record remains announced only.

Graphite · Apr 3, 2026 · freshness floor Aug 13, 2026

US antidumping and countervailing duty investigations on Active Anode Material from China (2024-2026): concluded without orders

Rescinded actual

The marquee US trade action on battery-grade graphite. Five domestic producers petitioned on 18 December 2024; Commerce initiated in January 2025 and reached final affirmative determinations on both dumping (up to 102.72 percent) and subsidies (up to 66.86 percent), published 17 February 2026. The ITC then made a final NEGATIVE determination, published 3 April 2026, finding that the establishment of a US active anode material industry is not materially retarded by the subject imports. Because the injury leg failed, no antidumping or countervailing duty order issued: the proceedings terminated, suspension of liquidation was lifted, and cash deposits were refunded.

Gallium · Feb 27, 2026 · freshness floor Aug 18, 2026

USTDA Monte Muambe support excludes the gallium workstream

Announced announced

USTDA signed a grant agreement on 27 February 2026 for the Monte Muambe rare-earth pre-feasibility study. The primary notice limits the funded work to rare-earth mining and processing; it does not fund the separate gallium recovery concept and does not confer gallium manifest membership.

Rare earths, Graphite · Jan 14, 2026 · freshness floor Aug 11, 2026

Section 232 Action on Processed Critical Minerals and Derivative Products (EO 14272 and Proclamation 11001)

Amended actual

EO 14272 (Apr. 15, 2025) ordered a Section 232 national security investigation into imports of processed critical minerals, expressly including rare earth elements, and their derivative products such as permanent magnets. Commerce's report (transmitted Oct. 24, 2025) found the imports threaten to impair national security, and Proclamation 11001 (Jan. 14, 2026) concurred, directing Commerce and USTR to negotiate agreements, with price floors to be considered, rather than imposing immediate tariffs.

Graphite · Jan 1, 2026 · freshness floor Aug 13, 2026

Section 301 tariff increase on Chinese natural graphite to 25 percent, effective 1 January 2026

Effective actual

In the statutory four-year review of the Section 301 China action, the President's memorandum of 14 May 2024 directed USTR to raise the additional duty on natural graphite from China to 25 percent in 2026. USTR's notice of modification of 18 September 2024 declined to amend the proposal and set the increase for three natural graphite subheadings, 2504.10.10 (crystalline flake), 2504.10.50 (powder or flakes) and 2504.90.00 (other), applicable to goods entered for consumption on or after 1 January 2026. USGS records the pre-existing normal trade relations rate for all three subheadings as Free as of 31 December 2024, and describes the change as an increase from 0 percent to 25 percent.

Graphite · Nov 9, 2025 · freshness floor Aug 13, 2026

China's export controls on graphite items (MOFCOM/GAC Announcement No. 39 of 2023 and later measures)

Amended actual

China licenses exports of battery-relevant graphite. Joint MOFCOM/GAC Announcement No. 39 of 20 October 2023 moved three high-sensitivity graphite categories into dual-use export licensing effective 1 December 2023 (high-purity, high-strength, high-density synthetic graphite; natural flake graphite; and derived products including spherical and expandable graphite) while lifting temporary controls on five low-sensitivity items used in steel, metallurgy and chemicals. Two later measures are recorded here as separate dated events and are not conflated with the 2023 regime: Announcement No. 46 of 3 December 2024, whose Article 2 imposed stricter end-user and end-use review for dual-use graphite exports to the United States, and Announcement No. 58 of 9 October 2025, which added lithium-battery, cathode-material and artificial-graphite-anode-material items and their equipment and technology. Announcement No. 58 was suspended by Announcement No. 70 from 7 November 2025 until 10 November 2026, one day before it was to take effect, and Article 2 of Announcement No. 46 was suspended from 9 November 2025 until 27 November 2026.

Gallium, Germanium · Nov 9, 2025 · freshness floor Aug 18, 2026

Temporary suspension of provision 2 of China Announcement No. 46

Amended actual

• Operative state: Suspension in force through 2026-11-27 (china-us-ga-ge-suspension-2025-amended)

MOFCOM Announcement No. 72 suspends provision 2 of Announcement No. 46 from 9 November 2025 through 27 November 2026. The 2023 licensing regime and the military-user and military-use prohibition remain in force.

Rare earths · Nov 7, 2025 · freshness floor Aug 11, 2026

China export controls on seven medium/heavy rare earths and related magnet items (April 2025, as amended)

Amended actual

MOFCOM/GAC Announcement No. 18 of 4 April 2025 imposed export licensing on samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium and their metals, alloys, oxides, compounds, mixtures, and permanent-magnet materials — the pivotal chokepoint event for the rare earths-to-magnets chain, since these elements dominate heat-resistant NdFeB and SmCo magnet supply. The October 2025 expansion (extraterritorial 0.1% content rule and technology controls) was suspended for one year in November 2025, but the April controls themselves remained in force and actively enforced through mid-2026.

Rare earths, Graphite · Nov 7, 2025 · freshness floor Aug 11, 2026

USGS/Interior Critical Minerals List — 2018, 2022, and 2025 Revisions

Amended actual

The Department of the Interior's critical minerals list, first published in 2018 pursuant to EO 13817 (35 commodities including the rare earth elements group), was revised in 2022 (50 minerals, with rare earths listed as individual elements) and again in the final 2025 list (60 minerals). Listing keeps rare earth elements eligible for the statutory and program preferences that key off the list, from permitting priorities to Section 232 scoping, which defined critical minerals by reference to the USGS list.

Rare earths · Nov 1, 2025 · freshness floor Aug 11, 2026

US-China trade frameworks touching rare earth export licensing (2025-2026)

Announced actual

Series of US-China de-escalation frameworks — Geneva (May 2025), London (June 2025), and the Busan meeting deal announced 1 November 2025 — in which restored rare earth and magnet export flows were a central US objective. The two governments' accounts of what China committed to on rare earth licensing diverge materially, and reporting through mid-2026 describes only partial relief, so this record keeps each event tied to what its source states.

Rare earths, Graphite · Apr 8, 2025 · freshness floor Aug 11, 2026

Executive Order 14241 — Immediate Measures To Increase American Mineral Production

Amended actual

EO 14241 (Mar. 20, 2025) ordered fast-tracked permitting for priority mineral projects, federal land prioritization for mineral production, and new financing channels, and delegated DPA section 303 authority to the Secretary of Defense and DPA Title III authorities to the DFC for domestic mineral production. Its definitions expressly cover processing through metals and master alloys and derivative products such as permanent magnets, putting the rare earths-to-magnets chain squarely in scope.

Graphite, Lithium · Dec 27, 2024 · freshness floor Aug 13, 2026

US Treasury treatment of graphite as an impracticable-to-trace battery material under the section 30D foreign-entity-of-concern rules

Amended actual

Treasury and the IRS decided in final regulations published 6 May 2024 (TD 9995) that graphite contained in anode materials, both natural and synthetic, is an 'identified impracticable-to-trace battery material'. For new clean vehicles whose qualified manufacturer files its periodic written report before 1 January 2027, the foreign-entity-of-concern due-diligence requirement may be satisfied by excluding those materials, and they may be excluded from the determination of whether a battery cell is FEOC-compliant. Treasury's stated reasons are the commingling of natural and synthetic graphite and the difficulty of tracing synthetic graphite fully upstream. The companion section 45X final regulations (TD 10010, 28 October 2024) define graphite as an applicable critical mineral when purified to a minimum 99.9 percent graphitic carbon by mass.

Lithium · Dec 27, 2024 · freshness floor Aug 18, 2026

U.S. section 30D/FEOC and section 45X rules for lithium feedstocks and chemicals

Amended actual

Treasury and IRS final regulations directly govern lithium extraction, processing and recycling procurement chains under section 30D and define qualifying lithium under section 45X as lithium converted to lithium carbonate or lithium hydroxide, or purified to at least 99.9% lithium by mass.

Gallium, Germanium · Dec 3, 2024 · freshness floor Aug 18, 2026

China US-directed dual-use gallium and germanium measure

Effective actual

• Operative state: In force, suspended through 2026-11-27 (china-us-ga-ge-measure-2024-effective)

MOFCOM Announcement No. 46 prohibits dual-use exports to US military users and uses and states that licenses should in principle not be granted for US-bound gallium and germanium dual-use items.

Rare earths · May 30, 2024 · freshness floor Aug 11, 2026

10 U.S.C. 4872 — DoD Restrictions on Chinese-Sourced NdFeB and SmCo Magnets (FY2019 NDAA sec. 871 through FY2024 NDAA sec. 854)

Amended (stale)stale actual

Next scheduled event: effective on Jan 1, 2027. It is not the current operative state.

Section 871 of the FY2019 NDAA (10 U.S.C. 2533c, now 4872) barred DoD acquisition of samarium-cobalt and neodymium-iron-boron magnets (and tungsten) melted or produced in North Korea, China, Russia, or Iran. Section 844 of the FY2021 NDAA expanded the bar to material 'mined, refined, separated, melted, or produced' in those countries, and section 854 of the FY2024 NDAA set that full mine-to-magnet restriction to take effect January 1, 2027, making DoD demand a forcing function for a non-Chinese rare earth magnet supply chain.

Rare earths, Graphite · May 23, 2024 · freshness floor Aug 11, 2026

EU Critical Raw Materials Act (Regulation (EU) 2024/1252)

Effective actual

EU framework regulation for secure and sustainable critical raw materials supply, in force 23 May 2024. Its 2030 benchmarks (10% extraction, 40% processing, 25% recycling, no more than 65% of any strategic raw material from a single third country) and fast-permitting Strategic Projects mechanism are the EU's principal policy lever for building an ex-China rare earth magnet chain, and the first strategic-projects list recognises five rare earth facilities tracked in this database.

Rare earths · Dec 21, 2023 · freshness floor Aug 11, 2026

China export ban on rare earth extraction, separation, and magnet-making technology (December 2023)

Announced actual

On 21 December 2023 China's Ministry of Commerce revised its Catalogue of Technologies Prohibited or Restricted from Export to ban export of rare earth extraction and separation technology, rare earth metal and alloy production technology, and technology for making some rare earth magnets. The ban locks in China's roughly 90% share of global separation capacity by blocking transfer of the process know-how that ex-China separation and magnet projects would otherwise buy.

Gallium, Germanium · Aug 1, 2023 · freshness floor Aug 18, 2026

China gallium and germanium export licensing regime

Effective actual

• Operative state: In force (china-ga-ge-export-licensing-2023-effective)

MOFCOM and China Customs Announcement No. 23 requires export licenses for listed gallium and germanium items from 1 August 2023. It is a licensing regime, not a categorical ban.

Rare earths, Graphite · Jun 14, 2022 · freshness floor Aug 11, 2026

Minerals Security Partnership (MSP)

Announced actual

Multilateral partnership announced by the US State Department and partner governments in June 2022 to catalyze government and private investment in critical mineral supply chains. It is the main allied-coordination vehicle for ex-China rare earth projects: by the September 2024 principals' meeting, 10 of the 32 MSP-endorsed projects involved rare earth elements.

Rare earths, Graphite · Feb 24, 2021 · freshness floor Aug 11, 2026

Executive Order 14017 — America's Supply Chains (100-Day Reviews)

Announced actual

EO 14017 (Feb. 24, 2021) ordered 100-day supply chain risk reviews, including a report by the Secretary of Defense, as National Defense Stockpile Manager, on critical minerals and other strategic materials explicitly including rare earth elements. The resulting June 2021 review track shaped the federal framing of the rare earths-to-magnets chokepoints and follow-on DoD and DOE actions.

Rare earths, Graphite · Sep 30, 2020 · freshness floor Aug 11, 2026

Executive Order 13817 — A Federal Strategy To Ensure Secure and Reliable Supplies of Critical Minerals

Amended actual

EO 13817 (Dec. 20, 2017) made it federal policy to reduce U.S. vulnerability to critical-mineral supply disruptions and directed the Secretary of the Interior to identify critical minerals, producing the 2018 list on which rare earth elements appear. It is the root instrument of the modern U.S. critical-minerals policy chain that runs through the USGS lists, EO 13953, and later rare-earth supply chain actions.

Rare earths, Graphite · Sep 30, 2020 · freshness floor Aug 11, 2026

Executive Order 13953 — National Emergency on Reliance on Critical Minerals From Foreign Adversaries

Announced actual

EO 13953 (Sept. 30, 2020) declared a national emergency under the National Emergencies Act and IEEPA over U.S. reliance on critical minerals from foreign adversaries, citing the fact that the United States imported 80 percent of its rare earth elements directly from China as its lead example. It directed agencies to prioritize secure critical-mineral supply chains, ordered consideration of a grants program for domestic mineral processing equipment, and amended EO 13817 to require periodic list updates.

Rare earths · Jul 22, 2019 · freshness floor Aug 11, 2026

Presidential Determinations 2019-16 through 2019-20 — DPA Title III Rare Earth Production Capability

Announced actual

Five Presidential Determinations signed July 22, 2019 under section 303(a)(5) of the Defense Production Act (50 U.S.C. 4533) found that domestic production capability for heavy and light rare earth separation and processing, rare earth metals and alloys, NdFeB sintered material and permanent magnets, and SmCo permanent magnets is essential to the national defense. They unlocked DPA Title III purchases and purchase commitments across every stage of the rare earths-to-magnets chain and underpin subsequent DoD Title III awards to separation, metal, and magnet projects.