Last week, the U.S. updated its critical mineral list. This piece describes these recent updates, comparing the critical and strategic minerals identified by the United States and China, and indicating which materials are currently subject to China's export control regime.

Several years ago, the U.S. Department of the Interior published a 2022 Final List of Critical Minerals, which identified 50 mineral commodities critical to the U.S. economy and national security. A 2025 draft update of the list, put out by the United States Geological Survey (USGS), suggested adding potash, silicon, copper, silver, rhenium and lead to the list, while proposing the removal of arsenic and tellurium. The final 2025 list, issued last week, includes 10 new elements: boron, copper, lead, metallurgical coal, phosphate, potash, rhenium, silicon, silver and uranium. It also retained arsenic and tellurium, which had been proposed for removal in the draft. Among the newly added items, copper, potash, and uranium have been considered as strategic minerals by China.

The list would be used to evaluate mineral supply chain risks and develop strategies for securing supply chains. Ned Mamula, USGS director, said that "[c]ritical minerals underpin industries worth trillions of dollars, and import dependence puts key sectors at risk. This work helps secure the materials needed for U.S. economic growth and technological leadership." The list could also be used to determine future U.S. tariffs pending the ongoing Section 232 investigation. Critical minerals are also at the center of a recent report published by the U.S. Select Committee on the Chinese Communist Party, where U.S. lawmakers argued that China "manipulates the critical minerals markets to further its global authoritarian ambitions."

China is also poised to update its own critical mineral list. A new Chinese law (link in Chinese) governing mineral resources requests the government to formulate a catalog of strategic mineral resources. Given the law's enforcement date of July 2025, Beijing is expected to publish a new list of strategic and critical minerals soon. Currently, the most definitive document identifying strategic minerals is a government planning document for 2016 and 2020 (link in Chinese) published by the National Development and Reform Commission, which listed graphite, antimony, chromium, nickel, tungsten, cobalt, lithium, rare earth, and zirconium, among others, as strategic minerals.

A significant number of these materials, whether identified by the U.S. or China, or both, are currently covered by China's export control regime, a system that Beijing intends to expand. In January, a MOFCOM spokesperson said that China will "add relevant strategic resources to the [dual-use item] list and strengthen export controls in a timely manner," based on "its own needs such as maintaining national security" and "its international obligations such as non-proliferation." Further supporting this intent, a recent draft of China's next five-year plan calls for a modernized national security system, including improving its export control and security review mechanism.

The expansion of China's export control regime is clearly demonstrated by actions taken concerning rare earth elements (REEs). China initiated export controls on seven of the seventeen classified REEs in April, establishing a preliminary scope. The scope was broadened most recently on October 9, when Beijing announced new export controls, subjecting five more REEs, holmium, erbium, thulium, europium, ytterbium, along with their related alloys, oxides, mixtures, and compounds to mandatory export licensing requirements. The expanded export control measures were scheduled to take affect on November 8, 2025, but have been suspended for one-year following a recent U.S.-China trade deal. Absent a future policy modification by Beijing, these export controls are scheduled to be reimposed on November 10, 2026. The current export control status of all seventeen REEs are detailed below.

This is an update of a previous comparison published in September.