- Presidential order prioritises strategic mineral availability
- Tungsten scrap emerges as key defence resource
The US has authorised export restrictions on recoverable critical minerals and materials, signalling a broader shift towards retaining strategic resources for domestic manufacturing and defence applications. President Donald Trump signed Presidential Determination No. 2026-19 on 30 July, invoking the Defense Production Act (DPA) of 1950 after concluding that inadequate domestic supplies of critical minerals pose increasing risks to national security and industrial resilience.
Published in the Federal Register on 4 August, the determination empowers the Department of Commerce to restrict exports of recoverable critical minerals and materials, including tungsten scrap and recycled battery feedstocks, through separate implementing regulations.
Defence concerns drive policy shift
The administration cited the US’s growing dependence on overseas suppliers and the vulnerability of critical mineral supply chains as key reasons behind the measure. The order forms part of a broader strategy to strengthen domestic supply security and reduce reliance on foreign processing capacity, particularly for materials used in defence systems, advanced manufacturing and clean energy technologies.
The latest move follows a series of policy interventions this year, including investigations into mineral imports and tighter procurement rules for the defence sector. From 1 January 2027, the US defence industrial base is expected to phase out sourcing of certain critical minerals from Chinese suppliers.
Tungsten scrap becomes strategic feedstock
Tungsten has emerged as a priority material because the US has not commercially mined the metal since 2015, leaving recycled scrap as one of the country’s few domestic sources. The metal is widely used in munitions, aerospace components and industrial machinery due to its high melting point and durability.
According to data from the US Geological Survey, the US exported around 3,300 tonnes (t) of tungsten scrap in 2025, compared with approximately 3,480 t in 2024. Net import reliance has exceeded 50% of apparent consumption since 2021, while Chinese imports account for around 14% of total US demand.
Industry participants have argued that unrestricted scrap exports could weaken domestic supply security. Earlier this year, US recycler Amermin led a coalition of processors and manufacturers seeking tighter controls on tungsten scrap shipments, warning that outbound material flows could undermine industrial and military readiness.
Battery recycling sector faces structural challenges
The policy also targets recycled battery materials containing lithium, nickel and cobalt, reflecting Washington’s efforts to strengthen domestic critical mineral supply chains.
The Basel Action Network estimates that the US exports nearly 33,000 t of electronic waste every month, much of which contains recoverable critical minerals. However, black mass is not separately classified in US trade data, making precise export volumes difficult to estimate.
Although domestic recycling investments are increasing, the sector continues to face financial and operational challenges. Several companies have announced new processing facilities, but recent bankruptcies among major recyclers have highlighted concerns over profitability and the industry’s ability to absorb additional feedstock.
Trade flows may undergo realignment
The export controls could reshape existing trade patterns for both tungsten scrap and recycled battery materials. Canada and Mexico currently account for a substantial share of US tungsten scrap exports, while battery recycling materials are often shipped to processing hubs in South Korea, Japan and other Asian markets.
As domestic recycling capacity expands, the US appears to be repositioning recyclable materials as strategic industrial inputs rather than waste streams.
Outlook
The Presidential Determination marks a significant shift in US industrial policy towards securing domestic access to critical minerals. Market participants will closely monitor the implementing regulations issued by the Department of Commerce, particularly regarding the scope of export restrictions, compliance requirements and their potential impact on global recycling trade flows.
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