Policy & Export Control Tracker

Batteries on EU market must contain minimum percentage of recycled cobalt, lithium, nickel, lead. Specific percentages via delegated acts (expected 2028–2029).

New EV/industrial batteries must contain ≥6% recycled lithium, rising to 12% by 2036.

New EV/industrial batteries must contain ≥6% recycled nickel, rising to 15% by 2036.

All battery recycling must achieve ≥90% cobalt recovery. Current rate ~3% of Li-ion batteries. Drives commercial recycling infrastructure investment.

Companies >€40M revenue must implement OECD Due Diligence, trace cobalt from mine to manufacturer, undergo third-party audits, and report publicly.

EV batteries containing Chinese-processed graphite will completely lose access to the $7,500 tax credit. Major forcing function for Western anode supply.

Export restrictions imposed (quota/licensing details TBD). Exposes China's vulnerability despite 73% refining — dependent on DRC feed. Spot market tightening.

Enhanced public reporting requirements for Good Delivery refiners on sourcing from red-flag locations. Strengthens transparency in gold supply chains.

25% tariffs applied to Chinese tungsten products (carbides, concentrates, oxides) to counter dependency and spur allied supply chains.

Temporary relief through Nov 27, 2026. Licensing regime continues. Market uncertainty persists.

Suspends October announcements (57, 61, 62) until 2026-11-10. April 2025 controls remain in effect. Creates temporary but uncertain reprieve.

First-time inclusion for Silver, reflecting its vital role in defense, grids, PV, and advanced electronics, plus a 64% US import reliance.

Controls apply to rare earth items produced outside China if containing >0.1% value ratio of China-origin controlled inputs. Semiconductor end-use screening added.

Controls on REE metals, oxides, compounds, targets, and NdFeB magnets containing Dy/Tb. Licensing requirements for export of listed items.

Official confirmation of China's ban; highlights 100% US import dependency.

Applying USGS methodology, copper's supply risk score rose from 0.334 (2018) to 0.488 (2023), exceeding the 0.40 threshold. Argues copper should be added to the 2025 USGS Critical Minerals List.

Complete ban on Ga shipments to US. Further tightening of supply for American semiconductor manufacturers.

Complete ban. Prices reach $2,850-3,000/kg (99.999%). US scrambles for alternative sources.

Includes PGMs as Strategic Raw Materials due to their role in emissions control and the emerging hydrogen economy.

Designates cobalt as critical. 2030 targets: 10% EU extraction, 40% EU processing, 25% recycling. Max 65% from single third country.

Copper listed as strategic raw material (not critical, but strategic). 2030 targets: 10% EU extraction, 40% EU processing, 25% recycling. Import dependency capped at 65% from any single third country.

Establishes framework for supply chain resilience. Gallium listed as critical material with extraction and processing targets.

Germanium listed as critical. Targets: 10% extraction, 40% processing, 25% recycling by 2030.

Acknowledging the impossibility of sourcing non-Chinese anodes immediately, the US grants a 2-year grace period for graphite tracing under the FEOC rules.

Lists graphite as a strategic raw material, aiming for 10% domestic extraction and 40% domestic processing by 2030.

Lists lithium as Strategic. Sets 2030 targets: 10% EU extraction, 40% EU processing, 25% from recycling.

Lists rare earths for permanent magnets (Nd, Pr, Tb, Dy, Gd, Sm, Ce) as strategic raw materials. Mandates recycled-content disclosure for magnets >0.2 kg.

Through 2026: restrictions on magnets "melted or produced" in covered nations. From 2027: expanded to "mined, refined, separated, melted, or produced."

Gallium officially designated as critical raw material with systemic risk to EU value chains.

Requires special permits for exporters of highly sensitive graphite products, including battery-grade spherical graphite. South Korea and Japan heavily impacted.

Mine closure removes ~330–350 kt copper/year (~1.5% of global supply). Government initiates multi-month closure plan. Highlights governance and social license risks for large copper projects.

Mandatory due diligence for Co, Li, Ni, graphite sourcing. 90% cobalt recovery by Dec 2027. Battery passport by 2027. Minimum recycled content by Aug 2031.

All gallium exports require individual license with 45-day approval process. Immediate supply disruption.

95%+ volume drop in August-September. Supply disruption begins. Prices start climbing.

All Ge exports require individual license application. No immediate price impact.

Establishes due diligence for lithium supply chains, sets minimum recycling efficiency for Li-based batteries (65% by 2025), and ≥50% lithium recovery.

Mandates supply chain due diligence from Aug 2027. Recyclers must recover 95% of nickel by 2031.

EV tax credit ($7,500) requires 40–80% FTA-sourced critical minerals (2023–2027). Only 8% of refined cobalt is IRA-compliant. Excludes China, DRC, Indonesia.

Sets strict local sourcing requirements for battery components to qualify for the $7,500 EV tax credit, targeting Chinese anode dominance.

Formal investigation into national security impact of NdFeB magnet imports. Documents qualification barriers and supply chain vulnerabilities.

DOE frames comprehensive NdFeB magnet supply-chain assessment, quantifying concentration risks and substitution difficulty.

Mandatory due diligence for EU importers of tin, tantalum, tungsten, and gold (3TG) from conflict-affected areas. Requires risk assessment, mitigation, third-party audits, and annual reporting.

Banned export of raw laterite ore, forcing tens of billions in foreign direct investment into domestic smelters.

Global treaty requiring countries with significant ASGM to develop National Action Plans to reduce mercury use. ~46 ASGM countries covered. Targets: 37% reduction by 2025, 70% by 2030.

Requires Good Delivery refiners to implement OECD-aligned due diligence against human rights abuses, conflict financing, money laundering, and mercury use. Multiple iterations since.

Five-step framework for risk-based due diligence covering mines, traders, refiners, and downstream companies. Becomes the reference standard for EU and LBMA rules.

60 strategic projects approved from 170 applications in 2024 (first round). Includes processing and recycling projects. Fast-track permitting for designated projects.

Tighter vehicle emissions regulations sustain high PGM loadings in autocatalysts, keeping demand robust despite EV penetration.

Classified as critical due to high economic importance and extreme supply risk, triggering mapping and strategic funding.