The UK has now released its new Critical Minerals Strategy which outlines the prospective domestic and international policy actions that the UK Government will take, or will consider, in its pursuit of critical minerals security. By doing so, the UK joins a host of regions (the United States, EU, Canada, Australia, Japan, African countries) that have emphasised the central role of critical minerals in their trade policies, foreign policies, and green industrial strategies. These regions also published their respective strategic approaches to critical minerals recently.

There is a powerful narrative in developed economies regarding the indispensability of critical minerals for national and economic security, seeking to strengthen supply chains and make them more resilient by reducing ‘import dependence’ imports and diversifying international sourcing. Concern over  Chinese, near-monopolistic involvement in critical minerals supply chains, which could be weaponised, provides the main geopolitical context for most of these actions.

At the same time, mineral-rich countries, which range from those in the developing world (including African and Southeast Asian countries) to Australia and Canada, are looking to leverage their mineral wealth to secure their own mineral-led industrial futures while exploring the right policy mix to attract investments and provide secure partnerships to access-seeking regions.

The UK government strategy proposes a variety of domestic and international actions to increase domestic supply through both extraction and circularity. The policies proposed include regulatory barriers, financial and non-financial support for the private sector, stockpiling, trade policy, recycling/reuse and international cooperation. This aligns with similar strategies of other access-seeking nations, and typically permit (or require, from the view of the UK government) intervention to redirect markets. In a world built on liberal trade principles and multilateralism, such intervention requires a high level of transparency and precision. Our first observation concerns the strategy’s potential shortcomings. Our second observation highlights a key omission. Our final observation addresses the implications of combining growth and security.

Information and Transparency (or lack thereof)

According to the strategy, critical minerals are “identified as a foundational industry to the majority of the Industrial Strategy’s growth driving sectors”, which primarily refers to advanced manufacturing, clean energy, defence, digital technologies, and life sciences. But the strategy does not identify which critical minerals feeding into which value chains are being considered, and what corresponding policies are being deployed. The strategy itself also does not showcase any statistics on the levels of import dependence and supply chain concentration that UK critical minerals import face. Therefore, it does not distinguish between the reasons for the non-resilience of specific supply chains: a failure of domestic policy, absence of domestic policy, geopolitics, or failure of international cooperation. Instead, in the footsteps of the others, the strategy signals a policy-mix approach without a cost-benefit analysis of such policies in the first place, a question linked to the size of the UK market, and the associated opportunities and dependencies.

Similarly, the strategy also does not explain the figures behind the EU Critical Raw Materials Act style benchmarks for achieving more critical minerals security by 2035:  a) For domestic production to supply, 10% of total industrial demand for critical minerals, including at least 50,000 tonnes of domestically produced lithium; b) that 20% of total industrial demand should be met through recycling and recovery of critical minerals from end-of-life products; and c) no single source should account for more than 60% of the UK’s critical mineral supply. It is important to know how such figures have been calculated, their economic and geological basis, and the corresponding current figures.

Regarding international cooperation, the strategy aims for EU-style chapters dedicated to critical minerals in prospective FTAs. It also seeks to facilitate supply chain collaboration through bilateral critical minerals deals. Priority partners include the US, the EU, Australia, Canada, Japan, Saudi Arabia, and India, while existing partnerships (including Indonesia, Kazakhstan, Mongolia, South Africa, Uzbekistan, and Zambia) will be “refined”. However, the texts of many such partnerships are not publicly available, leaving unanswered questions about their contents and how the government plans to use them. Transparency and government scrutiny relating to such non-binding international partnerships should be discussed, especially if public funds are involved.

Omissions

Multilaterally, the strategy stresses the importance of cooperation at G7, G20, the WTO, the International Energy Agency, and interestingly, NATO, looking to ensure the uptake of sustainable and responsible practices in critical mineral supply chains.

However, the topic of deep seabed mining of critical minerals is omitted. The deep seabed, particularly in international waters, is increasingly becoming a battleground for critical minerals even though the effect of such mining on the marine environment and ecosystem is still unclear. This is exacerbated by the International Seabed Authority (ISA), the international body governing deep seabed mining, struggling to make rules on this issue. The UK, in its 2022 (now withdrawn) Critical Minerals Strategy had agreed not to issue any licenses on exploration of seabed mining and to contribute to discussions at the ISA. In 2023, the UK announced that it supported a moratorium on deep seabed mining to protect the marine environment, something the Labour Party had called for while in opposition. But the reality of 2025 or the vision of 2035 does not align with the reality of 2023. The US announced this year that it is shunning international law and cooperation to mine the deep seabed in international waters, citing “national security”.  In this changing geopolitical context, the omission of deep seabed mining from the critical minerals strategy, even if to reiterate an existing position, begs critical inquiry.

Blurred Lines

Our third observation pertains to an apparent artificial distinction drawn between three lists. The strategy is concerned primarily with economic growth, which happens to include defence and green sectors. The lists are defined as: “critical minerals” as identified in the 2024 Criticality Assessment, “growth minerals” as considered necessary for the Industrial Strategy’s growth sectors but are not critical, and “critical and growth minerals” which contains an overlap between the two.

The report makes it difficult to clearly understand the distinctions between “critical minerals” and “critical and growth minerals”, potentially risking the misunderstanding of applicable policies. On the policy side, there is a substantial overlap between critical minerals and growth minerals, and some policies of the strategy are extended to the “growth minerals” list (which are not critical). What then, is the purpose of the different lists, unless it is to expand government support to non-critical growth minerals? Conversely, what is the purpose of support for the critical-only minerals list (not growth), if economic growth through linkage with the Industrial Strategy’s growth sectors is the main objective of the strategy?

As an illustration, on p. 42 we see: “A deep dive into copper illustrates how the list will enable initiatives across government to secure supply of critical minerals for growth sectors”. This highlights the obfuscation between copper, a growth-only mineral, and its apparent treatment as a “critical” mineral for the purpose of the strategy. While it is difficult at this juncture to pinpoint any legal issues that may arise, definitional delimitations are typically important in government policies and legislations, and governments must be careful about consequent legal obligations.

Conclusion

Ultimately, the UK’s Critical Minerals Strategy offers a wide-ranging vision but remains sparse on the operational details that would determine its real impact. The document sets out an ambitious agenda requiring considerable government involvement in finance, trade, industrial policy, and international partnerships, in line with other similar strategies globally. But it largely defers the harder questions: exactly how will these commitments be executed and what is the evidence base for such commitments? Given the extensive intervention the strategy anticipates, its effectiveness will depend more on the implementation and the accountability of that implementation, than on the policy aspirations themselves.

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