On September 25, 2025, SAFE’s Center for Critical Minerals Strategy submitted comments in response to the U.S. Geological Survey’s (USGS) Notice of Opportunity for Public Comment on the 2025 Draft List of Critical Minerals.
SAFE commends the U.S. Geological Survey for incorporating many of the improvements it urged in comments submitted on the 2021 draft list. The new methodology provides even more granularity than the previous assessment for 11 mineral commodity supply chains, by separately evaluating—where data exists—the different production stages as well as the distinct forms minerals are converted into.
SAFE also offered comments on two of the three issues identified for public comment: Inclusion of metallurgical coal and uranium on the final List of Critical Minerals and the Merit of moving to an annual update for the USGS technical input to List of Critical Minerals.
On top of that, SAFE offered additional comments on how to expand the list and methodology to capture possible consequences for national security that extend beyond modeled economic impacts, and how to monitor progress and prevent its reversal when a mineral is removed from the list.
Read SAFE’s Center for Critical Minerals Strategy’s full comments here.
