In August 2026, the U.S. Commerce Department imposed temporary domestic-allocation requirements on black mass and tungsten scrap. The move signaled a broader shift in minerals policy: end-of-life products and manufacturing scrap are being treated as strategic feedstock that can supplement primary production and strengthen domestic supply.
This issue brief from SAFE’s Center for Critical Minerals Strategy, “Retain, Recycle, Secure: The Role and Limits of Export Restrictions“ assesses where export restrictions fit within the broader policy toolkit to secure supplies of recoverable critical minerals and promote domestic recycling. 
While U.S. capacity for material recovery is expanding, it remains insufficient to handle the volumes of scrap generated domestically. And for certain products like lithium-ion batteries, recycling capacity remains highly concentrated in China.
As such, the issue brief finds that retaining recyclable materials domestically does not guarantee an increase in domestic critical minerals production. Export restrictions must be complemented by investments in processing capacity, measures to strengthen collection, sorting, and preprocessing, and policies that address permitting barriers.
“Retain, Recycle, Secure“ provides case studies of batteries, rare earth permanent magnets, copper, and tungsten that illustrate why recycling capacity must be assessed by feedstock and processing stage: battery shredding and black-mass refining require different capabilities; rare earth magnets must be identified and separated from discarded products; and copper and tungsten scrap require processing matched to their grade and composition.
Key takeaways include:
- Export restrictions should be flexible and targeted to specific national security risks and demonstrated supply-chain bottlenecks, with scope and duration reassessed as conditions change.
- Restricting exports can increase feedstock availability and lower input costs for domestic processors where sufficient recovery capacity exists. However, falling scrap prices could weaken incentives to collect, sort, and pre-process materials, ultimately undermining the recycling ecosystem these restrictions aim to support.
- Existing trade classifications do not always distinguish critical-mineral-bearing scrap from other waste streams.
- U.S. export restrictions could encourage trading partners to adopt similar measures for primary or secondary feedstocks, undercutting U.S. efforts to maintain open critical minerals markets and limiting U.S. access to critical materials elsewhere in the supply chain.
- U.S. recycling industries rely on international networks, including specialized processing facilities in allied countries that can bridge gaps in domestic capabilities in the near term.
The measure of success for policies to strengthen domestic supply is not how much scrap stays in the United States, but rather, how much they strengthen supply chains that turn recyclable material into usable inputs for U.S. industry.
