On March 19, 2026, SAFE’s Center for Critical Minerals Strategy submitted comments in response to the United States Trade Representative’s Request for Comments on the Design of a Plurilateral Agreement on Trade in Critical Minerals and Policy Actions to Strengthen the Resilience of Critical Mineral Supply Chains.
Unilateral trade actions by the United States have limited influence on global critical mineral markets because U.S. producers remain highly exposed to global dynamics. This limitation stems from the United States’ incomplete supply chain capabilities across many critical minerals, including key processing steps and the capacity to manufacture derivative products at scale. U.S. producers, particularly in the midstream, depend on both foreign-sourced materials and foreign buyers.
To meaningfully shift business practices, the United States must coordinate with other major mineral-consuming countries and midstream producers to exchange information, align standards, and ensure a consistent response against non-market behavior across jurisdictions. SAFE, therefore, welcomes the U.S. Trade Representative’s (USTR) pursuit of a plurilateral agreement as a constructive step toward diversifying supply chains and fostering more level competition.
The design of any plurilateral agreement on critical minerals must begin with a clear articulation and alignment on the problem that members agree to solve, and it should be understood as part of a broader policy architecture rather than a standalone solution.
As USTR pursues plurilateral agreements in trade, SAFE’s Minerals Center recommends the following: USTR should limit the scope of the agreement, at least initially, to a small number of minerals; Target minerals should be selected based on the availability of alternative supply outside of China and a large enough demand base within the trade zone; The price floor should target processed and refined forms of critical minerals; Countries that import and transform processed materials should be prioritized as partners; Pricing mechanisms should be anchored in a sustainable production price floors.
Read SAFE’s full comments here.
