Trump Orders National Security Investigation for Critical Minerals

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Apr. 16, 2025
By: Pietro N. Bianchi

On April 15, 2025 Trump ordered a Section 232 investigation for processed critical minerals, including rare earth minerals, and derivative products. Section 232 has been used to impose increased duties on imports of steel, aluminum, derivatives of steel and aluminum articles, and certain vehicles and their parts. Similar investigations for copper, timber, lumber, and derivatives were announced earlier in Trump’s second term.

The critical minerals under investigation are those listed in a United States Geological Survey, and include:

Aluminum; antimony; arsenic; barite; beryllium; bismuth; cerium; cesium; chromium; cobalt; dysprosium; erbium; europium; fluorspar; gadolinium; gallium; germanium; graphite; hafnium; holmium; indium; iridium; lanthanum; lithium; lutetium; magnesium; manganese; neodymium; nickel; niobium; palladium; platinum; praseodymium; rhodium; rubidium; ruthenium; samarium; scandium; tantalum; tellurium; terbium; thulium; tin; titanium; tungsten; vanadium; ytterbium; yttrium; zinc; and zirconium.

The rare earth elements under investigation are identified by an April, 2020 Department of Energy publication, and include:

Lanthanum; cerium; praseodymium; neodymium; promethium; samarium; europium; gadolinium; terbium; dysprosium; holmium; erbium; thulium; ytterbium; lutetium; scandium; and yttrium.

All semi-finished goods and final products made with these minerals are subject to the investigation. These include semiconductor wafers, anodes, cathodes, permanent magnets, batteries; smartphones; and microprocessors.

In a similar vein, the Bureau of Industry and Security requested comments on the Section 232 investigation on Imports of Semiconductors and Semiconductor Manufacturing Equipment, which include critical minerals in their production.

The critical and rare earth minerals investigation will focus on predatory practices and strategies of foreign actors that process critical minerals, domestic capabilities, and supply chains vulnerabilities. The Trump administration ordered this investigation less than two weeks after China, which produces and refines an overwhelming majority of the world’s critical and rare earth minerals, imposed export restrictions on samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium in response to the April 2, 2025, IEEPA Tariffs.

If you have questions about Section 232 or IEEPA tariffs do not hesitate to contact an attorney at Barnes, Richardson & Colburn, LLP.