Minerals Hub / Policy & Geopolitics / What makes a mineral critical, and who decides
Policy & Geopolitics · · 6 min read
What makes a mineral critical, and who decides
The EU, the United States and Australia each decide criticality by their own method, measuring different things, keeping different tiers and reaching different lists.
Reviewed by Peter Uppal
The short version
The EU, the United States and Australia each decide criticality by their own method, so the same element can be on one list and off another. The EU's 2023 assessment scored candidate raw materials on two main criteria, economic importance and supply risk, and EU law names 34 critical raw materials and 17 strategic ones, which the critical list must include. Zirconium is on the United States' 2025 list and on Australia's list as updated in February 2024, but on neither list in the EU's Critical Raw Materials Act.
One element, three answers
Zirconium appears on the United States' Final 2025 List of Critical Minerals, published 7 November 2025, and on Australia's Critical Minerals List as updated 20 February 2024. The text of Regulation (EU) 2024/1252 as published in the Official Journal does not contain "zircon" or "zirconium" anywhere, its two lists included.
The Commission's 2023 study scored zirconium at the extraction stage with a supply risk of 0.8 and an economic importance of 3.5, against thresholds that remain at SR ≥ 1.0 and EI ≥ 2.8 rounded to one decimal. Zirconium cleared the economic-importance bar and fell short on supply risk.
Hafnium differs in another way. It is on the US 2025 list and Australia's, and in EU law it is critical, in Annex II, but not strategic, in Annex I.
What the EU's assessment measures
The 2023 study says its methodology is based on the two main criteria of Economic Importance (EI) and Supply Risk (SR). In the EU method, economic importance is based on the value added of corresponding EU manufacturing sectors, corrected by a substitution index; supply risk is based on supply concentration at global and EU levels weighted by a governance performance index, corrected by recycling and substitution parameters. The method was developed by the Commission with an ad hoc expert working group in 2017.
The 2023 round assessed 70 candidate raw materials and proposed 34 for the critical list. Not all 34 met both thresholds: the study says copper and nickel do not meet the CRM thresholds, but are included as SRMs, strategic raw materials. In law, under Article 4(2) of the Regulation, the critical list shall include the strategic raw materials, as well as any other raw material that reaches or exceeds the threshold of 1 for supply risk and 2.8 for economic importance.
Two tiers, and the benchmarks belong to one
Annex I of the Regulation lists 17 strategic raw materials and Annex II lists 34 critical raw materials. An updated strategic list is to include those that score among the highest in terms of strategic importance, forecasted demand growth and difficulty of increasing production.
Stage matters. The 2023 study found titanium in all forms, around 80% used as white pigment, not critical, but assessed titanium metal as a specific and critical form of titanium, due to its strategic applications and a very concentrated production. The entry in both annexes is titanium metal.
Under Article 5(1)(a), the Commission and Member States are to ensure that by 2030, Union capacities for each strategic raw material have significantly increased so that, overall, Union capacity approaches or reaches three benchmarks: for extraction, at least 10 % of the Union's annual consumption of strategic raw materials, to the extent possible in light of the Union's reserves; and for processing and recycling, at least 40 % and at least 25 % of the same consumption. Article 5(1)(b) adds a diversification aim, with a view to ensuring that, by 2030, the Union's annual consumption of each strategic raw material at any relevant stage of processing can rely on imports from several third countries or from overseas countries or territories, and that no third country accounts for more than 65 % of it. On this publication's reading, a material that is critical but not strategic, such as hafnium, falls outside the wording of Article 5's three benchmarks and its diversification aim.
A score on two axes, a pair of thresholds, two annexes, and a date to look again.
Washington and Canberra apply other tests
The USGS 2025 methodology is based on two primary criteria: an economic effects assessment that quantified the potential impacts of foreign trade disruption scenarios on the U.S. economy, and an examination of whether a mineral commodity's supply chain relied on a sole domestic producer that represented a single point of failure. The method did not produce the whole list: six minerals were added by interagency designation. The final list has 60 minerals, including hafnium, titanium and zirconium, with titanium named without a stage.
Australia's list covers minerals "essential to our modern technologies, economies and national security", "for which Australia has geological potential for resources", "in demand from our strategic international partners" and "that are vulnerable to supply chain disruption". Its list page, last updated 20 February 2024, shows 31 entries in its Table 1 (the department's announcement said 30), alongside a separate Strategic Materials List of five items: aluminium, copper, phosphorus, tin and zinc. On Australia's lists as updated 20 February 2024, hafnium, rare-earth elements, titanium and zirconium are on the critical list, not the strategic one. So "strategic" does not travel: the EU's strategic list sits inside its critical list, while Australia's is a separate list from its critical one.
Every list has a review date
The 2023 study was the fifth technical assessment, and the critical count has moved between rounds, from 14 of 41 candidates screened in 2011 to 30 of 83 in 2020. Regulation (EU) 2024/1252 is dated and signed 11 April 2024, was published in the Official Journal on 3 May 2024, and entered into force on 23 May 2024. The Commission must review and, if necessary, update the strategic list by 24 May 2027, and every three years thereafter, and the critical list by 24 May 2027 and at least every three years thereafter, and both can be amended by delegated act. As of 13 October 2026, EUR-Lex lists no act amending Regulation (EU) 2024/1252, only corrigenda; two amending proposals are pending. One of them, COM(2025) 946 (Council mandate of 4 March 2026), changes articles, not the annexes.
The US 2025 list revises the list published in 2022, which included 50 minerals, and US law requires review at least every 3 years, or more frequently as the Secretary considers to be appropriate. Australia's government says it will review the lists at least every 3 years.
Related
- Government Policy — the instruments that sit behind a list
- Supply Chain Risk — the supply side of a criticality score
- Processing Capacity — why the stage a list names matters
- Strategic Stockpiles — the forms in which a listed material can be held
- International Partnerships — where one government's list meets another's
Sources
- PRIMARYEuropean Commission (Grohol, M. and Veeh, C., DG GROW), Study on the Critical Raw Materials for the EU 2023: Final Report, 2023. Executive summary and section 2.2: the two main criteria (economic importance, supply risk) and how each is calculated; methodology developed with the Ad hoc Working Group in 2017; thresholds SR ≥ 1.0 and EI ≥ 2.8 rounded to one decimal. p. 2: fifth technical assessment; candidates screened and critical counts by round. p. 3 and p. 39 (Table 13): titanium in all forms not critical; titanium metal a critical form. p. 20 (section 3.1): 70 candidates assessed, 34 proposed; copper and nickel included as strategic raw materials without meeting the thresholds. Annex, overview of assessment results: zirconium SR 0.8, EI 3.5, stage extraction.
- PRIMARYRegulation (EU) 2024/1252 of the European Parliament and of the Council of 11 April 2024 (Critical Raw Materials Act), Official Journal L series, 3.5.2024, EUR-Lex HTML of the OJ text, read in full. Title and signature line ('Done at Brussels, 11 April 2024'); Articles 3(2)–(3) and 4(2)–(3) (selection of strategic raw materials; thresholds; reviews by 24 May 2027; delegated acts); Article 5(1)(a) and (b) (2030 benchmarks); Annex I, Section 1 (17 strategic raw materials); Annex II, Section 1 (34 critical raw materials). Full-text search for 'zircon' (which also matches 'zirconium') over the published text: zero hits.
- PRIMARYEUR-Lex document page ('ALL' tab) for CELEX 32024R1252, read 13 October 2026. Date of effect 23/05/2024 (entry into force, date of publication plus 20, Article 49(1)); 'Modified by' lists corrigenda only (R(01) to R(05)) and no amending act; two pending amending proposals, 52025PC0946 and 52026PC0590.
- PRIMARYCouncil of the European Union, document 6997/26, 4 March 2026, file 2025/0385 (COD), mandate on the Proposal for a Regulation amending Regulation (EU) 2024/1252 (COM(2025) 946). Amends Articles 7(3), 24, 28(1), 29 and 38; not the annexes.
- SECONDARY30 U.S.C. 1606 (Energy Act of 2020, sec. 7002), as reproduced by the Cornell Legal Information Institute. Subsection (c)(5)(A): review at least every 3 years, or more frequently as the Secretary considers appropriate. A host reproduction of the US Code; the official uscode.house.gov text could not be reached.
- PRIMARYU.S. Geological Survey / Department of the Interior, Final 2025 List of Critical Minerals, 90 FR 50494 (FR Doc. 2025-19813), published 7 November 2025 (current edition). The 60 minerals listed; the two primary criteria of the 2025 methodology; six minerals added by interagency designation under section 7002(c)(4)(B); revision of the 2022 list.
- PRIMARYU.S. Geological Survey / Department of the Interior, 2022 Final List of Critical Minerals, 87 FR 10381, published 24 February 2022 (superseded edition). The 50 minerals of the 2022 list.
- PRIMARYAustralian Government, Department of Industry, Science and Resources, 'Australia's Critical Minerals List and Strategic Materials List', published 20 June 2023, updated 20 February 2024. The list's four criteria; Table 1 (31 rows, counted; the page states no total), including Hafnium, Rare-earth elements, Titanium and Zirconium; the Strategic Materials List (aluminium, copper, phosphorus, tin, zinc); review of the lists at least every 3 years.
- PRIMARYAustralian Government, Department of Industry, Science and Resources, news item 'Updates to Australia's Critical Minerals List' (no date shown). States that the updated list consists of 30 minerals or groups of minerals.
- ANALYSISANALYSIS: the reading that a raw material that is critical but not strategic, such as hafnium, falls outside the wording of the Article 5 benchmarks.Non-public document · no public URL
