Dear MMTA Members and Colleagues,

Welcome to the Conference edition of the Crucible.

If you are reading it in Lisbon, as we hope you are able to, it is designed to help you navigate the conference — what is happening where when. The International Minor Metals Conference is the highlight of the minor metals year, and for us as the Minor Metals Trade Association, seeing our members and industry colleagues come together, discuss ever-evolving topics and, enjoy the event.

If you are an MMTA member, on Tuesday morning, 8th April, please revive yourself with coffee kindly sponsored by Exotech first thing and come and join fellow MMTA members for the Annual General Meeting at 9am. In this issue you will find who is standing for election or re-election to the MMTA board. This is also your chance to hear what the Association has been doing for its members over the past year since we last met in Singapore and what plans are afoot, ask questions and to make suggestions for the year ahead.

Make it make sense

It’s not just that we are now past the Spring Equinox and that days are growing longer, but that we have learned in the past few months that even a day is a long time in politics.

For example, a 25% tariff on US imports of cars from neighbouring Canada and Mexico can be imposed by an executive order one day and disappear the next. The EU, no stranger to tariffs itself (having hiked them to up to 45% of Chinese EV’s last year) has been looking nervously across the Atlantic as a tornado of hostile rhetoric heads its way, expecting 25% tariffs on its own cars to be imminent… and still be waiting weeks on to see if they materialise. And then, one day, they did, just like that, after the Crucible print issue went to press. Like the 25% blanket US tariffs on aluminium and steel.

Between the issue going to press and this article going online, the US imposed tariffs on most countries it could think of, and some places that did not have anything to export. The rationale has left mathematicians and many economists perplexed, but increasing, commentators  have been recognising the strategy of maximum disruption as a geopolitical powerplay. Even if it costs US businesses and knocks stock markets out of kilter across the globe, disruption of an order can be as an end in itself.

The reasoning is not entirely random. The UK, with which the US has trade surplus is subject to 10% tariffs, its neighbours in the EU,  to 20%. This is not a patch on the level of tariffs implemented on Asian countries, with general tariffs on China rising to a compound 54%. China is singled out as a US competitor. Russia, by contrast, is exempt. This is geopolitics much more than business-minded economics.

The swathe of tariffs announced by the US Administration can be followed in the White House Announcements https://www.whitehouse.gov/presidential-actions/ and the USITC Harmonized Tarriff Schedule revision here: https://hts.usitc.gov.

However, a number of metals, including a range of minor metals some of which are defined as critical raw materials in the US, some types of scrap and certain ferroalloys are exempt from new tariffs, a list of which can be found here: https://www.whitehouse.gov/wp-content/uploads/2025/04/Annex-II.pdf
That is testament to the thinking not being entirely random, in the middle of a tariff war there is a recognition of the critical materials that the US cannot source domestically and needs to import.

Although the new tariffs are coming into force within days of being announced, there is a limited exemption from the enforcement of general and country-specific tariffs for goods in transit, e.g. “on the water”,  as follows:

The baseline tariffs (10%) on imports apply from 5^th April for goods entering the US apply “except loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern daylight time and entered for consumption or withdrawn from warehouse for consumption after 12:01 a.m. eastern daylight time on April 5, 2025,”.

For imports subject to specific country reciprocal tariffs , such tariffs apply from 9^th April except for “ goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern daylight time on April 9, 2025, and entered for consumption or withdrawn from warehouse for consumption after 12:01 a.m. eastern daylight time on April 9, 2025.”

The Source for all this is the following President Trump’s executive order of 2 April 2025 here: https://www.whitehouse.gov/presidential-actions/2025/04/regulating-imports-with-a-reciprocal-tariff-to-rectify-trade-practices-that-contribute-to-large-and-persistent-annual-united-states-goods-trade-deficits/

Tales of the unexpected

An avalanche of executive orders that need to be executed right now is not a common way of doing government. However, it was for President Trump’s first administration, and it is even more so for Trump administration 2.0. But two can play that game — that is easier done in a political structure where power is concentrated in the executive, than in a parliamentary democracy where policy is shunted back and forth, amendments get tabled and, if a risk assessment hadn’t been done yet, then it is already forthcoming. Risk or assessment rarely come into policies issued by decree.

Step up China’s usually more considered MOFCOM, that, when announcing a new piece of non-barrier red tape would at least give a month’s warning, perhaps two. Not anymore.

The December ban on exports to the US of antimony, gallium  and germanium in retaliation to US bans on semiconductors  was swift. It was announced and there it was, not a day’s grace to prepare. Two months later, and the dual goods list of a swathes of products including bismuth and tellurium metals, cadmium telluride and every conceivable kind of tungsten  was published with the words “This announcement will be officially implemented for the day of publication”. That’s it.

Two months later, on 4 February China’s MOFCOM announced new export controls one certain tungsten, tellurium, bismuth. molybdenum and indium products,  again citing national security and non-proliferation. These products were;

• Ammonium paratungstate (APT), tungsten oxides and carbides, tungsten metal and alloys, such as those alloyed with copper or silver, and W-nickel-iron alloys.
• Tellurium metal, including monocrystalline polycrystalline high-purity tellurium as well as
• Cadmium telluride, cadmium zinc telluride and cadmium mercury telluride
• Bismuth in every metallic form ingots, granules, powders etc), along with bismuth germanate (used in civil applications such as medical radiography), as well as some organic bismuth compounds
• Indium chemicals: indium phosphate, trimethylinium and triethylindium
• Molybdenum and molybdenum alloy powders up up to 50 micrometres in size, that MOFCOM stated could be used to manufacture missile components.

Needless to say, the new export controls came into force on the day of the announcement, 4 February. This promptly disrupted the market, choking off the flow of supply, quickly felt in Europe.

Then exactly two months later, on 4 April, MOFCOM followed up with a dual-use export licensing regime for certain rare earths elements in metal, oxide or compound forms, REE alloys and sputtering targets, alongside scandium metal and alloys and certain magnetic materials including powders. As in previous such measures MOFCOM cited national security and commitments to  non-proliferation.

The products affected by these latest export controls include:

• Samarium metal, oxides, compounds and mixtures, alloys of samarium with cobalt, nickel, aluminium, magnesium and iron, magnetic samarium alloys and samarium, samarium-cobalt and samarium-iron sputtering targets;
• Gadolnium metal, oxides, compounds and mixtures; alloys of gadolinium with magnesium, aluminium, cobalt or iron; gadolinium, gadolinium-iron and gadolinium iron sputtering targets;
• Terbium metal, oxides and compounds and mixtures, terbium alloys with cobalt or cobalt-iron, terbium and terbium-cobalt sputtering targets;
• Dysprosium metal oxides, compounds and mixtures, dysprosium -iron alloys, dysprosium and terbium-dysprosium-iron alloy sputtering targets;
• Neodymium-iron-boron  (NdFeB) magnetic alloys containing terbium or dysprosium;
• Lutetium metal, oxides, compounds and mixtures, luterium sputtering targets, ytterbium-lutetium alloy;
• Scandium metal, oxides, compounds and mixes; alloys of scandium with aluminium, magnesium or copper;
• Yttrium metal, oxides, compounds and mixes; yttriu, yttrium-aluinium and yttrium-zirconium sputtering targets; yttrium alloys with aluminum, magnesium, nickel.

The full list of regulated materials is HERE.  The export controls came into force , again, on the same day they were announced, 4 April 2025. An executive decision, executed right now.

No time to plan or mitigate— or obtain a licence overnight. This is where you can take a punt and bet on MOFCOM either banning the export of something or requiring a licence for it exactly two months on, which would be 4 June. Or will it? And which set of metals or metal salts or other materials will it be? 

Unpredictability can play havoc with economies and markets. It makes pricing hard to forecast (invariably someone rides that wave and makes a profit, but volatility can damage markets in the long term—it’s a great motivator for substitution, for example). In this Crucible issue, CRU consultant Pyush  Goel  walks us through the reasons and scenarios of how export curbs, on gallium and germanium in particular, may play out in the mid-and long-term. But ultimately, metal markets are now looking to geopolitics somewhat more than to fundamentals, and that makes trends difficult to predict.

Critical Raw Materials — time to be more critical?

We are meeting in Lisbon in a very different time from just years ago when words like “neodymium” or “lithium” would have drawn a blank stare. Everyone is now an expert on rare earths (or they think they are, even when talking about a niobium deposit).

Our industry is suddenly important (it has always been, but now visibly so). The term Minor Metals would still draw a blank, but everyone has heard of Critical Metals— and that term is not about geology, it’s about geopolitics. So what makes some, if not most, minor metals critical?

1. Applications: is a metal used in a much needed, growing technology
(a rechargeable battery, a solid state drive, a motor magnet)?

2. Is it rare — can you get hold of it and enough of it?

3. And that veers from “critical” into “strategic” materials — is someone else sitting on its resources who could stop you getting it, e.g. by putting an export quote or a dual-goods licence on it, or banning exports altogether (the Ministry of Commerce sends regards)?

Everybody has a slightly different assessment of what Critical Metals are in their region (and indeed whether to call them Critical Metals, Critical Minerals or Critical Raw Materials (CRM rolls of the tongue, and common usage is gravitating in that direction). The EU has a CRM list, Japan has such a list, Canada, Australia, UK… And, as our North American correspondent Tom Butcher has previously pointed out, the US has several CRM lists that all somewhat vary.

In creating a new Criticality List in November 2024, the UK Critical Minerals Intelligence Centre, (CMIC) part of the British Geological Survey, took a more geological/materials science, rather than geopolitical approach. CMIC’s new list of critical
minerals includes 34 elements. Some make instant sense, but some have left the minor metals trade baffled. The 34 critical minerals (17 up on the 2021 UK) list are:

Aluminium	Indium	Niobium	Tantalum
Antimony	Iridium	Phosphorus	Tellurium
Bismuth	Iron	Platinum	Tin
Borates	Lithium	REE	Titanium
Cobalt	Magnesite	Rhenium	Tungsten
Gallium	Magnesium	Rhodium	Vanadium
Germanium	Manganese	Ruthenium	Zinc
Hafnium	Natural graphite	Silicon
Helium	Nickel	Sodium

This is a geological approach. While it takes into account low volumes and concentration, it does not always consider the maturity of UK’s recycling industry for some of these elements. It does not consider geopolitics (e.g for niobium, unless the UK finds it self in conflict with Brazil) and price volatility (also causing substitution) is not a factor. But policymakers have to factor in geopolitics and market economics.

Once a country or region has a list in place, policymaking kicks off about how to secure them. If you are lucky, you could discover that you have lithium deposit sitting in the Balkans (Jadar in Serbia) or an untapped stream of hydrogen beneath a chrome mine (Bulqizë) in Albania (on that note Albania’s Vega Solar is building the country’s, first 100MW Li-ion battery plant for solar energy storage, with the help of an Indian solar-energy focused venture).

But you can also soon discover you don’t have the resources, and need to “friendshore” them from countries that won’t hit you with an export ban, or recycling. The EU is realising that it can’t both secure critical materials supply and make it difficult or costly to move scrap or metals around: sustainability and hazardous waste regulations clash with CRM strategies.

The review of REACH regulations that involve costly dossiers of materials imported into the EU for hazard purposes keeps being pushed back. After the introduction of CBAM carbon tracking on selected products, the CRM Act is pushing the European Commission to create sustainability reporting for CRMs that will force anyone putting these materials on the market to publish their environmental footprint declarations. On 9th April the Commission is holding a workshop on how to go about this.

There is a conflict here: while in February the commission issued an Omnibus legislation to  cut regulatory burden for EU businesses by 25%, and by 35% for small and medium sized businesses, by the end of its mandate in 2029, this sustainability reporting will create more administrative burden on companies operating in the very CRM space it seeks, with the other hand, to develop and safeguard. Administrative burden raises cost. And perversely, cost can kill sustainability: see the demise, two decades ago, of European and North American electrolytic magnesium industries that were a lot cleaner than thermally reducing dolomite in China.

Resource wars

We are meeting in peaceful Lisbon, whose history is fraught with war — fights for a strategic port at the heart of global trade whose Jewish, Muslim and Christian merchants hailing from across Europe, Middle East and North Africa made up its rich medieval heritage.  The 17th century baroque stately buildings we will see around up were built with a royal levy of Brazilian gold.

Resource wars are happening now. M23 rebels — ostensibly defending the minority Tutsi ethnic population in majority Hutu eastern Democratic Republic of Congo, but widely believed to be Rwandan-backed, after recently taking over North Kivu’s trade hub of Goma, overrunning the country’s largest tantalum mine Rubaya, then South Kivu’s capital Bukavu,
quickly imposed a governance, putting a levy on artisanal miners. It took them no time at all to build a quazi-governmental administrations around a resource economy, they came prepared. The DRC conflict is a resource war. As the MMTA magazine went to press, the M23 offered to leave Walikale, home to Bisie tin mine, for a ceasefire.

Tom Butcher pointed out in the December Crucible that President Trump understands the importance of CRMs. But The President’s language on CRM has since turned to claims to Greenland and Canada and a demand for half of Ukraine’s resources in return for alleged $500bn not yet spent by the US on backing Ukraine. As this issue goes to press, he is still pushing for a deal.

Ukraine might agree, though not to half its resources, and not without security guarantees. Ukraine’s new 100-year security-backed agreement with the UK, involves a clause on developing minerals. Go back 150 years, and you will find that the two countries have an Industrial Revolution era history of building a coal and steel industry together. 

In the id 20th century, Ukraine became the raw materials end of the Soviet Union’s titanium industry that downstream encompassed Russia and Kazakhstan, its aluminium and steel industries—a now disparate industrial chain that Russia is keen to rebuild. In post-Soviet 21st cenury Ukraine, Russia lost its raw materials base, but gained an industrial competitor
in ferro-alloys and steel.

Behind Ukraine’s offer to develop resources with US backing lie orebodies at a very early stage of exploration. Why shouldn’t Ukraine leverage them to guarantee peace, especially if by the time pre-feasibility studies come in, the Trump and Putin administrations might be gone?

The Putin administration offers the US a similar deal: access to both Russia’s and
occupied Ukrainian territories’ resources. Maybe US could even be tempted to drill an Arctic REE deposit in a spot winter temperatures fall below 50°C? Why not sell London Bridge and bring in investment all at once?

To get at Greenland’s resources, the Arctic ice needs to melt. Hydrocarbon-focused policies could do that, but that might make it too late for critical minerals to build sustainable energy generation to replace oil and gas. Most CRMs are only critical because they are critical to the energy infrastructure 5 needed to ensure survival. The CRM rush and resource wars often ignore survival.