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January 15th

Trump administration directs negotiations on critical minerals imports under section 232

Date of publication: January 15, 2026

Key Actions

The Trump Administration previously initiated a comprehensive trade action targeting imports of processed critical minerals and their derivative products (PCMDPs), citing national security concerns under Section 232 of the Trade Expansion Act of 1962. On January 14, 2026, President Trump signed a proclamation ordering the U.S. Secretary of Commerce and U.S. Trade Representative to jointly negotiate agreements with trading partners to address threatened national security impairment from PCMDP imports. The administration has established a 180-day negotiation window, after which alternative measures, including tariffs, may be imposed if satisfactory agreements are not reached.

National Security Findings

The Commerce Department's Section 232 investigation concluded that current import quantities and circumstances of PCMDPs threaten to impair U.S. national security, finding these materials indispensable to nearly every industry, including national defense programs and critical infrastructure. The investigation revealed several critical vulnerabilities:
  • As of 2024, the United States was 100 percent net-import reliant for 12 critical minerals and 50 percent or greater net-import reliant for 29 additional critical minerals
  • Despite being the second-largest producer of mined rare earth oxides globally, limited U.S. processing capacity requires exporting these materials for refining before reimportation
  • Critical mineral production in the United States has been declining, with facility closures and offshore relocation of production activities

Proposed Negotiating Framework

The administration will promote adoption of price floors for trade in PCMDPs when negotiating with allies. This represents a significant shift in U.S. trade policy, potentially establishing minimum pricing mechanisms for critical mineral transactions. The proclamation directs negotiators to consider:
  • Price floor mechanisms for critical minerals trade
  • Other trade-restricting measures as appropriate
  • Agreements to ensure adequate U.S. critical mineral supplies
  • Supply chain vulnerability mitigation strategies

Scope and Coverage

PCMDPs encompass a broad range of materials essential to modern manufacturing and defense applications. Examples include rare earth permanent magnets used in virtually all electronics and vehicles, as well as materials supporting all 16 critical infrastructure sectors. Critical sectors affected include:
  • Defense industrial base (fighter aircraft, munitions, naval ships, communications systems)
  • Chemical manufacturing (lithium, fluorite, bromine)
  • Communications infrastructure (gallium, germanium, indium, yttrium)
  • Energy systems (cobalt, nickel, uranium, rare earth elements)

Compliance Implications

Trade compliance professionals should monitor several key developments.
Immediate Actions:
  • The Secretary of Commerce will continue monitoring PCMDP imports and inform the President of circumstances requiring further Section 232 action
  • Negotiations may result in country-specific agreements with varying terms
  • If agreements are not concluded within 180 days, are not implemented effectively, or prove ineffective, the President may impose alternative measures including tariffs
Potential Future Measures:
The proclamation explicitly contemplates minimum import prices for specific critical mineral types if negotiations prove unsuccessful.

Strategic Context

This action builds upon critical minerals agreements the administration has secured with Australia, Saudi Arabia, Malaysia, Thailand, Japan, and other allies to diversify global supply chains and reduce dependence on adversarial nations. The administration frames this initiative as part of broader efforts to restore U.S. critical minerals dominance, including unleashing offshore resources, increasing efficiency for federally funded projects, and approving infrastructure like Alaska's Ambler Road Project.

Next Steps for Compliance Teams

Trade compliance professionals should:
  1. Monitor negotiations: Track bilateral and multilateral agreement developments over the next 180 days
  2. Assess supply chains: Evaluate current PCMDP sourcing and potential exposure to future restrictions
  3. Review country of origin: Understand which trading partners may receive preferential treatment through negotiated agreements
  4. Prepare for price floors: Model potential impacts of minimum pricing requirements on procurement costs
  5. Watch for implementing regulations: Anticipate detailed guidance from Commerce, USTR, and Homeland Security
The administration has authorized these agencies to issue regulations, rules, and guidance to implement the proclamation, with authority to temporarily suspend or amend existing regulations as needed. Further information can be found in the White House Fact Sheet. For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk and regulatory compliance as we move into 2026, contact your Account Manager or Client Success Manager.

This article applies to:

  • Product: ONESOURCE Global Trade