Silverado Submits Comments to USTR for a Plurilateral Critical Minerals Agreement

Silverado Policy Accelerator submitted comments to USTR on the design of a plurilateral critical minerals agreement and broader actions to strengthen supply chain resilience. Our recommendations focus on several key areas:

Prioritizing Minerals

We recommend a tiered approach that applies baseline rules across all critical minerals while designating a targeted subset for tools like price stabilization and coordinated investment. Prioritization should focus on minerals with high U.S. import reliance, significant exposure to foreign entities of concern, and concentrated global processing capacity.

Price Adjustment Mechanisms

Price tools should be applied only where markets are highly concentrated and structurally distorted, particularly where strategic price suppression risks undermining new supply. Mechanisms should be mineral-specific, applied at the most transparent point in the value chain, and include defined sunset periods aligned with project commercialization timelines.

Partner Selection

This cannot be a buyers’ club. The agreement should integrate resource-rich mining jurisdictions, midstream processors, and major consuming economies, with participation tied to commitments on production expansion, permitting reform, and coordinated offtake.

Addressing Regulatory Arbitrage

We propose a standards-based market anchored in enforceable labor, environmental, and governance commitments. Countries may be required to adopt Action Plans addressing gaps in enforcement, with tools like Rapid Response Mechanisms to investigate facility-level violations and ensure compliance.

Investment Rules and Coordination

The agreement should include coordinated inbound and outbound investment screening, enhanced scrutiny of state-backed financing, and early warning systems to track acquisitions and supply disruptions. A standing supply chain coordination group would align actions across screening, trade measures, and financing tools.

Additional Policy Tools

Targeted incentives will be critical to scale supply. These include access to commercial stockpiles like Project Vault, coordinated deployment of development finance and export credit tools, and deeper collaboration on recycling, recovery, and mineral traceability systems.