From a $30 million mining fund in wartime Ukraine to export restrictions on battery scrap in American recycling yards, the United States is assembling a multi-front architecture to reduce its dependence on Chinese-controlled critical mineral supply chains. With Beijing's suspended export controls set to expire on November 10, three converging deadlines are compressing a decade of supply chain anxiety into a matter of weeks. What emerges from that pressure may define the shape of Western industrial policy for a generation.
Introduction
On a Tuesday morning in early October, Conor Coleman, the head of investments at the U.S. International Development Finance Corporation, sat down in Kyiv to announce what he called an investment in Ukraine's future. The deal was modest by the standards of sovereign wealth funds or Pentagon procurement budgets: roughly $30 million committed through the U.S.-Ukraine Reconstruction Investment Fund to a joint platform with BGV Group, a firm connected to one of Ukraine's wealthiest businessmen. The target assets were early-stage mining projects scattered across a country still absorbing Russian missile strikes. The minerals in question, rare earths, beryllium, uranium, zirconium, are not yet being produced at commercial scale anywhere in Ukraine.
And yet the announcement carried a weight that the numbers alone do not convey. Coleman was careful about his framing. "All of these are on the U.S. critical minerals list," he told reporters, "so this aligns very well with what we are trying to achieve in terms of the administration's priorities." That phrase, administration's priorities, is doing a great deal of work. It connects a wartime reconstruction initiative in Eastern Europe to a presidential determination signed in a Washington office building in July, to a trade truce with Beijing whose clock is ticking down to November 10, to a Defense Department procurement ban that takes full effect on January 1, 2027.
Taken individually, the URIF minerals deal, Trump's Defense Production Act determination over battery scrap, and China's expiring suspension of sweeping rare earth export controls each represent a significant policy development. Taken together, they reveal something more consequential: the emergence of a coherent, if improvised, American mineral doctrine, one that simultaneously tries to cultivate new upstream sources abroad, retain secondary supply at home, and manage a deteriorating strategic standoff with the country that still refines the majority of the world's critical minerals.
The Ukraine Gambit: Minerals as Security Architecture
The story of the URIF minerals deal begins not in Kyiv but in Washington, in the fractious winter negotiations of early 2025, when the Trump administration briefly demanded $500 billion in Ukrainian mineral revenues as compensation for prior U.S. military assistance. Ukrainian negotiators eventually talked Washington back from that position. The final agreement, signed on April 30, 2025 by Treasury Secretary Scott Bessent and Ukrainian Economy Minister Yuliia Svyrydenko, was more measured: a joint fund, equal decision-making, and revenues from natural resource exploitation contributing to reconstruction, with the first ten years of profits reinvested entirely within Ukraine.
Bessent, at the signing, described the arrangement as a "tacit security guarantee because of the economic partnership." That framing is worth examining carefully. In the absence of formal security commitments from Washington, the Trump administration offered something different: an alignment of financial interests. The logic, as Coleman articulated it in Kyiv last week, is that U.S. economic presence in Ukraine's subsoil creates a durable stake in Ukrainian sovereignty that military guarantees, politically undeliverable in the current Congress, cannot provide.
Whether that logic is convincing to Vladimir Putin is debatable. What is less debatable is the strategic calculus on the mineral side. Ukraine sits atop deposits of rare earth elements, lithium, titanium, uranium, and beryllium, many of which remain underexplored or undeveloped after decades of Soviet-era extraction and more recent conflict. The BGV Group platform will initially focus on early-stage projects, meaning that production is years away under the most optimistic assumptions. But the investment signals something: Washington is willing to plant flags in the Ukrainian resource landscape even while the war continues, even while the infrastructure to develop those deposits does not yet fully exist.
The total committed through URIF now stands at approximately $70 million across five sectors, a figure that, as Coleman acknowledged, represents a beginning rather than an end. The fund is actively seeking additional capital, and a parallel DTEK loan of 85 million euros for battery storage infrastructure suggests that the mineral and energy threads of the reconstruction strategy are being woven together deliberately. As I reported in October, Australia's Critical Minerals Strategic Reserve has been making a similar bet in its own neighborhood, deploying offtake agreements and equity instruments to lock in supply from projects that are not yet producing. The URIF model echoes that approach, transposing it into an active war zone and calling it diplomacy.
The Clock on the Truce: What November 10 Actually Means
While Coleman was making announcements in Kyiv, analysts in Washington, Brussels, and Tokyo were focused on a different date. November 10, 2026, is when China's suspension of its October 2025 rare earth export controls is scheduled to lapse. Those controls, issued through MOFCOM Announcements 55 through 58, 61, and 62, would have imposed licensing requirements on five additional rare earth elements and, most alarmingly, introduced extraterritorial provisions capable of reaching any product made anywhere in the world if it contained Chinese-origin rare earth materials at 0.1 percent of value or more. The Busan APEC summit in late October 2025 produced a one-year pause. That year is now nearly gone.
The architecture that remains active, even through the suspension period, is itself formidable. China's April 2025 controls, which are not suspended, already require case-by-case export licenses for seven medium and heavy rare earth elements: samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium, along with their metals, oxides, alloys, compounds, and permanent magnet materials. Controls on tungsten, tellurium, bismuth, molybdenum, and indium remain in full force. The number of mineral tariff codes subject to some form of Chinese export control has tripled since 2023, according to IEA data, encompassing materials critical to aerospace, defense, semiconductors, and clean energy.
What Beijing holds in reserve is what concentrates minds. According to analysis from the Council on Foreign Relations, China has not yet imposed export controls on at least ten additional rare earths and nine further critical materials, including silicon metal, manganese, and magnesium. If the Busan truce lapses without renewal, those materials become available as escalation tools. The IEA has estimated that full reimplementation of the October 2025 framework, including the extraterritorial provisions, could put $6.5 trillion in annual economic activity outside China at risk, spanning automotive, electronics, defense, and energy sectors.
Three scenarios are now being modeled by industry counsel and compliance teams: a mutual extension of the suspension, a selective reinstatement targeting specific elements or end-use categories, or full reimplementation. MOFCOM has been publicly silent on which path it prefers, though a spokesperson noted that China "will study and refine specific plans" during the remaining suspension period, suggesting the pause has been used to finalize licensing frameworks that can be activated quickly. As I wrote in September, the truce was never likely to be a genuine concession; it was a deferral. The question now is what shape the resumption takes, and whether it arrives before or after a second Trump-Xi summit that both sides continue to discuss without scheduling.
The Black Mass Rule: Closing the Back Door at Home
On July 30, 2026, President Trump signed a Presidential Determination under Section 101 of the Defense Production Act, declaring recoverable critical minerals and materials, including black mass, end-of-life rare-earth permanent magnets, swarf, and mineral-bearing industrial scrap, to be scarce and critical materials essential to national defense. The determination delegated export restriction authority to the Secretary of Commerce. Seven days later, the Bureau of Industry and Security published a Temporary Final Rule that effectively prohibits the export of black mass and tungsten waste without prior BIS authorization. The rule took effect August 27.
Black mass is what remains when lithium-ion batteries are shredded at end of life: a dark, granular mixture containing recoverable concentrations of lithium, cobalt, nickel, manganese, and graphite. It is, in a sense, a secondary ore, a mineral resource that has already been extracted once and processed into a product, and which can be processed again into battery-grade material if the industrial infrastructure exists to do so. The problem, as the GAO identified in its July 2026 report on 60 vulnerable critical minerals, is that the United States has been exporting rather than processing this material. The Basel Action Network estimates that approximately 33,000 metric tons of electronic waste leave U.S. ports monthly, and a substantial portion of that stream, once it arrives at foreign processing facilities, ends up being refined in China or in countries within China's supply chain orbit.
The DPA rule closes that particular door, at least for now. Under the BIS framework, U.S. persons who sell black mass or tungsten scrap must allocate 100 percent of monthly sales to U.S. persons unless they obtain an explicit adjustment or exception from BIS in advance. The rule is temporary, running for one year, and BIS is accepting public comment through November 4. But the policy logic it embodies is unlikely to be reversed: the White House fact sheet accompanying the Presidential Determination made clear that recoverable minerals are "pervasive in defense supply chains" and that allowing them to flow to foreign processors amounts to a subsidy of strategic competitors.
The rule arrives at a complicated moment for the domestic recycling industry. Li-Cycle and Ascend Elements, two of the most prominent U.S. battery recycling ventures, have both filed for bankruptcy, partly because they could not compete on feedstock cost against Asian buyers willing to pay premium prices for black mass exports. The GAO found that black mass can account for roughly 48 percent of hydrometallurgical recycling costs, a structural disadvantage for domestic processors trying to build scale without access to the subsidized integration that Chinese counterparts enjoy. Restricting exports addresses the feedstock leakage problem, but it does not automatically create the domestic processing infrastructure needed to absorb the retained material. That gap remains.
Three Deadlines, One Doctrine
What makes this moment distinctive is not any single policy action but the compression of multiple timelines into a narrow window. The BIS black mass rule took effect August 27. China's export control suspension expires November 10. The Pentagon's DFARS procurement ban, which will bar Chinese-origin rare earth magnets and metals from defense contracts if any stage of production occurred in China, reaches its full scope on January 1, 2027. Within roughly four months, the United States will have activated restrictions on outbound scrap flows, potentially faced a reimposition of Chinese controls on inbound mineral inputs, and imposed a sourcing requirement on defense contractors that the domestic industrial base is not yet capable of fully satisfying.
That last point deserves emphasis. In 2024, China produced approximately 300,000 tons of neodymium-iron-boron magnets while the United States produced almost none. Beijing controls roughly 99 percent of global heavy rare earth processing, including the dysprosium and terbium refining steps that make high-performance magnets functional at elevated temperatures. U.S. domestic manufacturers are not projected to reach meaningful NdFeB magnet capacity until 2028 at the earliest. The DFARS ban, as defense analysts have noted, may require waivers or exceptions at a scale that the Pentagon has not publicly planned for, because the alternative supply chains it presupposes do not yet exist.
The Ukraine deal is, in part, a response to exactly this problem. Beryllium is used in aerospace and defense components. Rare earth elements feed the magnet supply chain. Zirconium has applications in nuclear fuel assemblies and specialty alloys. By committing capital to early-stage Ukrainian projects now, Washington is trying to create future supply optionality in materials where it currently has almost none outside of Chinese-linked processing. The timing of that optionality, years away even under optimistic scenarios, does not resolve the near-term crunch. But the doctrine being assembled, retain secondary supply at home, cultivate upstream sources abroad, manage the China relationship through calibrated pressure and periodic truce, reflects a strategic logic that is more coherent than the piecemeal interventions of prior administrations.
The Foundation for Defense of Democracies, assessing the Busan truce earlier this year, noted that the suspension "pauses some hostile trade actions" while leaving core restrictions intact. That characterization applies equally well to the broader U.S. posture. The DPA determination does not immediately create domestic recycling capacity. The URIF deal does not immediately produce Ukrainian rare earths. The DFARS ban does not immediately conjure American magnet manufacturing. What these actions do, collectively, is establish the legal architecture, the financial commitments, and the sourcing requirements that make a more independent supply chain theoretically possible, and then bet that capital and technology will follow policy in time to matter.
The Limits of Doctrine Without Infrastructure
There is a recurring tension in this emerging American mineral doctrine that none of its architects have fully resolved. Policy can restrict exports, establish funds, sign bilateral agreements, and declare national emergencies. What it cannot do, at least not quickly, is manufacture the processing knowledge and integrated industrial infrastructure that China assembled over four decades while American and European policymakers were focused elsewhere. As one defense industry analyst put it to me recently, it is a manufacturing knowledge problem, and capital cannot buy 40 years of process expertise that China's rare earth industry built while American plants sat idle.
That gap shows up across all three of the policy actions now in motion. The URIF minerals deal funds exploration and early-stage development in a country where the mining sector has been disrupted by war, where permitting and environmental frameworks are being rebuilt alongside everything else, and where the nearest commercial-scale processing infrastructure is not yet defined. The DPA black mass rule creates a domestic feedstock pool but does not guarantee that domestic processors can absorb it economically, particularly as the battery chemistry mix shifts toward lithium iron phosphate formulations that contain neither cobalt nor nickel, making recycling economics harder. And the DFARS ban creates a sourcing requirement for defense contractors that the domestic supply chain cannot fully meet by the deadline.
The GAO, in its July report, was characteristically measured but clear: battery recycling could reduce import dependence within two to three years if the right infrastructure investments are made, but substitution technologies in the semiconductor and magnet sectors may take a decade or more. That is a long time when Beijing has the option to reimpose extraterritorial export controls in 37 days.
What the next few weeks will reveal, perhaps more than any policy announcement, is whether the Busan truce produces a sequel or a cliff. If Beijing extends the suspension, it will likely extract something in return, whether in tariff relief, semiconductor access, or a softer line on Taiwan arms sales. If it allows the controls to lapse, the $6.5 trillion downstream exposure that the IEA has quantified will move from theoretical to operational, and the full inadequacy of Western supply chain diversification efforts will become visible in ways that even the most optimistic projections have not fully priced in.
Conclusion: A Doctrine Still Under Construction
When Conor Coleman sat down in Kyiv on October 2 to describe a $30 million investment in Ukrainian mining projects, he was asked whether he was confident the fund would succeed. His answer was framed not in terms of return on investment or mineral project economics but in terms of presence. "It's absolutely imperative for the Ukrainian people that we're investing now," he said. The word now carries the full weight of the geopolitical moment: now, before the ceasefire that has not yet arrived; now, before the November 10 deadline that has nearly arrived; now, while the legal authority granted by the Defense Production Act is still being translated into regulations that will shape an entire secondary mineral industry.
This is what an emerging doctrine looks like before it is finished: not a coherent system but a collection of bets placed at different odds on different timescales, connected by a shared conviction that dependence on Chinese-controlled supply chains has become strategically untenable and that the cost of reducing it, borne now, is lower than the cost of not reducing it, borne later. Whether that conviction is correct, and whether the bets pay off in time to matter, are questions that three converging deadlines, one in Kyiv, one in Beijing, one in the Pentagon's procurement office, are about to begin answering.
The mineral doctrine is real. Its infrastructure is not yet.