The recently announced stockpile represents significant opportunities, but much of that depends on unresolved details that companies must continue to monitor.

By Charles E. Carpenter, Joshua W. Marnitz, and Austin J. Pierce

Key Points:

  • The $12 billion stockpile has been characterized as similar to other US strategic “reserves” but has a distinct setup with both public and private funding.
  • Questions remain on how the stockpile will take into account US policy priorities and function in practice.

Introduction

On February 2, 2026, the Trump administration announced Project Vault, an approximately $12 billion initiative from public and private sources to develop a critical minerals stockpile in the United States. The project represents an increasing recognition that access to such minerals is a matter of industrial and national security.

In this way, the stockpile is comparable to the strategic petroleum reserve (SPR) that was launched in the wake of the oil crises in the 1970s. The stockpile is just one part of the administration’s broader policy efforts to support domestic and allied minerals projects. However, Project Vault differs from the SPR in critical ways, and important questions remain outstanding — as discussed in this article.

How Will Project Vault’s Stockpile Be Governed?

Unlike the SPR, the stockpile contemplated under Project Vault is not a reserve authorized by Congress. The SPR was created as part of the 1975 Energy Policy and Conservation Act, which established governmental procedures and conditions for both filling the SPR and distributing the stored petroleum.

While Congress has contemplated legislation on a similar reserve for critical minerals, most recently with the SECURE Minerals Act, federal support for Project Vault required the use of existing authorities, including a $10 billion loan from the Export-Import Bank of the United States (EXIM).

Importantly, Project Vault funding includes over $1.5 billion of private capital. While that contribution is significantly less than the loan from EXIM, EXIM’s role as a loan provider does not convey equity or necessarily entail government control or management of the entity that maintains the stockpile. The ultimate allocation of this oversight will influence how different motivations potentially manifest in associated stockpile policies.

How Will Project Vault Reflect Participant Motivations?

Project Vault’s top-line priority — fostering the resilience of critical minerals supply chains — is open to several competing interpretations, each with radically different approaches. On the one hand, the stockpile could serve as a sustained demand signal, offering a price floor and/or consistent offtake for critical minerals companies that align with the United States’ strategic aim of creating supply chains that counterbalance China’s dominant position. However, such supplies do not materialize overnight, and a wide range of sectors — including automotive, defense, and advanced computing — could face challenges if China responds by restricting the supply of such minerals before the alternative supply chains have reached sufficient maturity.

Alternatively, the stockpile could look to purchase supply quickly and cheaply in order to be able to release held minerals and insulate participants against supply shocks while alternative capacity is developing. This approach would not provide as much nurturing for alternative critical minerals suppliers, but it would help provide short-term relief to companies that rely on such minerals as the United States works to neutralize China’s near-monopoly position.

In all likelihood, Project Vault will need to strike a balance between these policy aims, particularly due to the mix of commercial and geopolitical interests involved. However, given that the sourcing priorities are likely to be set by manufacturers participating in the initiative, the sourcing strategy may favor downstream security over nurturing significant supply growth (particularly for high-volume commodities). The specific equilibrium will inform companies on both the supply and demand sides of the equation about how engaging with the stockpile may benefit them and where they may still need to look for alternative or additional solutions.

What Will Terms for the Stockpile Look Like?

The policy considerations discussed above will shape how the stockpile functions practically. While many factors are at play, key factors relate to eligibility for and preference in stockpile access (from both the demand and supply side). For example:

Composition

Unlike the SPR, where petroleum is generally considered fungible, critical minerals are by their nature chemically distinct and suited to different applications. Administration officials have indicated that the stockpile may include any minerals identified as “critical” by the United States Geological Survey (within the Department of Interior). As of late 2025, this included 60 minerals, such as aluminum, antimony, copper, germanium, silver, and zirconium. However, the stockpile may not actually store all of these minerals, or the quantities of such stockpiles.

And, regardless of the minerals ultimately prioritized, the stockpile could store them in various forms: raw ore (such as oxides or sulfides); purified metal; specialized alloys; or derivative goods such as magnets, anodes/cathodes, and capacitors. Because of the current “midstream” bottleneck for critical minerals in the United States and allied countries, there may be strategic reasons to focus the stockpile on processed minerals and associated support for processing facilities, rather than ore. However, benefits for mining companies will be indirect unless they also have sufficient processing facilities associated with their operations.

Eligibility

The provenance of the minerals in question could impact eligibility. Considerations include where the underlying material comes from or is processed (as part of the aim to bolster alternative supply chains), as well as the identity of the entities in that supply chain. Beneficial ownership could also be a factor, with ongoing scrutiny of foreign investment in sectors critical to national security.

Access

Companies benefiting from the stockpile may be scrutinized to ensure they are deploying their resources in a manner that the US government believes contributes to industrial security. As such, in addition to facing scrutiny on their affiliations, companies could be required to agree to various restrictions to protect the longer-term interests of the initiative and the United States’ evolving industrial policy.

These restrictions could include constraints on export and use of certain products dependent on the underlying materials. However, given that Project Vault’s largest backing comes from EXIM — which has a mandate to support US exports — the scope of such restrictions may depend on the alignment of certain geopolitical blocs, including the critical minerals trading bloc that the US administration has recently floated.

How Can Companies Prepare in the Near Term?

Given the various aspects of Project Vault that remain outstanding, companies should closely monitor for additional developments, including to the extent that pending congressional legislation creates a mandate for a government-controlled critical minerals reserve in parallel to Project Vault.

More immediately, companies should consider their engagement strategy. In addition to flagging interests in the initiative, this may include educating policymakers and other proponents on the knock-on impacts of various decisions the stockpile will have to make. Early engagement could allow parties — particularly on the demand side — to provide critical input on some of the outstanding questions, which will influence how the stockpile ultimately functions (and, therefore, the practical benefit for different companies and sectors).

Simultaneously, companies should look at how their own operational strategies align with Project Vault. On the demand side, this includes assessing how Project Vault may impact the price of and access to associated minerals and their derivative products. Both mining and processing capacity take time to come online. As such, Project Vault could create demand shocks that companies should consider in their near-term procurement plans while exploring how participation in the initiative could help smooth out such economic shocks in the longer term.

On the supply side, mining and metals companies should consider how Project Vault could impact the overall financial viability of their projects, particularly where long-term offtake agreements are not yet in place. This approach could also potentially entail engaging with the commodities purchasers and/or other participants in Project Vault on creating such offtake channels as part of the United States’ evolving industrial policy.

To capitalize on this opportunity, companies should consider how well they are prepared to respond to any conditions that Project Vault may have for stockpile participation. For example, companies should consider reviewing their value chain and capital stack for potential vulnerabilities and ensuring appropriate documentation is in place to demonstrate readiness to participate in Project Vault’s stockpiling efforts. Such review could also include matters of operational readiness and any product specifications that may subsequently be announced.

All of these considerations can be incorporated into a company’s broader critical minerals strategy, particularly given that Project Vault represents only the latest development in a political trend that is set to continue.