Project Vault and US$12bn stockpile: regulatory takeaways for mine planners
Reviewed by Tom Sullivan

First reported on MINING.com
30 Second Briefing
Project Vault will create a US$12 billion US critical minerals stockpile, combining US$1.67 billion in private capital with a US$10 billion Export-Import Bank loan to buy and store materials for automakers, tech firms and other industrial users. Following a Section 232 probe covering the full USGS critical minerals list plus uranium, the administration found imports threaten national security but chose negotiated price floors and trade mechanisms over tariffs. Forthcoming US–Mexico and US–EU–Japan action plans, under the new FORGE framework, will define which minerals are prioritised, how any border-adjusted price floor is calculated, and how rules of origin or downstream products are treated.
Technical Brief
- Section 232 investigation scope covered the full USGS critical minerals list plus uranium, not just battery metals.
- Commerce explicitly linked mineral price volatility to underinvestment in US and allied mining and processing capacity.
- National security finding was made under Section 232, yet the remedy chosen was negotiated trade tools, not tariffs.
- USTR and Commerce have been tasked to design trade-restrictive mechanisms centred on administratively set price floors.
- Legal uncertainty currently centres on how any border-adjusted price floor will be benchmarked against China-based reference prices.
Our Take
Project Vault’s $10 billion US Export-Import Bank facility sits at the upper end of state-backed critical minerals support in our Policy coverage, signalling that Washington is prepared to deploy export-credit scale tools rather than rely solely on tax incentives or DFC-style project finance.
Linking Project Vault to BHP’s $18 billion Vicuna copper build in Argentina underlines that US security-of-supply strategies will increasingly hinge on third-country assets, which may complicate permitting and community-risk allocation for operators looking to qualify under US-origin or ‘trusted partner’ rules.
The related Section 232 piece on processed critical minerals (28 January 2026) shows the US leaning towards supply agreements over tariffs for copper and silver, suggesting that projects tied into Vault-style stockpiles could gain preferential offtake visibility rather than pure price protection.
Prepared by collating external sources, AI-assisted tools, and Geomechanics.io’s proprietary mining database, then reviewed for technical accuracy & edited by our geotechnical team.
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