US scrap rules: processing bottlenecks and security ratio for engineers
Reviewed by Tom Sullivan

First reported on MINING.com
30 Second Briefing
US export restrictions taking effect later in August will force some lithium-ion battery scrap, including black mass, and tungsten scrap to be sold to US buyers, but GEM Mining Consulting’s Alina Karpunina argues supply security hinges on how much of this material is actually converted into qualified secondary minerals. DOE data show a 2023 US mismatch, with intermediate facilities able to process nearly 175,000 tons of batteries and scrap, but only about 35,500 tons of battery-material recovery capacity and 76,000 tons more merely planned. Karpunina proposes a “scrap-to-security conversion ratio” based on contained critical-mineral units recovered to customer specification, warning that export controls without robust domestic processing risk idle feedstock and continued reliance on primary mining.
Technical Brief
- GEM’s “recoverable strategic supply” framework requires scrap to clear five hurdles from availability to qualification.
- GEM’s proposed “scrap-to-security conversion ratio” uses contained critical-mineral units meeting spec divided by retained units.
- Lack of harmonised US datasets tracking metal-content flows through collection, pre-treatment, recovery and qualification blocks ratio calculation.
Our Take
The 68% ‘scrap-to-security’ conversion ratio used here mirrors GEM Mining Consulting’s separate finding that only around two‑thirds of headline lithium supply is truly usable to 2035, underlining that processing losses and off‑spec output are now a systemic constraint across critical minerals rather than a niche recycling issue.
In another recent GEM policy piece on processing bottlenecks, sulphuric acid supply and plant throughput – not ore – were flagged as likely triggers of the next supply shock for copper, nickel and graphite; the US rules on lithium‑ion battery scrap and tungsten scrap therefore risk tightening an already fragile mid‑stream for these same commodities if domestic plants underperform.
Within our 127 Policy stories, relatively few focus on tungsten compared with lithium and copper, so the note that US tungsten mining ceased in 2015 while seven domestic processors remain suggests future US security-of-supply debates may pivot from new mines to securing long‑term scrap and concentrate feed for this small group of converters.
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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