Critical Minerals vs Critical Materials: Two Lists, Two Agencies, and Why the Difference Sets Regulatory Scope

The two phrases get used as though they mean the same thing. They do not. Critical minerals vs critical materials is a statutory distinction with two separate designating authorities, two separate lists, and two different tests for what qualifies. Anyone reading a rule that references either category needs to know which one is being invoked, because the wider of the two reaches materials the narrower one never touches.

The Department of Energy sets out both definitions on its Critical Minerals and Materials Program pages, and the structure it describes explains a good deal about how recent trade measures were scoped.

Two Definitions, Two Statutory Authorities

Both definitions come from the same statute, the Energy Act of 2020, and they diverge immediately.

A critical mineral is defined as any mineral, element, substance, or material designated as critical by the Secretary of the Interior, acting through the director of the U.S. Geological Survey. That is a designation test rather than a substantive one. A commodity is a critical mineral because Interior says so, and the current designation is the 2025 list published in the Federal Register on 7 November 2025, which runs to 60 commodities.

A critical material is defined two ways at once. It is any non-fuel mineral, element, substance, or material that the Secretary of Energy determines has a high risk of supply chain disruption and serves an essential function in one or more energy technologies, including technologies that produce, transmit, store, and conserve energy. It is also, separately, any critical mineral as defined by the Secretary of the Interior.

That second clause is the part most summaries drop, and it is the one that matters. Every critical mineral is automatically a critical material. The reverse does not hold. The Department of Energy can designate a material that Interior has never listed, and that designation stands on its own energy-security test.

So the relationship is not two overlapping circles. It is one category containing the other, with room left over.

Critical Minerals vs Critical Materials: What Sits on One List and Not the Other

The practical consequence shows up in the non-elemental entries, where the Department of Energy publishes both lists side by side.

The non-elemental critical minerals designated by USGS are natural graphite, metallurgical coal, phosphate, potash, and synthetic graphite. The non-elemental critical materials designated by DOE are natural graphite, metallurgical coal, electrical steel, and silicon carbide.

Electrical steel and silicon carbide appear on the DOE list and not on the USGS list. Both are engineered rather than naturally occurring, which is a deliberate feature of the DOE methodology rather than an oversight. The Department's assessment explicitly includes engineered materials, on the reasoning that a supply chain risk to a manufactured input is still a supply chain risk to the energy technology that depends on it.

That is a meaningful widening. A rule written against critical minerals reaches mined and refined commodities. A rule written against critical materials reaches those plus manufactured inputs that no geological survey would ever designate.

How the Two Categories Are Assessed

The designation tests differ as much as the definitions do.

The Department of Energy published a comprehensive criticality assessment in 2023 that evaluates materials on two axes. Supply risk accounts for basic availability, competing technology demand, political, regulatory and social factors, codependence on other markets, and producer diversity. Importance to energy accounts for energy demand and substitutability. The results are plotted on a criticality matrix that sorts materials into critical, near critical, and not critical bands across a medium-term window running from 2025 to 2035.

Two features of that methodology are worth noting for anyone trying to anticipate how the list evolves. It is forward-looking, built on energy deployment scenarios rather than on current consumption. And it incorporates material intensity, meaning the quantity of material required per component or system, including for innovative technologies that may reduce material requirements in future.

A material can therefore move on the DOE list because a technology roadmap changed, without anything changing in the ground. The list is a statement about projected energy systems as much as about supply.

The DOE list has also been amended in operation rather than only at scheduled revisions. Metallurgical coal was added by a separate May 2025 notice rather than waiting for a full list cycle.

What the Criticality Matrix Says About Battery Commodities

The 2023 assessment does not treat every designated commodity as equally exposed. The criticality matrix sorts materials into critical, near critical, and not critical bands by plotting supply risk against importance to energy, and the medium-term view covering 2025 to 2035 is the one most relevant to capacity decisions being made now.

That banding is worth understanding for what it does and does not do. It informs the Critical Materials List and the Department's programme priorities. It does not itself impose any obligation, and a commodity's position on the matrix carries no regulatory consequence on its own. The matrix is an analytical output, not an instrument.

Its usefulness is in the reasoning it exposes. A commodity lands in the critical band because two independent conditions hold at once: the supply is judged to be at risk and the energy system is judged to depend on it. A material with concentrated supply and no energy application does not qualify. Neither does a material central to energy technology with diverse, secure supply. Anyone arguing that a given commodity deserves more policy attention is implicitly arguing about one of those two axes, and it is worth being clear which.

Why Graphite Appears on Both Lists Twice Over

Graphite is the most instructive entry in the whole structure, and it is directly relevant to battery recycling.

Natural graphite appears as a non-elemental critical mineral on the USGS list and as a non-elemental critical material on the DOE list. Synthetic graphite appears on the USGS critical minerals list as a separate entry. So the commodity is captured under both authorities, and the synthetic route is designated independently of the natural one.

That treatment is unusual. Most entries are a single commodity designated once. Graphite carries a natural designation, a synthetic designation, and a dual-agency listing, which is about as strong a signal of concern as the framework can express without a separate instrument.

Recovered graphite from battery recycling sits in the same commodity category while following neither of those two production routes. It is not mined and it is not manufactured from petroleum coke or coal tar pitch. It is reclaimed from material that already exists inside the domestic economy, arriving through battery collection and processing rather than through mining or synthesis. The commodity designation attaches to the material regardless of route, which is the subject of our analysis of the recycled graphite supply chain.

Where This Feeds Into the Recoverable Minerals Order

The distinction stops being academic once a rule cites one definition rather than the other.

Presidential Determination No. 2026-19 defines critical minerals and materials by incorporating several sources at once, including critical materials as defined by section 7002(a)(2) of the Energy Act of 2020, alongside Executive Order 14241, 50 U.S.C. 98h-3, and anything the Secretary of Commerce designates. The Determination reached for the wider of the two Energy Act categories.

That has a specific consequence for the residual clause. As we set out in our analysis of which recoverable critical minerals could come next, the Determination covers black mass, end-of-life rare earth magnets and other finished goods, swarf, and other waste and scrap containing critical minerals and materials. Read that residual clause against the critical materials definition rather than the critical minerals list, and the potential scope includes waste and scrap containing engineered materials such as electrical steel and silicon carbide.

Swarf is the clearest illustration. Machining residue from electrical steel processing is waste and scrap containing a designated critical material, even though electrical steel is not a critical mineral and could not be, because no geological survey designates a manufactured product. A company reading only the USGS list would conclude its scrap stream is outside the category. Reading the definition the Determination actually cites gives a different answer.

None of that means such material is restricted. The Bureau of Industry and Security has implemented restrictions on four Schedule B codes covering black mass and tungsten waste and scrap, and nothing else, as covered in our breakdown of the BIS Directive Allocation Order. The point is about the size of the authority, not about the size of the current rule.

What Recyclers and Procurement Teams Can Take From This

Four practical observations follow, and none of them require predicting agency behavior.

The first is that the category a document cites tells you how wide it reaches, which is why critical minerals vs critical materials is worth keeping straight rather than treating as interchangeable phrasing. Critical minerals points at the USGS list. Critical materials points at that list plus DOE's energy designations. Where a rule, a grant condition, or a contract clause uses one of these phrases, the specific term is doing work.

The second is that both lists move. USGS has stated the critical minerals list will be updated at least biannually. The DOE list has been amended between cycles. Any compliance position built on a snapshot of either list needs a review cadence attached to it.

The third is that recovered material occupies the same commodity categories as mined and manufactured material. Recycling does not create a separate designation. Recovered graphite is graphite for the purposes of these lists, and the same logic runs through the nickel, cobalt, manganese, and lithium recovered from battery streams.

The fourth is that domestic recovery addresses the supply risk factors the DOE methodology actually measures. Producer diversity and codependence on other markets are two of the five supply risk factors in the assessment, and material recovered inside the United States from batteries already in the domestic economy is by definition not exposed to either in the way imported units are.

Green Li-ion's operation at Atoka, Oklahoma produces four materials that map directly onto these lists. GREEN HYDROREJUVENATION™ converts unsorted black mass into precursor cathode active material, technical-grade lithium carbonate, recycled graphite, and NCM hydroxide, with pCAM produced at 99 percent purity through a single-step conversion. Graphite, lithium, nickel, cobalt, and manganese are all designated commodities under one or both authorities.

Procurement teams mapping which of their input streams fall within these categories can begin partnership conversations with qualified recyclers such as Green Li-ion, whose output sits in commodity categories that appear on both lists.

The Honest Summary

Critical minerals vs critical materials is a distinction with statutory force. A critical mineral is whatever the Secretary of the Interior designates through USGS, currently 60 commodities on the 2025 list. A critical material is that entire set, plus anything the Secretary of Energy determines carries high supply chain disruption risk and serves an essential function in energy technologies. The second category contains the first.

The difference is visible in the non-elemental entries. Electrical steel and silicon carbide are critical materials and not critical minerals, because DOE's methodology deliberately includes engineered materials that a geological survey would never designate.

Graphite is the entry that matters most for battery recycling. Natural graphite is designated by both agencies, and synthetic graphite carries its own separate USGS designation. Recovered graphite sits in the same commodity category without following either production route.

Two limits on this analysis. The paragraph-level statutory citations here follow the Determination's own references rather than an independent reading of the Energy Act, and anyone building a compliance position should verify the section numbering against the statute directly. And describing what falls inside a definitional category is not the same as describing what is regulated. The only operative restriction covers four Schedule B codes. Everything else in these lists is designated, not restricted, and treating designation as regulation would misread both documents.