Introduction

The Trump Administration has taken meaningful steps to address one of the most significant vulnerabilities in American industrial policy: China's stranglehold on critical minerals markets. The announcement of Project VAULT, a publicly-enabled, privately-led commercial stockpile capitalized through the Export-Import Bank, and the recent launch of FORGE at last month’s State Department Ministerial Meeting represent genuine progress toward building a resilient, diversified supply chain. Employ America is pleased to see the administration recognize the value of financial intermediaries, market development, and allied coordination in developing independent critical minerals markets and supply chains removed from Chinese dominance.

Analysis

We are particularly gratified to see Project VAULT structured in a manner closely resembling the proposal we published in April 2024, which called for using federal lending authority to capitalize a special-purpose vehicle through which intermediaries and traders could acquire and sell critical minerals. The Export-Import Bank has done just that, and the selection of major trading houses, Traxys, Hartree, and Mercuria among them, as procurement intermediaries reflects an understanding of how commodity markets actually function. Equally notable is the inclusion of commercial original equipment manufacturers, who have direct experience with the costs of supply chain insecurity, particularly as China has escalated rare earth restrictions in the past year. 

FORGE signals that the administration understands the allied dimension of this challenge. The draft framework for the meeting, signed into MOUs between the President and the leaders of Japan, Australia, and the United Kingdom, calls on participants to use “economic policy tools and coordinated investment to accelerate the development of diversified, liquid, and fair markets for critical minerals.” This language reflects the market infrastructure approach we have long advocated. Building a liquid, functional market outside of China requires the kind of coordinated infrastructure, shared benchmarks, trusted counterparties, and physical storage that no single country can construct alone. If implemented well, VAULT and FORGE could form the foundation of a genuine, market-based strategy for achieving stable and secure critical minerals supplies.

Looking Ahead

Now the effort turns to execution. Significant implementation questions remain, and the administration has so far provided little transparency on the details that will determine whether these initiatives succeed or fall short. How intermediary participation is structured matters enormously: whether traders are being deployed to actively provide liquidity or simply procure on behalf of the government could shape the market signal the program sends. The covenants governing the SPV, the strike prices at which it intervenes, and the criteria for selecting counterparties are all design choices with major consequences for both efficacy and cost to American consumers and businesses.

This is not a minor concern. Industrial policy works by sending credible, durable signals to private markets — signals that only land if the market understands the rules and trusts that they will be consistently applied. A strategic reserve whose mandate, governance, and intervention logic remain opaque is poorly positioned to crowd in the private investment that would make it transformative rather than merely symbolic. We look forward to engaging with the administration on these questions, and to pushing for the kind of transparent, well-designed implementation that this promising start deserves.

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