In 2023, the U.S. Department of Energy mapped critical-materials risk for the 2025 to 2035 period. It remains a useful starting point. But the conditions behind that map have changed.


Export controls have expanded. Demand from AI infrastructure, defense production, electrification, and data centers is increasing. Processing and refining remain concentrated in a small number of countries and facilities. For many manufacturers, material risk is now moving faster than annual sourcing plans.
Xtrium updated the 2023 view using recent DOE, USGS, and IEA data, along with current export-control and supply-chain developments. This is a directional update, not an official DOE ranking. DOE has not released a 2026 Critical Materials Assessment.

What Has Changed
Several materials now carry more risk than they did three years ago.
• Gallium, germanium, graphite, cobalt, tungsten, and rare earth elements have greater supply and geopolitical exposure.
• Copper, silicon, and uranium are more strategically important. All three were added to the final 2025 U.S. Critical Minerals List.
• AI infrastructure, data centers, electrification, semiconductor manufacturing, and defense production are increasing demand for copper, rare earths, gallium, germanium, graphite, and other strategic materials.
• Export controls, licensing requirements, and concentrated processing capacity are changing supply conditions faster than many procurement systems can track.
These materials were already important in 2023. What has changed is the level of exposure. A material can be available today and still become difficult to source, export, process, or qualify by the time a product reaches production.

Export Controls Are Now a Sourcing Issue
Export controls are no longer a policy topic that sits outside the supply chain.
China’s restrictions and licensing requirements have affected materials used in semiconductors, electronics, batteries, magnets, defense systems, and high-performance alloys. Gallium, germanium, graphite, tungsten, antimony, and certain rare earth materials have all faced varying forms of export controls or licensing requirements.


The United States is also taking steps to keep more strategic material within domestic and allied supply chains. This includes policy actions affecting recovered battery materials and other inputs needed for energy, defense, and industrial production.


For manufacturers, availability is no longer only a question of price, volume, and logistics. It can depend on export licenses, end-use rules, country of origin, refining location, and the supply chain behind a component.

What Changes in 2027
The policy environment is making material traceability and sourcing decisions more urgent.
A recent White House executive order declared a national emergency related to security risks from certain foreign-made hardware and software used in the U.S. power system. The order is broader than critical minerals, but it signals the direction of travel. Strategic risk is now being evaluated across raw materials, components, equipment, software, and control systems.


The January 1, 2027 sourcing deadline for certain defense-related materials raises the stakes further. Manufacturers that supply defense programs may need to stop sourcing rare earth elements, magnets, tungsten, molybdenum, and tantalum from China, Russia, Iran, and North Korea.
For companies affected by these rules, the question is not simply whether a material is available today. It is whether the material, its processing route, and the component supply chain will remain compliant in 2027.

Why Static Lists Fall Short
Criticality can change quickly.


A material’s risk profile can shift when demand rises, a refinery is disrupted, export rules change, a new defense requirement is introduced, or a new technology creates a surge in demand. Copper is one example. It appeared on DOE’s 2023 critical-materials list for energy technologies and was later added to the 2025 U.S. Critical Minerals List.


The same pattern can apply to silicon, uranium, rare earths, graphite, gallium, germanium, tungsten, cobalt, and other materials that depend on concentrated processing or specialized manufacturing steps.


A static critical-minerals list is not enough for product and sourcing teams. Companies need to understand:

• Which materials are embedded in products, components, tooling, and manufacturing processes.
• Where those materials are refined, alloyed, processed, and converted into usable forms.
• Whether suppliers depend on a limited number of countries, facilities, or logistics routes.
• Which materials face export-control, licensing, or end-use restrictions.
• What alternatives are technically viable and how long qualification would take.
• Whether suppliers and material inputs will remain compliant through 2027.

What Xtrium Is Tracking
Xtrium tracks material risk from the mine through processing and into finished products.
That work goes beyond identifying where a mineral is mined. A material may be extracted outside a high-risk geography but still depend on concentrated refining, alloying, magnet production, battery processing, semiconductor fabrication, or component qualification elsewhere.

For companies preparing for 2027, the work should start now:
• Map material and component dependencies through Tier 1, Tier 2, and Tier 3 suppliers.
• Identify materials with concentrated refining or processing exposure.
• Verify country-of-origin and processing data for strategic materials and components.
• Develop alternative material and supplier paths before a disruption or compliance deadline.
• Estimate the testing, requalification, certification, cost, and production impacts of substitution.
• Monitor export controls and related policy changes as they develop.

The takeaway is simple. Critical-materials risk can change faster than corporate sourcing strategies can keep up.
Companies that prepare for 2027 now will have more options when markets, policy, or supply chains change again