EXIM Launches Supply Chain Resiliency Initiative to Bolster U.S. Competitiveness

On Jan. 8, the Export-Import Bank of the United States (EXIM) announced the creation of the Supply Chain Resiliency Initiative (SCRI), a targeted financing program aimed at diversifying and strengthening critical mineral and rare earth element supply chains. Officially launched through a vote of approval by the EXIM Board of Directors, the initiative is designed to support projects that secure critical minerals and rare earth materials and reduce U.S. reliance on the People’s Republic of China (PRC) for these materials, which are essential for technologies such as energy storage, semiconductors and electric vehicles (EVs). By supporting international projects that ensure critical minerals flow into U.S.-based production facilities, SCRI aims to bolster domestic manufacturing, create domestic jobs and enhance national and economic security.

Background on EXIM

EXIM, the official U.S. export credit agency since 1934, supports domestic jobs by facilitating exports through financing, insurance and loan guarantees under its $135 billion lending authority. Over its history, EXIM has stepped in during critical junctures to secure supply chains essential to U.S. security. The launch of SCRI builds on recent efforts to counter China’s dominance in critical minerals markets. In October 2024, the EXIM Board of Directors adopted a Non-Binding Resolution in Support of Critical Minerals and Rare Earth Elements Financings, affirming its commitment to securing these supply chains. Additionally, EXIM’s collaboration with the Minerals Security Partnership (MSP) during the UN General Assembly in 2022 underscored the urgency of diversifying global critical mineral sources. These actions align with broader U.S. initiatives, such as the Partnership for Global Infrastructure and Investment (PGII), which seeks to mobilize $600 billion in global infrastructure investments by 2027. For more information regarding PGII’s directives and ongoing collaboration with EXIM, please click this link.

Implications of SCRI

The SCRI reflects a strategic shift in U.S. policy to counter PRC market dominance and manipulation. Key elements include:

• Reduced Dependence on PRC: By funding projects in trusted partner nations, SCRI ensures that critical minerals flow into U.S. production, decreasing reliance on PRC-controlled supply chains that have been subject to market manipulation, export bans and economic coercion.

• Support for U.S. Manufacturers: SCRI will back agreements between U.S. manufacturers and global mineral suppliers, enabling sectors like automotive, battery production and semiconductors to secure necessary inputs while protecting and expanding domestic jobs.

• Onshoring and Economic Ripple Effects: Financing through SCRI encourages the development of midstream processing and battery production facilities within the United States, fostering a stronger domestic supply chain and reducing vulnerabilities.

Eligibility and Safeguards

Projects funded under SCRI must have signed off-take agreements with U.S. companies and cannot involve PRC-controlled entities or technologies, ensuring taxpayer funds support reliable supply chains and align with U.S. national security interests. While EXIM financial assistance is typically contingent on the recipient’s ability to expand U.S. exports to foreign entities, the SCRI framework is tied to U.S. import authority. Therefore, financing provided by EXIM is dependent upon the percentage of off-take from a given project abroad that is guaranteed to U.S. importers.

Congressional Backing

Following EXIM’s announcement, SCRI has garnered bipartisan praise as a critical step to secure U.S. competitiveness and reduce dependence on China. Chairman of the House Select Committee on the Chinese Communist Party John Moolenaar (R-MI) lauded the initiative for helping “build more resilient American supply chains “ while noting that the U.S. “industrial economy is dangerously dependent on our foremost adversary for essential critical minerals.” He emphasized the need for EXIM to ensure taxpayer dollars are not supporting PRC-controlled entities. Rep. Rob Wittman (R-VA), cochair of the Select Committee’s Critical Mineral Policy Working Group (PWG), praised EXIM for helping to “update many of our financial tools” in accordance with a December 2024 report released by the PWG and underscored the need to reduce reliance on adversaries and strengthen domestic production. Rep. Kathy Castor (D-FL), also cochair of the PWG, applauded the initiative for its role in derisking critical mineral supply chains, saying, “The SCRI will finance projects that increase critical mineral supplies for domestic manufacturing, create American jobs, and position the United States as a global player in battery markets.”

Next Steps

EXIM’s launch of SCRI marks a significant advancement in U.S. efforts to rebuild secure and sustainable supply chains for critical minerals, providing a significant opportunity for U.S. firms seeking to expand their international operations in key regions globally, including the Middle East, Africa, Central Asia, and Central and South America. We expect the Trump administration will further emphasize the importance of processing critical minerals and rare earths domestically. Brownstein’s international practice has excelled in connecting both U.S. and international businesses with U.S. financing tools such as EXIM, guiding them through funding processes and requirements. With its expertise, Brownstein is well-positioned to help U.S. companies partner with EXIM’s SCRI to expand their reach into emerging economic regions, fostering supply chain resilience, infrastructure development and modernization efforts. Going forward, Brownstein will continue to monitor SCRI’s development to identify opportunities to engage with this critical new financing tool. For more information on how to engage with the incoming administration and EXIM, please contact Samantha Carl-Yoder and Lauren Diekman.

THIS DOCUMENT IS INTENDED TO PROVIDE YOU WITH GENERAL INFORMATION REGARDING EXIM'S NEW SUPPLY CHAIN INITATIVE. THE CONTENTS OF THIS DOCUMENT ARE NOT INTENDED TO PROVIDE SPECIFIC LEGAL ADVICE. IF YOU HAVE ANY QUESTIONS ABOUT THE CONTENTS OF THIS DOCUMENT OR IF YOU NEED LEGAL ADVICE AS TO AN ISSUE, PLEASE CONTACT THE ATTORNEYS LISTED OR YOUR REGULAR BROWNSTEIN HYATT FARBER SCHRECK, LLP ATTORNEY. THIS COMMUNICATION MAY BE CONSIDERED ADVERTISING IN SOME JURISDICTIONS.