Project Vault and FORGE Signal Next Phase of U.S. Critical Minerals Policy

Brownstein Client Alert, Feb. 5, 2026

On Feb. 4, National Security Advisor and Secretary of State Marco Rubio, joined by Vice President JD Vance and senior Cabinet officials, convened representatives from 54 countries and the European Commission, including 43 foreign and other ministers, for the inaugural 2026 Critical Minerals Ministerial. During the ministerial and a Feb. 3 government-industry dialogue at the Center for Strategic and International Studies (CSIS), the administration announced several new international and domestic critical minerals initiatives, including Project Vault (announced Feb. 2), the Forum on Resource Geostrategic Engagement (FORGE), and multiple bilateral agreements. These actions advance the Trump administration’s objective of strengthening U.S. access to critical minerals essential to defense, energy, advanced manufacturing and emerging technologies, while reducing exposure to supply chain vulnerabilities linked to foreign adversary dominance.

Project Vault

On Feb. 2, President Donald Trump, alongside the U.S. Export-Import Bank (EXIM), formally announced plans to launch Project Vault, also known as “VaultCo,” a $12 billion critical minerals stockpile intended to support national security. According to an EXIM fact sheet, the initiative is expected to combine $2 billion in private capital with a $10 billion EXIM loan, which the EXIM board approved earlier on Feb. 2, marking the largest financing in the agency’s history.

According to administration officials, the reserve is intended to provide a buffer against supply disruptions involving critical minerals, particularly those sourced from China. During a White House press conference, President Trump said the stockpile would “ensure that American businesses and workers are never harmed by any shortages.” In a separate Bloomberg interview, EXIM Chair Jovanovic said the stockpile will include all 60 minerals listed on the U.S. Geological Survey’s 2025 Critical Minerals List, with particular emphasis on the 17 rare earth elements and minerals, including cobalt, used in high-demand technologies. Copper is also expected to be a priority, given projected supply constraints, as are materials where China controls processing streams, such as germanium, scandium and gallium.

EXIM described Project Vault as a partnership between original equipment manufacturers (OEMs) and private capital providers. Participating companies would commit to purchasing materials at a set price, pay upfront fees and retain the option to draw from the stockpile at that price as needed. The project would procure and store the materials, with manufacturers required to replenish withdrawn supplies. In the event of a major supply disruption, participants would be permitted to withdraw their full allotment at once. The administration has compared the initiative to the U.S. Strategic Petroleum Reserve, established in 1975 following the Arab oil embargo, as a mechanism to help insulate domestic industries from global market disruptions.

The announcement follows broader administration efforts to address critical mineral supply risks, including under its “Unleashing American Energy” executive order, and parallels legislative proposals in Congress. On Jan. 15, Rep. Rob Wittman (R-VA) introduced the SECURE Minerals Act (H.R.7126), which would establish a Strategic Resilience Reserve to increase “America’s share of global critical mineral and material production.” Rep. Wittman has stated that National Security Council Minerals Advisor David Copley reviewed the proposal as a potential framework for the stockpile.

In the private sector, companies including General Motors, Stellantis NV, Boeing Co., Corning Inc., GE Vernova Inc. and Alphabet Inc.’s Google have reportedly expressed interest in participating, though the White House has not confirmed their involvement. A U.S. official said that Hartree Partners, Traxys North America and Mercuria Energy Group will serve as the trading houses responsible for procuring raw materials for the stockpile.

Bilateral Critical Minerals Frameworks

During the ministerial, the United States government signed 11 new bilateral critical minerals frameworks or memoranda of understanding with Argentina, the Cook Islands, Ecuador, Guinea, Morocco, Paraguay, Peru, the Philippines, the United Arab Emirates and Uzbekistan. These agreements add to 10 critical minerals frameworks or MOUs concluded since October 2025, including frameworks with Australia and Japan and MOUs with Thailand, Malaysia, Cambodia, Saudi Arabia and additional partners.

The administration has reportedly completed negotiations on similar agreements with 17 other countries although they are not yet public. During the Feb. 3 CSIS event, Interior Secretary and head of the National Energy Dominance Council Doug Burgum stated that an additional 20 countries have expressed interest in signing such frameworks, further strengthening the United States’ supply chain for key minerals.

As of this writing, the U.S. government has not detailed the substance of the 11 announced agreements. They may reflect a more expansive framework similar to those concluded with Australia and Japan in October 2025, which include commitments to cooperate on “adopting standards-based systems that enable free trade within a pricing framework, such as price floors.” Alternatively, the agreements may align more closely with the narrower MOUs signed with other countries over the past five months.

Separately, on Feb. 3, the European Union, Japan and Mexico announced agreements with the United States to develop new policies, including price floors, to address critical mineral supply chain vulnerabilities, according to statements from the Office of the U.S. Trade Representative. These “Action Plans” are intended to “develop coordinated trade policies and mechanisms, such as border-adjusted price floors,” and to include “consulting on how price floors may be incorporated in a binding plurilateral agreement on trade in critical minerals.” A similar partnership was announced between the United States and the United Kingdom later that evening.

Forum on Resource Geostrategic Engagement

Also at the ministerial, Vice President Vance announced the creation of the Forum on Resource Geostrategic Engagement (FORGE) as the successor to the Biden-era Minerals Security Partnership, citing the expanding network of U.S. bilateral critical minerals agreements. FORGE, which will be chaired by the Republic of Korea through June, is intended to address ongoing challenges in the global critical minerals market and establish a U.S.-led preferential trade zone for critical minerals.

According to Vice President Vance, the trade zone would be insulated from external market disruptions through enforceable price floors supported by adjustable tariffs. Vance stated that FORGE would set “reference prices” for critical minerals at each stage of production and implement “pricing that reflects real-world fair market value.”

The initiative reflects the administration’s assessment that the United States does not control a majority of global mining assets and will need to partner with allies to expand mining and processing capacity. It also reflects recognition that unilateral funding of price floors is not financially feasible and that coordinated approaches are necessary to support long-term price stability.

Next Steps

The Trump administration’s latest efforts to secure critical minerals supply chains build on a series of actions taken over recent months. In December 2025, the administration launched the Pax Silica initiative, now involving nine partner countries, aimed at establishing a secure, resilient and innovation-driven silicon supply chain to support semiconductor manufacturing and artificial intelligence (AI) development. Earlier this month, President Trump issued a proclamation directing the departments of Commerce and the Treasury to pursue trade agreements intended to address national security risks associated with U.S. reliance on China for these materials. These steps coincide with a significant expansion of U.S. funding for critical minerals projects domestically and abroad, led by the departments of War, Commerce and Energy, along with the U.S. International Development Finance Corporation (DFC) and EXIM.

Brownstein’s International and Critical Minerals teams bring deep experience in the critical minerals space and work closely with the agencies involved in advancing the administration’s financing, trade and diplomatic engagement on critical minerals. We coordinate with private industry, investors and foreign governments to support supply chain security, navigate U.S. financing tools on behalf of our clients and identify opportunities for public-private partnerships. Our team also holds extensive experience in connecting private industry leaders with the U.S. government on issues related to supply chain security, global investment strategies, financing and other top issues impacting clients. We are prepared to assist clients in assessing project eligibility, coordinating with relevant agencies and developing strategies to secure federal support in a rapidly evolving investment environment. If you have any questions, please contact the authors of this alert.


THIS DOCUMENT IS INTENDED TO PROVIDE YOU WITH GENERAL INFORMATION REGARDING CRITICAL MINERAL POLICY. 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.