Leading the Way or Falling Behind? Comparing Allied Critical Minerals Investment Control Regimes

Allied Regimes in Flux

Critical minerals—lithium, rare earths, cobalt, graphite, and others essential for batteries, defense systems, semiconductors, and clean energy—have become central to national security as China dominates processing and has repeatedly used export controls as leverage. In February 2026, the US hosted a Critical Minerals Ministerial with delegations from dozens of countries, resulting in 11 new bilateral frameworks and MOUs, plus action plans with partners like Mexico, Japan, and the EU. These initiatives promote coordinated investment screening, trade policies, price floors, and financing to diversify away from China-dominated chains.

This diplomatic push coincides with US domestic moves like Project Vault, a $12 billion stockpile initiative funded by the Export-Import Bank, and the launch of FORGE (Forum on Resource Geostrategic Engagement) as a plurilateral coalition to succeed earlier partnerships. Vice President JD Vance highlighted price stability and aligned screening to unlock private investment, underscoring that erratic policies deter capital.

Among Five Eyes allies, approaches vary. The US maintains CFIUS (Committee on Foreign Investment in the United States), which has broadened scrutiny of critical minerals. Australia uses its Foreign Investment Review Board with heightened focus on sensitive sectors. The UK and New Zealand have tightened regimes post-2020s. Canada, rich in deposits but facing development hurdles, overhauled its Investment Canada Act (ICA) national security rules, flagging critical minerals for enhanced review since 2022 and expanding criteria in 2025 to include economic security, often targeting state-owned or linked entities—leading to forced divestitures of Chinese stakes in lithium projects.

These differences create tensions: overly stringent screening risks diverting capital to less regulated jurisdictions or non-allied players, slowing mine development amid urgent demand. Yet lax regimes could allow adversarial influence over strategic assets. Recent G7 efforts, including the 2025 Critical Minerals Action Plan under Canada's presidency, stress aligned tools like investment policies to counter non-market distortions.

Non-obvious angles include the trade-off between speed and security—projects worth tens of billions face delays from reviews, while mismatched allied standards fragment efforts. Public opinion in Canada shows support for limits on foreign investment even if it stalls development. Broader geopolitical context: China's 2025 export restrictions on certain minerals heightened urgency, though some eased in trade deals, the threat persists.

Concrete stakes involve timelines—many allied projects target production ramps in the late 2020s to meet defense and net-zero goals—plus costs from delays running into hundreds of millions per project, and risks like supply shortages for military tech if diversification falters.