Business priorities for responsible critical mineral supply chains

Demand for critical minerals is accelerating as governments pursue the energy transition, expand digital infrastructure and scale advanced manufacturing. Yet the policy landscape governing these supply chains is fragmented. More than 100 sustainability standards and initiatives now apply to the minerals and metals sector, and jurisdictions are adopting divergent definitions, due diligence rules and traceability requirements. For businesses operating across mining, processing, trading and end-use, as well as for investors and original equipment manufacturers, this fragmentation causes complexity and uncertainty, becoming a significant constraint on resilient supply.

This ICC policy paper sets out seven business priorities for a coherent, inclusive and responsible global approach to critical minerals.

1. Recognise the full range of interests at stake

Critical minerals policy should recognise the diversity of actors and interests across the value chain – from multinational miners and junior explorers to state-owned enterprises, traders and manufacturers – each operating under different regulatory and financial conditions.

Likewise, producing and consuming economies are varied, each with a different set of priorities. Policy frameworks must therefore be flexible, risk-based and proportionate to scale and capacity – rather than prescriptive or one-size-fits-all.

2. Harmonise existing standards

The proliferation of overlapping standards falls hardest on smaller operators and businesses in developing economies, which often lack the capacity to navigate multiple parallel systems.

Governments should primarily support convergence efforts, such as the Consolidated Mining Standard Initiative. They should pursue mutual recognition and interoperability across jurisdictions, and involve producing and consuming countries, industry, civil society and affected communities in standard-setting processes. New standards should only be created where a genuine market gap has been demonstrated.

3. Strengthen trust through interoperable traceability

Traceability is increasingly central to due diligence and market confidence, but poorly designed systems can create unnecessary compliance burdens – a barrier which disproportionately impacts smaller and developing-economy operators.

Digital interoperability initiatives, such as the UN Transparency Protocol, and the upcoming Global Materials Data Hub are helping to improve the exchange of sustainability and traceability data across existing systems. Looking ahead, shared infrastructure should be built through inclusive, multi-stakeholder processes that preserve data ownership and confidentiality.

4. Advance sustainability through circularity and material efficiency

Recycling, recovery and more efficient use of materials can reduce the emissions, environmental impact and long-term supply risks associated with critical mineral extraction. However, significant barriers remain, including limited recycling collection infrastructure and underdeveloped markets for recycled goods.

Critical mineral policy should support both circularity and responsible primary production. Governments should invest in collection, recovery and end-of-life infrastructure. They should consider blended finance mechanisms for recycling and demand-side incentives for secondary materials. Updates to the Basel Convention could also help to distinguish waste destined for disposal from material shipped for recovery.

5. Enable responsible critical material investment and development

Permitting delays, regulatory uncertainty and fragmented standards are identified as bigger constraints on investment than the availability of finance itself.

Business needs predictable long-term policy signals, efficient and transparent permitting and financing frameworks that reward strong environmental performance. To unlock investment, governments and development finance institutions should expand the use of blended finance and political risk insurance – particularly through multilateral development banks in emerging and developing economies.

6. Close the gap between critical minerals and the climate agenda

Critical minerals underpin the technologies needed to deliver on the Paris Agreement and Nationally Determined Contributions. Yet climate, industrial, trade and resource policy remain poorly coordinated.

Governments must integrate minerals considerations into climate finance and transition planning. Responsibly produced minerals should be recognised as enablers of decarbonisation and just transition objectives.

7. Protect biodiversity and ecosystems integrity

Protecting biodiversity must be an integral part of responsible supply chain development and critical mineral extraction. ICC calls for consistent, risk-based biodiversity assessments built on existing international standards and better data made available through multistakeholder instruments such as the Global Materials Data Hub. Efforts to protect biodiversity and critical mineral supply chains must also align with existing global biodiversity goals and reporting frameworks – such as the Kunming-Montreal Global Biodiversity Framework the Taskforce on Nature-related Financial Disclosures.