关于关键矿产贸易多边协定的设计和加强关键矿产供应链弹性的政策行动的评论（英）

Beia Spiller, Michael Toman, and Madeline Craig-Scheckman Public CommentMarch 2026 March 19, 2026 Office of the US Trade Representative600 17th Street NWWashington, DC 20508Attn: Joseph Sullivan, Senior Director for Policy Dear Ambassador Greer, On behalf of Resources for the Future (RFF), I am pleased to share the accompanying comments to theOffice of the United States Trade Representative (USTR) on the proposed design of a plurilateral RFF is an independent, nonprofit research institution in Washington, DC. Its mission is to improveenvironmental, energy, and natural resource decisions through impartial economic research and policyengagement. While RFF researchers are encouraged to offer their expertise to inform policy decisions,the views expressed here are those of the individual authors and may differ from those of other RFFexperts, its officers, or its directors. RFF does not take positions on specific policy proposals. However, To that end, and given the significance that policy will play in pricing and market characteristics, RFFresearchers are encouraged by the USTR’s desire to evaluate policy actions that will enhance moresecure supplies of critical minerals and improve the overall resilience of US critical minerals supplychains. Led by Dr. Beia Spiller, we provide these comments across the range of topics USTR hasrequested. We base these comments on foundational economic principles, including the competitive If you have any questions or would like additional information, please contact Dr. Beia Spiller atbspiller@rff.org. Sincerely, Carlos E. Martín Comment on the Design of a PlurilateralAgreement on Trade in Critical Minerals and Beia SpillerFellow and Transportation Program Director, Resources for the Future Michael TomanSenior Fellow, Resources for the Future Madeline Craig-ScheckmanPhD Candidate, School of Public Policy and Urban Affairs, Northeastern University, and RFF Critical Minerals Research Lab Scholar craigscheckman.m@northeastern.edu Introduction We are submitting these comments in response to the Office of the United States TradeRepresentative’s (USTR’s) request for input on a plurilateral agreement to strengthen critical mineralsupply chain resilience, supported by coordinated mineral import tariffs. In our view, for such anagreement, the core design question is how the agreement can help build reliable, scalable alternatives There is an inherent tension between coalition-level resilience and national industrial policy goals,including onshoring. If the coalition’s objective is supply chain resilience at a reasonable cost, theagreement should be structured to enable friendshoring and to let members specialize where they have Practically, improving supply chain resilience means increasing geographic diversity in mineral extractionand (especially) processing capacity. That diversification may reduce China’s market share, and it will beregarded by China as a significant trade measure. The burden imposed on China, and the risk of their Adequate diversification does not require eliminating China from these markets. Rather, it requiresensuring that buyers have credible alternatives at scale. What counts as “adequate” diversification willvary by mineral and by market structure. It is ultimately a policy choice that should be madeintentionally and explicitly because it drives how the coalition is structured, how pricing (or other In addition, the coalition can benefit from supply growth outside of its membership. If producers andprocessors outside the coalition, but not associated with Prohibited Foreign Entities, increase output, Several considerations frame the challenges of using a coalition-wide price floor supported by importtariffs on China to simultaneously reduce Chinese dominance and expand coalition capacity. First, thescale of mineral production is a binding constraint. Many allied countries currently produce and processonly a small fraction of China’s volumes. As illustrated in Figure 1 below, aggregate processing capacityacross ministerial participants (and, for that matter, Pax Silica participants and MSP/FORGE participants) Second, maintaining a multi-country tariff regime is inherently challenging. Individual members haveincentives to relax or drop tariffs for multiple reasons, including: (1) domestic cost pressures, (2) Chineseretaliation or negotiation pressure, and (3) large flows of non-mineral trade with China. Sustaining Third, tariffs alone do not ensure that new mineral extraction and processing capacity will be built in theUnited States. If a supported price creates an investment signal, firms across the coalition will competeto supply the market, and new projects may be located where costs are lowest within the bloc—whichmay not necessarily be in the United States. For that reason, US policy should be explicit about whether Finally, there is an inherent tradeoff between strong investment incentives and near-term affordability.Higher tariffs