Cullen S. HendrixMay 2026. The confluence of global energy transitions, the artificialintelligence (AI) revolution, and great power militarism is causingdemand and prices for critical minerals to surge. China hasweaponized export controls on critical minerals as part of theongoing US-China technology and trade wars. Many mineral-richmiddle-income and developing economies are eager to moveup the value chains from just producing ore to also refining andprocessing these materials and are using export restrictions asleverage to encourage inward investment. Cullen S. Hendrixis seniorfellow at the PetersonInstitute for InternationalEconomics, nonresidentsenior research fellow atthe Center for Climate& Security, and fellow atthe Payne Institute at theColorado School of Mines.He is also a consultant toWillis Towers Watson, aglobal insurance brokerageand risk advisory firm.This analysis is not to beconstrued as representativeof any position, view, orcommercial interest ofWillis Towers Watson. Thefirm had no role in theresearch, writing, or reviewof this Policy Brief. Meanwhile, the United States remains highly dependent onimports of these minerals, including rare and heavy rare earthelements, which are critical for semiconductors, renewable energy,and national defense applications. Supply disruptions can imposehigh economic and social costs, so these developments providea compelling rationale for critical mineral stockpiling. A centralcomponent of the US response strategy is Project Vault, a$12 billion program to shield US—and eventually, allied—manufacturers against supply disruptions by physically storingan emergency supply of critical minerals. If intended as insurance, Project Vault must be designed inways that address both the common ways insurance markets fail and the specific challenges of these highly complex mineralsupply chains. The underlying strategic logic of private-enterprise-oriented stockpiling is sound. But the blueprint could use severalimportant modifications. The specific institutional design of Project Vault raises importantquestions about the plan’s durability and day-to-day operations.But those questions are all downstream of a more fundamentalquestion: Assuming those specific challenges are surmountable, canProject Vault actually provide insurance for the US industrial baseagainst supply chain risk? This Policy Brief analyzes three well-known challenges facingrisk pooling–based insurance schemes: correlated risk, adverseself-selection, and difficulties in maintaining and processinghighly differentiated critical minerals and their derivativeproducts. If not addressed, these challenges could cause thesystem to fail at the most critical time. The brief then proposesfour corresponding solutions: (1) mandatory firm participationin the program with fees scaled to firm size, (2) fundingbenchmarked to worst-case disruption scenarios, (3) clarityon the stockpiling balance between raw ore and intermediate,processed products, and (4) a frank recognition of the USmidstream processing gap. THE PLAN Project Vault is envisioned as a public-private partnership initiallycapitalized by a $10 billion loan from the Export-Import (EXIM)Bank of the United States—the largest in the EXIM Bank’s 92-yearhistory—and augmented by roughly $2 billion in private capital.Unlike the Strategic Petroleum Reserve (SPR), a similar stockpile-based insurance mechanism against oil market volatility and supplydisruptions, Project Vault has not been specifically authorized byCongress.1Rather, the administration is relying on two existingEXIM authorities2and a third-party workaround because directly running the reserve would clearly violate the EXIM Bank’s statutorymandate. Key elements of Project Vault include: 1The Supply Chain Resiliency Initiative, which provides financingfor international mining projects that have signed long-termofftake agreements with US companies. 2The Make More in America Initiative, which provides financingto domestic critical minerals projects that are expected todedicate at least 15 percent of production or shipments to USexport markets. 3A new, independent third-party entity that will actually run thereserve. Three commodities trading firms—Hartree Partners,Traxys North America, and Mercuria Energy Americas—areparticipating so far and will operate the reserve and managematerials procurement, stockpiling, and replenishment. The goal is for offtake agreements—contracts under which a buyercommits in advance to purchase a specified quantity of a producer’sfuture output—with Vault to help solve persistent bankability issuesfacing Western critical minerals projects: Without guaranteed demandat predictable prices, these projects struggle to attract private capitalbecause anticipated returns are too low relative to risk, particularlywhen competing against Chinese producers whose costs areeffectively subsidized by the state (Hendrix 2026). The program covers all 60 minerals on the US GeologicalSurv