Trump Memo Opens Door to Export Controls on Recycled Critical MineralsA · FULL TRANSLATION
- A presidential memorandum signed on 30 July authorises the Commerce Secretary to control exports of recyclable critical minerals.
- The legal basis is Section 101 of the Defense Production Act, framed as domestic supply-chain reinforcement.
- Coverage includes battery black mass, scrapped rare-earth permanent magnets, metal swarf and critical-mineral-bearing waste.
- Copper scrap is excluded, having been addressed by a separate presidential proclamation in July 2025.
- The Commerce Department will set the specific items, scope and timing.
Scrap is becoming a strategic material, and that matters more to Taiwan than it first appears. Taiwan is a significant node in Asia's recycling and processing chain, with electronic waste, spent batteries and rare-earth-bearing scrap moving across the region. Once Washington controls exports of recyclable critical minerals, those flows follow policy rather than price.
Black mass is the item to watch. The dark powder left after shredding spent lithium batteries carries lithium, nickel and cobalt — the part of recycling that actually earns money, and the feedstock every battery supply chain wants. Keeping it onshore removes a source for Asian recyclers while shielding US refining capacity. Scrapped magnets follow the same logic: recovery is the shortest route around a rare-earth mining bottleneck.
Taiwanese firms should map their feedstock now. If a meaningful share comes from the US, line up alternatives. If you sell equipment or process technology, this cuts the other way — US capacity has to expand, and that is exactly what it lacks. The memo is only an authorisation so far; the list is still to come, which makes this a window to adjust rather than wait.
Watch the Commerce Department's item list and effective dates, and whether the EU and Japan follow with their own limits on scrap.
President Trump issued a memorandum on 30 July 2026 authorising the Secretary of Commerce, under Section 101 of the Defense Production Act, to impose export controls on recyclable critical minerals and materials originating in the United States.
Coverage includes black mass from processed waste batteries, scrapped rare-earth permanent magnets, finished goods containing critical minerals, metal swarf from machining, and critical-mineral-bearing waste and scrap. Copper scrap is explicitly excluded, having been covered by a separate presidential proclamation in July 2025.
The Commerce Department will determine the specific items, the substance of the controls and the timing. The measure is positioned as part of the administration's push to strengthen domestic critical-mineral supply chains. Refer to the original report for full detail.