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# UK Critical Minerals Strategy: What Electronics Manufacturers Need to Know

The UK's Critical Minerals Strategy identifies 18 minerals — including lithium, cobalt, rare earths, and graphite — as critical to the UK economy. For electronics makers, the Strategy signals growing government and investor expectations around supply chain transparency, concentration risk assessment, and resilience planning for the raw materials that go into batteries, magnets, and semiconductors.

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At a glance

List

18 critical minerals

Key categories

Batteries, magnets, semis

Partnerships

Australia, Canada, Zambia

Mandatory?

Policy (not yet legally required)

## Critical minerals and electronics hardware

### The UK's critical minerals list

The UK Government's Critical Minerals Strategy identifies minerals assessed as critical to the UK economy due to their supply risk and economic importance. The current list includes lithium, cobalt, nickel, rare earth elements (neodymium, dysprosium), graphite, manganese, tungsten, and others — directly relevant to battery cells, permanent magnets, PCB materials, and semiconductor manufacturing. The list is reviewed periodically as supply conditions change.

### Why it matters for electronics supply chains

Electronics hardware — batteries, motors, sensors, semiconductors — is among the most critical-mineral-intensive product categories. A lithium-ion battery cell contains lithium, cobalt, nickel, manganese, and graphite. Permanent magnets in speakers and motors use rare earth elements. The Strategy signals Government intent to support UK access to these materials through international partnerships, domestic processing, and recycling — but also raises expectations on manufacturers about supply chain transparency and resilience.

### UK international mineral partnerships

The UK has established bilateral mineral partnerships with Australia, Canada, Zambia, and others to diversify supply away from single-country dependence (primarily China for processing of rare earths and many battery minerals). These partnerships create preferential cooperation pathways for UK-based manufacturers — including potential access to supply agreements, joint ventures, and government-backed financing for mineral projects in partner countries.

### Supply chain due diligence expectations

While the UK Critical Minerals Strategy does not impose legal supply chain due diligence obligations on manufacturers in the way the EU's CSDDD does, it creates a strong policy expectation that major electronics manufacturers understand where their critical minerals originate, assess concentration risks, and have contingency plans for supply disruption. UK procurement frameworks and investor ESG expectations are increasingly driving disclosure of critical mineral sourcing in company reporting.

## Supply chain risk assessment steps

01

Map your bill of materials against the UK's critical minerals list — identify which components and materials in your products contain one or more critical minerals, and in what quantities.

02

Trace the supply chain for each critical mineral to at least the refining/processing level — many critical minerals are processed in a small number of countries, and concentration at this tier is the primary supply risk.

03

Assess supply concentration risk: what percentage of each critical mineral in your supply chain passes through a single country or supplier? Set a threshold (e.g., >50% from one country) that triggers a diversification review.

04

Engage with your tier-1 suppliers about their own critical mineral sourcing — request disclosure of origin information and, where available, certificates of origin or smelter/refiner declarations.

05

Explore UK Government-supported programmes: the Critical Minerals Intelligence Centre (CMIC) publishes supply risk data; the British Geological Survey provides geological and supply data; and the Government's Faraday Battery Challenge supports battery supply chain development relevant to lithium, cobalt, and nickel.

06

Evaluate recycled content sourcing for critical minerals — the UK Battery Regulation and equivalent frameworks are driving recycled content requirements that create incentives for closed-loop critical mineral supply alongside primary sourcing.

07

Report critical mineral supply chain risks in your annual report and ESG disclosures if you are a listed company or supply to customers with supply chain transparency requirements — investor and customer expectations on this topic are increasing rapidly.

## Frequently asked questions

### Is critical mineral due diligence legally required in the UK?

Not through a dedicated mandatory framework as of 2026 — unlike the EU's CSDDD for supply chain due diligence or the US Dodd-Frank conflict minerals reporting. However, the UK Modern Slavery Act Section 54 reporting covers labour and human rights risks in supply chains including mining operations. Large listed companies also face supply chain disclosure expectations under the TCFD framework and the FCA's sustainability disclosure requirements. Mandatory due diligence legislation is under ongoing review.

### Which electronics categories are most exposed to critical mineral supply risk?

Battery products (EVs, consumer electronics, energy storage) are the highest-exposure category due to lithium, cobalt, nickel, manganese, and graphite content. Motors and speakers using permanent magnets are exposed to rare earth element (REE) supply risk — primarily neodymium and dysprosium from China-dominated supply chains. Semiconductors use tungsten, gallium, and germanium. IoT devices with small batteries and sensors typically have lower absolute exposure but the same supply chain concentration risk per unit weight.

### How do UK-Australia and UK-Canada mineral partnerships benefit UK manufacturers?

These partnerships are government-to-government frameworks designed to facilitate investment in mineral projects in partner countries and create more diverse supply chains for UK industry. In practice, they can benefit UK manufacturers through government-backed trade missions, introduction to mining and processing companies in partner countries, and access to government financing (via UK Export Finance) for projects that supply UK or allied-nation manufacturing. Direct benefits to individual SMEs are more indirect — the partnerships primarily de-risk the broader supply ecosystem over a longer timeframe.

### Does the UK Critical Minerals Strategy interact with UK battery regulations?

Yes — the UK Batteries Regulation (which mirrors the EU Battery Regulation's structure) is expected to include recycled content requirements and due diligence obligations for battery materials, specifically cobalt, lithium, nickel, and natural graphite. The Critical Minerals Strategy and the Battery Regulation are part of the same policy system: the Strategy addresses supply resilience, and the Battery Regulation uses regulatory levers (recycled content mandates, due diligence requirements) to drive market-level change in how critical minerals are sourced.

**Disclaimer:** Educational resource only. The UK's critical minerals policy framework is evolving. Consult the CMIC, BGS, and a qualified supply chain adviser for product-specific sourcing risk analysis.

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