InfluenceMap’s analysis of corporate engagement with three major US vehicle emissions standards under consultation in 2023-2024 reveals that oppositional companies and industry associations have strategically used concerns about critical mineral supply chains to delay the transition to electric vehicles. These narratives echo and adapt long-standing fossil fuel talking points, particularly around national security, affordability, and energy reliability, to weaken policy.
Policymaker language in the final emissions standards reflected this lobbying pressure. Across all three regulations, critical mineral supply chains are mentioned more than 350 times, including references to national security, energy security, environmental and social impacts, and the demands of the energy transition. In 2025-26, powerful actors continue to use mineral-related narratives to supplement their oppositional climate advocacy, including efforts to significantly weaken GHG emissions and fuel-efficiency (CAFE) standards. This negative advocacy highlights risks for other policies globally if laggard automotive and energy actors succeed in employing these misleading narratives in other key markets.
Over 90% of regulatory comments from 2023 and 2024 that mentioned ‘critical minerals’ used pro-fossil fuel narratives to undermine the credibility of the transition away from fossil fuels and technologies. This trend reflects an evolution of the fossil fuel narrative playbook, previously documented by InfluenceMap, now extended to encompass the material inputs of the energy transition. In comments on the CAFE Standards, Light- and Medium-Duty Vehicle Standards, and Heavy-Duty Vehicle Standards, critical minerals have become a focal point of anti-transition advocacy.
Negative actors emphasized narratives related to critical mineral supply chains to legitimize their opposition to the Standards’ provisions. Two of the most widely used narratives argued that the use of critical minerals in EVs raised concerns about affordability and national security For example, oil and gas and automotive associations, including the American Petroleum Institute, American Fuel & Petrochemical Manufacturers, and the Alliance for Automotive Innovation, argued that over-dependence on China for critical mineral supply threatens both US energy security and national security. The cross-sector association, the US Chamber of Commerce, also used these narratives in its negative advocacy. Notably, oil and gas actors also emphasized the climatic, social, and environmental impacts of EV value chains, while failing to acknowledge the consequences of the fossil-fuel value chain for ICE vehicles.
InfluenceMap finds that many of these narratives are not aligned with Intergovernmental Panel on Climate Change (IPCC) science for delivering the 1.5ºC goal of the Paris Agreement, or contradict guidance and outlooks set out by the International Energy Agency (IEA) and previously the Environmental Protection Agency on mineral supply chains and EVs. They also fail to acknowledge how effectively addressing critical mineral supply chain issues can facilitate the sustainable production of energy transition technologies.
In contrast, Tesla and the Zero Emissions Transport Association were the only positively engaged actors to reference critical minerals. Both constructively referenced critical mineral supply chains, arguing that while supply challenges exist, they do not justify weakening ambition. However, this engagement was outweighed by the volume and consistency of oppositional messaging.
The IPCC’s 2022 Mitigation of Climate Change report highlights that emissions reductions to limit global warming to 1.5-2°C will require the accelerated electrification of buildings, transport, and industry. This shift towards net zero energy, underpinned by renewables and electric vehicles (EVs), is driving significant global demand for ‘critical minerals’, including copper, cobalt, lithium, nickel, and zinc.
According to the International Energy Agency (IEA), solar PV and wind energy are highly intensive in copper, zinc, and silicon. At the same time, electric vehicles require more copper, graphite, nickel, and manganese than combustion engine vehicles. Consequently, demand for critical minerals is expected to quadruple by 2040. Governments have responded to this anticipated demand growth with efforts to secure domestic supply, including significant policies such as the EU Critical Raw Materials Act and the US Critical Minerals Security Act.
This increase in demand has highlighted the potential risks surrounding critical mineral supply chains, including their security, sustainability, economic viability, and capacity to meet the demands of the energy transition. The IEA’s 2025 Critical Minerals Outlook report highlighted issues such as price volatility, supply chain bottlenecks, geopolitical concern, and their potential impacts on supply chains. A prominent example of action on this was US President Donald Trump’s executive order to both shore up domestic critical mineral supplies and investigate potential “national security risks from imports of processed critical minerals and their derivative products.”
This briefing examines how concerns about critical mineral supply chains are being leveraged in US corporate lobbying to influence key climate-related automotive policies. While securing a mineral supply is a legitimate consideration for policymakers, these concerns are increasingly cited by oppositional actors to justify weakening climate policy ambition.
This research utilizes InfluenceMap’s database of over 1,000 companies and 330 industry associations, along with its established system for assessing their climate policy engagement (see the LobbyMap methodology). It focuses on regulatory comments to 3 key automotive climate policies in the US (Section 2.1), as tracked on InfluenceMap’s Automotive Climate Tool. Using a narrative analysis approach, the briefing assesses how arguments about critical mineral supply have been incorporated into corporate lobbying and how these align with and adapt the broader fossil fuel narrative playbook, both when these policies were first proposed in 2023-24, and now in 2026. This includes recurring themes around national security, affordability, and technological feasibility, now repurposed to challenge the transition to electric vehicles.
InfluenceMap’s July 2024 report on the oil and gas industry’s historical influence on climate policy identified a playbook of narratives that the fossil fuel sector has employed for decades to delay and oppose the transition to more sustainable alternatives, including renewables and electric vehicles. The playbook consists of three broad narratives:
‘Solution Skepticism’ aims to downplay alternative energy sources or amplify the perceived challenges of transitioning away from fossil fuels. Arguments portray fossil fuels as ‘clean’ or ‘low carbon’ or emphasize greenhouse gas (GHG) emissions and other limitations of renewable alternatives.
‘Policy Neutrality’ is used to insert fossil-fuel-reliant technologies into policies and discussions explicitly aimed at reducing fossil fuel dependence, thereby reopening the debate on the best technology pathways for climate mitigation.
‘Affordability and Energy Security’ encompasses arguments that claim a transition away from fossil fuels poses a threat to energy security, affordability, economic stability, and jobs, while also highlighting the financial benefits associated with fossil fuel development and use.
These narratives all advocate for a slower, less ambitious energy transition away from fossil fuels toward low-carbon alternatives, compared to the recommendations put forward by the IPCC for achieving the 1.5ºC goal of the Paris Agreement.
This research finds that the same narratives are increasingly being deployed in the context of critical mineral supply chains, with their associated issues and uncertainties being exaggerated and overemphasized by negative actors to delay the mass electrification of transport.
InfluenceMap’s policy database was used to assess the level of engagement on critical minerals across key climate policies in the US, based on a keyword search for the prevalence of the term ‘critical minerals’ in regulatory comments. This resulted in three automotive policies being flagged as having a significant level of comments referencing critical minerals (Table 1).
According to InfluenceMap’s previous analysis of lobbying on each policy, all three of these policies have faced significant opposition from the oil and gas sector and laggard automotive actors, who have successfully advocated for meaningful reductions in the climate ambition of the Standards (Figure 2). Since this advocacy, the Trump administration has proposed repealing emissions standards for light-, medium-, and heavy-duty vehicles, as well as significantly weakening Biden-era fuel efficiency standards (CAFE standards), alongside temporarily waiving all compliance penalties with CAFE standards.
| Policy | Date of Finalization | Current Status | Policy Summary |
|---|---|---|---|
| Corporate Average Fuel Economy (CAFE) Standards | July 2024 | Rollback proposed (December 2026) | Standards that require new vehicles to be more fuel efficient every year. Targets vary per vehicle type, such as passenger cars and light-duty trucks. |
| Emissions Standards for Light- and Medium- Duty Vehicles | March 2024 | Repealed (February 2026) | Greenhouse gas emissions standards that apply to new light and medium-duty vehicles sold each year from 2027-2032 and beyond to reduce their emissions annually. |
| Emissions Standards for Heavy-Duty Vehicles | April 2024 | Repealed (February 2026) | Greenhouse gas emissions standards that apply to heavy duty vocational vehicles such as delivery trucks, refuse haulers, public utility trucks, transit, shuttle, school buses, etc., and require new vehicles sold each year from 2027-2032 and beyond to reduce their emissions annually. |
A narrative analysis approach was used to categorize the types of critical mineral-related arguments corporate actors used to justify their negative advocacy in response to these Standards. This involved an initial analysis of each regulatory comment that included the term ‘critical minerals’. Each comment was then assessed to determine whether its argument included one of the three narrative categories of the fossil fuel narrative playbook (Solution Skepticism, Policy Neutrality, Affordability & Energy Security), with narrative tag(s) then assigned to each if they were included.
This research shows the fossil fuel narrative playbook has been adapted to leverage concerns around critical mineral supply chains to oppose, weaken, or delay key automotive climate legislation in the US. These narratives emphasize the issues and uncertainties associated with critical mineral supply chains, using them to question the viability of transitioning from internal combustion engine (ICE) vehicles to electric vehicles (EVs), as well as the policies that would facilitate this transition.
InfluenceMap finds that many of these narratives are not aligned with Intergovernmental Panel on Climate Change (IPCC) science for delivering the 1.5ºC goal of the Paris Agreement, or contradict guidance and outlooks set out by the International Energy Agency (IEA) and previously the Environmental Protection Agency on mineral supply chains and EVs. Crucially, they also fail to acknowledge how effectively addressing critical mineral supply chain issues can facilitate the responsible and sustainable production of energy transition technologies. A breakdown of these narratives and sub-narratives and their misalignment with critical mineral scientific research is provided in Table 2.
| Fossil Fuel Narrative | Critical Mineral Sub-Narratives | What Global & US Scientific Bodies Say |
|---|---|---|
| Solution Skepticism | Emphasizing greenhouse gas (GHG) emissions related to critical mineral usage (including downstream emissions through lifecycle emissions) to delay electrification. Emphasizing the social/environmental impacts of critical mineral usage to delay electrification.mpacts of critical mineral usage to delay electrification. | Statements emphasizing the life-cycle emissions of EVs to imply they are higher than battery electric vehicles directly contradict IPCC science, which states in its April 2022 that “electric vehicles powered by low emissions electricity offer the largest decarbonization potential for land-based transport, on a life cycle basis (high confidence)” (SPM-41, C.8; and, figure 10.4). While production emissions for EVs are typically higher than ICE-powered vehicles initially, they are significantly less when assessed over their lifetime. The IPCC also states that meeting climate goals would require “transformative changes in the transport sector” (Technical Summary 5.3), and that transitioning away from ICE vehicles has various social and non-climatic environmental benefits, including significant reductions in air pollution and related health implications (Chapter 3). It also reports on various health and environmental impacts related to petroleum use and ICE vehicles (Chapter 10). |
| An energy transition approach that has a focus on critical mineral-intensive pathways is unfeasible/impractical/unrealistic. Stressing critical mineral supply-demand gap; there are insufficient quantities of critical minerals available for the energy transition. | The IEA’s 2025 Global Critical Minerals Outlook Report stated that supply-demand projections “should not be interpreted to mean that energy transition goals are unattainable due to material constraints,” and reported that supply-demand balances through 2035 are improving compared to recent years. Nickel, cobalt, graphite, and rare earths suppliers are reportedly catching up with demand growth. It also states that supply-demand gaps can be addressed via the development of new technologies and scaling up of mining, refining and recycling, with adequate policy support. For example, minerals like copper and lithium are 100% recyclable; in the US, recycled copper currently meets over 30% of copper demand. | |
| Policy Neutrality | Advocating for internal combustion engine (ICE) and/or ICE-powered hybrids over battery electric vehicles to reduce critical mineral demand. Advocating for an ‘all of the above’ strategy that prolongs ICE vehicles to reduce mineral demand.vehicles to reduce critical mineral demand. | The IPCC’s AR6 WGIII report notes that ICE, hybrid and plug-in hybrid technologies, which are all powered using combustion engines, have limited potential for deep reductions of GHG emissions compared to battery electric vehicles. While electric vehicles require specific minerals in higher quantities than ICE vehicles, such as lithium, nickel, and cobalt, new battery chemistries are rapidly developing, such as lithium iron phosphate (LFP) batteries which require neither nickel or cobalt, and are lower cost. Additionally, research by the US Geological Survey (USGS) highlights ICE vehicle supply chains have their own reliance on minerals, such as barite used in oil drilling. Further, the IEA’s 2025 Global Critical Minerals Outlook Report notes that hybrids also have their own reliance on other minerals, particularly platinum group metals, while EVs do not require them to the same extent. These narratives also overlook the raw material demands of ICE vehicles: while an EV uses approximately 30kg of raw materials (if recycled), ICE cars consume 17,000 liters of petrol over their lifetime. |
| Claims that there is no demand for battery electric vehicles and their mineral components. | The IEA’s Global Critical Minerals Outlook 2024 report found that demand growth for critical minerals for energy transition applications has remained robust. EVs consolidated their position as the largest-consuming segment for lithium in 2023. Although US EV sales declined in 2025 as purchase tax credits expired, globally EV sales continue to grow, exceeding 17 million sales (20% of all car sales) globally in 2024. | |
| Affordability and Energy Security | Critical mineral usage will exacerbate energy security and affordability issues; equating ‘mineral security’ with ‘energy security’; emphasizing the security of petroleum fuels over minerals. Emphasizing critical mineral costs. | IEA research suggests that mineral security cannot be directly equated with energy security, and that minerals have different security of supply constraints compared to petroleum products. In its 2021 report on the Role of Critical Minerals in Clean Energy Transitions, the IEA explained that, in the event of an oil supply crisis, all consumers of ICE vehicles are impacted, whereas a shortage or spike in the price of a mineral affects only new EV supplies, not existing EV drivers. In addition, the combustion of oil means that new supply is essential to the continuous operation of ICE vehicles, however minerals have the potential to be recovered and recycled. In its 2025 Global Critical Minerals Outlook Report, the IEA stated that supply increases since 2023 resulted in a decline in mineral prices to pre-pandemic levels. Lithium prices have fallen by over 80% since 2023, and in December 2025 lithium-ion battery pack prices fell to a record low of $108/kwh. Furthermore, low critical mineral prices and increasing competition between battery manufacturers drove down battery pack prices in all markets in 2024, according to the IEA’s 2025 Global EV Outlook Report. |
| Critical mineral usage will result in negative regional impacts and/or impact manufacturing. A lack of supply of critical minerals will create product shortfalls, affecting supply chains. | Evidence from the IEA indicates continued growth in demand for critical minerals. The IEA’s Global Critical Minerals Outlook 2024 report found that demand growth for critical minerals for energy transition applications has remained robust. Its Global EV Outlook 2025 report found that EV sales (and hence manufacturing) continue to break records globally. | |
| Emphasizing over-dependence on foreign countries for critical minerals supply, attributing an impact on national security. | Previous research by the US Environmental Protection Agency (EPA) highlights domestic regulations in the US that will help prop-up regional mineral value chains and reduce foreign dependencies. It identified significant initiatives by the Federal government, local government, and private firms that support the development of domestic critical mineral, battery, and EV production. For example, 2025 funding notices for scaling the mining, processing, manufacturing, and recycling of critical minerals in the US were announced to reduce US dependency on foreign entities for critical minerals. |
InfluenceMap research found that over 90% of 2023-24 regulatory comments that referenced ‘critical minerals’ across the US Corporate Fuel Economy (CAFE) Standards, GHG Emissions Standard for Light- (LDVs), Medium-Duty (MDVs), and Heavy-Duty Vehicles (HDVs) used the pro-fossil fuel narratives outlined to argue against a transition away from fossil fuels and related technologies.
A total of 210 responses from companies and industry associations across the three policies were analyzed. Overall, 63 were found to have referenced ‘critical minerals’, and of these, over 90% used fossil fuel narratives adapted for critical mineral supply chains to attempt to weaken the polices’ climate provisions.
Several companies and industry associations used multiple types of fossil fuel narratives in their comments, across the three narrative categories: Solution Skepticism, Policy Neutrality, and Affordability & Energy Security (Figure 3). Overall, the three Affordability & Energy Security sub-narratives were the most widely used, identified 86 times across the 63 regulatory comments. In contrast, Policy Neutrality narratives were used much less frequently, accounting for just 5% of the narratives identified.1
1 Policy neutrality narratives are used heavily in reference to other climate policies, particularly by automotive actors, but less so regarding critical minerals where the idea of 'technological neutrality' is less relevant (e.g. lithium should be treated the same as cobalt).
Automotive and energy companies, and their related associations, as well as two cross-sector associations, were the only entities assessed in the LobbyMap database found to have used these narratives across the three comment periods on US vehicle emissions policy.
Of the 27 companies and industry associations identified as using these narratives, the top 5 users were all industry associations strategically engaged in oppositional climate advocacy activities (Figure 3). Of these, there were three energy associations (American Petrochemical & Fuel Manufacturers (AFPM), American Petroleum Institute (API), and Renewable Fuels Association), one automotive association (Alliance for Automotive Innovation), and one cross-sector association (US Chamber of Commerce). AFPM and API used fossil fuel sub-narratives in their advocacy significantly more than any other actor, having employed them at least 22 times each across the three policy comment periods.
These five associations are among the most powerful in the US, with a collective disclosed lobbying spend across all issues of $114,801,448 in 2024. Their high level of engagement on US vehicle emissions policy compared to their corporate members suggests that companies rely on these influential industry groups to strategically oppose climate policy on their behalf. This is reflected in their membership dues: for example, Shell, Chevron, and Exxon have disclosed that they pay between $5 million and $12.5 million per year to retain their API membership.
Of the responses examined across the three policies, oil and gas actors most frequently used affordability and energy security narratives (64%) to justify weakening the policies’ climate provisions. The most used sub-narratives within this category included those referencing the impact of critical mineral supply chains on energy security, affordability, and national security (Figure 4).
Oil and gas actors took advantage of geopolitical tensions and instability to push for weakened standards, including emphasizing China’s perceived monopoly over critical mineral supplies as a threat to US national security. For example, in September 2023, the American Fuel & Petrochemical Manufacturers (AFPM) submitted regulatory comments opposing the proposed CAFE Standards, stating that the US should not leave its economy “dependent and financially beholden to countries that control the minerals required to manufacture EV batteries.” Other examples include comments by the American Petroleum Institute (API) and the Renewable Fuels Association.
Negative impacts on US energy security and affordability from the transition to EVs were emphasized by opponents during a period of energy instability following the war in Ukraine. In June 2023, the American Petroleum Institute (API) stated in regulatory comments on the HDV Emissions Standards that mineral security and energy security are “essentially interchangeable,” emphasizing that “affordable” US critical mineral supplies are “largely inaccessible due to permitting challenges.” Additionally, the Renewable Fuels Association stated in its October 2023 comments to the CAFE Standards suggested that stringent rules may trade “our foreign oil vulnerability for a foreign critical minerals vulnerability.”
Solution Skepticism narratives were used in combination with emphasizing the climatic, environmental, and social impacts of mineral production to push for weaker emissions standards.
Oil and gas actors emphasized the climatic, social, and environmental impacts of EV value chains, while failing to acknowledge the consequences of the fossil-fuel value chain for ICE vehicles. For example, in comments to both the LDV/MDV Standards and HDV Standards, Chevron stated that the EPA should prioritize assessing the lifecycle greenhouse gas (GHG) emissions produced by mining and shipping minerals, and stressed the environmental impacts, hazards, noise, and other effects of mining of these minerals. Other groups using this narrative while advocating to weaken key provisions of the standards that promoted electric vehicles included AFPM and Chevron.
Many of the actors opposing robust vehicle emission standards who raised these concerns have themselves been accused of historical environmental and social violations and of lobbying against related policies, including regulations to reduce fossil-fuel-related air pollution. Their advocacy did not acknowledge both the negative impacts across the fossil fuel value chain and the positive environmental and social benefits of transitioning to zero-carbon transport, such as major reductions in local air pollution. As such, there is a risk that fossil fuel actors are co-opting social and environmental concerns in bad faith to weaken and delay policies designed to promote electric vehicles, as InfluenceMap research has recently identified in corporate communications related to the Just Transition.
Automotive actors opposing robust climate measures in their sector used both affordability and energy security narratives, as well as Solution Skepticism narratives, when making their case. For example, the Alliance for Automotive Innovation (the Alliance) and its five most negatively engaged automotive members (ranked by their LobbyMap ‘Performance Bands’) all used Solution Skepticism and Energy Security & Affordability narratives at least once in their advocacy (Table 3).
| Entity | Solution Skepticism | Policy Neutrality | Affordability and Energy Security |
|---|---|---|---|
| Alliance for Automotive Innovation (the Alliance) |  | | |
| BMW | | | |
| Ford Motor | | | |
| Hyundai Motor | | | |
| Stellantis | | | |
| Toyota Motor | | | |
Both light- and medium-to-heavy-duty transport actors emphasized energy security and affordability concerns surrounding mineral supply chains for EVs. For example, in June 2023, the Truck & Engine Manufacturers Association (EMA) commented on the HDV Standards, stating that the rules could alter the balance of power between nations that mine and process raw materials and those that don’t. Additionally, auto and truck makers such as BMW, Hyundai, and the Volvo Group emphasized cost concerns surrounding critical minerals in their advocacy to reduce the stringency of the standards and to support a longer-term role for ICE vehicles.
Laggard automotive actors argued that supply bottlenecks for critical minerals would limit the penetration of EVs and the achievement of emissions targets to advocate against stringent standards. For example, in comments on the LDV and MDV Standards, the Alliance commissioned a study which found that there will be a lack of mining, processing, and production capacity to supply minerals for EV battery packs, that over 300 new mines will be needed in the next decade, and that recycling will not satisfy society’s short-term demands. In its regulatory comments, BMW, an Alliance Member, echoed the association’s concerns, stating that the undersupply of minerals, combined with high costs, will not allow for price parity between ICE vehicles and EVs in time to support emissions targets.
Powerful cross-sector associations also adopted mineral-related narratives in their responses to the Standards. For example, the National Association of Manufacturers (NAM) emphasized critical mineral supply-demand disparities in comments to the CAFE Standards, and the US Chamber of Commerce stated in comments to the same Standards that critical mineral supply chains will impact US energy security, energy affordability, and national security. These narratives were employed to justify the associations’ advocacy to weaken the automotive emissions standards.
Of the entities on InfluenceMap’s database, only two, Tesla and the Zero Emissions Transport Association (ZETA), referenced critical mineral supply chains alongside supportive advocacy on the three emissions standards. Both actors are strategically engaged with climate policy and were automotive sector leaders in promoting positive and ambitious climate advocacy. In their regulatory comments, both actors addressed and countered some of the critical mineral supply chain narratives used by oppositional actors, acknowledging existing supply chain challenges while advocating for strong climate ambition.
Tesla highlighted the contradictory nature of the oil and gas sector’s emphasis on the mineral intensity of EV value chains, a Solution Skepticism narrative. In its comments on the LDV/MDV Standards, Tesla highlighted that a low-carbon economy requires lower levels of mineral extraction than a fossil-based economy, and detailed the US oil and gas industry's historic dependence on critical minerals from China. The company argued that the EPA has never found this supply chain constraint to impact fuel supply for ICE vehicles; therefore, this constraint should neither diminish the viability of EV technology nor limit deployment volumes to meet stringent emissions standards.
Zero Emissions Transport Association (ZETA) evidenced that extraction, recycling, new technologies, and policy support can meet critical mineral demand for the energy transition. In its comments on the CAFE Standards and HDV Standards, the association stated that “there is reason to believe that most critical minerals demand can be met through extraction in democratic countries.” It also highlighted battery recycling as a key component to meeting EV demand, alongside the development of alternative battery chemistries to diversify mineral demand and lower costs. It also called for a supportive policy environment, such as permitting reforms for mining, implementing best practices for battery recycling, and funding public and private sector research. As of 2026, all these policy levers have been implemented to varying degrees.
In the final text of the 2024 CAFE Standards, LDV/MDV Standards, and HDV Standards, the term ‘critical minerals’ was mentioned 58, 191, and 108 times, respectively. Each policy directly referenced critical mineral supply chains and concerns regarding national security, energy security, environmental and social impacts, and meeting the demands of the energy transition. This indicates that critical mineral supply chains are firmly on the policymaker agenda and likely shaped by corporate influence.
Both government bodies responsible for the rules (National Highway Traffic Safety administration and the Environmental Protection Agency) previously acknowledged the concerns surrounding critical mineral supply chains, but concluded that due to diversifying mineral sources and friend-shoring; strong federal incentives (including tax credits); recycling and substitution initiatives; and rapidly expanding federal and private investments, critical minerals were not expected to prevent compliance with the Standards.
Despite this, all three policies’ final provisions were weaker than their original proposals, influenced by oppositional advocacy for oil and gas and by laggard automotive actors, who often used the fossil fuel narrative playbook. The critical mineral narratives employed by these actors were part of a broader strategy to delay the energy transition.
In 2025-26, the Trump administration has adopted some of these mineral narratives, particularly those emphasizing the impact of China’s monopoly over critical mineral supply chains on US national and energy security. The President has personally overseen orders to investigate critical mineral imports that may impact national security, as well as exploration into seabed mineral resources. However, the Trump administration aims to secure the US critical mineral supply chains not for the energy transition but for defense, infrastructure, and reindustrialization.
Simultaneously, the administration has removed all GHG emissions standards for LDV, MDV, and HDV vehicles, and is moving to significantly weaken fuel efficiency (CAFE) standards in 2026. The government has already waived penalties for non-compliance with CAFE standards. In September 2025, in regulatory comments on EPA's Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, key entities such as the US Chamber, the Alliance for Automotive Innovation (the Alliance), and the American Fuel & Petrochemical Manufacturers (AFPM) used oppositional critical mineral narratives to supplement their advocacy to repeal Biden-Era US GHG Standards. The US Chamber argued that the EPA had previously disregarded the association’s concerns with the standards, including around mineral security, and that current EPA leadership should consider revoking the standards based on these concerns (among others). The Alliance argued that the present emissions standards are not appropriate, as the EPA based them on “optimistic” assessments of the supply of critical minerals, and the AFPM repeated arguments based on sovereignty, national security, and energy security related to critical minerals.
