On 22 November 2025, the United Kingdom’s (“UK”) Government launched Vision 2035, the third iteration of its Critical Minerals Strategy since summer 2022 (the “CMS”). This publication marks a significant pivot in the UK’s approach to critical minerals, shifting the strategic emphasis from sustainability and electrification towards sovereign capability, defence security, and economic resilience. This follows a similar trend to the European Union (“EU”), Australian and United States (“U.S.”) critical minerals strategies. In this article, we examine the CMS’ key objectives, its strengths and weaknesses, and the legal implications for foreign direct investment.
The CMS articulates three core objectives: ensuring the UK has the critical minerals necessary to drive economic growth and the clean energy transition; harnessing the UK’s competitive advantage in midstream processing; and expanding the recycling of critical minerals. To meet these objectives, the Government has established specific targets for 2035, including meeting 10 percent of annual demand through domestic production and 20 percent through recycling, whilst ensuring no single country supplies more than 60 percent of annual demand.
The global race for control over mining and processing supply chains has intensified, exposing structural vulnerabilities for countries dependent on imports. The UK, like the EU and the U.S., is a net importer of critical minerals, leaving it strategically exposed to supply disruptions and geopolitical leverage. Against this backdrop, the CMS prioritises diversification and supply chain resilience, with particular emphasis on safeguarding the defence sector.
Combining an international and domestic approach
The CMS takes a pragmatic approach by acknowledging both the UK’s vulnerabilities and its competitive advantages within the global critical minerals landscape. A central pillar of the CMS is strengthening supply chain visibility and security. This involves systematically mapping dependencies, assessing exposure to geopolitical risk, and considering measures such as mandated industry-held stockpiles. It also includes ensuring that minerals essential to defence equipment are sourced from multiple jurisdictions rather than a single supplier. Together, these steps aim to reduce vulnerability to supply disruption, and extreme market volatility.
However, the CMS recognises that domestic capability alone cannot deliver full resilience. Diversification extends beyond the UK’s borders through the development of strategic growth partnerships with resource-rich countries and key technology partners. By embedding itself within trusted supply networks, the UK seeks to secure stable, long-term access to critical minerals while reducing overreliance on concentrated sources of production. Priority partners include the U.S., the EU, Canada, Australia, Saudi Arabia, India, and Japan.
At the same time, the CMS builds on clear domestic strengths. The UK possesses world-class research and development expertise in mining, materials science, and processing, supported by institutions such as the Camborne School of Mines, the University of Birmingham, and Queen’s University Belfast. London’s position as a global hub for mining finance and metals trading, anchored by the London Stock Exchange and the London Metal Exchange, provides powerful commercial leverage and access to capital. In addition, the UK maintains important midstream processing and recycling capabilities. Companies such as Johnson Matthey, the world’s largest secondary refiner of platinum group metals, demonstrate the country’s strength in high-value refining and circular economy processes. Emerging regional clusters in Cornwall, County Durham, Teesside, and South Wales further offer potential for domestic extraction and industrial revitalisation.
In addition, the UK maintains important midstream processing and recycling capabilities. Companies such as Johnson Matthey, the world’s largest secondary refiner of platinum group metals, demonstrate the country’s strength in high-value refining and circular economy processes. Emerging regional clusters in Cornwall, County Durham, Teesside, and South Wales further offer potential for domestic extraction and industrial revitalisation.
Financing and investment
The ambitious targets set out in the CMS need a solid financing framework. The strategy allocates £50 million channelled through the Department for Business and Trade to support early-stage domestic critical minerals projects. This funding is intended to operate alongside existing public financing mechanisms, including the National Wealth Fund and UK Export Finance. The UK Government contends that the National Wealth Fund has £27.8 billion in financial capacity to help deliver critical minerals projects.
However, the funding allocation raises significant concerns. The £50 million commitment appears insufficient given the scale of investment required to achieve the CMS’ objectives. Fifty million pounds are only a drop in the ocean compared to the costs of establishing a mine. Further, as grant funding, it is predominantly focused on early-stage firms rather than on scaling up midstream production, which is identified as a key strategic priority. The CMS places heavy reliance on private investment, which remains vulnerable to price volatility and the long lead times characteristic of mining projects. Notably, unlike the U.S., Canada, and the EU, the UK has reportedly no plans to introduce price support mechanisms, such as price floors.
This focus on private investment will have its own implications. Critical minerals have long been a focus of the UK’s investment screening framework under the National Security and Investment Act 2021 (“NSIA”). Activities spanning extraction, refinement, processing, production, and end-of-life recovery are currently captured within the “advanced materials” sector definition. As a result, acquisitions that cross the 25 percent, 50 percent, or 75 percent share or voting rights thresholds of UK entities carrying out such activities trigger mandatory notification requirements under the NSIA. In practice, transactions in the advanced materials sector have attracted consistent scrutiny and are among the most likely to undergo detailed review.
Meeting the CMS’ targets will require significant capital investment from both domestic and international sources. Many of these investments will fall within the NSIA’s jurisdiction and may require mandatory (or, in some cases, voluntary) notification.
Investors should therefore anticipate the potential need for clearance and, in certain circumstances, conditions attached to approval, particularly where foreign ownership or links to sensitive supply chains are involved. Although the overwhelming majority of transactions under the NSIA and comparable foreign direct investment regimes are approved without remedies, these processes can materially affect deal timing and execution.
The CMS marks a clear strategic shift in the UK’s critical minerals policy towards sovereign capability, defence resilience, and economic security, combining domestic capacity-building with international diversification and measurable production and recycling targets. While the framework is coherent and aligned with wider geopolitical trends, its success will depend on whether financing mechanisms are sufficient to crowd in the scale of private investment required in a capital-intensive and volatile sector.
