The federal government is moving to keep recoverable critical minerals within the United States, which is worth paying attention to because it represents a rapid pivot from an environmental nice-to-have to a national security imperative. A Presidential Determination signed July 30, 2026, under the Defense Production Ac…
Header Image Alt-Text: Comstock Metals - Solar Panels and the New Federal Push to Keep Critical Minerals in America
The federal government is moving to keep recoverable critical minerals within the United States, which is worth paying attention to because it represents a rapid pivot from an environmental nice-to-have to a national security imperative. A Presidential Determination signed July 30, 2026, under the Defense Production Act allows the Department of Commerce to require that recovered critical minerals be sold to U.S. buyers, beginning with battery black mass and tungsten scrap. Because solar panels contain several of the same critical minerals, recycling them is a likely candidate for future phases of this policy.
On July 30, 2026, the federal government made a formal determination under the Defense Production Act. They found that certain recoverable critical minerals are scarce and essential to national defense. In turn, this finding gave the Department of Commerce the authority to restrict how these materials are sold and to enforce a domestic process without exporting them overseas.
The first two materials affected are battery black mass and tungsten scrap. Starting August 27, 2026, companies selling either must sell 100 percent of it to U.S. buyers unless they obtain a license from the Bureau of Industry and Security. Exporting is not banned outright, but it is evident now that it is no longer the default option. Government officials have also said this list of critical materials could expand over time.
The federal government’s determination follows an earlier federal investigation into the extent of America's reliance on imported critical minerals, particularly from China. Over the past year, China has restricted exports of several of these same materials, contributing to rising prices domestically.
These actions form a clear pattern. The federal government first assessed the nation's dependence on foreign sources and is now moving to ensure that recoverable materials already within U.S. borders remain there. Both measures look to strengthen the domestic supply of critical minerals, and this effort is likely to expand.
This isn’t something new. It's a version of what's been called urban mining. Instead of digging new minerals out of the ground, you recover them from products already in this country: an end-of-life solar farm, a retired battery, a scrapped tool. That's the basic premise of a circular economy: value stays in circulation instead of ending up buried.
A typical solar panel contains aluminum, copper, silicon, lead, and silver, with some panels also containing tin, zinc, gallium, indium, and tellurium. A typical solar panel contains aluminum, copper, silicon, and silver, with some panels also containing gallium, indium, and tellurium. Every one of these materials appears on the government's official list of critical minerals, the same list underlying these new restrictions. Given this overlap, materials recovered from solar panels are a logical candidate for inclusion in future phases of this domestic push.
Silver recovery, in particular, is worth watching closely. Silver was one of the highest-profile additions to the government's 2025 critical minerals list, and it's present in nearly every crystalline-silicon solar panel. A domestic recycler with real critical mineral recovery capability, one that can reliably pull silver, gallium, indium, and tellurium out of a retired panel at scale (not just strip the aluminum frame), is positioned exactly where this policy is heading.
This chart illustrates the overlap: of the ten materials commonly found in solar panels discussed above, nine currently appear on the government's critical minerals checklist below. Lead was added in the same 2025 update as silver and isn't yet reflected in this graphic.
Mineral
New to the List in 2025
Found in a Solar Panel
Aluminum
,
Yes
Antimony
,
,
Arsenic
,
,
Barite
,
,
Beryllium
,
,
Bismuth
,
,
Boron
Yes
,
Cerium
,
,
Cesium
,
,
Chromium
,
,
Cobalt
,
,
Copper
Yes
Yes
Dysprosium
,
,
Erbium
,
,
Europium
,
,
Fluorspar
,
,
Gadolinium
,
,
Gallium
,
Yes
Germanium
,
,
Graphite
,
,
Hafnium
,
,
Holmium
,
,
Indium
,
Yes
Iridium
,
,
Lanthanum
,
,
Lead
Yes
Yes
Lithium
,
,
Lutetium
,
,
Magnesium
,
,
Manganese
,
,
Metallurgical Coal
Yes
,
Neodymium
,
,
Nickel
,
,
Niobium
,
,
Palladium
,
,
Phosphate
Yes
,
Platinum
,
,
Potash
Yes
,
Praseodymium
,
,
Rhenium
Yes
,
Rhodium
,
,
Rubidium
,
,
Ruthenium
,
,
Samarium
,
,
Scandium
,
,
Silicon
Yes
Yes
Silver
Yes
Yes
Tantalum
,
,
Tellurium
,
Yes
Terbium
,
,
Thulium
,
,
Tin
,
Yes
Titanium
,
,
Tungsten
,
,
Uranium
Yes
,
Vanadium
,
,
Ytterbium
,
,
Yttrium
,
,
Zinc
,
Yes
Zirconium
,
,
This direction in federal policy reflects a standard we have already adopted. At Comstock Metals, we recover critical minerals from solar panels domestically, including silver recovery at scale. We are zero-landfill, and none of the materials we process are exported internationally. Our facilities in Nevada, California, and Ohio keep these materials within the domestic supply chain from the moment a panel arrives until its materials are ready for reuse. Federal policy has moved steadily in this direction over the past two years, and solar recovery stands out as a natural next step, which is why we see ourselves not as one option among many, but as the primary domestic solution for operators who need to get ahead of it.
Here at Comstock Metals, our process is not only efficient but also built to meet emerging federal policy standards.
The federal government has decided that recoverable critical minerals belong in the domestic supply chain, and it now has the authority under the Defense Production Act to enforce that. Battery black mass and tungsten scrap are first, but officials have made it clear that the list can grow, and materials inside a solar panel, including silver, are already on the government's critical minerals list. Companies handling end-of-life panels should plan ahead, rather than waiting to be directed. If you are looking for a recycling partner whose materials already stay in the United States, Comstock Metals was built to do exactly that.
The landscape of American energy is shifting from extraction to reclamation. As federal mandates tighten and the value of domestic minerals rises, your decommissioning strategy will define your project's long-term ROI and compliance profile, whether you're a developer, an asset manager, an EPC firm, or an investor evaluating a portfolio's ESG exposure.
Don't wait for a regulatory audit to figure out your recycling plan. Partner with Comstock Metals to secure your domestic supply chain and ensure compliance with new federal mineral mandates.
The President signed a determination under Section 101 of the Defense Production Act, finding that recoverable critical minerals and materials are scarce and essential to the national defense. The determination delegates authority to the Secretary of Commerce to secure the domestic supply of those materials.
Battery black mass and tungsten scrap are the first two materials covered, beginning August 27, 2026. Companies selling either must sell 100 percent of it to U.S. buyers unless they obtain a case-by-case exception from the Bureau of Industry and Security.
No. Exporting is still possible with an exception from the Bureau of Industry and Security, but it is no longer the default option. The default is now a domestic sale.
Not yet, but they are looming. Solar panel materials aren't on the initial list, but the overlap is too significant to ignore: aluminum, copper, silicon, lead, silver, tin, zinc, gallium, indium, and tellurium are all already on the government's critical minerals list, making solar recovery a logical candidate for the next phase. Waiting for an official mandate is a risk in itself; the more strategic move for anyone handling end-of-life panels is building a domestic-only recovery process before it's required, not after.
Comstock Metals recovers critical minerals from solar panels domestically, is zero-landfill, and exports none of the materials it processes. Its facilities in Silver Springs, Nevada; Hanford, California; and Cambridge, Ohio, keep recovered materials within the U.S. supply chain.
The White House, “Presidential Determination Pursuant to Section 101 of the Defense Production Act of 1950, as Amended, on Recoverable Critical Minerals and Materials,” July 30, 2026
The White House, “Fact Sheet: President Donald J. Trump Delegates Defense Production Act Authority with Respect to Recoverable Critical Minerals and Materials That Are Essential to Our National Defense,” July 30, 2026
Forbes, Noel Fletcher, “US To Restrict Foreign Exports Of Recycled Critical Minerals,” July 30, 2026