The Expanding Universe of Criticality
Criticality is a rapidly moving frontier. Market infrastructure needs to catch up.
A decade ago, the metalloid antimony was a footnote. Brittle, silvery and unglamorous, used in flame retardants, lead-acid batteries and ammunition primers, it attracted the attention of almost nobody beyond a small circle of specialist traders. Then, in August 2024, China placed its export under licence, and in December 2024 banned shipments to the United States outright. A footnote became a front page. Defence planners were reminded how heavily their munitions supply chains leaned on a single jurisdiction. The price roughly trebled over the year, closing 2024 near $40,000 a tonne, the sharpest rally recorded since price tracking began in 1980. Governments scrambled.
The geology of antimony had not changed. What changed was everything around it. And that is the argument of this piece: critical is not a property of a mineral. It is a property of the relationship between technological advancement and geology. That relationship moves in only one direction, and the market infrastructure it depends on has not moved with it.
A list that only grows
Look at the official lists. The United States Geological Survey identified 35 critical minerals in 2018. By 2022 the list had grown to 50. In November 2025 it reached 60, and the ten new entrants tell their own story. Alongside the exotic sit boron, phosphate, potash, silicon, silver, uranium and, most strikingly, copper. The least exotic metal imaginable, worked by humans for ten thousand years and present in almost every building on earth, is now formally designated critical by the world's largest economy.
The European Union tells the same story. Its Critical Raw Materials list has been revised five times since 2011: 14 materials, then 20, then 27, then 30, then 34. Five assessments, and a larger list every time. Individual materials occasionally move off as methods and markets shift, but the aggregate has never once contracted. Copper appears here too, added not because it is rare but because projected demand from electrification, declining ore grades and lengthening permitting timelines have made ubiquity of demand its own form of scarcity.
Why does the ratchet turn only one way? Because two clocks are running at different speeds. A new mine takes sixteen to eighteen years on average to move from discovery to first production, and that number is lengthening rather than shortening; a copper mine in the United States now averages nearly twenty-nine years. A technology product cycle turns in years, not decades. Every turn of the fast clock conscripts new materials; the slow clock cannot keep pace. The gap between the two clocks is the structural scarcity thesis, and every list revision widens it.
Signals, patterns, trends
The pattern I am describing is established by nearly a century of history. Every technology wave drafts its own cohort of materials into strategic service. Electrification drafted copper. The jet age drafted titanium and nickel and cobalt superalloys. The digital age drafted silicon, tantalum and indium. Electric vehicles and renewables drafted lithium, cobalt and neodymium, and turned quiet corners of the periodic table into instruments of national power.
The signals are present tense. Rearmament and advanced semiconductors are conscripting gallium, germanium and antimony, each now subject to export controls. Grid build-out is straining copper decades ahead of the supply response. Data centres are forcing forecasters to tear up demand assumptions written five years ago.
The trend is the forward projection. Quantum technologies, fusion and next-generation semiconductors will draft cohorts of their own. Some candidates we can already name: laboratory grown diamond for thermal management and quantum sensing, isotopically engineered silicon, the ultra-wide bandgap materials enabling chips to run hotter, faster, smaller and use less energy wasted as heat. Others we cannot yet see. You cannot predict which mineral is next. Watch the signals in export controls and defence procurement; expect the pattern to form around each new technology wave; and act on the only certainty the trend offers: there will always be a next mineral, even if nobody can yet name it.
The scarcity is infrastructural, not geological
The uncomfortable truth beneath the lists is that most of the materials on them are not geologically scarce. Gallium is a by-product of aluminium refining, germanium of zinc smelting. The earth's crust holds ample supplies of nearly everything the lists name. What is scarce is everything around the material. Refining capacity concentrated in a single jurisdiction. Transparent prices. Provenance architecture. Investable access.
This should sound familiar. It is the missing tier again, this time at the level of an entire asset category: an ever-expanding roster of critical materials, and no adequate expansion in the market architecture beneath them. And the gap applies as much to the minerals already on the lists as to those still to join them. Three building blocks are missing, and all three have been built before, because the diamond industry spent the last two decades constructing exactly this machinery. The sequence matters.
First, formalise the informal
Supply chains begin with people, not benchmarks. A meaningful share of critical mineral supply sits outside formal channels, most visibly in the Democratic Republic of the Congo, where some two hundred thousand artisanal miners dig for cobalt and copper and their share of output swings with the price cycle: undocumented, unbanked, invisible to compliance regimes and therefore locked out of legitimate markets. Diamonds faced precisely this problem, and during my time with De Beers we built GemFair to address it, bringing artisanal and small-scale miners into formal, ethical channels with digital tools, transparent pricing and a route to market. The lesson transfers directly. Formalisation is simultaneously a development agenda, a supply security agenda and an ESG agenda, and it cannot be delivered by producers or consumers acting alone. It requires a neutral convenor with commercial credibility on both sides of the trade.
Second, provenance and standards
Formalised supply then needs verifiable identity. Few industries can match the diamond industry's prior art here. I was privileged to lead the build out of Tracr, one of the first examples of a digital trust platform in the natural resources sector, that traces diamonds from source at industrial scale, recognised three times on the Forbes Blockchain 50 list of the world's leading blockchain innovations. If traceability can be made to work for millions of individually unique stones, it can be made to work for cobalt, lithium and artisanal gold. Nor does transformation break the analogy: diamonds are traded in blended parcels as often as single stones and are themselves physically transformed from raw state to polished state, so diamond traceability has already had to survive aggregation and transformation. Minerals that are smelted and chemically processed will lean more heavily on mass balance and digital product passports, but the problem is one the diamond industry has already confronted. And there is a sharper point beneath the engineering: standards are instruments of market power. Who writes the rulebook wins, and the jurisdiction that convenes the standard captures the market that forms around it. The critical minerals rulebook is fragmented: standards exist in pieces, but nothing joins them up, and nobody has yet convened the whole. Diamonds have written such a rulebook before. The Kimberley Process, convened in 2003 across governments, industry and civil society, showed what a global certification regime can achieve: near-universal coverage of the rough diamond trade built from a standing start. Any critical minerals equivalent should carry forward the best of it and design out the worst.
Third, price discovery
Verified provenance is what makes transparent pricing possible, which is why this block comes last: each enables the next. Outside the exchange-traded majors, most critical minerals trade on opaque bilateral contracts and thin reference prices. Without benchmarks, futures struggle to form; without futures, hedging is bespoke and expensive; without cheap hedging, institutional capital demands a premium or stays away. Diamonds were once the same, and De Beers' auction sales business pioneered change to that back in January 2008, introducing online spot auctions and forward contracts for physical rough diamonds. It was a genuine breakthrough in spot and forward price discovery for a famously opaque material, later recognised with a Ruban d'Honneur at the 2014 European Business Awards, and helped catalyse a wider shift towards greater price discovery and transparency across the producing world. If price discovery can be engineered for the most idiosyncratic commodity on earth, it can certainly be engineered for materials that lend themselves more readily to standardisation.
Who builds the tier?
So who builds these blocks? The instinctive answer is the producer countries themselves, and they are not waiting to be asked. Across the producing world, governments are moving to capture more of the value at origin: beneficiation requirements, restrictions on the export of raw material, national marketing companies and plans for domestic exchanges. The virtues of these efforts are real. They assert sovereignty over finite resources, they retain value and employment where the geology sits, and they carry a political legitimacy at the mine face that no offshore construct can match. But the challenges are structural. A single-origin platform concentrates precisely the risk that investors seek to diversify; a state with a direct interest in the price will struggle to persuade buyers of its benchmark's neutrality; and parallel national initiatives fragment liquidity at exactly the point where liquidity most needs to pool.
The neutral hub answers a different part of the problem, and this is where Dubai's claim becomes hard to answer. The DMCC has built market architecture as a matter of institutional habit in diamonds, in gold, in tea and coffee, sitting deliberately between producing nations and consuming markets and earning the trust of both. What the hub offers is what origin platforms find hardest to build alone: aggregation across sources, distance from the price, and the depth of capital, regulation and market infrastructure that credible benchmarks require.
But it’s key to understand that this is not a contest. The infrastructure that matters runs from origin to market, and no single jurisdiction owns that corridor. The realistic path is partnership: origin-to-market infrastructure built jointly, with formalisation and provenance anchored where material comes out of the ground, and pricing, custody and investment products anchored where capital and regulation run deepest. The alternative, separate efforts built in isolation on the assumption that they will somehow knit together later, would simply reproduce the fragmentation that has kept so much of this category beyond direct institutional reach. The formula proven in diamonds, formalise, then verify, then price, is jurisdiction-agnostic; what it needs is jurisdictions willing to run it together.
What makes the investment rational under conditions of uncertainty is the compounding logic. The infrastructure is mineral-agnostic. Partners that build the permanent tier once, the formalisation programmes, the provenance rails, the benchmarks and the custody, capture every future entrant to the criticality universe, whatever it turns out to be.
The mineral that is not on the list yet
Which mineral joins the lists next? The honest answer is that nobody knows with certainty. If criticality were predictable, the right response would be a portfolio of mineral bets. Because it is not, the right response is infrastructure: the permanent market architecture that serves whatever the relationship between technology and geology conscripts next. The lists will keep growing. At every revision to date, they have done nothing else. The question is whether the market infrastructure finally grows with them, and who owns it when it does.