# Cobalt's Regulatory Gauntlet: How the US, EU, and Canada Are Hardwiring Supply-Chain Sovereignty Into Law

Regulatory Scan | 2026-07-20

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## Beat 1 — Scope & Key Points

**Scope:** Cobalt and co-listed critical minerals · United States, European Union, and Canada · regulatory instruments active, terminated, or proposed as of 2026-07-20, with forward monitoring triggers.

**Key Points**

- **The US §30D Clean Vehicle Credit is terminated.** The One Big Beautiful Bill Act (Pub. L. 119-21, signed 2025-07-04) ended §30D eligibility for vehicles acquired after 2025-09-30. The credit's Foreign Entity of Concern (FEOC) cobalt-sourcing restrictions retain force only for vehicles placed in service on or before that date. [IRS Final Rule 26 CFR 1.30D, Federal Register 89 FR 37706]

- **A new US supply-chain exclusion regime is now live but incompletely defined.** The Prohibited Foreign Entity (PFE) / Material Assistance Cost Ratio (MACR) framework under §45X, §45Y, and §48E — the successor to the §30D FEOC test — took effect 2025-07-04. IRS Notice 2026-15 (2026-02-12) is interim guidance only; definitive MACR safe-harbor thresholds and the full PFE definition await forthcoming Treasury regulations. [IRS Notice 2026-15 — OBBBA Pub. L. 119-21]

- **The §45X Advanced Manufacturing Production Credit remains active but now phases out for cobalt.** Cobalt (as an applicable critical mineral) earns a 10%-of-production-costs credit through 2030, then steps down to zero after 2033 under the OBBBA amendment. [IRS Notice 2023-44, 26 USC §45X]

- **The EU Battery Regulation (2023/1542) is the most structurally consequential instrument for cobalt demand.** It mandates 16% recycled cobalt content in new batteries from 2031, rising to 26% by 2036, and requires a battery passport from 2027. A 2025 amendment (Regulation (EU) 2025/1561) tightens due-diligence obligations on economic operators. [EU Official Journal L 191/1; EUR-Lex SPARQL]

- **Canada has hardened its foreign-investment screen.** The 2022 Investment Canada Act policy presumption treats state-owned-enterprise acquisitions in critical minerals — including cobalt — as presumptively injurious to national security, regardless of deal size, structure, or stage of the value chain. [Innovation, Science and Economic Development Canada, ICA Policy Statement]

- **The EU CBAM's definitive financial phase begins January 2026, and battery raw materials — including cobalt — are under active review for scope expansion.** [Official Journal of the European Union, Regulation (EU) 2023/956; CBAM Registry]

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## Beat 2 — Regulatory Context

**Governing frameworks and agencies**

The cobalt regulatory landscape across the three jurisdictions is shaped by four overlapping policy logics: supply-chain security (who may extract and process), domestic-content incentives (where value must be added), environmental and due-diligence standards (how production must occur), and trade-flow controls (what tariff or carbon cost applies at the border).

In the **United States**, the primary statutory authorities are the Inflation Reduction Act (Pub. L. 117-169) as amended by the One Big Beautiful Bill Act (Pub. L. 119-21), administered by the Internal Revenue Service and the Department of the Treasury. The USTR administers Section 301 tariff actions. The USMCA and the US-Japan Critical Minerals Agreement govern preferential-origin treatment. Congressional Research Service reports provide analytical context but are not binding instruments.

In the **European Union**, the Critical Raw Materials Act (Regulation (EU) 2024/1252) establishes the overarching supply-security framework. The EU Battery Regulation (2023/1542, as amended by 2025/1561) governs recycled-content and due-diligence obligations. The Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) applies carbon pricing at the border. The Euro 7 vehicle-emissions regulation (2024/1257) and the ecodesign regulation for chargers (2025/2052) sit at the product end of the battery value chain.

In **Canada**, the Investment Canada Act (R.S.C. 1985, c. 28) — as sharpened by the October 2022 ISED policy statement — is the primary foreign-investment screen. The Canadian Critical Minerals Strategy (December 2022) and the Critical Minerals List (34 minerals, including cobalt) set industrial-policy priorities. The Critical Minerals Exploration Tax Credit (CMETC), the Impact Assessment Act, and the Canadian Environmental Protection Act govern project development and environmental compliance. The Canada-US Joint Action Plan on Critical Minerals Collaboration (2020) frames bilateral coordination.

**Current implementation phase**

The US is in a transition between two credit regimes: the §30D framework (now terminated for prospective vehicles) and the emerging §45X/§45Y/§48E PFE/MACR framework (effective but awaiting final regulations). The EU is in the early implementation phase of both the Battery Regulation (battery passport and carbon-footprint labelling obligations begin 2027) and the CBAM (transitional reporting ended December 2025; financial obligations began January 2026). Canada's enhanced ICA screening has been operative since October 2022 and has already resulted in ordered divestitures.

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## Beat 3 — Timeline of Actions

| Date | Action | Actor / Authority | Primary Source | Affected Scope | Status / Effective |
|---|---|---|---|---|---|
| 1985-06-20 | Investment Canada Act enacted — foreign investment review framework established | Parliament of Canada | Canada Gazette | All foreign investment in Canada, including critical minerals | ACTIVE |
| 1999-03-31 | Canadian Environmental Protection Act — mining effluent provisions operative | Parliament of Canada | Canada Gazette | Mining operations, including cobalt extraction | ACTIVE |
| 2019-08-28 | Impact Assessment Act — federal environmental review requirements for major mining projects | Parliament of Canada | Canada Gazette | Major mining projects requiring federal assessment | ACTIVE |
| 2020-01-09 | Canada-US Joint Action Plan on Critical Minerals Collaboration signed | Natural Resources Canada / US Department of the Interior | Canada Gazette | Bilateral critical minerals supply-chain coordination | ACTIVE |
| 2020-07-01 | USMCA enters into force — 75% regional value content for autos; battery packs as core parts | USTR / CBP | USTR USMCA Text, CBP USMCA Implementation | North American automotive and battery supply chains | ACTIVE |
| 2021-03-11 | Canadian Critical Minerals List (34 minerals, including cobalt) published | NRCan | NRCan Canadian Critical Minerals List | Eligibility for CMETC, Infrastructure Fund, accelerated permitting | ACTIVE |
| 2022-04-07 | Critical Minerals Exploration Tax Credit (CMETC) — 30% credit for flow-through share exploration expenditures | Canada Revenue Agency | canada.ca | Cobalt and other listed critical mineral exploration | ACTIVE |
| 2022-07-01 | Clean Fuel Regulations — battery recycling requirements operative | Environment and Climate Change Canada | Canada Gazette | Fuel suppliers and battery recyclers | ACTIVE |
| 2022-10-28 | ICA Critical Minerals National Security Review — enhanced SOE screening policy issued; presumption of injury for state-owned-enterprise acquisitions in critical minerals | ISED | Innovation, Science and Economic Development Canada, ICA Policy Statement | Foreign SOE and government-linked investment in Canadian critical minerals at all value-chain stages | ACTIVE |
| 2022-12-09 | Canadian Critical Minerals Strategy published — 5 pillars, 3.8B in federal commitments, cobalt named priority mineral | NRCan | NRCan Canadian Critical Minerals Strategy, December 2022 | Federal funding, infrastructure, and R&D programs for cobalt and co-listed minerals | ACTIVE |
| 2023-01-01 | IRA §30D Clean Vehicle Credit operative — critical minerals and battery component content thresholds begin phasing in | IRS / US Treasury | IRS Final Rule 26 CFR 1.30D, Federal Register 89 FR 37706 | New clean vehicles; cobalt as applicable critical mineral | **TERMINATED** (for vehicles acquired after 2025-09-30, per OBBBA Pub. L. 119-21) |
| 2023-01-01 | IRA §45X Advanced Manufacturing Production Credit operative — 10% of production costs for cobalt and co-listed critical minerals | IRS / US Treasury | IRS Notice 2023-44, 26 USC §45X | US domestic producers of cobalt and battery components | ACTIVE |
| 2023-03-28 | US-Japan Critical Minerals Agreement signed — Japan granted FTA-country status for §30D critical-mineral content purposes | USTR | USTR press release + agreement text, March 28 2023 | Japanese-processed cobalt, lithium, nickel, manganese, graphite for §30D credit | ACTIVE (note: host §30D credit terminated for prospective vehicles; agreement's forward relevance to successor credits not established in the data) |
| 2023-10-01 | EU CBAM transitional period begins — quarterly embedded-emissions reporting required, no financial obligation | European Commission | Official Journal of the European Union, Regulation (EU) 2023/956 | Importers of cement, steel, aluminum, fertilizers, electricity, hydrogen into EU | ACTIVE |
| 2024-01-01 | FEOC Battery Component Exclusion operative — vehicles with FEOC-manufactured battery components ineligible for §30D component credit | IRS / US Treasury | US Treasury FEOC Final Rule, 89 FR 37706 | EV battery component supply chains; cobalt-containing cathode materials | **HISTORICAL** (§30D terminated; exclusion retains force only for vehicles placed in service on or before 2025-09-30) |
| 2024-02-18 | EU Battery Regulation 2023/1542 enters into force — recycled cobalt content mandates (16% by 2031, 26% by 2036), battery passport from 2027, carbon footprint labelling from 2027 | European Parliament / Council | EU Official Journal L 191/1 | All batteries placed on EU market; cobalt as named recycled-content mineral |ACTIVE |
| 2024-05-06 | 26 CFR 1.30D-6 FEOC Final Rule published — three-step FEOC-compliance determination, impracticable-to-trace transition rule for commingled minerals (available through 2026-12-31) | IRS / US Treasury | US Treasury / IRS final rule 26 CFR 1.30D-6, Federal Register May 6 2024 | Qualified manufacturers determining cobalt FEOC-compliance in battery supply chains | **HISTORICAL** (operative only for vehicles placed in service on or before 2025-09-30) |
| 2024-09-27 | Section 301 tariffs on Chinese battery materials and components — 25% on lithium-ion EV and non-EV batteries, battery parts, with graphite and permanent magnets phasing in 2025-2026 | USTR | USTR Section 301 Four-Year Review, Federal Register 89 FR 46306 | Chinese-origin battery materials, components, and cobalt-containing products | ACTIVE |
| 2025-01-01 | FEOC Critical Minerals Exclusion operative — vehicles with FEOC-extracted, -processed, or -recycled cobalt ineligible for §30D minerals credit | IRS / US Treasury | US Treasury FEOC Final Rule, 89 FR 37706 | Cobalt and co-listed critical minerals in EV battery supply chains | **HISTORICAL** (§30D terminated; exclusion retains force only for vehicles placed in service on or before 2025-09-30) |
| 2025-07-04 | §45X/§45Y/§48E Prohibited Foreign Entity (PFE) / Material Assistance Cost Ratio (MACR) regime effective — taxpayer-level bar on Specified Foreign Entities and Foreign-Influenced Entities; supply-chain MACR test for material assistance from PFEs | IRS / US Treasury (OBBBA Pub. L. 119-21) | IRS Notice 2026-15 — OBBBA Pub. L. 119-21 | US advanced-manufacturing, clean-electricity, and energy-storage credits; cobalt supply chains | ACTIVE (interim guidance only; final regulations pending) |
| 2026-01-01 | EU CBAM definitive period begins — importers must surrender CBAM certificates equal to embedded emissions, priced at EU ETS weekly average | European Commission | Official Journal of the European Union, Regulation (EU) 2023/956 | Importers of in-scope goods; battery raw materials under review for future scope expansion | ACTIVE |
| 2026-06-23 | Notice of Receipt of Complaint; Solicitation of Comments Relating to the Public Interest — US Federal Register | US Federal Register | US Federal Register | Scope not specified in the record | ACTIVE |

### Instruments in scope without a dated action in our data

The following instruments are confirmed in-force or proposed but their effective dates are not present in the source records. They are listed here with their adoption context noted in prose only where that information appears in the instrument title.

- **Regulation (EU) 2024/1252 — Critical Raw Materials Act** (adopted 11 April 2024 per title): establishes the EU framework for securing and diversifying supply of critical raw materials, including cobalt. Status: IN_FORCE. [EUR-Lex SPARQL]
- **Regulation (EU) 2024/1257 — Euro 7 vehicle-emissions and battery-durability regulation** (adopted 24 April 2024 per title): sets emissions and battery-durability type-approval requirements for motor vehicles. Status: IN_FORCE. [EUR-Lex SPARQL]
- **Regulation (EU) 2025/1561 — Battery Regulation due-diligence amendment** (adopted 18 July 2025 per title): amends Regulation (EU) 2023/1542 to tighten obligations on economic operators concerning battery due-diligence policies, directly affecting cobalt supply-chain transparency requirements. Status: IN_FORCE. [EUR-Lex SPARQL]
- **Commission Regulation (EU) 2025/2052 — Ecodesign requirements for chargers and portable batteries** (adopted 13 October 2025 per title): lays down ecodesign requirements for external power supplies, wireless chargers, and battery chargers for portable batteries of general use. Status: IN_FORCE. [EUR-Lex SPARQL]
- **CBAM Scope Expansion Review — Potential Addition of Battery Raw Materials**: proposed review of whether cobalt and other battery raw materials should be added to CBAM's covered goods list. Status: PROPOSED. The record cites Article 30(2) of Regulation (EU) 2023/956, which requires the Commission to report on the possibility of extending scope before the end of the transitional period. No adoption date is present in the record. [CBAM Registry]
- **Congressional Research Service reports** (five published analytical reports on battery supply chains, critical minerals policy, domestic permitting, and the Defense Production Act): these are published reference documents, not binding instruments. No effective dates are recorded. [CRS Reports]

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## Beat 4 — Substance Summary per Action

**EU Battery Regulation 2023/1542 (as amended by 2025/1561)**
The regulation is the most operationally specific cobalt instrument in the dataset. It mandates that batteries placed on the EU market contain a minimum share of recycled cobalt — 16% from 2031, rising to 26% from 2036 — and requires documentation of the percentage of cobalt recovered from waste. From 2027, each EV battery, LMT battery, and industrial battery above 2 kWh must carry an electronic battery passport recording provenance and carbon-footprint data. The 2025 amendment (Regulation (EU) 2025/1561) strengthens due-diligence obligations on economic operators across the battery supply chain, directly implicating cobalt sourcing practices. [EU Official Journal L 191/1; EUR-Lex SPARQL] [Confidence: MEDIUM — regulation text and OJ citation are present verbatim in the records; the 2025 amendment's specific operational provisions are not detailed in the source record beyond the due-diligence scope.]

**IRA §45X Advanced Manufacturing Production Credit (as amended by OBBBA)**
Section 45X provides a production tax credit equal to 10% of costs incurred in producing cobalt (as an applicable critical mineral) domestically and selling it to an unrelated party. Under the original IRA, this credit was permanent for critical minerals; the OBBBA amendment introduced a phase-out: 100% through 2030, stepping down to zero after 2033. A separate, steeper phase-out applies to battery cells and modules (zero after 2032). The credit is available only for production in the United States and sale to unrelated parties. [IRS Notice 2023-44, 26 USC §45X] [Confidence: MEDIUM — credit rates, phase-out schedule, and mineral definitions are present verbatim in the record.]

**§45X/§45Y/§48E Prohibited Foreign Entity (PFE) / MACR Regime**
The OBBBA (Pub. L. 119-21) introduced a two-pronged successor to the §30D FEOC test. First, a taxpayer-level bar: a Specified Foreign Entity or Foreign-Influenced Entity — defined by reference to 26 U.S.C. § 7701(a)(51) — cannot claim the §45X, §45Y, or §48E credit at all, effective for tax years beginning after 2025-07-04. Second, a supply-chain test: the Material Assistance Cost Ratio (MACR) disallows credits where a qualified facility or eligible component receives material assistance from a Prohibited Foreign Entity; for critical minerals including cobalt, this test phases in from 2030 (the record states 0% threshold through 2029). IRS Notice 2026-15 (2026-02-12) is interim guidance that largely restates the statute and defers definitive MACR safe-harbor thresholds and the full PFE definition to forthcoming regulations. [IRS Notice 2026-15 — OBBBA Pub. L. 119-21] [Confidence: MEDIUM — the interim guidance is confirmed published, but the definitive regulatory parameters (MACR thresholds, PFE definition) are explicitly deferred and not present in the source record.]

**ICA Critical Minerals National Security Review (Canada)**
The October 2022 ISED policy statement established a presumption that investments by foreign state-owned enterprises — or private investors closely tied to or subject to direction from foreign governments — in Canadian critical minerals sectors will be found injurious to national security. This presumption applies regardless of deal value, whether the investment is direct or indirect, controlling or non-controlling, and across all stages of the value chain including extraction, processing, and recycling. The record notes that following this policy, the government ordered divestiture of three Chinese-backed investments in Canadian lithium and rare earth companies. [Innovation, Science and Economic Development Canada, ICA Policy Statement] [Confidence: MEDIUM — policy text is quoted verbatim in the record; the named divestiture orders are cited in the scope text of the same record.]

**EU CBAM — Carbon Border Adjustment Mechanism**
The CBAM's definitive financial phase began January 2026: importers of in-scope goods must now surrender CBAM certificates equal to the embedded emissions of their imports, priced at the EU Emissions Trading System weekly average. The transitional period (October 2023 through December 2025) required only quarterly reporting of embedded emissions with no financial obligation. Battery raw materials, including cobalt, are not currently in scope but are under active review: Article 30(2) of Regulation (EU) 2023/956 requires the Commission to report on the possibility of extending scope to other goods at risk of carbon leakage before the end of the transitional period. [Official Journal of the European Union, Regulation (EU) 2023/956; CBAM Registry] [Confidence: MEDIUM — article text and phase dates are present verbatim in the records.]

**US Section 301 Tariffs on Chinese Battery Materials**
Following the USTR's four-year review, Section 301 tariffs on Chinese-origin battery supply-chain goods were updated effective 2024-09-27. Lithium-ion EV and non-EV batteries (HS 8507.60) and battery parts (HS 8507.90) are subject to 25% tariffs; natural graphite (HS 2504) and permanent magnets (HS 8505.11) phase in at 25% from 2025 and 2026 respectively. The record notes these build on existing 7.5–25% tariffs from 2018–2019 rounds. The record does not specify a cobalt-specific HS code or rate; cobalt-containing materials are described as "under review." [USTR Section 301 Four-Year Review, Federal Register 89 FR 46306] [Confidence: MEDIUM — rates and HS codes are present in the record; the cobalt-specific rate is explicitly absent, which is noted as a gap.]

**IRA §30D FEOC Restrictions (Historical)**
The §30D(d)(7) FEOC exclusions — barring the battery-component credit for vehicles with FEOC-manufactured components (from 2024) and the critical-minerals credit for vehicles with FEOC-extracted, -processed, or -recycled cobalt (from 2025) — are now historical instruments. The §30D credit was terminated by OBBBA (Pub. L. 119-21 §70502) for vehicles acquired after 2025-09-30. These exclusions retain legal force only for vehicles placed in service on or before that date. The FEOC concept — covering entities owned by, controlled by, or subject to the direction of the governments of China, Russia, North Korea, or Iran, including entities with 25% or more board seats, voting rights, or equity interest held by those governments or their agents — has been carried forward and broadened into the PFE/MACR regime. [US Treasury FEOC Final Rule, 89 FR 37706; US Treasury Final Rule, Federal Register 89 FR 37706] [Confidence: MEDIUM — termination authority, effective date, and FEOC definition are present verbatim in the records.]

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## Beat 5 — Monitoring: What to Watch

**1. Treasury / IRS Final PFE Regulations (US — highest near-term priority)**
IRS Notice 2026-15 explicitly defers the definitive Prohibited Foreign Entity definition and the MACR safe-harbor threshold tables to forthcoming Treasury regulations. Until those regulations are published, cobalt producers and battery manufacturers claiming §45X credits cannot determine with certainty whether their supply chains clear the material-assistance test. **Trigger:** publication of proposed or final Treasury regulations defining MACR thresholds for critical minerals. **Direction:** tighter thresholds would exclude more Chinese-processed cobalt from §45X-eligible supply chains; looser thresholds would preserve more existing sourcing arrangements. **Fires into:** §45X credit eligibility for all US cobalt producers and battery manufacturers. [IRS Notice 2026-15 — OBBBA Pub. L. 119-21]

**2. EU Battery Regulation — 2027 Battery Passport and Carbon-Footprint Labelling Obligations**
From 18 February 2027, each EV battery, LMT battery, and industrial battery above 2 kWh placed on the EU market must carry an electronic battery passport and bear a carbon-footprint performance-class label. **Trigger:** 2027-02-18. **Direction:** non-compliant batteries — including those with undocumented cobalt provenance — will be barred from the EU market. **Fires into:** market access for all battery producers selling into the EU; cobalt supply-chain traceability infrastructure requirements. [EU Official Journal L 191/1]

**3. EU Battery Regulation — 2031 Recycled Cobalt Content Mandate**
From 18 August 2031, batteries must be accompanied by documentation confirming that 16% of cobalt content is recovered from waste, rising to 26% by 2036. **Trigger:** 2031-08-18 (first threshold); 2036 (second threshold — the record does not specify the exact date for the 2036 step). **Direction:** insufficient secondary cobalt supply or traceability infrastructure would create compliance risk and potential market-access barriers. **Fires into:** demand for recycled cobalt, battery recycling infrastructure investment, and secondary-market pricing. [EU Official Journal L 191/1]

**4. CBAM Scope Expansion — Battery Raw Materials Review**
Article 30(2) of Regulation (EU) 2023/956 requires the Commission to report on the possibility of extending CBAM scope to other goods at risk of carbon leakage before the end of the transitional period. Battery raw materials including cobalt are explicitly identified in the record as under review. **Trigger:** Commission report and any subsequent legislative proposal. **Direction:** inclusion of cobalt or cobalt compounds in CBAM scope would impose a carbon-certificate cost on EU cobalt imports, affecting sourcing economics from high-emissions jurisdictions. **Fires into:** import cost structures for EU battery manufacturers; competitive position of lower-carbon cobalt sources. [CBAM Registry; Official Journal of the European Union, Regulation (EU) 2023/956]

**5. §45X Critical Minerals Phase-Out — 2031 Step-Down**
The OBBBA amended §45X to phase out the critical-minerals credit beginning in 2031: 75% (7.5% of costs) in 2031, 50% (5%) in 2032, 25% (2.5%) in 2033, zero after 2033. **Trigger:** 2031-01-01 (first step-down). **Direction:** declining credit value reduces the economics of US domestic cobalt processing; any legislative reversal or extension would alter investment calculus. **Fires into:** US cobalt refining and processing investment decisions; domestic supply-chain buildout timelines. [IRS Notice 2023-44, 26 USC §45X]

**6. Canadian ICA Screening — Ongoing SOE Investment Decisions**
The October 2022 ISED policy presumption against SOE investment in Canadian critical minerals is operative and has already produced divestiture orders. **Trigger:** any announced foreign SOE or government-linked acquisition, joint venture, or greenfield investment in Canadian cobalt assets. **Direction:** the presumption of injury applies regardless of deal size or structure; the threshold for approval is described as "exceptional basis" only. **Fires into:** foreign direct investment flows into Canadian cobalt mining and processing; bilateral investment treaty considerations not addressed in the data. [Innovation, Science and Economic Development Canada, ICA Policy Statement]

**Freshness + half-life:** This scan reflects records current as of 2026-07-20. The PFE/MACR regulatory docket and the CBAM scope-expansion review are the fastest-moving elements; a re-pull within 90 days is warranted for both.

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## Data Limitations & Confidence

- **PFE/MACR regime (MEDIUM confidence):** The §45X/§45Y/§48E Prohibited Foreign Entity framework is the most consequential forward-looking US instrument in this scan, and it is the least defined. IRS Notice 2026-15 is interim guidance; the definitive MACR thresholds, the full PFE entity definition, and safe-harbor mechanics are explicitly deferred to forthcoming regulations not yet in the dataset. This is the primary confidence gap.

- **EU instruments without effective dates:** Four EUR-Lex instruments (the Critical Raw Materials Act, Euro 7, the 2025 Battery Regulation due-diligence amendment, and the 2025 ecodesign regulation) are confirmed in-force but their effective dates are absent from the source records. Their operational phase-in schedules and implementing acts are not available in the dataset.

- **Cobalt-specific Section 301 tariff rate:** The USTR Section 301 record does not specify a cobalt-specific HS code or tariff rate; cobalt-containing materials are described as "under review." This is a stated gap — no rate has been inferred.

- **US-Japan Critical Minerals Agreement forward applicability:** The agreement granted Japan FTA-country status for §30D purposes. With §30D terminated for prospective vehicles, the agreement's applicability to successor credits (§45X, §45Y, §48E) is not addressed in any record in the dataset.

- **CRS Reports:** Five Congressional Research Service reports are in scope as published analytical documents. They provide contextual framing but are not binding instruments and carry no operative provisions. Their specific analytical conclusions are not reproduced here because the source records do not contain their text.

- **2026-06-23 Federal Register notice:** The record for the Notice of Receipt of Complaint (US Federal Register, 2026-06-23) does not specify the subject matter, complainant, or affected scope. No substantive claims have been drawn from it.

- **What would raise confidence:** Publication of final Treasury PFE/MACR regulations; effective-date fields for the four EU instruments; a USTR determination on cobalt-specific Section 301 rates; and Commission publication of the CBAM scope-expansion report required under Article 30(2).

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## Methodology

This scan is a single-pass synthesis over the 35 regulation records provided in the source packet, after exclusion of 12 off-topic records (6 aviation safety, 5 free-trade-zone site notices, 1 Superfund remediation) identified in the dataset's own rollup. All counts are derived from the rollup figures or from the enumerated lists in this document. Every substantive claim is anchored to a named source record. No external knowledge, world-knowledge background, or facts not present in the source packet have been introduced.

*This report is intelligence, not legal advice. Readers should obtain qualified legal counsel before acting on any regulatory interpretation contained herein.*

## Figures

**Regulatory landscape — timeline of dated actions**
| Date | Jurisdiction | Action type | Regulation name |
| --- | --- | --- | --- |
| 1985-06-20 | Canada | ENACTED | Investment Canada Act — Critical Minerals Foreign Investment Screening |
| 1999-03-31 | Canada | ENACTED | Canadian Environmental Protection Act — Mining Effluent Provisions |
| 2019-08-28 | Canada | ENACTED | Impact Assessment Act — Mining Project Requirements |
| 2020-01-09 | Canada | ENACTED | Canada-United States Joint Action Plan on Critical Minerals Collaboration |
| 2020-07-01 | United States | ENACTED | USMCA — United States-Mexico-Canada Agreement |
| 2021-03-11 | Canada | ENACTED | Canadian Critical Minerals List (34 Minerals) |
| 2022-04-07 | Canada | ENACTED | Canadian Critical Minerals Exploration Tax Credit (CMETC) |
| 2022-07-01 | Canada | ENACTED | Clean Fuel Regulations — Battery Recycling Requirements |
| 2022-10-28 | Canada | ENACTED | Investment Canada Act — Critical Minerals National Security Review |
| 2022-12-09 | Canada | ENACTED | Canada Critical Minerals Strategy 2022 |
| 2022-12-09 | Canada | ENACTED | Canadian Critical Minerals Strategy |
| 2023-01-01 | United States | ENACTED (current status: TERMINATED) | IRA Section 30D — Clean Vehicle Tax Credit |

*Showing 12 of 24 rows — full data in the PDF/DOCX export.*

*Source: LodeIQ computed rollup over 35 packet records (21 sources: NRCan Canadian Critical Minerals Strategy, December 2022; Canada Gazette; canada.ca; +18 more). Computed deterministically by LodeIQ from the report's source packet · Source tier: T3*

**Regulatory landscape — jurisdiction**
| Name | Share |
| --- | --- |
| United States | 48.6 |
| Canada | 28.6 |
| EU | 11.4 |
| European Union | 8.6 |
| United States + Japan | 2.9 |

*Source: LodeIQ computed rollup over 35 packet records (21 sources: NRCan Canadian Critical Minerals Strategy, December 2022; Canada Gazette; canada.ca; +18 more). Computed deterministically by LodeIQ from the report's source packet · Source tier: T3*

**Regulatory landscape — status**
| Name | Share |
| --- | --- |
| ACTIVE | 54.3 |
| PUBLISHED | 17.1 |
| IN_FORCE | 11.4 |
| HISTORICAL | 8.6 |
| TERMINATED | 5.7 |
| PROPOSED | 2.9 |

*Source: LodeIQ computed rollup over 35 packet records (21 sources: NRCan Canadian Critical Minerals Strategy, December 2022; Canada Gazette; canada.ca; +18 more). Computed deterministically by LodeIQ from the report's source packet · Source tier: T3*