ReMA Comments on Department of Energy’s 2026 Energy Critical Materials Assessment
On Friday, July 25, the Recycled Materials Association (ReMA) submitted comments to the Department of Energy (DOE) in response to its Request for Information (RFI) regarding the 2026 Energy Critical Materials Assessment.
To inform the implementation of its critical minerals and materials projects, DOE conducts an Energy Critical Materials Assessment. Materials are evaluated and screened based on their importance to the energy sector and supply risk. The 2023 Critical Materials Assessment considered 38 materials used in eight major technologies, of which 23 materials were ultimately evaluated for criticality.
DOE was seeking feedback on energy technologies of interest, materials of interest, supply chain information, market dynamics, challenges to domestic industry, methodology, critical minerals and materials lists, and other issues related to critical materials.
On January 20, 2025, President Trump issued Executive Order 14154, Unleashing American Energy, which in part sets a policy to establish the United States as a leading producer and processor of non-fuel minerals, including rare earth minerals. The Executive Order also directs the Secretary of Energy to ensure critical mineral projects, including the processing of critical minerals, receive consideration for Federal support, contingent on the availability of appropriated funds.
“ReMA appreciated the opportunity to respond to DOE’s RFI on the 2026 Energy Critical Materials Assessment and to underscore to senior DOE officials that the recycled materials industry is an essential supplier to the nation’s manufacturing supply chains,” said ReMA’s Chief Scientist Dr. David Wagger.
As part of the comments, ReMA suggested that recycled Energy Critical Materials (ECMs) can be used in the manufacturing process. Based on DOE’s 2023 Assessment, ECMs include cobalt, lithium, magnesium, neodymium, and nickel and come from natural resources, but recyclable ECMs may be obtained from used or obsolete products and materials from industrial and manufacturing operations and also the commercial, institutional, and residential sectors. The need for market-based movement of recycled materials in the U.S. and across borders is a critical pillar to the success of the recycled materials industry domestically and globally, and ultimately of the broader manufacturing economy.
The comments also noted that when restrictive policies and practices, such as tariffs, quotas, licensing requirements, or outright bans are enacted, they narrow the flow of free movement of recycled materials to countries and regions where they may be demanded.
“ReMA and the recycled materials industry are ready to support and participate in the establishment of strong domestic supply chains for ECMs,” Wagger said. “As manufacturers increasingly look for more materials for production, the recycled materials industry will be a key partner in securing the manufacturing supply chain.”