Brazil Sets 27-Mineral Critical List With Three-Tier Priority for State Incentives

Inside Brazil's New 27-Mineral Priority List

Brazil's federal government has taken a concrete step in its push to turn the country's mineral wealth into an industrial policy tool. At the first meeting of the National Council for Industrialization of Critical and Strategic Minerals (CIMCE) on Thursday, November 5, the government approved a list of 27 minerals classified as "critical and strategic" and sorted them into three priority tiers. The meeting at the Palácio do Planalto was attended by President Luiz Inácio Lula da Silva and chaired with input from Casa Civil Minister Miriam Belchior.

The classification rests on criteria set out in the National Policy for Critical and Strategic Minerals, signed into law in September. The government drew on existing lists from the Ministry of Mines and Energy, the Ministry of Development, Industry, Trade and Services, and the national development bank BNDES, as well as classifications used by other countries. "Critical" minerals are those essential to key sectors whose insufficient, unstable or vulnerable supply could threaten production, employment, the energy transition and national security. "Strategic" minerals are those with significant reserves in Brazil that contribute to the economy, industrial and technological development, regional growth and emissions reduction.

Five parameters determine which tier a mineral lands in: geopolitical risk, concentration of global supply, substitutability, Brazil's position in the production chain, and the country's degree of dependency and vulnerability. The highest priority goes to minerals where geopolitical risk, supply concentration and dependency are high, while substitutability and Brazil's chain position are low. The top tier contains nine minerals: rare earths, graphite, lithium, nickel, cobalt, copper, manganese, silicon and uranium. These will receive maximum priority for public financing instruments and will be subject to screening of ownership changes and sales contracts.

The intermediate tier includes eight minerals — tungsten, chromium, vanadium, tantalum, titanium, phosphate, potassium and sulphur — which face the same two screening mechanisms but lower priority for development funding. The low-priority tier covers ten minerals: niobium, tin, iron, zinc, gold, magnesium, molybdenum, thorium, aluminium and the platinum group. These face only ownership-change screening and have the least access to state incentives. Belchior said the list is initial and may be revised to include other substances, and signaled that Brazil welcomes foreign investment provided it brings security, predictability and a commitment to adding value inside the country.

What the Three-Tier System Means for Miners and Foreign Investors

Why the Tier System Matters More Than the List Itself

The 27-mineral list is broad enough to cover most of Brazil's mining output, so the real policy signal lies in the tier assignments. By placing rare earths, lithium, nickel, cobalt and copper in the top tier, the government is effectively telling markets where it will concentrate scarce public financing and where it will apply the most scrutiny to foreign deals. The screening of ownership changes and sales contracts in the top two tiers gives the state a de facto veto or delay mechanism over transactions involving those minerals — a significant shift for a sector that has historically operated with relatively light state involvement.

What the Criteria Reveal About Brazil's Strategic Logic

The five parameters — geopolitical risk, supply concentration, substitutability, chain position and dependency — mirror the frameworks used by the EU, US and Japan, but with a distinctly Brazilian twist. The inclusion of uranium and rare earths in the top tier reflects both global supply anxiety and Brazil's own ambitions in nuclear and advanced manufacturing. Meanwhile, niobium and iron ore, where Brazil is already a dominant global supplier, sit in the lowest tier. That is a deliberate choice: the government appears to be prioritizing minerals where Brazil is a price-taker and wants to move up the value chain, rather than those where it already has market power.

The Foreign Investment Balancing Act

Belchior's statement that Brazil is "open to foreign investment" but with "security, predictability and a commitment to adding value in Brazil" is a carefully calibrated message. On one hand, Brazil lacks the capital and processing technology to develop rare earth and lithium chains alone. On the other, the screening mechanisms give the state leverage to demand local processing, joint-venture structures or technology transfer. For foreign investors — particularly Chinese, European and North American firms active in critical minerals — the framework introduces both opportunity and uncertainty. The opportunity is preferential access to state financing and a clear government partner. The uncertainty is that deal terms may be subject to political review, and the list itself can be revised.

Where This Leaves Brazilian Mining Companies

Established players like Vale and smaller juniors focused on lithium, rare earths and nickel stand to benefit from prioritized financing and streamlined licensing if the policy is implemented effectively. But the ownership-screening requirement could complicate M&A exits for junior explorers, which often rely on selling to larger foreign buyers. The policy also creates a two-speed market: top-tier projects may attract sovereign and state-backed capital, while low-tier minerals like gold and iron ore remain largely driven by private market dynamics. For context, Brazil's rare earth reserves are estimated to be among the world's largest, but commercial production remains minimal — a gap the policy aims to close.

Short and Medium-Term Outlook

In the short term (0–6 months), expect the government to issue implementing regulations defining exactly how the screening of ownership changes and sales contracts will work, and which financing instruments will be prioritized. Mining companies with top-tier assets should prepare for more detailed disclosure requirements in any M&A process. In the medium term (6–24 months), the first test cases will reveal whether the policy accelerates projects or creates bottlenecks. If screening is slow or politicized, it could deter the very foreign capital Brazil needs. If it is predictable and paired with real financing, it could unlock significant investment in lithium, rare earths and nickel processing.

What Mining Executives and Investors Should Watch Next

The most important insight: Brazil's critical minerals policy is now operational, and the tier system will determine which projects get state money and which foreign deals face political review.

For mining executives, investors and dealmakers exposed to Brazil, the immediate priority is understanding where their assets or targets sit in the three-tier classification. Top-tier minerals — rare earths, graphite, lithium, nickel, cobalt, copper, manganese, silicon and uranium — will face the most state involvement, both in support and in screening.

• Map your portfolio against the tiers now. If you hold or are targeting top-tier assets, assume that any change of control or sales contract will be reviewed. Build regulatory and political risk into deal timelines and valuations.
• Engage with CIMCE and the relevant ministries early. The implementing rules for screening and financing are not yet published. Companies that participate in the consultation process can shape how the mechanisms work in practice.
• For foreign investors: Belchior's "value-added in Brazil" condition is a clear signal that processing and refining capacity will be a key negotiation point. Joint ventures or local processing commitments may improve the odds of approval.
• Watch for the next CIMCE meeting and implementing decrees. The list is explicitly revisable, and the operational details of the screening and financing mechanisms will be defined in the coming months.
• Monitor BNDES and MME financing announcements. The first disbursements under the prioritized framework will indicate which projects and companies the government actually intends to back.