The Trump administration has announced plans to ban the export of lithium-ion battery waste and tungsten waste from the United States, as part of a broader effort to reduce American dependence on Chinese processing capacity for critical minerals. The move was reported in early August 2026. Lithium-ion battery waste and tungsten scrap are both feedstocks for the production of critical minerals used in defence manufacturing, electric vehicles, and energy storage. By restricting their export, the administration aims to retain these materials within domestic supply chains rather than shipping them to China, which currently dominates the global processing and refining of many critical minerals. The measure has international trade law dimensions. Export restrictions of this kind must be consistent with obligations under the World Trade Organization (WTO) framework, and unilateral export bans on raw materials have previously been challenged at the WTO by trading partners. The EU and other allies of the United States who also depend on access to scrap feedstocks may raise concerns, even if the primary target of the restriction is Chinese processing dominance. For London practitioners, the measure is relevant because it forms part of a broader pattern of trade decoupling between the US and China that affects cross-border supply chain contracts, foreign direct investment (FDI) screening, and sanctions compliance work. English law governs a significant proportion of international commodity supply contracts, meaning disputes arising from disrupted material flows may be litigated or arbitrated in London.
Why this matters
Critical minerals supply chain policy has become one of the most active areas of international economic law, combining trade restrictions, export controls, FDI screening, and sanctions compliance into a single compliance challenge for global businesses. The US export ban on battery and tungsten waste adds another restriction to an already complex landscape, and the precedent it sets may encourage the EU and other jurisdictions to introduce reciprocal measures. For law firms with international trade and sanctions practices, this type of measure generates a continuous stream of advisory mandates as clients seek to restructure supply contracts and assess compliance exposure.
On the Ground
The legal work created spans international trade, sanctions compliance, and commercial contracts. Firms advising mining companies, battery manufacturers, or defence contractors need to assess how the new export restrictions affect existing supply agreements and whether force majeure or material adverse change clauses are triggered. A trainee on international trade advisory work would assist by preparing sanctions screening memos, drafting choice-of-law summaries for affected contracts, and coordinating local counsel instruction letters where supply chain restructuring requires legal analysis in multiple jurisdictions.
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