Updating Australia’s Critical Minerals List: issues paper

QRC Submission
Updating Australia’s Critical Minerals List
17 August 2023

ABN 59 050 486 952
Level 13 133 Mary St Brisbane Queensland 4000
T 07 3295 9560 F 07 3295 9570 E info@qrc.org.au
www.qrc.org.au
Introduction
The Queensland Resources Council (QRC) welcomes the recent release of the Australian Critical
Minerals Strategy and one of the key underlying action as part of the strategy, to establish a
process to update Australia’s Critical Minerals List. As such, this submission deals with the
questions set out in the Critical Minerals List issues paper only.

QRC is the peak representative organisation of the Queensland minerals and energy sector.
QRC’s membership encompasses minerals and energy exploration, production, and processing
companies, and associated service companies. QRC works on behalf of members to ensure
Queensland’s resources are developed profitably and competitively, in a socially and
environmentally sustainable way.

Given that the strategy sets out a broad policy direction, QRC agrees with the government
approach to decouple the strategy from the list, the latter of which will need to be more
responsive to geopolitical considerations. It is important the list is able to be updated in response
to global events and strategic, technological and policy changes.

The strategy has affirmed Australia’s definition of critical minerals as ‘metallic or non-metallic
materials that are essential to our modern technologies, economies and national security, and
whose supply chains are vulnerable to disruption’. Given the critical minerals listed may benefit
from project facilitation and increased investment, it is vital that the criteria is clear to allow
alignment, where possible between State and Federal strategies and policy decisions.

QRC acknowledges that mineral criticality is not static but will likely change over time. As such,
we are pleased to see the government will establish a process to update the Critical Minerals List
and notes this should be driven by market demands and evolving critical mineral supply chain
risks. The Australian Government could also consider working with state jurisdictions to ensure
that approaches to critical minerals and their assignation remain consistent and/or
complementary.

Page | 2 – Updating Australia’s Critical Mineral List – QRC Submission
Responses
1. Is the current set of criteria still fit for purpose? The Critical Minerals List currently includes
minerals:
• essential to modern technologies, economies and national security
• whose supply chains are vulnerable to disruption
• that our strategic partners need; and
• for which Australia has potential economic geological resources

QRC understands the Australian Critical Minerals List is an important policy tool differentiating
geopolitical significance in meeting the world’s net-zero and security ambitions. The existing
criteria focuses on more immediate supply chain vulnerabilities but should also consider the risk of
supply disruption over the medium and longer term. Some minerals, for example copper, which
may not currently be vulnerable to supply chain disruption, are instead at risk of supply disruption
in the future, particularly given the long lead times to bring a new mine to production in the existing
regulatory environment and the capital-intensive nature of investment in the commodity. Copper
supply shortages would bring huge disruption to Australia’s decarbonisation ambitions.

Recent geopolitical events have exposed the vulnerabilities in commodity supply chains and
made the need for more resilient supply chains more urgent. The geographic concentration of
processing and refining of critical minerals has become an increasingly important issue and the
criteria should acknowledge the risk to supply chains in not just extraction but also downstream
processing and manufacturing of some critical minerals, such as rare earth elements. The linkages
between mineral extraction, early-stage processing and manufacturing are strategically
important for Australia and our trading partners, all of whom have acknowledged the importance
in having access to reliable global supply chains.

Beyond the needs of strategic partners, the criteria should also consider the impact of Australia’s
partners policy and legislative tools. The Inflation Reduction Act in the USA and increasing green
incentives out of the European Union will present opportunities for Australia to partner with other
countries to develop and maintain reliable supply chains. This could be better reflected in the
criteria.

2. For minerals that are currently on the list, or minerals that should be considered for
addition to or removal from the list:
a. Which technologies does the mineral feed?
b. What evidence is there of supply chain disruption relating to those minerals?
c. What market, financing, technical or other barriers affect these supply chains?
d. Are the barriers or supply chain disruption risks more acute in certain applications
or levels of mineral grade or purity than others?

Australia is endowed with a number of minerals, not currently included in the Critical Minerals List,
which will play an increasingly significant role in the future as global efforts to decarbonise
intensify, technological advancements continue, and national security remains a priority. These
minerals are vulnerable to supply shocks. In correspondence to Minister King on 20 June 2023, QRC
outlined the need for government to consider adding the following minerals to the Critical
Minerals List.
- Aluminium, alumina and bauxite: Aluminium is one of the most widely used commodities
in the global energy transition; it is widely used in solar panels wind turbines and will be
critical to the transmission infrastructure required for increased electrification across

Page | 3 – Updating Australia’s Critical Mineral List – QRC Submission
Australia. Bauxite is the primary ore of alumina, mostly smelted to make aluminium.

- Copper: Copper is at the centre of decarbonation build-out with the electrification of a
range of traditionally fuelled based processes and products. The projected copper
demand to enable this transition is enormous yet with little proven and probable new
copper resources due to come to fruition to meet the demand. Significant focus will need
to be applied to copper supply through new resources and secondary processing in
Australia.

- Nickel: The element forms a crucial component in some of the leading battery
compositions, meaning demand will continue to grow in the coming decades. In addition,
nickel plays a huge part in the circular economy because the ore can be repurposed
again and again without losing its quality, meaning the nickel recycling industry can
complement primary production1.

- Potash and phosphate: Both potash and phosphate are critical for continued agricultural
productivity and contribute to food security. Potash is a crucial fertiliser for agricultural
production but Australia’s potash industry is still emerging, with the first commercial
production only achieved in 20212. A significant increase in production will be required to
meet domestic needs. Potash and phosphate play a vital role in food security. QRC
supports the inclusion of potash and phosphate on the Australian Critical Minerals List to
reduce Australia’s reliance on imports for the supply of fertiliser. This will assist with
mitigating future supply chain risks to regional food security. QRC understands the
Queensland Farmer’s Federation wrote to Minister King on 10 July 2023 seeking the
inclusion of potash and phosphate to reduce the agriculture industries reliance on fertiliser
imports.

- Silica: increasing photovoltaic capacity is driving an increase in demand for high purity
silica sand (HPSS) to make the highly transparent glass in solar PV modules. Australia has
significant reserves of HPSS which can be developed for the export market but can also
be used to secure local supply chains to manufacture ethically sourced solar panels.

- Zinc: protecting steel against corrosion is the most important market for zinc, representing
60% of the mineral’s use worldwide3. Zinc is also used in brass and bronze, as well as the
die-casting industry. Zinc oxide is a key component of solar cells.

In support of this proposal, between some of Australia’s closest trading partners - the USA, Canada,
Europe and Japan – aluminium, bauxite, nickel, copper and/or zinc have all been identified as
critical minerals based on strategic development priorities 4. Last year the European Union also
listed metallurgical coal as a critical mineral given its economic and strategic importance to the
region.

1 Proactive Australia, Nickel and zinc have joined the critical minerals list – here’s why they’re important, 12
Jan 2022
2 Geoscience Australia https://www.ga.gov.au/news-events/news/latest-news/australia-records-boost-in-

critical-mineral-resources
3 Proactive Australia, Nickel and zinc have joined the critical minerals list – here’s why they’re important, 12

Jan 2022
4 Yina Su, Dewen Hu, Global Dynamics and Reflections on Critical Minerals, 2022

Page | 4 – Updating Australia’s Critical Mineral List – QRC Submission
3. Should Australia differentiate between criticality or importance of minerals, and the
capability to process them, through categories within the list or a separate category that
sits alongside the list? This differentiation could reflect the size and maturity of markets
and the different challenges or barriers faced.

It should be made clear why the mineral is listed on the list, rather than separate lists which may
become confusing and unnecessary. Being clear for the reasons it is listed as critical should be
sufficient and signal to investors and the broader industry community on its importance and
eligibility for various types of government support.

4. What lessons could be learned from other countries’ approaches or the ways in which
they consider their criteria for listing critical minerals?

Adding value to our critical minerals is a key component of strengthening our supply chains and
harnessing Australia’s full potential opportunity. Adding value to bulk commodities can be a
different and well-trodden model, however how this translates to successful value-add for small
volume, high value commodities is more difficult. A more collaborative approach between
industry and government and within the industry will be important, therefore learnings from other
jurisdictions that relate to the facilitation of greater collaboration should be a focus.

Conclusion
Thank you for the opportunity to provide feedback on updating Australia’s Critical Mineral
List. The role of critical minerals in the quality of Australian’s everyday life is constant and is
set to grow. It is important we set clear goals and ambitions to exploit our critical mineral
resources and have strong policies that can drive the industry to complete on a global
scale.

Any further engagement can be directed to QRC Assistance Policy Director, Anna Wright,
at Annaw@qrc.org.au

Page | 5 – Updating Australia’s Critical Mineral List – QRC Submission