Critical minerals, geopolitics and sovereignty: Brazil's institutional challenge

The acceleration of the energy transition and the digitalization of economies have elevated lithium, copper, graphite, rare earth elements and other minerals to the center of contemporary geopolitical disputes, pressing Latin America — and Brazil in particular — to formulate a critical minerals policy commensurate with its geological endowment. This paper presents an integrative and comparative review of the academic literature and main regulatory frameworks on the subject, arguing that criticality is not an intrinsic property of a mineral but a contingent relation among economic and technological importance, supply risk, substitutability, circularity and the vulnerability of the system under analysis. This relational framing carries a direct implication for producing countries: uncritically adopting lists formulated by consuming economies means incorporating a hierarchy of priorities calibrated for those on the other side of the supply chain, not for those who hold the resources. To substantiate this argument, the paper compares the criticality assessment architectures of the United States — 60 minerals on the 2025 list —, the European Union — 34 critical raw materials and 17 strategic raw materials under the 2024 Critical Raw Materials Act —, China and Australia — 31 minerals, as updated in 2024 —, showing that quantitative, qualitative and hybrid models coexist and are, in every case, technically led by the respective national geological surveys. The resulting analytical framework is applied to the Brazilian case, with a critical examination of Bill 1754/2026, which proposes a production-sharing regime and the conversion of the Geological Survey of Brazil into a mining company, and of Bill 2780/2024, approved by the Chamber of Deputies, which establishes the National Policy on Critical and Strategic Minerals (PNMCE). Both bills reproduce the conceptual conflation of critical and strategic minerals, establish no verifiable methodology for criticality assessment, and exhibit distinct institutional weaknesses: the former subordinates state geological intelligence to extractive operations; the latter institutionalises financialisation mechanisms — streaming contracts and unrestricted access to the National Climate Fund — that undermine long-term mineral sovereignty. The paper concludes that the central challenge for Brazil and Latin America is to translate geological endowment into industrial, technological and institutional capacity, avoiding a new round of subordinated re-primarisation and preserving the geological survey as the locus of state intelligence over mineral resources.