As fertilizer costs continue to squeeze farm margins, a broad coalition of agriculture trade associations, commodity groups, and industry stakeholders is calling on the Biden administration to designate phosphate and other key fertilizer inputs as "critical minerals."

In formal comments submitted to the U.S. Geological Survey (USGS) as part of its public consultation on the 2025 Critical Minerals List, ag stakeholders welcomed the proposed re-inclusion of potash, but expressed concern over the exclusion of phosphates, a decision they argue could deepen U.S. agriculture's vulnerability to foreign market shocks and supply chain disruptions.

"With input prices continuing to remain high, Nebraska Corn is exploring any avenue that can help return profitability to corn growers," stated a joint comment by the Nebraska Corn Board and Nebraska Corn Growers Association.

The Department of the Interior had initially considered adding phosphates to the 2025 list, but dropped the material from the draft following a review of domestic supply. That omission has drawn criticism from across the ag industry.

A joint submission from 12 national ag organizations - including the American Farm Bureau Federation, American Soybean Association, and USA Rice - warned that skipping phosphate was a serious misstep:

"Supply chain volatility has been a driving force in the skyrocketing cost of producing our nation's food, feed and fuel."

These groups argue that designating phosphates as a critical mineral would promote loterm supply stability and provide policy support for domestic production and investment.

The Critical Minerals List informs federal permitting and investment decisions. Potash was included in the 2018 list, removed in 2022, and is now proposed for reinstatement in 2025. Phosphates have never been included, despite playing a vital role in the nitrogen-phosphorous-potassium (NPK) fertilizer blend.

Bayer U.S. emphasized that phosphate is also a key input in glyphosate, one of the most widely used herbicides in American agriculture. Recent disruptions from Hurricane Ida underscored the fragility of this supply chain, Bayer noted, warning that continued reliance on foreign sources could leave U.S. farmers vulnerable to supply shocks and price manipulation.

"It is easy to anticipate a situation where a significant break in glyphosate supply could leave U.S. farmers dependent on China," said Michael Holland, Bayer's director of government affairs.

The push is gaining traction in Congress, with more than 60 bipartisan lawmakers recently urging Interior Secretary Doug Burgum to revise the draft list and include phosphate. They pointed to China's frequent export restrictions on products like DAP, MAP, and phosphoric acid, which have driven up global prices.

Ag leaders argue that USGS' supply chain disruption models overlook the vulnerability of finished phosphate products, focusing instead on the availability of raw phosphate rock. The Agricultural Retailers Association recommended that phosphate rock, phosphoric acid, DAP, and MAP all be added to the list, and called for updated modeling to account for export bans and plantiseason shocks.

Rio Tinto, the world's largest mining firm, also weighed in, urging inclusion of borates-another important fertilizer micronutrient-highlighting that the U.S. is a net importer despite having reserves in California.

On the same day these comments were submitted, USDA Secretary Brooke Rollins announced a new initiative to shield farmers from extreme price swings across fertilizers, seeds, energy, and equipment. Rollins cited "undue foreign influence" as a key reason for a 37% rise in fertilizer prices over the last four years.

The outcome of the USGS review could significantly impact the future cost structure and input security of U.S. agriculture, especially as producers prepare for the 2025 planting season amid ongoing global instability.