


Canada released its first Defence Industrial Strategy (the Strategy), which outlines Canada’s commitment to develop a strong defence industrial base and, thereby, boost economic growth. Central to this effort will be securing a reliable supply chain of defence-related critical minerals, which will necessitate a whole-of-government approach to supporting critical mineral development. In this bulletin, we examine the details of this pillar, building on our previous coverage of the Strategy’s core elements.
Pillar IV of the Strategy acknowledges that a robust domestic defence sector depends on complex supply chains, including a reliable supply of critical minerals. In order to strengthen such domestic supply chains, the Strategy lays out the following priorities:
According to the Strategy, by the second quarter of 2026, the Canadian Government will publish its plan to expand production, processing, stockpiling, and procurement of defence-related critical minerals, while supporting coordinated action with various allies, including through the G7 Critical Minerals Production Alliance and NATO. The Strategy does make note that of the 12 “defence-critical raw materials” identified by NATO, Canada produces 10, namely, aluminum, gallium, germanium, graphite, and tungsten.
The Strategy states that the Canadian Government is committed to helping steel and aluminum producers “pivot and retool” to manufacture the grades and products required by Canada’s defence sector. This aligns with the Canadian Government’s Policy on Prioritizing Canadian Materials in Federal Procurements announced in December 2025, which mandates the use of Canadian steel, aluminum, and wood products in federal defence procurements valued at $25 million or more.
The inclusion of the critical minerals supply chain as part of the Strategy is further evidence of the commitment by all levels of government in Canada to supporting domestic critical mineral development. These initiatives include the following:
In recent months, we’ve also seen a number of critical mineral investments by public investment vehicles, such as Canada Growth Fund’s investment of up to US$85 million in the Thompson Nickel Complex in Manitoba and a C$156 million investment in Foran Mining for the construction of the McIlvenna Bay copper-zinc mine in Saskatchewan.
The creation of the Major Projects Office (MPO) in August 2025 is also part of the Canadian Government’s wider strategy to encourage the development of particular projects that are in Canada’s national interest. To date, five critical mineral projects have been referred to the MPO for further consideration (Foran Mining’s McIlvenna Bay Copper project in Saskatchewan, Newmont & Imperial Metals’ Red Chris mine expansion in BC, Canada, Nickel’s Crawford project in Ontario, Nouveau Monde Graphite’s Matawinie project in Québec, and Northcliff Resources’ Sisson project in New Brunswick). However, none have yet been designated a project of national interest.
In the coming months, we anticipate that the Government of Canada will release additional guidance and follow-up measures, including legislation establishing the DIA as a standalone entity, reforms to the Industrial and Technological Benefits (ITB) Policy to ensure procurements benefit Canada’s defence industrial base, and a framework for identifying and onboarding Canadian strategic industry partners, among others. Defence sector participants, mining companies, and investors should closely monitor these developments as Canada intensifies its focus on sovereign capability and its defence industrial base, especially as it relates to expanding production, stockpiling, and processing of defence-critical minerals.
In the coming weeks, the Torys Defence team will release additional analysis detailing the Strategy’s impact across multiple sectors, including procurement, mining, infrastructure, and life sciences, with additional considerations for investors and other stakeholders.
To discuss these issues, please contact the author(s).
This publication is a general discussion of certain legal and related developments and should not be relied upon as legal advice. If you require legal advice, we would be pleased to discuss the issues in this publication with you, in the context of your particular circumstances.
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