Evidence Review: Trade Barriers and Opportunities for Critical Minerals Supply Chain Integration

Living Document - First Version Updated: December 2025 Disclaimer: This document is a draft, intended to support collaboration and preliminary feedback from the Department of Foreign Affairs and Trade. It is not intended for wide distribution and may contain errors.

Executive Summary

Key Messages

• Behind-the-border barriers dominate critical minerals trade: Standards fragmentation, administrative frictions, and regulatory divergence create greater impediments than tariffs for Australia-Southeast Asia supply chain integration.
• Current FTAs contain no minerals-specific constraints on export restrictions: Resource nationalism policies like Indonesia's nickel ban remain unconstrained despite battery supply chain significance. While some agreements (e.g., CPTPP) discipline export duties generally, country-specific carve-outs (e.g., Vietnam) preserve policy space.
• Standards divergence enables ESG arbitrage in minerals processing: Environmental variations between Australian mining and Southeast Asian processing risk carbon leakage without mutual recognition frameworks.
• Multiple instruments available beyond comprehensive FTA renegotiation: Administrative improvements, MRAs, and investment facilitation can address critical minerals trade barriers faster.
• Barrier patterns extend beyond critical minerals: Agriculture and green economy sectors face analogous standards fragmentation and administrative frictions.

Purpose and Approach

This evidence review examines trade barriers and FTA modernisation opportunities for critical minerals supply chains in Southeast Asia, serving as an evolving background paper for stakeholder consultations planned for October-November 2025. The analysis adopts a "pathfinder sector" approach: critical minerals supply chains provide the analytical anchor while also exploring whether identified barriers, opportunities, and solutions in that context extend to agriculture, green economy, and other priority sectors for Australia.

Three Priority Findings

1. Behind-the-border barriers exceed tariff barriers in practical significance - Standards fragmentation, administrative frictions (permitting delays, customs documentation), and regulatory divergence create greater impediments to trade and investment than tariffs, which are largely eliminated across major markets. Industry consultations will validate the relative significance of different barrier categories.

2. Export restrictions and processing mandates remain largely unaddressed by current FTAs - Indonesia's nickel export ban (January 2020) illustrates the gap: current Australia-Southeast Asia FTAs contain no minerals-specific constraints on resource nationalism policies or processing mandates, despite AANZFTA, RCEP, and IA-CEPA coverage. While CPTPP includes disciplines on export duties (Annex 2-C), countries negotiated carve-outs preserving policy space (e.g., Vietnam retained certain export duties on raw minerals). Partner countries retain substantial sovereign discretion over export restrictions for industrial development objectives.

3. Standards divergence enables regulatory arbitrage and creates ESG risks - Environmental, social, and governance (ESG) standard variations between Australian mining operations and Southeast Asian processing facilities create potential for "carbon leakage" where production shifts to lower-standard jurisdictions. No current FTA establishes mutual recognition frameworks for environmental assessments or minimum sustainability floors.

Priority Hypotheses for Consultation

1. Are standards fragmentation and administrative "red tape" as significant in practice as desk evidence suggests, or do other barriers dominate commercial decision-making?
2. Would mutual recognition agreements for environmental assessments reduce regulatory duplication and compliance costs while maintaining environmental protection levels?
3. Which instrumental options (FTA upgrades, quick fixes, investment agreements, cooperation mechanisms) are politically acceptable to Southeast Asian partners given development objectives and sovereignty concerns?
4. Do agriculture and green economy stakeholders recognise similar barrier patterns to those identified for critical minerals, validating cross-sectoral approaches?

Evidence Limitations

Desk research establishes baseline regulatory frameworks, FTA provisions, and processing infrastructure but cannot assess practical significance, compliance costs, or cross-sectoral validation without industry stakeholder input (October-November 2025 consultations).

Next Steps

October-November 2025 consultations with Australian industry, Southeast Asian partners, and Australian Government departments will validate preliminary findings, test hypotheses, and inform Technical Paper development with specific model provisions (January 2026). Consultation outcomes feed directly into Consultation Summary (December 2025) and Final Report (February 2026) with implementation roadmap to 2040.

1. Introduction and Analytical Scope

This evidence review documents preliminary findings on trade barriers, processing opportunities, and potential Free Trade Agreement (FTA) modernisation pathways for critical minerals supply chains in Southeast Asia. As a living document, this first version will be updated monthly as consultation findings and additional evidence emerge.

Purpose and Deliverable Context

The evidence review serves as an authoritative background paper examining options for FTA modernisation to strengthen critical mineral supply chains for the Indo-Pacific green economy transition. It integrates within a structured project deliverable framework alongside consultation summaries and technical recommendations. This document performs three distinct functions:

1. It establishes baseline documentation of current FTA architecture, documented trade barriers, regional processing landscape, sustainability dimensions, and available policy instruments. This baseline provides the factual foundation for stakeholder discussions by documenting what publicly available sources reveal about regulatory frameworks, market access conditions, and processing constraints across Southeast Asian partner countries.

2. The review explores whether patterns identified through critical minerals analysis extend to other priority sectors including agriculture and green economy. This cross-sectoral pattern identification addresses whether barriers, opportunities, and potential solutions discovered through the minerals "pathfinder" have broader applicability beyond a single commodity sector.

3. The document explicitly frames questions for industry stakeholder engagement scheduled for October-November 2025, identifying evidence gaps that only industry practitioners and government officials can address through consultations. These gaps include practical significance of documented barriers, magnitude and frequency of regulatory frictions, effectiveness of policy instruments in practice, and cross-sectoral validation of preliminary patterns.

This deliverable integrates into a structured project timeline where findings feed directly into the Consultation Summary (December 2025) synthesizing stakeholder input and the Technical Paper with Specific Recommendations (January 2026) translating evidence and consultation outcomes into actionable policy options. The evidence review provides the analytical foundation, consultations validate and refine findings, and the Technical Paper delivers targeted recommendations informed by both evidence and consultation streams.

Analytical Scope and Approach

Taking into account consultations with the Australian Department of Foreign Affairs and Trade on 4 September 2025, this evidence review adopts a "pathfinder sector" approach. Critical minerals supply chains serve as the analytical anchor while exploring whether identified barriers, opportunities, and solutions extend to agriculture, green economy, and other priority sectors. Five priority themes shape the analysis: (1) industry needs identification through targeted consultations, (2) standards and behind-the-border barriers as potential quick wins, (3) cross-sectoral pattern identification for broader applicability, (4) instrumental flexibility considering the full spectrum of policy options beyond comprehensive FTA renegotiation, and (5) practical liberalisation focus on specific regulatory frictions given already relatively liberal frameworks for goods, services, and investment.^[1]

The pathfinder approach allocates analytical effort across three tiers:^[2]

• Core critical minerals examination: Investigates trade barriers, processing constraints, standards fragmentation, and ESG requirements for lithium, nickel, rare earths, and cobalt supply chains.
• Adjacent trade dependencies: Identifies cross-sectoral patterns in infrastructure, services, technology transfer, and investment frameworks.
• Identifying applications to broader sectors: Develops frameworks for extending findings to agriculture, manufacturing, and green economy contexts where evidence suggests analogous barriers or opportunities.

Geographic scope encompasses Australia's five Southeast Asian FTA partners where critical minerals trade and processing are most strategically significant. Indonesia supplies substantial nickel crucial for electric vehicle batteries and has implemented export restrictions to spur domestic processing capacity.^[3] The Philippines holds the world's fifth-largest nickel deposits valued at substantial but largely untapped resources.^[4] Malaysia contributes advanced processing expertise through facilities including rare earth processing operations and participates in regional manufacturing networks. Thailand positions itself as a regional hub for electric vehicle production and battery manufacturing, offering advanced manufacturing capabilities and supply chain connectivity.^[5] Vietnam builds downstream manufacturing capacity in batteries and electronics, requiring stable critical mineral imports to support its emerging industries.^[6] Together, these countries represent both supply (Indonesian and Philippine nickel resources, Malaysian processing) and demand (Thai and Vietnamese manufacturing) dimensions of regional critical minerals value chains.

Analysis examines seven key trade agreements governing these relationships: AANZFTA (multilateral framework with 10 ASEAN members including all five focus countries), RCEP (mega-regional agreement including Australia, Southeast Asian partners, and major regional economies), CPTPP (high-standard plurilateral including Vietnam and Malaysia), IA-CEPA (bilateral with Indonesia specifically addressing mining and processing sectors), SAFTA (bilateral with Singapore), MAFTA (bilateral with Malaysia), and TAFTA (bilateral with Thailand).

Evidence Base and Limitations

This first version synthesizes publicly available documentary sources across five categories. First, FTA legal texts provide the authoritative baseline for understanding tariff commitments, rules of origin, investment protections, services liberalisation, and institutional mechanisms across the seven agreements under examination. Second, official government policy documents establish regulatory frameworks, development strategies, and policy announcements from both Australian and Southeast Asian partner governments regarding critical minerals, trade, and economic cooperation. Third, academic and policy literature offers analytical perspectives on critical minerals trade, supply chain dynamics, sustainability challenges, and trade policy innovations from peer-reviewed research and authoritative policy institutions. Fourth, industry reports and investment data provide commercial perspectives on processing capacity, project economics, financing challenges, and market dynamics from mining companies, industry associations, and investment analysts. Fifth, preliminary consultations with Australian government officials inform the project's analytical priorities and strategic direction.

These sources provide evidence concerning regulatory frameworks, FTA provisions, documented trade patterns, and processing infrastructure. However, four categories of limitations require validation through the October-November 2025 consultation process before findings can be translated into specific recommendations:

1. Industry perspectives on practical implementation barriers can only be assessed by companies navigating regulatory requirements in practice. Publicly available sources document formal rules but cannot capture how regulations operate on the ground or where compliance creates unexpected costs or delays. For instance, Indonesia's TKDN regulations specify 40-60% local content thresholds, but publicly available sources don't document how these percentages are calculated, what compliance costs firms face, or how frequently requirements are waived in practice.

2. Magnitude and frequency of specific regulatory frictions require industry input to distinguish between theoretically concerning provisions and practically significant impediments. Not all documented barriers have equal impact on commercial decisions. Export restriction frequency data—how often specific shipments face delays or denials—cannot be assessed from regulatory texts alone.

3. Cross-sectoral applicability of identified patterns needs validation from agriculture and green economy stakeholders to test whether critical minerals findings genuinely extend beyond minerals-specific contexts. While SPS fragmentation in agriculture appears analogous to environmental standards divergence in minerals, only direct stakeholder input can validate whether regulatory cooperation mechanisms would work comparably across both sectors.

4. Effectiveness of different policy instruments in practice depends on implementation experience that only government officials and industry practitioners possess. Sources may document formal mechanisms but cannot evaluate what works versus what remains aspirational. IA-CEPA's skills exchange provisions exist in legal text, but whether they deliver measurable technology transfer or remain underutilized requires implementation experience assessment.

Consultation validation will refine preliminary findings into tested conclusions suitable for recommendation development in the planned Technical Paper (to be completed January 2026).

Structure

Section 2 provides baseline assessment of current FTA architecture. Section 3 documents five categories of trade barriers with available evidence. Section 4 maps regional processing capabilities and constraints. Section 5 examines sustainability dimensions and standards variations. Section 6 reviews instrumental options available for addressing identified barriers. Section 7 synthesizes preliminary patterns and frames questions for consultation validation.

2. Current FTA Architecture - Baseline Assessment

Australia's trade relationship with Southeast Asian partners operates through seven overlapping agreements negotiated primarily before critical minerals gained strategic prominence. This architecture provides a foundation for minerals trade but contains significant gaps in provisions addressing export restrictions, processing mandates, technology transfer, and sustainability standards. Understanding the current baseline establishes what exists, where coverage gaps persist, and how recent developments like the AANZFTA 2025 upgrade signal evolving approaches.

Agreement Landscape and Temporal Context

Seven agreements govern Australia-Southeast Asia trade in goods, services, and investment with varying coverage and standards:

This overlapping architecture creates both complexity and strategic opportunities. Countries subject to multiple frameworks face choices about which agreement provides optimal treatment for specific transactions. Vietnam and Malaysia can invoke AANZFTA, RCEP, or CPTPP provisions for Australian trade, with CPTPP offering the strongest environmental commitments, RCEP the broadest regional coverage, and AANZFTA the most developed ASEAN-specific cooperation mechanisms. Indonesia's relationship with Australia operates under AANZFTA, RCEP, and the bilateral IA-CEPA, with the latter providing minerals-sector depth lacking in multilateral frameworks. Malaysia's 2022 CPTPP accession (November 29, 2022) effectively introduces environmental commitments into the Australia-Malaysia relationship that were absent from the 2013 MAFTA, demonstrating how newer agreements can supplement older bilateral frameworks with evolved standards. This layering enables Australia and partners to leverage multiple frameworks strategically while creating administrative complexity for businesses navigating different rules of origin, dispute settlement procedures, and coverage across overlapping agreements.^[14]

Non-FTA Policy Instruments: While FTA legal texts establish baseline frameworks, significant critical minerals trade and investment activity occurs through supplementary instruments outside formal agreement disciplines. Bilateral cooperation includes Indonesia-Australia EV and battery supply chain cooperation initiatives and Vietnam-Australia annual ministerial energy-minerals dialogues. Australia participates in the Minerals Security Partnership (MSP), a coordination platform for critical minerals supply chain resilience and responsible sourcing standards.^[15] Domestic measures shape practical conditions: Australia's 2023-2030 Critical Minerals Strategy and "Future Made in Australia" initiative provide processing incentives through production tax credits and hydrogen support, while partner countries deploy processing mandates and investment requirements outside FTA constraints. Understanding trade and investment conditions requires examining the interplay between FTA disciplines and these parallel policy instruments.

AANZFTA 2025 Upgrade: First Regional Sustainability Framework

The AANZFTA Second Protocol entered into force in April 2025, marking a significant evolution in regional trade governance. The upgrade introduces the first Trade and Sustainable Development (TSD) chapter in any ASEAN-led FTA, creating a framework for cooperation on environmental protection, climate action, green and blue economy, circular economy, and energy.^[8:1] This development directly addresses topics relevant to critical minerals supply chain sustainability.

The TSD chapter affirms that each country maintains sovereign rights to regulate for sustainable development and declares it "inappropriate to weaken or reduce" environmental laws to encourage trade or investment—language paralleling CPTPP environmental provisions. However, the implementation approach differs fundamentally: AANZFTA's TSD chapter emphasizes cooperation over enforcement, with commitments not subject to binding dispute settlement.^[16] The chapter is explicitly carved out from the FTA's dispute mechanism, relying on dialogue and voluntary cooperation rather than legal penalties for non-compliance.

This cooperative architecture reflects ASEAN's preference for consensus-based mechanisms over hard law enforcement. The chapter formally acknowledges environmental and labor issues in trade while maintaining policy space for developing members. For critical minerals specifically, the cooperation framework could facilitate dialogue on processing standards, environmental practices, and technology sharing, though the absence of binding enforcement limits its effectiveness in addressing export restrictions or processing mandates. Consultation validation will assess whether the cooperation mechanisms deliver practical outcomes or remain aspirational.

Coverage Gaps for Critical Minerals

Despite the breadth of FTA coverage, three critical minerals-specific issues remain unaddressed by current agreement frameworks:

• Export restrictions and processing mandates are not effectively regulated by current Australia-Southeast Asia FTAs. Indonesia's nickel ore export ban, implemented in January 2020 to spur domestic processing, illustrates this gap. The export restriction proceeded despite Indonesia's AANZFTA commitments, with no FTA mechanism to challenge or constrain the policy.^[17] While IA-CEPA facilitates Australian investment in Indonesian nickel processing—potentially providing a pathway to participate in the value addition strategy—the agreement's legal text does not address export restrictions themselves. CPTPP includes disciplines on export restrictions in Annex 2-C, but countries negotiated significant carve-outs: Vietnam retained the right to maintain certain export duties on raw minerals, demonstrating that even comprehensive modern agreements preserve policy space for resource nationalism.^[18] Partner countries retain substantial sovereign discretion to impose processing mandates and export limitations for industrial development objectives.

• Technology transfer and capacity building receive treatment only through voluntary cooperation frameworks. IA-CEPA contains the most developed provisions among Australia's Southeast Asian FTAs, establishing a dedicated chapter on human capital development, skills exchange programs (including up to 200 Indonesian skills training visas annually), and commitments to share agricultural technology and know-how.^[19] However, these mechanisms address general capability development rather than minerals-specific technology transfer for processing. Standard intellectual property chapters across all agreements protect existing rights but do not create obligations or incentives for technology cooperation in critical minerals processing, refining, or battery manufacturing.

• Sustainability standards harmonization and mutual recognition remain absent despite environmental provisions in CPTPP and the AANZFTA 2025 upgrade. While CPTPP Article 20.15 recognizes that transitioning to a low-emissions economy requires collective action and establishes cooperation on energy efficiency and renewable energy technologies, it does not address standards divergence or mutual recognition for environmental assessments.^[20] No agreement creates frameworks for mutual recognition of environmental impact assessments, minimum sustainability floors for minerals processing, or traceability mechanisms across supply chains. This gap enables potential regulatory arbitrage where Australian miners meeting strict environmental standards export to processors operating under different frameworks.

These gaps contrast with recent agreements in other regions that integrate critical minerals considerations more explicitly. The US-Japan Critical Minerals Agreement dedicates articles to "Facilitating Sustainable and Equitable Supply Chains," requiring high levels of environmental protection, continual improvement of minerals-related laws, and discouragement of forced labor imports.^[21] The EU-Chile Interim Trade Agreement includes commitments relevant to raw materials: no export restrictions toward the EU, limitations on dual pricing, joint commitments on sustainable mining, and environmental impact assessment principles reflecting EU standards. Chile commits to responsible sourcing aligned with EU Battery Regulation due diligence requirements.^[22]

USMCA (United States-Mexico-Canada Agreement) provides another model through its enforceable environment and labor chapters. USMCA makes environmental obligations subject to the same dispute settlement as commercial provisions, with possibility of trade sanctions for non-compliance—advancing beyond the cooperation-only approach in AANZFTA. The agreement includes a Rapid Response Mechanism enabling facility-specific enforcement of labor violations, demonstrating how FTAs can address on-the-ground implementation beyond national-level commitments.^[23] While USMCA does not contain minerals-specific chapters, its approach to binding sustainability provisions with robust enforcement mechanisms offers relevant precedents for addressing environmental and labor standards divergence in critical minerals processing.

These international models demonstrate technically feasible approaches for addressing critical minerals trade through FTA provisions. Whether similar provisions are politically achievable or desirable in Southeast Asian contexts—given development objectives, sovereignty concerns, and ASEAN's consensus-based institutional culture—requires stakeholder consultation validation.

Synthesis: FTA Architecture Baseline

This baseline assessment reveals an FTA architecture with broad geographic coverage but significant minerals-specific gaps. Six overlapping agreements provide multiple frameworks for Australia-Southeast Asia trade, creating both strategic opportunities through forum shopping for optimal provisions and administrative complexity for businesses navigating different rules and procedures. Recent developments like the AANZFTA 2025 upgrade introduce sustainability cooperation mechanisms, marking progress toward integrating environmental considerations into regional trade governance, though enforcement remains voluntary rather than binding.

Three critical gaps persist across all agreements: export restrictions and processing mandates remain outside FTA disciplines, enabling partner countries to impose resource nationalism policies; technology transfer receives only voluntary cooperation treatment without minerals-specific obligations; and sustainability standards harmonization lacks mutual recognition frameworks or minimum floors, creating potential for regulatory arbitrage. International models from US-Japan, EU-Chile, and USMCA demonstrate more advanced approaches with dedicated critical minerals provisions, binding sustainability commitments subject to dispute settlement, and facility-level enforcement mechanisms. Whether such approaches suit Southeast Asian contexts given development objectives and institutional preferences requires consultation validation. Section 3 examines the specific trade barriers operating within this FTA architecture.

3. Documented Trade Barriers - Five Categories

Trade barriers affecting critical minerals supply chain integration span five categories: tariffs, export restrictions, local content requirements, standards fragmentation, and administrative impediments. Publicly available sources provide stronger documentation for some barrier types (export restrictions, processing concentration) than others (tariff escalation patterns, local content compliance costs). This section documents available evidence while explicitly identifying areas requiring industry consultation validation to assess practical significance and quantify impacts.

Tariff Barriers and Processing Escalation

Traditional tariff barriers on critical minerals in raw form are relatively low across major markets. The most-favoured-nation (MFN) tariff applied to imports of critical minerals was approximately 4% in 2022, nearly 2 percentage points lower than in 2002,^[24] with the vast majority of EU imports of critical raw materials exempt from tariffs.^[25] This pattern reflects longstanding resource security priorities where consuming nations minimize barriers to raw material access. The focus in contemporary trade agreements has shifted toward locking in zero-tariff treatment and addressing non-tariff obstacles such as import licensing or quotas.^[26]

However, tariff escalation—where processed products face higher duties than raw materials—remains a structural feature incentivizing export of unprocessed minerals rather than domestic value addition. Tariff schedule analysis across Southeast Asian partners for critical minerals at different processing stages (ore, concentrate, refined metal, battery-grade chemicals) represents a priority for detailed regulatory review. Industry consultation will validate whether tariff escalation measurably influences processing location decisions or whether non-tariff barriers dominate commercial calculations.

Cross-sectoral patterns warrant examination: agricultural sectors frequently face tariff escalation for processed versus raw products (cocoa beans versus chocolate, coffee beans versus instant coffee), suggesting this barrier type may apply broadly beyond minerals. Whether similar dynamics affect green economy manufacturing inputs requires consultation validation.

Export Restrictions and Processing Mandates

Export restrictions on raw critical minerals represent a significant documented barrier, with Indonesia's nickel export ban serving as the clearest regional example. Indonesia implemented a complete ban on nickel ore exports in January 2020 to force domestic processing and value addition.^[27] This industrial policy tool succeeded in attracting substantial processing investment, though it proceeded despite Indonesia's AANZFTA commitments and triggered a WTO challenge from the European Union. The WTO panel report was circulated on November 30, 2022 and appealed by Indonesia on December 8, 2022; due to the non-functional Appellate Body, the report has not been adopted. The ban remains in effect as of October 2025, demonstrating that WTO disciplines on export restrictions face enforcement challenges even when violations are formally established.^[28]

The Indonesian case demonstrates both effectiveness and friction created by export restrictions. The ban succeeded as industrial policy: processing capacity expanded dramatically, cumulative investment in nickel smelters and refineries reached substantial levels estimated in the billions of dollars (though comprehensive investment tracking remains commercially sensitive and requires industry consultation validation), and Indonesia transformed from ore exporter to major processor of battery-grade nickel products. However, the policy created supply chain disruptions for third-country processors, including Australian nickel producers unable to access Indonesian ore for Queensland processing facilities. Chinese companies represent the predominant source of Indonesian processing investment, raising questions about whether resource nationalism policies effectively capture value or simply shift dependency.

Vietnam maintained export duties on certain raw minerals even within CPTPP's comprehensive framework (CPTPP Annex 2-C allows Vietnam to maintain or phase out listed export duties), demonstrating that countries negotiate carve-outs to retain policy space for processing mandates despite trade liberalization commitments.^[18:1] Malaysia has signaled intentions toward downstream processing requirements for rare earths, though specific policies remain under development. These patterns suggest export restrictions and processing mandates represent a persistent barrier category across Southeast Asian partners pursuing industrial development objectives.

The export restriction-processing mandate nexus creates tensions between resource sovereignty, industrial policy effectiveness, and international trade disciplines. WTO jurisprudence limits countries' ability to impose export restrictions, yet enforcement mechanisms remain weak, and development rationales carry political weight. FTA provisions generally lack stronger disciplines than WTO baselines. Whether modernized FTAs should strengthen constraints on export restrictions, facilitate cooperation around processing development, or maintain current policy space represents a central question requiring stakeholder consultation, particularly given partner countries' development priorities and Australia's dual identity as both minerals supplier and processing aspirant.

Cross-sectoral patterns remain unclear: while agricultural export restrictions exist for food security reasons (rice export bans during supply shocks), the systematic use of export restrictions to force domestic processing appears more characteristic of minerals than agricultural sectors. Green economy manufacturing inputs may face similar dynamics if battery production localizes in Southeast Asia and countries seek to capture full value chains.

Local Content Requirements and Equity Restrictions

Local content policies and foreign ownership limitations create investment barriers across Southeast Asian partners, though detailed regulatory requirements and compliance cost data remain limited in publicly available sources. Constitutional and regulatory frameworks impose equity restrictions in natural resource sectors, while procurement and supply chain regulations mandate domestic content thresholds. These policies reflect development objectives—technology transfer, employment generation, value capture—but create friction for foreign investors and complicate regional supply chain integration.

The Philippines reportedly maintains constitutional limitations restricting foreign ownership to 40% in natural resource extraction, with 60% reserved for Filipino citizens or corporations. Debates continue regarding constitutional amendments to enable greater foreign participation while maintaining processing incentives, though specific reform proposals await political resolution. Indonesia's TKDN (Tingkat Komponen Dalam Negeri—domestic content requirement) regulations reportedly require varying local content levels across sectors, with mining equipment and services facing 40-60% domestic value content requirements in some applications. Malaysia's bumiputera policies reportedly establish preferential equity participation requirements in certain sectors, though specific application to minerals processing requires regulatory clarification. Detailed regulatory framework specifications, current implementation practices, compliance costs, and investment deterrent effects require verification through government sources and industry consultation.^[29]

Quantifying compliance costs and investment deterrent effects requires industry consultation. General mining sector research suggests local content requirements increase project development costs, though Southeast Asian context-specific data remains unavailable in reviewed sources. Whether local content policies effectively achieve technology transfer and capability development goals, or simply increase costs without commensurate benefits, represents an empirical question requiring stakeholder validation.

Cross-sectoral applicability appears likely: agriculture and green manufacturing sectors may face similar local content and equity requirements as part of broader industrial policy frameworks. Whether coordinated approaches to local content—potentially through FTA provisions establishing transparency, predictability, or mutual recognition—could benefit multiple sectors warrants consultation exploration.

Standards Fragmentation and Behind-the-Border Barriers

Standards divergence emerged as a priority theme in the 4 September 2025 DFAT consultation, encompassing environmental standards, technical specifications, and transparency requirements. This barrier category creates compliance complexity for companies operating across multiple jurisdictions and enables potential regulatory arbitrage where production gravitates toward lower-standard environments.

Environmental standards variations between Australian mining operations and Southeast Asian processing facilities illustrate the challenge. Australian operations operate under comprehensive environmental regulations including detailed impact assessments, rehabilitation requirements, and stringent water management standards. Southeast Asian processing facilities operate under varied national frameworks with different baseline requirements, monitoring intensity, and enforcement capacity. This divergence enables potential "carbon leakage" effects where Australian miners meeting strict environmental standards export to processors operating under different frameworks, shifting environmental impacts rather than reducing them.

Emerging ESG requirements from key consuming markets compound fragmentation challenges. The EU Critical Raw Materials Act and US critical minerals procurement preferences coordinated through the Minerals Security Partnership appear to be creating potential market segmentation between "high-ESG" supply chains meeting stringent environmental and labor standards and conventional supply chains serving markets with lower baseline requirements.^[30] Southeast Asian producers may increasingly face strategic choices about which market segments to target, with compliance costs and market access implications.

Technical standards for battery-grade materials, transparency requirements for certification and traceability, and documentation requirements for customs clearance create additional behind-the-border friction. The DFAT consultation identified transparency requirements as creating market access impediments, though specific examples require industry elaboration. Whether mutual recognition agreements for technical standards, environmental assessments, or certification systems could reduce compliance complexity while maintaining protection levels represents a question for stakeholder consultation.

Cross-sectoral patterns appear highly relevant based on preliminary analysis: agricultural exports may face analogous standards fragmentation through biosecurity requirements, food safety standards, and organic/sustainability certifications varying across markets—for example, maximum residue limits (MRLs) for pesticides and sanitary/phytosanitary (SPS) measures likely differ across ASEAN member states and Australia, creating similar compliance complexity, though this requires validation through agriculture stakeholder consultations. Green economy manufacturing faces emerging product standards (battery regulations, recycled content requirements, carbon footprint disclosure) that will fragment as jurisdictions adopt different approaches. Standards harmonization or mutual recognition may offer cross-sectoral benefits extending well beyond critical minerals.

Administrative Barriers and Trade Facilitation

Administrative processes and "red tape" emerged as priorities in the 4 September 2025 DFAT consultation, encompassing permitting timelines, customs documentation, and trade facilitation infrastructure. These barriers affect all traded goods but may create particular friction for critical minerals given project scale, regulatory complexity, and supply chain coordination requirements.

Permitting timelines for major mining and processing projects represent significant administrative barriers. Globally, the average time from discovery to production ranges from 10-20 years, with substantial variation by jurisdiction: US mines average 29 years (second-longest globally after Zambia at 34 years), Australia averages 20 years, while Ghana, DRC, and Laos average 10-15 years.^[31] Country-specific data for Southeast Asian partners' critical minerals permitting processes requires detailed regulatory review and industry experience validation. Infrastructure deficits compound administrative barriers: even where policy permits trade, lack of processing facilities, port capacity for heavy minerals shipments, or transport infrastructure prevents commercial operations.^[32]

Customs documentation, certification requirements, and trade facilitation system sophistication vary across partners. Digital trade facilitation pilots demonstrate potential for substantial improvement: Singapore's Trade Data Exchange and Australian Border Force digital systems show substantial reductions in processing time and compliance costs through single-window systems and automated documentation, though comprehensive quantification requires industry validation. Whether these approaches can extend to critical minerals trade, where shipments may require specialized handling, quality certification, and traceability documentation, requires assessment.

Administrative barriers likely affect all sectors comparably, suggesting cross-sectoral approaches to trade facilitation could deliver broad benefits. Streamlined permitting through mutual recognition of environmental assessments, digital customs systems enabling automated clearance, and coordinated infrastructure development could reduce friction across minerals, agriculture, and green economy manufacturing simultaneously. These "quick fix" opportunities may deliver faster results than comprehensive FTA renegotiation.

Synthesis: Barrier Patterns and Consultation Priorities

Evidence documents barriers across all five categories with varying levels of detail. Export restrictions (Indonesia nickel ban, Vietnam duties) and processing concentration in China represent well-documented barriers with clear impacts on supply chain configuration. Standards fragmentation and ESG bifurcation trends show emerging barrier patterns as consuming markets impose sustainability requirements. Tariff escalation, local content compliance costs, and administrative process inefficiencies require industry consultation to validate practical significance and quantify impacts.

Several patterns emerge requiring stakeholder validation. First, non-tariff barriers appear more significant than traditional tariffs for critical minerals trade. Second, barriers may interact and compound: export restrictions combined with local content requirements and permitting delays create cumulative friction exceeding any single barrier's individual impact. Third, some barriers (administrative processes, standards fragmentation) likely affect multiple sectors comparably, suggesting integrated FTA modernization approaches could deliver broad benefits beyond minerals alone.

Priority consultation questions include: Which barriers create greatest practical impediments for specific industry operations? What evidence exists on magnitude, frequency, and costs of documented barriers? Do barriers compound each other in ways that amplify commercial impacts? Where do "quick fix" opportunities exist for administrative improvements delivering near-term results? How do cross-sectoral patterns inform whether integrated approaches to trade facilitation, standards mutual recognition, or customs modernization could benefit minerals, agriculture, and green economy sectors simultaneously? Section 4 examines the processing landscape these barriers affect.

4. Regional Processing Landscape: Capabilities and Gaps

Southeast Asia's critical minerals processing landscape reflects rapid recent development driven by resource nationalism policies, infrastructure investment, and battery supply chain opportunities. Indonesia and the Philippines lead nickel processing globally, Malaysia hosts significant rare earth processing capacity, and multiple countries position themselves as battery value chain participants. However, systemic mid-stream technology gaps, massive infrastructure financing requirements, and environmental standards variations create constraints on processing expansion and supply chain integration.

Processing Capacity and Geographic Concentration

Indonesia and the Philippines are the world's two largest nickel producers, with Indonesia accounting for roughly half of global nickel production growth between 2021-2025.^[33] Indonesia's 2020 raw ore export ban catalyzed dramatic processing capacity expansion: facilities concentrated in industrial parks attracted substantial investment estimated in the billions of dollars, primarily from Chinese companies, transforming Indonesia from ore exporter to major processor of battery-grade nickel products. Australian company Nickel Industries exemplifies foreign participation, securing A$943 million investment from Indonesian partner United Tractors to finance Indonesian processing operations leveraging the country's substantial nickel reserves.^[34]

Processing capacity extends beyond nickel. Malaysia, Thailand, Indonesia, Philippines, and Vietnam are emerging as battery value chain participants with existing manufacturing capacity, growing electric vehicle industries, and policy incentives creating opportunities for Australian companies to supply high-value battery material exports.^[35] Thailand hosts Australian company Alpha Fine Chemicals' planned nickel sulphate plant in Rayong province targeting 40,000 tonnes annual production for lithium-ion battery markets,^[36] demonstrating mid-stream processing development. Malaysia's Lynas rare earth processing facility at Kuantan processes concentrates from Western Australia, representing significant Southeast Asian processing capacity outside China, though detailed operational performance data remains commercially sensitive and requires industry consultation validation.

Technology Gaps and Transfer Mechanisms

Mid-stream processing technology represents a critical bottleneck constraining Southeast Asian processing expansion. Australian capability assessments identify 30+ mid-stream technologies where capabilities remain below Technology Readiness Level 6, with silicon, graphite, and rare earth magnet processing representing the most critical gaps.^[37] These constraints apply regionally: mid-stream refining concentration in China (exceeding 70% for many metals) creates dependencies, with Southeast Asian processors relying heavily on Chinese technology, equipment, and technical expertise.^[38]

Technology transfer faces unique challenges in minerals processing. Unlike modular manufacturing, mineral processing requires site-specific adaptation to ore characteristics, tacit knowledge accumulated over decades of operational experience, and continuous innovation as ore grades decline. IA-CEPA's technology and skills cooperation provisions—including vocational training, technical skill exchanges, reciprocal skills training visas (up to 200 Indonesians annually), and industry-specific training packages—provide mechanisms for addressing capability gaps.^[39] The agreement framework positions Australian mining equipment, technology, and services (METS) expertise and strong ESG standards as bridges to sustainable mineral practices, pairing Indonesia's resource base with Australian processing knowledge to raise environmental standards in Indonesian nickel processing.^[40]

Whether these cooperation mechanisms deliver measurable technology transfer outcomes or remain aspirational requires industry consultation validation. Intellectual property concentration patterns, technology licensing arrangements, and knowledge transfer effectiveness represent evidence gaps requiring stakeholder engagement.

Infrastructure and Financing Requirements

Processing facility development depends on coordinated infrastructure investment creating significant financing challenges. Southeast Asia requires an estimated $3 trillion in infrastructure investment by 2040, with climate-resilient infrastructure alone requiring approximately US$210 billion annually until 2030.^[41] Energy infrastructure represents a critical constraint: processing facilities require substantial, reliable electricity supply, with coal-powered generation predominating in Indonesia creating carbon intensity differentials compared to renewable-powered alternatives. Port capacity for heavy minerals shipments, water resources for hydrometallurgical processes, and grid modernization for industrial loads compound infrastructure requirements.

Financing patterns show blended public-private models. With Southeast Asian energy investment averaging US$70 billion annually (2016-2020), significant financing gaps require private sector participation.^[42] Australia's Export Finance Australia invested US$62 million in clean energy projects and is developing a US$200 million facility supporting Indonesia's energy transition, exemplifying blended finance approaches. Green investment needs—projected at A$4 trillion by 2030 and potentially A$15 trillion by 2050—create enormous opportunities while highlighting capital mobilization challenges.^[43] Whether infrastructure coordination across minerals processing, agriculture processing, and green manufacturing could deliver efficiencies, and whether FTA provisions could facilitate infrastructure financing or de-risk investment, represent consultation priorities. Section 5 examines sustainability dimensions affecting this processing landscape.

5. Sustainability Dimensions: Standards and Practices

Environmental and social governance considerations intersect with trade policy through standards variations, regulatory frameworks, and ESG market segmentation. Emerging ESG requirements from key consuming markets—particularly the EU Critical Raw Materials Act and US critical minerals procurement preferences coordinated through the Minerals Security Partnership—appear to be creating market segmentation where Southeast Asian producers may increasingly face strategic choices about targeting "high-ESG" supply chain segments meeting stringent standards or conventional markets with lower baseline requirements.^[15:1] This dynamic positions ESG standards as emerging trade barriers while creating opportunities for Australian METS expertise and partnership models raising environmental practices.

Australian mining operations operate under comprehensive environmental regulations including Environmental Protection and Biodiversity Conservation Act requirements, detailed impact assessments, rehabilitation bonds, and stringent water management standards. Southeast Asian processing facilities operate under varied national frameworks with different baseline requirements, monitoring intensity, and enforcement capacity. This divergence enables potential carbon leakage where Australian miners meeting strict standards export to processors operating under different frameworks, shifting environmental impacts rather than reducing them.

Australia's Critical Minerals Strategy explicitly positions world-leading ESG performance as a strategic differentiator, making "reliable and ethical supplier" status a competitive advantage.^[44] Whether this differentiation translates into market premiums, preferred supply relationships, or competitive disadvantage through higher costs requires industry validation. IA-CEPA demonstrates one approach: pairing Indonesia's resource base with Australian METS expertise and strong ESG norms to raise processing standards,^[45] though whether cooperation mechanisms deliver measurable improvements over baseline Indonesian practices needs stakeholder assessment.

Current FTAs lack comprehensive mutual recognition frameworks for environmental assessments or minimum sustainability floors. The AANZFTA 2025 TSD chapter establishes cooperation frameworks but not binding enforcement. CPTPP's enforceable environment provisions prohibit weakening laws to attract investment but don't mandate specific standards levels or mutual recognition. Whether FTA provisions could facilitate mutual recognition of environmental assessments (reducing regulatory duplication while maintaining protection), establish minimum standards floors (preventing races to bottom), or enhance capacity building for standards upgrading represents a consultation priority given cross-sectoral applicability to agriculture and green manufacturing facing analogous sustainability certification fragmentation.

6. Instrumental Options: What Mechanisms Are Available?

The 4 September 2025 DFAT consultation emphasized "instrumental flexibility"—considering the full spectrum of policy instruments rather than assuming comprehensive FTA renegotiation. Available mechanisms span FTA upgrades, quick-fix administrative improvements, bilateral investment agreements, and cooperation frameworks. The AANZFTA 2025 upgrade demonstrates amendment pathways: the Second Protocol added a Trade and Sustainable Development chapter through multilateral consensus, entering force in April 2025. This model shows sustainability provisions achievable through FTA upgrades without full renegotiation, though cooperation-based rather than binding enforcement reflects ASEAN's consensus preferences.

Quick-fix approaches target practical barriers through administrative action potentially not requiring FTA amendments. Digital documentation systems, single-window clearance mechanisms, and streamlined customs procedures could reduce compliance burdens identified in Section 3. Singapore's Trade Data Exchange and Australian Border Force digital systems demonstrate substantial reductions in processing times and costs, suggesting administrative modernization potential—agriculture sectors are already piloting electronic phytosanitary certificates and digital certificates of origin that could extend to minerals traceability documentation. Mutual recognition agreements for technical standards, environmental assessments, or professional qualifications could address standards fragmentation without comprehensive FTA renegotiation, though precedent analysis and process requirements require consultation validation.

Investment-focused pathways include the IA-CEPA model: sector-specific bilateral agreements addressing market access, investment protection, and cooperation beyond multilateral FTA baselines. IA-CEPA enabled Indonesian mining sector liberalization, skills exchange programs, and technology cooperation frameworks specifically addressing minerals processing gaps. Whether this model applies to other Southeast Asian partners requires negotiation feasibility assessment. Investment facilitation provisions—enabling investment through regulatory predictability, infrastructure coordination, and financing mechanisms rather than merely protecting existing investment—could address infrastructure and financing barriers documented in Section 4, with agriculture processing (cold chain, biosecurity facilities) and green manufacturing (renewable energy infrastructure, circular economy hubs) facing analogous power, logistics, and connectivity constraints.

Cooperation mechanisms can be impactful when backed by dedicated programs and budgets. Whether cooperation frameworks deliver concrete outcomes—coordinated infrastructure development, effective technology transfer, standards harmonization—versus remaining aspirational text requires stakeholder validation. The IA-CEPA skills exchange and technology cooperation provisions provide implementation test cases: are these delivering measurable capability development or remaining underutilized? Comparative examples from USMCA enforceable labor and environment provisions, US-Japan critical minerals sustainability commitments, and EU-Chile raw materials partnership offer alternative models with different implementation mechanisms and enforcement approaches.

Instrumental Options Comparison

Matching barriers to instruments suggests administrative barriers respond to quick-fix trade facilitation measures, standards fragmentation to mutual recognition agreements or cooperation, export restrictions and local content requirements to politically sensitive investment disciplines or development cooperation frameworks. Trade facilitation, standards mutual recognition, and investment facilitation mechanisms likely benefit agriculture and green economy sectors comparably to critical minerals, suggesting integrated cross-sectoral approaches could deliver broader value than minerals-specific interventions. Consultation priorities include industry preferences among instrumental options, political feasibility assessments, resource and timeline requirements, effectiveness evidence from comparable contexts, and sequencing recommendations for where efforts should focus first.

7. Preliminary Patterns and Questions for Consultation

This evidence review documents baseline conditions, identifies barrier categories, maps processing landscape, examines sustainability dimensions, and reviews available instrumental options. Several preliminary patterns emerge from desk research while significant questions require industry and stakeholder consultation validation.

Emerging Patterns Across Barrier Categories

• Pattern 1: Behind-the-border barriers may exceed tariff barriers in significance: DFAT consultation emphasized standards fragmentation, transparency requirements, and administrative procedures. Evidence suggests regulatory divergence and trade facilitation gaps create substantial friction even where tariffs are low or eliminated. Industry consultation should test relative significance of different barrier types.

• Pattern 2: Processing development faces infrastructure and technology constraints requiring coordinated responses: Section 4 documented Indonesia's industrial park approach succeeded in attracting investment through bundled infrastructure, incentives, and policy predictability. Whether similar approaches could enable processing development in other locations requires assessment.

• Pattern 3: Sustainability standards divergence creates regulatory arbitrage risks: Section 5 identified environmental regulation variations enabling potential "carbon leakage" where production shifts to lower-standard jurisdictions. Whether mutual recognition, harmonization, or minimum standards approaches can address divergence requires consultation validation.

• Pattern 4: Multiple instrumental options exist beyond comprehensive FTA renegotiation: Section 6 mapped quick fixes (administrative improvements, MRAs), investment agreements, and cooperation mechanisms. Matching instruments to priority barriers and assessing political feasibility requires stakeholder input.

Cross-Sectoral Pattern Analysis

Critical minerals pathfinder analysis aimed to test whether identified barriers and solutions apply to agriculture and green economy priority sectors. Systematic comparison suggests substantial cross-sectoral relevance, though validation through stakeholder consultations remains essential.

Comparison Matrix: Barriers Across Sectors

Agriculture-Specific Analysis

Agricultural sectors face documented standards fragmentation through divergent biosecurity requirements, varying maximum residue limits (MRLs) for pesticides across ASEAN member states, and multiple sustainability certification schemes (organic, fair trade, sustainable palm oil) without mutual recognition frameworks. Australian agricultural exporters navigate different MRL standards, phytosanitary certification requirements, and food safety regulations across Indonesia, Vietnam, Thailand, Malaysia, and the Philippines—creating compliance complexity analogous to environmental assessment variations for minerals processing.

Trade facilitation barriers including customs clearance delays, documentation requirements for perishable goods, and quarantine processes affect agricultural trade comparably to minerals. Whether mutual recognition agreements for SPS measures, digital phytosanitary certificates, or harmonized food safety standards could reduce friction requires agriculture stakeholder validation. However, the structural parallels to critical minerals regulatory fragmentation suggest integrated approaches to trade facilitation and standards cooperation may serve both sectors effectively.

Green Economy Manufacturing Analysis

Green economy manufacturing sectors—including battery production, solar panel manufacturing, electric vehicle assembly, and circular economy processing—face emerging standards fragmentation as jurisdictions adopt different approaches to product standards (EU Battery Regulation, US Inflation Reduction Act requirements), recycled content mandates, and carbon footprint disclosure. Infrastructure constraints (reliable renewable energy, logistics for heavy components, port capacity) mirror minerals processing challenges documented in Section 4.

Local content requirements for electric vehicles, batteries, and clean energy equipment create investment barriers comparable to mining sector TKDN regulations. However, unlike minerals where export restrictions address resource nationalism, green manufacturing faces different policy drivers (industrial development, climate objectives). This hypothesis requires validation through clean energy and manufacturing stakeholder consultations to assess whether regulatory patterns truly parallel critical minerals or reflect fundamentally different dynamics.

Targeted Consultation Questions by Sector

Agriculture stakeholders: Do you recognize similar patterns of standards fragmentation (SPS, MRLs, certification schemes), administrative barriers (customs clearance, documentation), and infrastructure gaps (cold chain, processing facilities) to those identified for critical minerals? Would integrated approaches to mutual recognition, trade facilitation, or infrastructure cooperation serve agricultural priorities?

Green economy stakeholders: Do battery/EV/clean energy manufacturers face comparable standards divergence, local content requirements, and infrastructure constraints to minerals processors? Are instrumental options (MRAs, investment facilitation, cooperation mechanisms) relevant to your sectors?

Note: Cross-sectoral patterns represent preliminary hypotheses based on analytical inference from desk research rather than documented evidence specific to agriculture and green economy contexts. October-November 2025 consultations must test whether these parallels hold in practice and validate cross-sectoral instrumental approaches.

Instrumental Insights for Further Assessment

Available evidence suggests instrumental flexibility question - whether FTA upgrades, quick fixes, investment agreements, or cooperation mechanisms best address priority barriers - requires matching exercise between:

1. Barrier characteristics (which barriers most impede industry operations?)
2. Instrumental capabilities (which mechanisms can address which barriers?)
3. Political feasibility (what's achievable given sovereignty concerns and negotiating constraints?)
4. Implementation requirements (what resources, capacity, and timelines required?)

Industry consultation should elicit preferences and validate matching between priority barriers and instrumental options.

Evidence Gaps Requiring Consultation Validation

Desk research documented baseline conditions but cannot answer:

• Practical significance: Which barriers create greatest actual impediments for industry operations? Are documented barriers theoretically concerning or practically significant?

• Magnitude and frequency: How often do identified barriers impede specific transactions? What costs do they impose?

• Quick win opportunities: Where could administrative action or simple mutual recognition deliver rapid improvements without requiring complex negotiations?

• Political feasibility: Which approaches are acceptable to partner countries given development objectives and sovereignty concerns?

• Cross-sectoral validation: Do agriculture and green economy stakeholders recognize similar patterns? Would integrated approaches serve multiple sectors?

Questions for Industry Consultations (October-November 2025)

Australian industry consultations should address:

1. Barrier significance: Of five documented barrier categories (tariffs, export restrictions, local content, standards fragmentation, administrative), which create greatest practical impediments to your operations?

2. Standards and trade facilitation: Are standards fragmentation and administrative "red tape" as significant as preliminary evidence suggests? Specific examples?

3. Processing constraints: What factors most constrain processing development decisions - technology access, infrastructure, financing, regulatory predictability?

4. Instrumental preferences: Among FTA upgrades, quick fixes, investment agreements, and cooperation mechanisms, which approaches would deliver greatest practical benefits? Why?

5. Cross-sectoral patterns: Do identified barriers and solutions apply beyond critical minerals to your operations in agriculture, green manufacturing, or other sectors?

Southeast Asian stakeholder consultations should address:

1. Development priorities: How do partner countries view trade-offs between maintaining policy space for industrial development vs providing regulatory predictability for foreign investment?

2. Standards cooperation: What approaches to environmental and technical standards - mutual recognition, harmonization, minimum floors, capacity building - align with partner country priorities?

3. Infrastructure coordination: Could coordinated infrastructure development serve multiple sectors including critical minerals, agriculture, and green economy?

4. Instrumental receptivity: Which approaches - FTA upgrades, bilateral investment agreements, cooperation mechanisms - are politically feasible and desirable from partner country perspectives?

Next Steps: From Evidence to Recommendations

This evidence review provides foundation for consultation engagement and subsequent Technical Paper development. Consultation findings (documented in Consultation Summary, December 2025) will:

1. Validate or refine documented barrier categories and significance rankings
2. Test cross-sectoral applicability of identified patterns
3. Assess instrumental options against industry needs and political feasibility
4. Identify priority areas for recommendation development

The Technical Paper (January 2026) will translate evidence and consultation findings into specific, actionable recommendations for FTA modernisation, matching instruments to priority barriers with implementation roadmaps.

Conclusion

This living document will be updated monthly as evidence accumulates and consultation findings emerge. Current version establishes baseline understanding of FTA architecture, documented barriers, processing landscape, sustainability dimensions, and instrumental options. Significant questions remain for consultation validation before proceeding to recommendation development.

Acronyms

• AANZFTA: ASEAN-Australia-New Zealand Free Trade Agreement
• ADB: Asian Development Bank
• CPTPP: Comprehensive and Progressive Trans-Pacific Partnership
• CRMA: Critical Raw Materials Act (EU)
• CSIRO: Commonwealth Scientific and Industrial Research Organisation
• DFAT: Department of Foreign Affairs and Trade
• ESG: Environmental, Social, and Governance
• FTA: Free Trade Agreement
• GATT: General Agreement on Tariffs and Trade
• IA-CEPA: Indonesia-Australia Comprehensive Economic Partnership Agreement
• IEA: International Energy Agency
• LCR: Local Content Requirement
• MAFTA: Malaysia-Australia Free Trade Agreement
• METS: Mining Equipment, Technology and Services
• MRA: Mutual Recognition Agreement
• MRL: Maximum Residue Limit
• MSP: Minerals Security Partnership
• RCEP: Regional Comprehensive Economic Partnership
• SPS: Sanitary and Phytosanitary
• TAFTA: Thailand-Australia Free Trade Agreement
• TKDN: Tingkat Komponen Dalam Negeri (Local Content Requirement - Indonesia)
• TSD: Trade and Sustainable Development
• UNSW: University of New South Wales
• USMCA: United States-Mexico-Canada Agreement
• WTO: World Trade Organization

This evidence review will be updated incrementally, with major updates monthly. Next major update: November 2025 incorporating initial consultation findings.

References