A proposal, on the public record
The Department of Industry, Science and Resources has paid two United Kingdom firms for rare earth cost curves, asset analysis and supply chain mapping, including a sole-sourced engagement to support due diligence for the Critical Minerals Strategic Reserve. Neither supplier has an Australian presence. This page sets out what that record shows, what the Commonwealth still cannot answer about its own money, and what CMAA already holds.
Every row below is a Commonwealth contract notice on AusTender, in the Department's own words.
| Supplier | Notice | What was bought | Value | Period | Method |
|---|---|---|---|---|---|
| The Project Blue Group Limited, London | CN4243671 | “Detailed rare earth elements cost curve data and asset analysis, including global refining coverage, supply chain mapping, and project assessments, to support government due diligence for the Critical Minerals Strategic Reserve” | A$180,000 | 25 May to 30 Jun 2026, five weeks | Limited tender, one supplier invited, certified as an absence of competition for technical reasons |
| The Project Blue Group Limited, London | CN4149028 | Critical minerals research, from open tender ATM 2025 1011 | A$300,000 at award, A$418,088 after two variations | 17 Apr 2025 to 30 Jun 2026 | Open tender |
| Benchmark Mineral Intelligence Limited, Swindon | CN4144036 | Graphite and cobalt | A$97,250 | 2 Apr 2025 to 31 Mar 2026 | Open tender |
The sole-source justification is contradicted by the Department's own record. On 20 January 2025 the same department ran an open tender, ATM 2025 1011, for materially the same thing, including “cost curves and breakdown of facility-level costs” with rare earths named a top priority. Two United Kingdom firms won it. Thirteen months later the Department certified an absence of competition for technical reasons and invited one supplier.
That reads as incumbency and switching cost, which are real, rather than as a technical absence of competition. It is an inference about the Department's reasoning, and no departmental or parliamentary document explaining the decision was retrieved.
Sources: AusTender contract notices CN4243671, CN4149028 and CN4144036, and approach to market ATM 2025 1011. Search boundary: four AusTender notices name Project Blue. Six keyword searches were run. AusTender's keyword search is word tokenised and cannot be filtered by supplier, so a fifth notice cannot be categorically excluded; none surfaced.
These are questions about Australian public support for Australian projects. Each is answerable from a register that records the conditions attached to every instrument, and each is currently answerable from nowhere else.
Across 40 public funding rows on 22 projects, aggregates excluded and currencies never summed, the money that has been announced is roughly twice the money that has been committed. The difference is letters of interest, indicative support and conditional approvals, which are not money. Nobody currently tracks whether an announcement converts.
Two government publications are the source of the stage recorded against a large part of this sector, including in this register.
Inside the twenty rare earth projects published in edition one, eight carry a stage set by a government listing rather than by a JORC report or a company study. Seven of those eight also hold a company study fact that the stage does not reflect, and four of those stage fields are stale against the company's own filings.
The listing is a floor rather than a position. That is not a criticism of either publication, which state their own basis. It is an argument for a layer underneath them that carries the company filing, the page it came from and the date it was said.
Of those 700 requirement assessments, 83 are met and 39 are not met. Of the remainder, 101 are closeable by finding a document and 297 are structural, meaning the criterion is a decision rather than a fact and never closes from any register. Separating those two is the product. A supplier who cannot tell you which of your criteria are unknowable is selling you effort.
Every figure above is reproducible from the published register at cmaa-register.pages.dev, and every fact on it names its document and page.
No merit score, no ranking of projects, and no valuation. That line is legal rather than editorial: a ranking of companies whose shares trade is capable of influencing a decision about a financial product.
No price forecast. Rare earth price decks are not disclosed by anyone, we hold no price, revenue or basket figure, and we will not model one and present it as evidence.
No advice to a named party on their own transaction, which is corporate advisory and requires an Australian Financial Services licence.
CMAA is a membership association and the assessed companies include members. The related party position is declared in writing before any engagement, not after it.
Christian Reiche, Critical Minerals Association Australia. christian@cmaaustralia.org