The Aluminium Federation (ALFED) has officially submitted a sector-specific response to the Department for Business and Trade (DBT) concerning the proposed UK Critical Minerals Demand Aggregation Platform—a key component of the government’s Vision 2035: Critical Minerals Strategy.

The platform, as outlined in the strategy, is designed to consolidate data on UK demand for critical minerals, enhance clarity around supply needs, and provide support for the development of evidence-based policies. It is part of the government’s broader initiative to bolster supply chain resilience for materials deemed strategically important to the nation.

In its submission, ALFED expressed support for the core goal of improving transparency and coordination in the critical minerals space. At the same time, the federation laid out clear safeguards and structural considerations necessary to ensure the platform delivers real, meaningful value to UK industry.

Aluminium as a Foundational Industrial Material

ALFED’s response emphasizes that aluminium should be classified as a foundational material within the UK’s critical minerals framework. The metal is integral to a wide range of sectors, including defense, electrification, grid infrastructure, transportation, construction, packaging, and advanced manufacturing. It also plays a central role in achieving net zero targets and maintaining long-term industrial resilience. Additionally, the UK aluminium sector boasts one of the most circular systems among major materials, supported by well-established recycling and remelting infrastructure.

ALFED stressed that resilience in aluminium supply chains is not just about accessing raw materials. Energy pricing, domestic processing capacity, trade alignment, and global competitiveness are equally vital factors. As such, any demand aggregation mechanism must account for the complexity of the aluminium value chain—including both primary and secondary production streams, as well as key alloying elements.

Proportionality and Data Governance

Given the commercial sensitivity of procurement data across the aluminium ecosystem—encompassing producers, recyclers, extruders, manufacturers, and distributors—ALFED highlighted the importance of three key elements: voluntary participation, safeguards for data anonymization, and clear governance frameworks. Strict compliance with competition law, transparency regarding how data will be used, and proportionate reporting requirements (especially for small and medium-sized enterprises, or SMEs) will be crucial to building and maintaining industry confidence in the platform.

A Balanced but Constructive Position

ALFED’s overall stance is supportive of the platform in principle, but only if it delivers tangible benefits. These include improved visibility of demand, enhanced risk monitoring, and stronger evidence to guide government policy decisions.

However, the federation warned that demand aggregation alone cannot solve the structural challenges facing the UK aluminium sector in terms of competitiveness. Concurrent action on energy costs, alignment of trade policies, domestic investment frameworks, and regulatory certainty is still essential to strengthening the sector.

Ongoing Policy Engagement

This consultation response is part of ALFED’s broader engagement efforts, which cover critical minerals, scrap policy, the implementation of the Carbon Border Adjustment Mechanism (CBAM), industrial energy reform, and long-term manufacturing strategy.

The federation will continue to work collaboratively with DBT and other government departments to ensure aluminium is recognized not as a secondary input, but as a strategic, enabling material that lies at the heart of the UK’s industrial future.