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Audit Trail

Every company reviewed and excluded from the inaugural index, with the specific reason. Forty-three names are covered.

Every company reviewed and excluded from the inaugural index is documented here with the specific reason. Companies whose absence might reasonably prompt a question are the priority. Forty-three names are covered. To challenge any exclusion, use the contact page at clayindices.com.

Excluded constituents

Company Ticker Exclusion reason
Iluka Resources ILU.AX Activity fail — REE refinery under construction; commissioning revised to 2027. Revenue dominated by mineral sands as of April 30, 2026. Per §10.1: eligible at future commissioning date, not today.
Energy Fuels UUUU Activity fail — uranium primary business (FY25: $48.2M U revenue vs REE pilot in non-commercial volumes). Pending ASM acquisition may change classification post-close. Also: NYSE American not explicitly named in §4.3 (v2.1 flag).
NioCorp Developments NB Activity fail — Elk Creek is niobium-scandium-titanium; REE is minor co-product. Niobium dominates EV.
Vulcan Energy Resources VUL.AX Activity fail — geothermal lithium primary business. No REE activity.
Solvay SA SOLB.BR Activity fail — REE separation at La Rochelle is one product line within Special Chem. FY24 revenue €4.7B dominated by other chemicals. REE is minority of EV.
Syensqo SA/NV SYENS.BR Activity fail — specialty chemicals spinoff from Solvay. REE separation retained by Solvay. No material REE activity.
TMC the metals company TMC Activity fail — deep-sea polymetallic nodule mining (Ni, Cu, Co, Mn). Not a REE company.
Perpetua Resources PPTA Activity fail — gold-antimony developer (Stibnite Gold Project, Idaho). Not a REE company.
Avalon Advanced Materials AVL.TO Activity fail (lithium primary at Separation Rapids) and market cap floor fail (USD 41M < USD 50M floor).
China Rare Earth Holdings 0769.HK Exclusion screen — trading suspended since June 18, 2024 (>10 consecutive trading days).
Daido Steel 5471.T Exchange not on eligible list — Tokyo Stock Exchange. Activity would likely fail in any case.
TDK Corporation 6762.T Exchange not on eligible list — Tokyo Stock Exchange. Activity would fail (electronic components conglomerate).
Shin-Etsu Chemical 4063.T Exchange not on eligible list — Tokyo Stock Exchange. Activity would fail (semiconductors/silicones primary).
Sumitomo Metal Mining 5713.T Exchange not on eligible list — Tokyo Stock Exchange. Activity would fail (diversified metals).
Proterial Ltd 5486.T (delisted) Not publicly listed — taken private by Bain Capital consortium, October 2022. Renamed from Hitachi Metals January 2023.
China Northern Rare Earth 600111.SH Exchange not on eligible list — Shanghai Stock Exchange (A-share only).
Shenghe Resources 600392.SH Exchange not on eligible list — Shanghai Stock Exchange (A-share only).
Ningbo Yunsheng 600366.SH Exchange not on eligible list — Shanghai A-share only. NdFeB magnet manufacturer.
Innuovo Magnetics 688199.SH Exchange not on eligible list — STAR Market (Shanghai). Bonded NdFeB manufacturer.
Sungeel HiTech 235980.KQ Exchange not on eligible list — KOSDAQ (Korea). REE recycler.
Rare Element Resources REEMF Exchange not on eligible list — OTC Markets (US). Also fails liquidity floor (ADTV ~USD 281K).
Peak Rare Earths PEK.AX (delisted) Delisted October 2025 following acquisition by Ganzhou Chenguang (Shenghe subsidiary). Ngualla project (Tanzania) no longer publicly accessible.
80 Mile Plc (formerly Bluejay Mining) 80M.L Activity fail — pivoted to industrial gas and hydrocarbons following July 2024 rebrand. REE no longer material.
Commerce Resources CCE.V Market cap floor fail — 30-day average ~USD 25M vs USD 50M floor. Activity passes (Ashram REE/fluorspar, Quebec).
Rare Earths Norway (private) Not publicly listed. Developing Fen Complex (Norway’s largest known REE deposit). No IPO announced.
Hastings Technology Metals HAS.AX Liquidity floor fail — 90-day ADTV ~USD 120K vs USD 500K floor. Market cap passes (~USD 73M). Activity passes (Yangibana NdPr).
Northern Minerals NTU.AX Liquidity floor fail — 90-day ADTV ~USD 408K vs USD 500K floor (18% below; outside 10% adjudication zone). Market cap passes (~USD 141M).
Ionic Rare Earths IXR.AX Market cap floor fail — 30-day average ~USD 47M vs USD 50M floor (within 6% — §10.3 zone noted). Activity passes (Makuutu ionic-clay + UK recycling JV).
VHM Limited VHM.AX Liquidity floor fail — 90-day ADTV ~USD 101K vs USD 500K floor. Market cap passes (~USD 55M).
American Rare Earths ARR.AX Liquidity floor fail — 90-day ADTV ~USD 239K vs USD 500K floor. Market cap passes (~USD 136M). Activity passes (La Paz, Arizona).
Dreadnought Resources DRE.AX Liquidity floor fail — 90-day ADTV ~USD 80K vs USD 500K floor. Activity borderline (multi-commodity).
Defense Metals DEFN.V TSXV liquidity floor fail — 90-day ADTV ~USD 74K vs USD 1M TSXV floor. Market cap passes (~USD 61M). Activity passes (Wicheeda, BC).
Mkango Resources (TSXV line) MKA.V TSXV liquidity floor fail — 90-day ADTV ~USD 53K vs USD 1M TSXV floor. Eligible via AIM listing (MKA.L) included in index.
Rainbow Rare Earths RBW.L Liquidity floor fail — 90-day ADTV ~USD 373K vs USD 500K floor (25% below; outside adjudication zone). Market cap passes (~USD 227M).
Leading Edge Materials LEM.V TSXV liquidity floor fail — 90-day ADTV ~USD 33K vs USD 1M TSXV floor. Market cap passes (~USD 51M).
Search Minerals SMY.V Market cap floor fail — 30-day average ~USD 11M vs USD 50M floor.
Geomega Resources GMA.V Market cap floor fail — 30-day average ~USD 32M vs USD 50M floor.
Heavy Rare Earths HRE.AX Market cap floor fail — 30-day average ~USD 5M vs USD 50M floor.
RareX Limited REE.AX Market cap floor fail — 30-day average ~USD 13M vs USD 50M floor.
GreenRoc Strategic Materials GROC.L Market cap floor fail — 30-day average ~USD 18M vs USD 50M floor.
ABx Group ABX.AX Activity fail (bauxite primary) and market cap floor fail (~USD 13M).
Vital Metals VML.AX Market cap fail (~USD 13M, 75% below floor) and liquidity fail (~USD 11K ADTV, 98% below floor). Post-2023 administration recovery in progress.
Aclara Resources ARA.TO Borderline — included in Tab 1 after adjudication (§5.1 of constituent note). Listed here for completeness; see constituent note for full reasoning.

Comparison to REMX

The VanEck REMX ETF holds companies that this methodology excludes — including diversified miners and chemical companies where rare earth activity is a minority of enterprise value, and companies listed on exchanges outside the eligible list. REMX was reviewed as a reference universe only; its holdings were verified independently against this methodology rather than accepted on inclusion.