TMC the metals company Inc. (NASDAQ: TMC) is having another one of its “this is definitely not a sleepy stock” days.
Shares of TMC fell sharply in Tuesday trading (Dec. 23, 2025), even as a major regulatory milestone landed on the U.S. government’s public agenda: NOAA is set to publish a Federal Register notice acknowledging receipt of amended exploration license applications from TMC’s U.S. subsidiary and announcing a public comment period and virtual public hearings in January 2026. [1]
For investors, it’s a familiar mix: big regulatory headlines, big price swings, and a company whose valuation is still mostly a bet on what regulators do next. [2]
What happened to TMC stock on Dec. 23, 2025?
TMC shares were down about 6% on the day, trading around $7.23 with heavy volume (roughly 5.0 million shares).
Market coverage of the move framed it as a pullback after recent strength, with TMC trading well above its longer-term moving averages and remaining prone to fast sentiment shifts. [3]
This comes just days after a separate burst of momentum: Trefis noted that TMC jumped +14% on Dec. 19 in what it described as an options-driven move with “no direct news catalyst,” highlighting how quickly positioning and derivatives flow can whip this name around. [4]
The big catalyst: NOAA’s Federal Register notice and January 2026 hearings
The most consequential “news” tied to Dec. 23 isn’t a quarterly earnings print or a new offtake agreement. It’s procedural — and in deep-sea mining, procedure is the whole game.
A NOAA document scheduled for publication in the Federal Register on Dec. 23, 2025 states that NOAA received amended applications from The Metals Company USA, LLC (TMC USA) for deep seabed mining exploration licenses in the Clarion‑Clipperton Zone (CCZ) — a vast area of the Pacific Ocean between Hawaii and Mexico that is rich in polymetallic nodules. [5]
Key points from the notice:
- NOAA says it received an amended application on July 27, 2025 (Application A) and a second amended application on July 28, 2025 (Application B). [6]
- NOAA determined the applications are fully compliant with applicable information requirements under the Deep Seabed Hard Mineral Resources Act (DSHMRA) and implementing regulations. [7]
- NOAA is opening a public comment period (the notice indicates comments are due 60 days after publication). [8]
- NOAA will hold two virtual public hearings on January 27 and January 28, 2026, from 3 p.m. to 7 p.m. ET. [9]
One important nuance for investors: this Federal Register notice addresses exploration licenses, not (yet) the commercial recovery permit. Exploration licenses are typically about surveys, testing, and defined-area work — while a commercial recovery permit is the authorization for full-scale extraction for commercial purposes. [10]
Still, markets often trade on “process milestones,” and a Federal Register notice plus scheduled hearings is a very real milestone in a sector where timelines are measured in regulatory steps, not quarters.
Why the NOAA step matters for TMC’s investment thesis
TMC’s core pitch is straightforward: polymetallic nodules on the seafloor contain high concentrations of nickel, cobalt, copper, and manganese — key industrial and battery metals — and harvesting them could (the company argues) reduce dependence on certain terrestrial mining supply chains while supporting U.S. critical mineral goals. [11]
But TMC’s business model is still largely pre-revenue and dependent on future regulatory approval, as analysts frequently emphasize. [12]
The regulatory storyline accelerated in 2025 after TMC pursued a U.S. pathway under DSHMRA. Reuters reported that TMC asked the Trump administration to approve plans to mine the international seabed via NOAA, a move that raised tensions with the U.N.-backed International Seabed Authority (ISA) and prompted sharp pushback from environmental groups and some governments. [13]
In company disclosures, TMC has highlighted that NOAA had not issued any commercial recovery permits under DSHMRA prior to TMC USA’s application — making TMC a potential test case for the modern use of that framework. [14]
In other words: if you own TMC stock, you’re not just betting on metallurgy. You’re betting on regulatory first-mover advantage and whether the U.S. will meaningfully operationalize deep seabed mining permissions in areas beyond national jurisdiction.
Policy tailwinds: U.S. critical minerals push and the Korea Zinc link
TMC isn’t operating in a vacuum. The broader policy environment has been moving in a direction that the company argues supports its strategy: reducing reliance on China-linked supply chains for critical minerals and processing.
A major recent development came from Korea Zinc, which announced plans to build a $7.4 billion critical minerals refinery complex in Tennessee with substantial U.S. government involvement and support, according to Reuters. That Reuters reporting also explicitly noted that Korea Zinc had agreed earlier in 2025 to help TMC process polymetallic nodules, tying the refinery narrative to TMC’s broader deep-sea mining thesis. [15]
Reuters has also reported that critical mineral firms broadly increased Washington lobbying efforts as the U.S. expanded investments across the sector — and mentioned Korea Zinc’s relationship with TMC in that context. [16]
Meanwhile, TMC’s own June 2025 announcement said Korea Zinc agreed to invest $85.2 million for a roughly 5% stake (via share purchase and a warrant structure), framing the partnership as strategic for future processing/refining and potential U.S.-based capacity. [17]
These links matter to investors because deep-sea nodules don’t become “battery materials” until they pass through processing and refining — and industrial partners help make the downstream side of the story feel less hypothetical.
Fundamentals check: cash, losses, and why the stock trades like a headline amplifier
TMC’s financial profile still looks like a development-stage company rather than an operating miner.
In its third-quarter 2025 corporate update (covering the period ending Sept. 30, 2025), the company reported:
- Total cash of about $115.6 million
- Operating loss of $55.4 million and net loss of $184.5 million for the quarter
- Net loss per share of $0.46, with results affected by non-cash and non-recurring items including fair value changes and share-based compensation [18]
That’s the backdrop for why TMC tends to trade like a “regulatory option”: when the stock moves, it often moves on shifting expectations of permitting timelines, political support, and market structure dynamics (options/short interest), not on revenue growth or operating margins.
The “economics pitch”: the $23.6B combined NPV headline
In August 2025, TMC released two economic studies (a Pre-Feasibility Study and an Initial Assessment) and promoted a combined project value headline: $23.6 billion in combined net present value across the studies, including a $5.5 billion after-tax NPV in the PFS for its NORI‑D project area. [19]
The same release also tied its development timeline to U.S. permitting outcomes, stating that it expected to commence commercial production in Q4 2027 if it received a commercial permit (with additional ramp assumptions thereafter). [20]
Investors should treat NPVs here as exactly what they are: model outputs that depend heavily on assumptions (commodity prices, capex, opex, timelines, discount rates, legal/regulatory permission, and actual performance in a harsh offshore operating environment). But they are central to the bull case — and they help explain why “process wins” like today’s NOAA notice can move the stock.
Forecasts and Wall Street views: still scattered, still cautious
Traditional sell-side coverage of TMC remains limited compared to large-cap miners, and “consensus” can vary depending on the data provider.
On Dec. 23, MarketBeat summarized analyst sentiment as mixed, citing a “Hold” consensus view with an average price target around $7.42, alongside a mix of buy/hold/sell-style ratings. [21]
Other market-data aggregators show different target distributions and “buy”-leaning consensus snapshots — which can happen when the underlying contributing analysts and update timing differ. [22]
The practical takeaway isn’t that one number is “right.” It’s that forecasts cluster around the same uncertainty: TMC’s valuation hinges far more on regulatory progress than on near-term financial performance.
The volatility accelerant: short interest and options flow
TMC has had the kind of setup traders love and long-term investors fear: a strong narrative catalyst, a relatively small company footprint, and meaningful short positioning.
Trefis explicitly pointed to short interest above 30 million shares (roughly around ~11% of float in its framing) and argued that the Dec. 19 spike looked like a mechanically driven squeeze fueled by call option activity. [23]
MarketBeat’s Dec. 23 recap also referenced insider ownership and relatively low institutional ownership, dynamics that can amplify volatility when retail-driven flows and options positioning dominate the tape. [24]
The risk stack: regulation, environmental pushback, and international legitimacy fights
A sober view of TMC stock has to sit with the uncomfortable part: deep-sea mining is one of the most contested frontiers in resource extraction.
Reuters, the AP, and others have detailed the political and legal tension around attempts to mine in international waters outside the ISA’s still-evolving ruleset, as well as warnings from environmental advocates about potential biodiversity impacts. [25]
Even if TMC clears U.S. procedural steps, it may face continued reputational and geopolitical resistance, and any “first permit” outcome could trigger new legal challenges or diplomatic friction.
And then there’s the basic corporate reality: development-stage projects tend to require more capital than early investors wish, and permitting timelines are rarely linear.
What investors should watch next
If you’re tracking TMC stock into year-end and early 2026, the next catalysts are more calendar-driven than operational:
- Public comment window tied to the Dec. 23 Federal Register publication (NOAA indicates a 60-day post-publication timeline). [26]
- Virtual public hearings on Jan. 27–28, 2026, which may surface themes NOAA will have to address in its review and documentation. [27]
- Any signal on how NOAA is applying (or potentially revising) DSHMRA processes, including the broader regulatory modernization NOAA discussed in 2025. [28]
- Updates on downstream processing strategy and strategic partners — especially with Korea Zinc expanding its U.S. footprint in critical minerals processing. [29]
For now, Dec. 23 delivers a classic TMC snapshot: the stock drops, the regulatory machine moves forward anyway, and the real story remains the permit pathway. [30]
References
1. public-inspection.federalregister.gov, 2. www.trefis.com, 3. www.marketbeat.com, 4. www.trefis.com, 5. public-inspection.federalregister.gov, 6. public-inspection.federalregister.gov, 7. public-inspection.federalregister.gov, 8. public-inspection.federalregister.gov, 9. public-inspection.federalregister.gov, 10. oceanservice.noaa.gov, 11. investors.metals.co, 12. www.trefis.com, 13. www.reuters.com, 14. www.sec.gov, 15. www.reuters.com, 16. www.reuters.com, 17. investors.metals.co, 18. investors.metals.co, 19. investors.metals.co, 20. investors.metals.co, 21. www.marketbeat.com, 22. valueinvesting.io, 23. www.trefis.com, 24. www.marketbeat.com, 25. www.reuters.com, 26. public-inspection.federalregister.gov, 27. public-inspection.federalregister.gov, 28. oceanservice.noaa.gov, 29. www.reuters.com, 30. public-inspection.federalregister.gov
