Exhibit 8.2

The Directors   BHP Billiton Finance (USA) Limited Level 18 171 Collins Street Melbourne VIC 3000 Australia   BHP Group Limited Level 18 171 Collins Street Melbourne VIC 3000 Australia 29 August 2025 By Email

Dear Directors

Private and Confidential

BHP US Shelf programme renewal 2025

Australian tax opinion

We refer to the Registration Statement on Form F-3 (the Registration Statement) of BHP Billiton Finance (USA) Limited and BHP Group Limited, which is proposed to be filed with the United States Securities and Exchange Commission on or about the date hereof, relating to the registration of an indeterminate amount of debt securities for future issuance. The Registration Statement contains a tax summary section, headed “Material Tax Consequences—Australian Taxation”, that summarises the Australian tax issues arising for non-resident holders of debt securities issued by BHP Billiton Finance (USA) Limited in accordance with the Registration Statement. You have asked that we provide you with a letter confirming that the Australian tax summary is appropriate for inclusion in the Registration Statement as a general summary of the Australian tax issues.

In preparing this letter we have reviewed:

1 the Registration Statement; and

2 the Indenture dated 28 February 2023 between BHP Billiton Finance (USA) Limited, as issuer, BHP Group Limited as guarantor, and The Bank of New York Mellon, N.A., as trustee (the Trustee) relating to the senior debt securities (the Indenture).

We understand that it is intended that the terms of the debt securities will be set on a basis that ensures that they will be debt interests under Division 974 of the Income Tax Assessment Act 1997 (Cth) and will not be equity interests under that Division. This is based on the following:

• the debt securities will be in legal form debt;

• BHP Billiton Finance (USA) Limited’s obligation to repay the principal in full and payments of interest will be non-contingent;

• interest and discount rates on the debt securities will be at the prevailing market rates at the time of the offering; and

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80 Collins Street Melbourne Vic 3000 Australia GPO Box 128 Melbourne Vic 3001 Australia	T +61 3 9288 1234 F +61 3 9288 1567 hsfkramer.com

• the debt securities will not be classified as equity by reason of any relationship with any other arrangement or as a result of BHP Billiton Finance (USA) Limited having the ability to exchange the debt securities for equity interests in any BHP Group entity.

Based on our review of the Registration Statement and Indenture, we advise that the statements set forth under the heading “Material Tax Consequences—Australian Taxation” are a fair and accurate general summary of the Australian tax treatment of non-resident holders of debt securities (“non-resident” having the meaning in the Income Tax Assessment Act 1936 (Cth)) and are appropriate for inclusion in the Registration Statement as such a general summary. Our opinion is based on Australian tax law as at the date of this letter. We consent to the inclusion of this opinion as an exhibit to the Registration Statement and to the reference to us under the heading “Material Tax Consequences—Australian Taxation” in the Registration Statement.

Yours sincerely

/s/ Herbert Smith Freehills Kramer

Toby Eggleston

Partner

Herbert Smith Freehills Kramer

+61 3 9288 1454

+61 413 151 183

toby.eggleston@hsfkramer.com 

Herbert Smith Freehills Kramer LLP and its affiliated and subsidiary businesses and firms, Herbert Smith Freehills Kramer (US) LLP and its affiliate, and Herbert Smith Freehills Kramer, an Australian Partnership, are separate member firms of the international legal practice known as Herbert Smith Freehills Kramer. We practise in Australia through Herbert Smith Freehills Kramer, an Australian Partnership (ABN 98 773 882 646).

2065802317 BHP US Shelf programme renewal 2025
Australian tax opinion page 2