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What they make, where they produce, the materials that matter — then what is coming, what it would do to the business, and the moves available. Sector: metals refining. Company profile →
POSCO Holdings Inc. (KRX: 005490) is the South Korean parent of the POSCO group, spanning integrated steelmaking (POSCO, the world's 6th-largest crude-steel producer) and a fast-growing battery-materials arm, POSCO Future M, which supplies cathode and anode active materials to EV and ESS cell makers. The group has vertically integrated upstream into the raw materials both businesses consume: lithium brine conversion in Argentina and a lithium-ore JV in Australia's Pilbara, a nickel MHP (mixed hydroxide precipitate) plant in Sulawesi, Indonesia, and full ownership of a ferrochrome producer in South Africa.
Verbatim from the dossier's “What they do” section — sources on the company profile.
This is where POSCO Holdings Inc. produces — approximate output shares from its dossier — not where it sells. Sales geography is not yet in our corpus for any company, so we cannot compute exposure to measures that bite on where products ship: an extraterritorial re-export rule follows the shipment and its material content, not the factory. Where such a measure touches its materials, the policy sections below flag it — but its sales-side incidence is not computable yet, and we say so rather than substitute the production map for it.
Of everything in its products, we track the critical inputs — the materials whose supply is concentrated in few countries, policy-exposed, or hard to substitute — because those are the ones a single measure can move. Each carries its role in the product, quoted from the dossier's own exposure note.
Graphite — bulk input, anode business. POSCO Future M signed a 2026 five-year, ~$668M contract to supply synthetic graphite anode active material to a global automaker (2027-2032) and is building a synthetic graphite anode plant in Vietnam to fulfil it.
Manganese — structural component, both businesses. Added to mid-nickel cathode chemistries for thermal-safety stabilization, and used as a steelmaking alloying element (POSCO's high-manganese and high-strength steel grades).
Cobalt — bulk input, battery cathodes. Used in POSCO Future M's high-voltage mid-nickel NCM/NCMA cathode formulations; the company states it is actively working to reduce cobalt content given its concentration/price risk (DRC-dominated supply).
Lithium — bulk input, cathode business. Converted to lithium carbonate/hydroxide for cathode active materials; POSCO Holdings produces lithium carbonate from an Argentine salar and holds a stake in a Pilbara, Australia spodumene mine via the POSCO Pilbara Lithium Solution JV that converts ore to hydroxide.
Nickel — bulk input, both businesses. POSCO Future M's cathode materials for standard and premium EVs run 60-95%+ nickel content; POSCO's stainless-steel business also consumes nickel as an alloying element. The group is building its own supply via a 120,000-tonne/year nickel MHP plant in Sulawesi, Indonesia (phase one: 60,000 t/y from 2025), reducing reliance on the concent…
In its verified exposure list, but the dossier carries no product-level note for it yet — we make no product claim until it does.
Chromium — bulk input, stainless steel. POSCO holds 100% of Poschrome, a South African ferrochrome (chromium alloy) producer acquired from Samancor Chrome; ferrochrome is an essential input to POSCO's stainless steel.
Scope. The non-critical remainder of the bill of materials — structural steel, polymers, glass and the like — is not tracked here because it is not supply-constrained: this section covers the constrained inputs, which is where policy risk concentrates, not a full bill of materials.
The top 5 are ranked mechanically — what the instrument does (its transmission class: an export ban is not a reporting duty), × how close to law (stage-derived likelihood band, never a probability) × how much of your tracked bill of materials it touches. Each unfolds as a chain: trigger → what it hits → the response the instrument actually calls for. A measure touching a material you produce can be an opportunity, not a threat.
BR · stage passed-vote → high likelihood · touches graphitemanganesecobaltlithiumniobium · flagged 19 Jun 2026, 108d pending
First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
source ↗Graphite — bulk input, anode business. POSCO Future M signed a 2026 five-year, ~$668M contract to supply synthetic graphite anode active material to a global automaker (2027-2032) and is building a synthetic graphite anode plant in Vietnam to fulfil it.
Manganese — structural component, both businesses. Added to mid-nickel cathode chemistries for thermal-safety stabilization, and used as a steelmaking alloying element (POSCO's high-manganese and high-strength steel grades).
Cobalt — bulk input, battery cathodes. Used in POSCO Future M's high-voltage mid-nickel NCM/NCMA cathode formulations; the company states it is actively working to reduce cobalt content given its concentration/price risk (DRC-dominated supply).
+2 more touched materials — see the composition section (3) above.
This changes the form of what Brazil exports, not whether you can buy: raw/unprocessed exports are restricted while domestically processed material stays available — that is the measure's own mechanism. Your Brazil-origin raw feed becomes processed-only; the route is a value-added purchase or a Brazil processing partner, not a supplier switch.
Brazil supplies 93% of world niobium mining — that is the stake if its terms tighten.
Brazil supplies 4.1% of world lithium mining — that is the stake if its terms tighten.
Brazil supplies 4.0% of world manganese mining — that is the stake if its terms tighten.
Secondary — only if you need to avoid Brazil entirely: niobium supply outside BR is 🇨🇦 CA 80%, 🇨🇩 CD 13%, 🇷🇺 RU 4.0% (shares renormalised after removing BR); lithium supply outside BR is 🇦🇺 AU 34%, 🇨🇳 CN 22%, 🇨🇱 CL 20% (shares renormalised after removing BR).
Further materials are covered in section 6 below.
TZ · stage awaiting-signature → high likelihood · touches graphitecobaltnickelniobium · flagged 26 Jun 2026, 101d pending
TZ Finance Bill establishes the Mineral Research Fund capitalised at 10% of gross mineral revenue (~TZS 141 billion/yr at 2025 collection levels); amends the Income Tax Act to formally recognise tax exemptions granted under individual mining Framework Agreements and introduces standard operating procedures — reduces discretionary government risk for large mining investors (Panda Hill niobium, graphite juniors, Buzwagi gold); parallel VAT amendments give equivalent statutory certainty for VAT exemptions; taken together, the bill moves Tanzania from discretionary tax administration toward a rule-of-law-based investor regime for all critical-mineral projects; budget targets Tanzania for top-4 niobium producer status (Panda Hill DA already signed March 24, 2026) and 50% geophysical survey coverage by 2030
source ↗Graphite — bulk input, anode business. POSCO Future M signed a 2026 five-year, ~$668M contract to supply synthetic graphite anode active material to a global automaker (2027-2032) and is building a synthetic graphite anode plant in Vietnam to fulfil it.
Cobalt — bulk input, battery cathodes. Used in POSCO Future M's high-voltage mid-nickel NCM/NCMA cathode formulations; the company states it is actively working to reduce cobalt content given its concentration/price risk (DRC-dominated supply).
Nickel — bulk input, both businesses. POSCO Future M's cathode materials for standard and premium EVs run 60-95%+ nickel content; POSCO's stainless-steel business also consumes nickel as an alloying element. The group is building its own supply via a 120,000-tonne/year nickel MHP plant in Sulawesi, Indonesia (phase one: 60,000 t/y from 2025), reducing reliance on the concent…
+1 more touched material — see the composition section (3) above.
The filed text doesn't state this instrument's mechanism clearly enough to classify, so we don't guess a response — the measure text above is the read.
Further materials are covered in section 6 below.
CD · stage passed-vote → high likelihood · touches cobalt · flagged 11 Aug 2026, 55d pending
On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
source ↗Cobalt — bulk input, battery cathodes. Used in POSCO Future M's high-voltage mid-nickel NCM/NCMA cathode formulations; the company states it is actively working to reduce cobalt content given its concentration/price risk (DRC-dominated supply).
The prohibition covers the raw/unprocessed form; material processed in DR Congo stays exportable under the order's own exemption — so a DR Congo processing route remains open alongside the alternatives below.
DR Congo supplies 74% of world cobalt mining — that share of your supply base is what this measure cuts off.
Supply outside 🇨🇩 CD: 🇮🇩 ID 66% · 🇷🇺 RU 12% · 🇲🇬 MG 6.1% · 🇵🇭 PH 5.6% — shares renormalised after removing CD.
CD · stage passed-vote → high likelihood · touches cobalt · flagged 20 Jul 2026, 77d pending
On ~29 June 2026 the Autorité de Régulation et de Contrôle des Marchés des Substances Minérales Stratégiques (ARECOMS) ordered that all first-half-2026 cobalt export quotas left unused by 30 June 2026 be forfeited and recovered, with a 5 July 2026 cutoff, and reallocated into ARECOMS's discretionary "strategic quota" pool (already ~10% of the 96,600 t/yr authorised volume) earmarked for national-interest local-processing projects. This is an escalation/operationalisation of the filed 2025-02-22 ARECOMS cobalt quota system: it concentrates additional volume under state discretionary control, tightens the effective free-market allocation for producers (Glencore/KCC, CMOC, ERG) on the world's dominant cobalt chokepoint (~76% of mine supply), and — via the linked customs-notification malfunction that blocked quota-linked export declarations after 1 July 2026 — created a real short-run supply interruption. IPTM action would be an AMENDMENT to 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system.
source ↗Cobalt — bulk input, battery cathodes. Used in POSCO Future M's high-voltage mid-nickel NCM/NCMA cathode formulations; the company states it is actively working to reduce cobalt content given its concentration/price risk (DRC-dominated supply).
DR Congo supplies 74% of world cobalt mining — that share of your supply base is what this measure cuts off.
Supply outside 🇨🇩 CD: 🇮🇩 ID 66% · 🇷🇺 RU 12% · 🇲🇬 MG 6.1% · 🇵🇭 PH 5.6% — shares renormalised after removing CD.
JP · stage awaiting-signature → high likelihood · touches nickelchromium · flagged 29 Jun 2026, 98d pending
Japan's METI + MOF made an affirmative PRELIMINARY determination in an anti-dumping investigation (initiated 22 Jul 2025 on an application from Nippon Steel, Nippon Yakin Kogyo, NAS Stainless Steel Strip and Nippon Kinzoku) into nickel-added cold-rolled stainless steel coil, sheet and strip originating in the People's Republic of China and the separate customs territory of Taiwan (Penghu, Kinmen, Matsu); Trade Minister Ryosei Akazawa indicated provisional duties of ~45% on Chinese product and ~21% on Taiwanese product, expected to take effect as soon as July 2026. On 19 Jun 2026 METI/MOF EXTENDED the investigation period by four months to 21 Nov 2026 (final determination pending). IPTM relevance: (1) a RARE Japan-issuer trade remedy — JP has ZERO trade-remedy actions on the register and seldom uses AD, so a Japanese AD wall is a notable issuer + instrument-bloc gap; (2) China/Taiwan-target on nickel-added stainless steel, a nickel+chromium chokepoint-adjacent material; re-prices a China/TW->Japan stainless flow into a major downstream manufacturing base; (3) parallels the active 2025-26 Asian steel-AD wave the register is now capturing (Thailand DFT aluminium-extrusions, Indonesia KADI HRC, Malaysia MITI galvanised steel).
source ↗Nickel — bulk input, both businesses. POSCO Future M's cathode materials for standard and premium EVs run 60-95%+ nickel content; POSCO's stainless-steel business also consumes nickel as an alloying element. The group is building its own supply via a 120,000-tonne/year nickel MHP plant in Sulawesi, Indonesia (phase one: 60,000 t/y from 2025), reducing reliance on the concent…
Chromium — bulk input, stainless steel. POSCO holds 100% of Poschrome, a South African ferrochrome (chromium alloy) producer acquired from Samancor Chrome; ferrochrome is an essential input to POSCO's stainless steel.
A duty raises the cost of the origins the measure names into Japan's market — a cost line on affected flows, not lost availability. Origins outside the measure's named targets are the route around it; the text above names the targets where its source does.
chromium — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).
Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the…
Establishes the first legally binding "safe level" benchmark for EU strategic stocks of each of the 17 strategic raw materials listed in the CRMA Annex I; benchmarks used as reference by Member State…
If enacted, chrome ore export tax and/or quota would disrupt South Africa's ~2.
President Peter Mutharika signed an executive order (dated 23 Oct 2025, effective 21 Oct 2025, announced at Sanjika Palace during a cabinet swearing-in) prohibiting the export of raw/unprocessed mine…
Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No.
Gabon (CTRI transitional government, President Oligui Nguema) announced at Africa Forward Summit in Nairobi (May 2026) its intention to subscribe to Eramet SA's €500M capital increase, giving the Gab…
Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators…
Revises 30 CFR Part 580 to streamline 10 provisions governing prospecting, leasing, and operations for hard minerals (manganese nodules, cobalt-rich crusts, seafloor massive sulfides) on the US Outer…
Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising…
RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence…
Cabinet-cleared bill to replace the 2006 Minerals and Mining Act, Act 703: raises mining royalties from current 3–5% range to 9–12% (price-linked sliding scale), introduces a new medium-scale mining…
Madagascar's Council of Ministers approved resumption of mining-permit issuance on ~28-29 Jan 2026, ending a moratorium in place since 2010 (imposed during a political transition amid mining-title sp…
Minister of Mines, Petroleum and Energy Mamadou Sangafowa-Coulibaly formally launched the revision of Côte d'Ivoire's 2014 Mining Code on 13 June 2026, standing up an expert team drawn from his minis…
Minister of Finance, acting under s.
Chinese battery-materials major Zhejiang Huayou Cobalt (603799.
Prohibits raw mineral exports unless 30% value-addition achieved domestically; affects Chinese mining companies (dominant in Nigerian critical minerals sector), Western offtake agreements, and all fo…
Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including bord…
10% free-carried state equity in ALL new mining and energy projects (no-cost government stake via Epangelo Mining); consultations on 51% Namibian ownership in new mining ventures; maximum royalty rat…
Second wave of CRMA Art.
On 10 July 2026 the African Development Bank Group, with the African Union Commission, the AfCFTA Secretariat and UNECA, convened African ministers of mining/energy/industry in Abidjan for the "Minis…
VP Constantino Chiwenga announced at the Zimbabwe-China Business Forum (Hangzhou) that Zimbabwe will no longer issue new mining licences for operations that extract only one mineral from a deposit —…
Zimbabwean officials have signalled intent ("raw chrome exports obsolete") to expand the 25-Feb-2026 raw-mineral/lithium-concentrate export ban (filed) to cover chrome CONCENTRATE specifically — conc…
On 28-Nov-2025 European Metals Holdings announced the Czech government approved a grant of up to EUR 360M under the Ministry of Industry and Trade's "Strategic Investments for a Climate-Neutral Econo…
In March 2026 the outgoing Boric administration reportedly fast-tracked and submitted to the Contraloría General de la República (Chile's comptroller) a batch of ~5 further Contratos Especiales de Op…
Draft law amending Morocco's 2015 Mining Code (led by the Ministry of Energy Transition and Sustainable Development, Minister Leila Benali), with public consultations reported open since ~Feb 2025.
New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12.
Gabon = ~25% world manganese reserves, world's 2nd largest manganese ore exporter (~8 Mt/year via COMILOG/Eramet); ban on raw ore exports forces domestic processing investment (silicomanganese, EMD,…
If adopted, creates a unified mining regulatory framework across Cameroon, CAR, Congo-Brazzaville, Gabon, Equatorial Guinea, and Chad — harmonising licensing regimes, fiscal terms, transparency oblig…
Ministry of Mines issued operational guidelines for the Mining Sector Reforms component under Scheme for Special Assistance to States for Capital Investment (SASCI) FY2026-27, with total ₹5,000 crore…
The 12 July 2025 Bougival Accord (13-page political agreement creating a "State of New Caledonia" within France, pending a 2026 referendum + French organic law) contains an economic-rebuilding pact t…
Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in advanced negotiations to acquire a 15-20% equity stake (deal value ~USD 1.
Full replacement of the Mining Act 1992 with sweeping new statute: state acquires up to 30% equity in any new mining project (Kumul Minerals free-carry); special mining leases (SML) issued for initia…
Indonesia = ~50% global nickel mine supply and dominant producer of NPI/ferronickel/MHP; export duty on downstream nickel products (NPI, ferronickel, nickel matte, MHP) would add a material cost laye…
All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension;…
The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — cover…
On 11 May 2026 Huayou Cobalt announced an all-cash agreement to acquire ASX/AIM-listed Atlantic Lithium for USD 210m, taking control of the Ewoyaa project (~1.
On 11 Feb 2025 the Attorney General of Canada filed a Notice of Application (Federal Court file T-472-25) seeking a court order under ICA s.
5 of 74 filed an explicit in-force stage; the rest (flagged below) default from an absent stage: field, not a filed assertion. Each links to the register entry with its primary source.
⚠ Extraterritorial measure — switching supplier origin may not exit its scope.
China State Council enacts unified Regulations on Export Control of Dual-Use Items claims reach over foreign-made goods (“extraterritorial”) — the rule follows the material, not the seller, so an alternative outside the issuer can still be captured if its products contain or are made with in-scope inputs. Verify each alternative's feedstock origin before treating it as an exit.
For a material it buys, a restriction tightens supply and raises input cost — a headwind. For the 1 it produces, the same restriction supports pricing — a tailwind. Scores are footprint-adjusted and buyer-relative (0–100, higher = more exposed).
Its customers sit in critical minerals — read via the graph's critical minerals processing node, the nearest equivalent of its sector. A measure supporting those sectors supports demand for this company's products; one restricting them puts that demand at risk. The sign shown is the mechanical read — click through to judge whether a measure protects or constrains the customer.
For each bought material: the ex-controller producers a procurement team can actually reach, from the alternatives map (derived 2026-10-05), viability-gated — each name carries its deployment status (with the verbatim dossier phrase it rests on), a capture check against the measure being escaped, and any contracted-capacity evidence. Deployable-now names sort first; a developer with zero tonnes is shown demoted, never dressed up as a switch you can make today. Tradability is inherited from the listing layer, never guessed.
This company sits on the supply side of chromium. Restrictions by 🇨🇳 CN push buyers toward ex-CN producers — the strategy is to be visible where those buyers look: the chromium chokepoint page and the watchlist.
⚠ Extraterritorial measure — switching supplier origin may not exit its scope.
China State Council enacts unified Regulations on Export Control of Dual-Use Items claims reach over foreign-made goods (“extraterritorial”) — the rule follows the material, not the seller, so an alternative outside the issuer can still be captured if its products contain or are made with in-scope inputs. Verify each alternative's feedstock origin before treating it as an exit.
No alternative in our corpus is currently producing — every name below is pre-production, possibly captured, or unverified. Treat this list as a research bench, not a switch you can make today.
+11 more tradable names, ranked below these by the same gate.
+26 more tradable names, ranked below these by the same gate.
+26 more tradable names, ranked below these by the same gate.
+34 more tradable names, ranked below these by the same gate.
+2 more tradable names, ranked below these by the same gate.
lib/policy-transmission.ts): an export prohibition in the measure's name/text → supply restriction; a raw/unprocessed-export limit or local-processing mandate → beneficiation (form change, not unavailability); reporting/disclosure/due-diligence language → compliance obligation; tariff/trade-remedy language → import cost; subsidy/fast-track/relaxation language → support; investment-screening/M&A language → investment control. When the text carries no signal we fall back to the action-type default and label the chip inferred; when neither exists the card says so and derives no response — we never assert a class the evidence doesn't support.lib/iptm-material-country-production.ts; mining stage preferred, refining as fallback — the stage and source year are in each figure's hover text). Ex-issuer supply removes the ISSUING country and renormalises the remaining listed shares (so they sum to 100% of what's left) — alternatives to the country making the rule, never a default ex-China list. Where the issuer holds no measurable share, the card says so plainly instead of implying supply loss.lib/alternative-viability.ts): each named alternative carries a deployment status — operating / ramping / restarting / development / unknown — derived from word-boundary signal phrases in its own dossier (“operating since 1896”, “restarting the … mine”, “FID taken”), and the verbatim matched phrase is shown as the basis so the claim is auditable; a dossier with no signal stays unknown, never guessed. Any evidenced production date is quoted verbatim (“first production targeted H2 2029” → “no tonnes before 2029”) — we never synthesize one. A measure whose own text claims extraterritorial / re-export / de-minimis / foreign-direct-product / percentage-of-value scope triggers the origin-switching warning above the list: such a rule follows the material, not the seller, so a foreign-made alternative can still be captured. Same-issuer register actions targeting an alternative's country and material mark it may be captured, with the entries linked. “Capacity partly committed” lines quote the dossier verbatim — we hold no structured free-capacity numbers and never imply a utilisation figure.How MacroLens tracks this for you. The policy register files new measures daily and this page recomputes from it — the same chokepoints are monitored live on the watchlist and in the full register.