Home / Companies / Saubermacher Dienstleistungs AG / Outlook

Saubermacher Dienstleistungs AG — policy outlook

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 recycling. Company profile →

18upcoming at elevated+Forward outlook50 in pipeline80 in force (sev ≥ 3)5 tracked materials (5 produced)0 customer sectors

1 · What they make

Saubermacher Dienstleistungs AG is an Austrian waste management and recycling group headquartered in Feldkirchen bei Graz, majority-owned by the founding Roth family's Roth-Privatstiftung (72.21%) alongside a ~27.8% minority stake held by Germany's REMONDIS International GmbH since June 2026, serving roughly 1,600 municipalities and 40,000+ companies across Central and Southeast Europe.

Rest of the descriptionShow

Its business spans household/municipal waste collection, hazardous waste treatment, refrigerator/freezer (WEEE) recycling, RDF/substitute-fuel production, and portable-battery recycling — it is a waste-management and materials-recovery operator, not a manufacturer.

Verbatim from the dossier's “What they do” section — sources on the company profile.

2 · Where it operates — production footprint

4production countries in its dossier · approx. output shares

This is where Saubermacher Dienstleistungs AG 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.

🇦🇹 Austria≈40%

Premstätten — wastewater treatment (~20,000t/yr)
Retznei — substitute fuel / RDF production (ThermoTeam)
Graz — plastic packaging sorting
Trofaiach — portable-battery sorting; industrial/hazardous wastewater treatment

🇩🇪 Germany≈30%

Offenbach — household/portable battery recycling — alkaline-manganese, zinc-carbon, NiMH (25,000 t/yr)
Ginsheim-Gustavsburg — household-battery sorting JV with Meinhardt Städtereinigung (AI/X-ray sorted by chemistry, up to 100 t/day, opened Apr-2026)

🇨🇿 CZ≈15%

Havlíčkův Brod — refrigerator/freezer recycling

🇸🇮 SI≈15%

Kidričevo — hazardous waste processing (~51,000t/yr)

3 · Composition — the materials that matter

5tracked critical materials · 5 produced, 0 bought

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.

manganeseproduces🇨🇳 CN controls supply83

Nickel and manganese — structural component of Saubermacher's own Offenbach am Main site (Germany), which recycles household and portable batteries (alkaline-manganese, zinc-carbon, nickel-metal-hydride) at ~25,000 t/yr, recovering nickel- and manganese-bearing fractions as saleable secondary raw material.

copperproduces🇨🇳 CN controls supply68

Copper and aluminium — structural components recovered at the Havlíčkův Brod (Czech Republic) refrigerator/freezer recycling plant, where compressor windings and casings/heat exchangers are separated into copper and aluminium fractions.

nickelproduces🇨🇳 CN controls supply64

aluminiumproduces🇨🇳 CN controls supply49

zincproduces🇨🇳 CN controls supply44

Zinc — same Offenbach line, from zinc-carbon and alkaline-manganese battery bodies; a bulk output stream of that process rather than a trace by-product.

Examined and excluded

The dossier also records the materials it investigated and rejected — the list above is narrowed deliberately, not cherry-picked. Its own words:

“Corrected out of the sector-derived defaults: lithium and cobalt. Saubermacher's lithium-ion "active mass" (nickel/cobalt/lithium/copper) production line was always at a different site — Bremerhaven, Germany, operated under the REDUX brand — which was sold to Redwood Materials in 2023. Saubermacher's current EV-battery-recycling service page describes that lithium-ion processing as a partnership with Redwood, not Saubermacher's own operation; Offenbach (which Saubermacher retained) handles a different, non-lithium-ion battery chemistry mix. Silver (also a sector default) is dropped for lack of any source tying it to a Saubermacher site.”

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.

4 · Threats & opportunities — in the pipeline

50proposed measures matching its inputs or sector · top 5 ranked by imminence × relevance · 18 at elevated+ likelihood

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.

#1🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)highBeneficiation / form changepossible opportunity — supply side

1 · If this passes

BR · stage passed-vote → high likelihood · touches manganese copper · 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 ↗

2 · What it hits for you

3 · Your options

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.

manganese — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).

copper — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).

#2🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)highSupply restrictionpossible opportunity — supply side

1 · If this passes

CD · stage passed-vote → high likelihood · touches copper · 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 ↗

2 · What it hits for you

3 · Your options

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.

copper — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).

#3🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)highSupply restrictionpossible opportunity — supply side

1 · If this passes

CN · stage passed-vote → high likelihood · touches copper · flagged 25 Jul 2026, 72d pending

Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.

source ↗

2 · What it hits for you

3 · Your options

copper — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).

#4🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)elevatedUnclassified · inferredpossible opportunity — supply side

1 · If this passes

US · stage passed-committee → elevated likelihood · touches manganese copper nickel · flagged 23 Jun 2026, 104d pending

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 Continental Shelf; eliminates environmental notification to adjacent state governors (§580. 31) and BOEM's own environmental review requirement (§580. 29); accelerates OCS hard mineral leasing pipeline in line with EOs 14285 and 14154 ("unleashing" OCS resources); comment period closed April 27, 2026; awaiting final rule

source ↗

2 · What it hits for you

3 · Your options

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.

manganese — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).

copper — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).

Further materials are covered in section 6 below.

#5🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)highSupply restrictionpossible opportunity — supply side

1 · If this passes

MW · stage passed-vote → high likelihood · touches copper aluminium · flagged 13 Aug 2026, 53d pending

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 minerals extracted in Malawi — uranium, rare earth elements, niobium, graphite, tantalum, bauxite, coal, limestone, gemstones, heavy mineral sands, vermiculite, phosphate, rutile, gold, diamonds, copper and others — with an exemption for minerals processed/refined/value-added domestically per Malawian mining law. Announced alongside a suspension of new mining-licence issuance and a review of mining laws (2026/27 State of the Nation Address), plus a planned sovereign wealth fund. Stated rationale: local beneficiation, targeting up to USD 500m/yr once the Kasiya rutile/graphite deposit (Lilongwe) and Kangankunde rare-earth project (Balaka, Mkango Resources — Africa's prospective first new REE mine since 2017, targeting late-2026 production) are fully developed. Violators face fines/penalties under Malawian law. MW is currently the THINNEST country in the register (1 prior action) despite this breadth of minerals covered. Export-ban/beneficiation-mandate, same instrument class as Zimbabwe's SI 213/2022 raw-mineral bans and Guinea's 2026 gold-export ban already in the register.

source ↗

2 · What it hits for you

3 · Your options

The prohibition covers the raw/unprocessed form; material processed in Malawi stays exportable under the order's own exemption — so a Malawi processing route remains open alongside the alternatives below.

copper — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).

aluminium — you sit on the supply side: a measure tightening others' supply pushes buyers toward you, so your move is positioning, not substitution (chokepoint page).

45 more in the pipelineShow

🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptionshighUnclassified · inferred

stage awaiting-signature → high · touches nickel, copper · flagged 26 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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…

🇬🇦 Gabon — Government to Subscribe to Eramet €500M Capital Increase, Acquiring Equity Stake in French Parent CompanyhighBeneficiation / form change

stage passed-vote → high · touches manganese · flagged 26 Jun 2026 · changes the form/terms of the issuer’s exports, not their availability

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…

🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026highBeneficiation / form change

stage passed-vote → high · touches copper · flagged 31 Jul 2026 · changes the form/terms of the issuer’s exports, not their availability

Minister of Finance, acting under s.

🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining PolicyelevatedUnclassified · inferred

stage passed-committee → elevated · touches aluminium, manganese · flagged 17 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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…

🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime ReformelevatedUnclassified · inferred

stage passed-committee → elevated · touches copper, zinc · flagged 14 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mini…

🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)moderateUnclassified · inferred

stage in-consultation → moderate · touches manganese, nickel, aluminium · flagged 9 Sept 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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…

🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensingmoderateUnclassified · inferred

stage draft-published → moderate · touches copper, manganese, nickel · flagged 27 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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…

🇬🇳 Guinea — Nimba Mining Company (NMC SA) Signs First Base Mining Convention (Tinguilinta Bauxite Concession, Boké)highUnclassified · inferred

stage passed-vote → high · touches aluminium · flagged 10 Sept 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

On 6 August 2026, at a ceremony at the Petit Palais of the Presidency chaired by Djiba Diakité (Minister Chief of Staff, chair of the Simandou 2040 Strategic Committee), Guinea's wholly state-owned N…

🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority righthighUnclassified · inferred

stage passed-vote → high · touches copper · flagged 29 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No.

🇯🇵 Japan METI/MOF Anti-Dumping Duty on Nickel-Added Cold-Rolled Stainless Steel Coil/Sheet/Strip from China and TaiwanhighImport cost

stage awaiting-signature → high · touches nickel · flagged 29 Jun 2026 · raises the cost of named origins into the issuer’s market — a cost line, not lost supply

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 S…

🇬🇳 Guinea Bauxite Export Volume Controls — Mines Minister Sylla Quota Regime (2026)moderateSupply restriction

stage in-consultation → moderate · touches aluminium · flagged 16 Jun 2026 · restricts outbound flow from the issuer — the response is ex-issuer sourcing

Guinea = world's #2 bauxite producer (183 Mt exported in 2025, ~45% of China's bauxite imports); Mines Minister Bouna Sylla confirmed in March 2026 that export volume curbs will be applied by early A…

🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrumentelevatedSupport / opportunity

stage consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29) → elevated · touches nickel, manganese, copper · flagged 30 Jul 2026 · support / opportunity, not a threat

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…

🇲🇬 Madagascar — Council of Ministers lifts 16-year moratorium on new mining-permit issuance (except gold), effective ~29 Jan 2026highSupport / opportunity

stage passed-vote → high · touches nickel, aluminium · flagged 13 Aug 2026 · support / opportunity, not a threat

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…

🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock BenchmarkshighCompliance obligation

stage awaiting-signature → high · touches nickel, manganese · flagged 15 Jun 2026 · an obligation on you — audit and file; it prohibits importing from nowhere, so no supplier change is implied and we list none

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…

🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y MetalurgiamoderateUnclassified · inferred

stage draft-published → moderate · touches zinc, copper · flagged 17 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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.

🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before exporthighBeneficiation / form change

stage awaiting-signature → high · touches zinc · flagged 14 Jun 2026 · changes the form/terms of the issuer’s exports, not their availability

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…

🇪🇺 STAGE UPDATE — EU CBAM COM(2025)989 Downstream Extension: Council adopts general approach June 12, 2026elevatedUnclassified · inferred

stage passed-committee → elevated · touches aluminium · flagged 26 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

Council's general approach expands the Commission's proposed downstream scope further (more products than Commission proposed); mandates annual Commission review for future scope additions; adds anti…

🇺🇸 USTR Plurilateral Agreement on Trade in Critical MineralsmoderateSupport / opportunity

stage in-consultation → moderate · touches nickel, copper, manganese · flagged 18 Jun 2026 · support / opportunity, not a threat

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…

African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)lowSupply restriction

stage announced → low · touches copper, manganese, aluminium · flagged 31 Jul 2026 · restricts outbound flow from the issuer — the response is ex-issuer sourcing

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…

🇬🇭 Ghana Minerals and Mining Act 703 Amendment — Cabinet-Approved Proposal (Royalty 9-12%, Lease Cuts, DA Abolition)moderateUnclassified · inferred

stage draft-published → moderate · touches aluminium · flagged 23 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

Gold mining royalties rise from 3-5% to 9-12% sliding-scale (price-indexed); mining lease maximum cut 30→15 years with renewals limited to 2×10-year additional terms; Development Agreements and Inves…

🇬🇳 Guinea Ministry of Mines — Bauxite Export Volume Cap (~150 Mt/yr, 2026)moderateUnclassified · inferred

stage in-consultation → moderate · touches aluminium · flagged 19 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

~25% reduction in Guinea's annual bauxite shipments to China (150 Mt target vs.

🇪🇺 EU CBAM Scope Expansion to ~180 Downstream Steel/Aluminum Products (COM(2025) 989 final)moderateUnclassified · inferred

stage draft-published → moderate · touches aluminium · flagged 16 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

Extends the Carbon Border Adjustment Mechanism from the existing Regulation (EU) 2023/956 sectors (steel, aluminium, cement, fertilisers, hydrogen, electricity) to approximately 180 downstream produc…

🇳🇦 Namibia new Minerals Bill (Minerals Prospecting and Mining Act overhaul)moderateUnclassified · inferred

stage in-consultation → moderate · touches manganese · flagged 14 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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…

🇬🇳 Guinea — Ministry of Mines plan to reduce bauxite export volumes to support prices (differential quota/allocation tied to downstream-investment commitments)lowSupply restriction

stage announced → low · touches aluminium · flagged 31 Jul 2026 · restricts outbound flow from the issuer — the response is ex-issuer sourcing

On 18 March 2026 Guinea's Minister of Mines Bouna Sylla told Reuters that Guinea — the world's top bauxite exporter (~40% of global seaborne supply, 2025 exports ~183 Mt, +25% y/y) — would reduce exp…

🇬🇳 Guinea bauxite export curbs / production-cap regime — Ministry of Mines & Geology sector-wide export-control measure (announced, no decree yet)lowSupply restriction

stage announced → low · touches aluminium · flagged 14 Jul 2026 · restricts outbound flow from the issuer — the response is ex-issuer sourcing

Guinea — the world's largest bauxite exporter (~single-largest feed to China's alumina/aluminium chain) — is preparing a sector-wide measure to CAP/reduce bauxite exports to stabilise falling prices…

🇬🇦 Gabon — Government Announcement: Ban on Crude Manganese Ore Exports from January 1, 2029lowSupply restriction

stage announced → low · touches manganese · flagged 19 Jun 2026 · restricts outbound flow from the issuer — the response is ex-issuer sourcing

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,…

🇪🇺 EU CRMA Strategic Projects — Second Designation RoundmoderateSupport / opportunity

stage in-consultation → moderate · touches manganese, nickel · flagged 15 Jun 2026 · support / opportunity, not a threat

Second wave of CRMA Art.

🇮🇩 Indonesia PP 19/2025 Mining Royalty Rate Hike — Implementation Postponed Indefinitely (May 2026)lowUnclassified · inferred

stage announced → low · touches nickel, copper · flagged 16 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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…

🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrumentmoderateBeneficiation / form change

stage in-consultation → moderate · touches nickel · flagged 29 Jun 2026 · changes the form/terms of the issuer’s exports, not their availability

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…

🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipelinelowSupport / opportunity

stage announced → low · touches aluminium, manganese, copper, nickel · flagged 26 Jun 2026 · support / opportunity, not a threat

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…

🇳🇨 New Caledonia (France) — "renewed nickel doctrine" + nickel-industry recovery pact under the Bougival AccordlowBeneficiation / form change

stage announced → low · touches nickel · flagged 14 Jul 2026 · changes the form/terms of the issuer’s exports, not their availability

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…

🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assetslowInvestment control

stage announced → low · touches copper, nickel · flagged 28 Jun 2026 · affects deal-making (stakes, M&A, JVs), not material flow

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.

🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)lowInvestment control

stage announced → low · touches copper, nickel · flagged 18 Jun 2026 · affects deal-making (stakes, M&A, JVs), not material flow

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…

CEMAC Common Mining Code — 6-member regional harmonisation (April 2026)moderateCompliance obligation

stage draft-published → moderate · touches manganese · flagged 20 Jun 2026 · an obligation on you — audit and file; it prohibits importing from nowhere, so no supplier change is implied and we list none

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…

🇬🇳 Guinea — Nimba Mining Company (NMC, 100% state-owned) / Glencore bauxite pre-financing and marketing agreementlowUnclassified · inferred

stage announced → low · touches aluminium · flagged 22 Sept 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

On 7 September 2026 Guinea's state-owned Nimba Mining Company and Glencore signed a five-year pre-financing agreement, announced by the government and Glencore on 10 September 2026, worth over USD 30…

🇮🇩 Indonesia NPI/Ferronickel/MHP Export Duty — ESDM Commitment, April 2026 Launch Postponed IndefinitelylowUnclassified · inferred

stage announced → low · touches nickel · flagged 25 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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…

🇬🇳 Guinea Bauxite Exchange (GBX) — Mines Minister Bouna Sylla announced July 2025 national bauxite price index targeting FOB pricing transparency and closing gap between declared export values and market prices; planned launch end-2025; Prospect Intel confirmed Guinea-Conakry launched GBX to reclaim pricing control; no enacted arrêté/décret confirmed in primary gazette sourceslowUnclassified · inferred

stage announced → low · touches aluminium · flagged 25 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

Supersedes 2022 bauxite reference price arrêté; establishes real-time FOB benchmark for all Guinea bauxite exports (~182 Mt/yr, world's largest supplier); estimated >$1bn/yr additional government rev…

🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026lowUnclassified · inferred

stage announced → low · touches copper · flagged 23 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

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;…

🇬🇳 Guinea Alumina Refinery Ultimatum — SMB and CBG 10-Day Deadline to Submit Construction Timeline (June 2026)lowUnclassified · inferred

stage announced → low · touches aluminium · flagged 16 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

Guinea's CNRD junta gives Societe Minière de Boke (SMB, China-linked, ~50% of Guinea's bauxite output) and Compagnie des Bauxites de Guinée (CBG, joint venture: Halco Mining/Alcoa/Rio Tinto/Dadco) 10…

🇬🇳 Guinea Bauxite Export Volume Controls 2026lowUnclassified · inferred

stage announced → low · touches aluminium · flagged 13 Jun 2026 · mechanism unclear from the filed text — read the measure; we don’t guess

GN ≈ 60% global seaborne bauxite; a ~150 Mt/yr cap (vs 183 Mt 2025) tightens the alumina→aluminium chain — direct hit to EU aluminium-vertical names

🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, SudanlowInvestment control

stage announced → low · touches copper · flagged 4 Oct 2026 · affects deal-making (stakes, M&A, JVs), not material flow

State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar…

🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold projectlowInvestment control

stage announced → low · touches copper · flagged 28 Jun 2026 · affects deal-making (stakes, M&A, JVs), not material flow

Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring…

🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold projectlowInvestment control

stage announced → low · touches copper · flagged 27 Jun 2026 · affects deal-making (stakes, M&A, JVs), not material flow

Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one…

🇸🇱 Sierra Leone No Raw Minerals Export Commitment (VP Jalloh, Mining Week May 2026)lowBeneficiation / form change

stage announced → low · touches aluminium · flagged 14 Jun 2026 · changes the form/terms of the issuer’s exports, not their availability

VP declared no new large-scale mining agreement will be concluded without a binding value-addition commitment; Mines Minister referenced Zimbabwe, Tanzania, Ghana, and Malawi precedents for raw-miner…

🇧🇷 Brazil BNDES "Mais Inovação" loan to Wave Aluminium Brasil SA (New Wave) — BRL 221m demonstration plant financing for bauxite-residue processing (Barcarena, Pará)lowSupport / opportunity

stage announced → low · touches aluminium · flagged 10 Jul 2026 · support / opportunity, not a threat

On 16 November 2025 Brazil's national development bank BNDES signed a BRL 221 million (~USD 41.

4b · Already in force

80in-force restrictions (severity ≥ 3) on its tracked materials

4 of 80 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.

US Section 232 Copper Tariff (Proclamation 10962): 50% on semi-finished + derivative copper🇺🇸 Tariff · coppersev 5

stage not filed — treated as in force

Mali Décret 2024-0396/PT-RM implementing 2023 Code Minier (Loi 2023-040)🇲🇱 Industrial policy · aluminiumsev 5

stage not filed — treated as in force

Panama Supreme Court declares Law 406/2023 (Minera Panamá / Cobre Panamá concession) unconstitutional🇵🇦 Regulatory · coppersev 5

stage not filed — treated as in force

77 more in-force restrictionsShow

Zimbabwe SI 5 of 2023 — Base Minerals Export Control (Unbeneficiated Base Mineral Ores) Order, 2023🇿🇼 Export control · copper, nickelsev 5

stage not filed — treated as in force

Indonesia bans raw nickel ore exports to force domestic processing🇮🇩 Export control · nickelsev 5

stage not filed — treated as in force

CMOC acquires 80% of Tenke Fungurume, world's second-largest cobalt mine🇨🇳 Industrial policy · coppersev 5

stage not filed — treated as in force

South Africa Mineral and Petroleum Resources Development Act (MPRDA), Act No. 28 of 2002🇿🇦 Industrial policy · manganesesev 5

stage not filed — treated as in force

US Defense Production Act of 1950 (Pub. L. 81-774) — parent industrial-mobilization and domestic-capacity statute🇺🇸 Industrial policy · manganese, nickelsev 5

stage not filed — treated as in force

Canada expands counter-tariffs on US goods to CA$27.6bn, matching US Section 338/232 tariffs dollar-for-dollar🇨🇦 Tariff · aluminiumsev 4

stage not filed — treated as in force

BIS DPAS Directive Allocation Order — 100% domestic-sale mandate for black mass and tungsten waste/scrap🇺🇸 Export control · manganese, nickelsev 4

stage not filed — treated as in force

Mozambique mining-sector reform bill (INAMI public consultation): 15% state stake, raw-mineral export ban, 25-year concessions, 10% local-development levy🇲🇿 Industrial policy · aluminiumsev 4

stage not filed — treated as in force

UK Carbon Border Adjustment Mechanism — Finance Act 2026 primary statutory framework (live 1 Jan 2027)🇬🇧 Tariff · aluminiumsev 4

stage not filed — treated as in force

Indonesia ESDM confirms 2026 nickel-ore RKAB quota cut to 260–270 million wmt🇮🇩 Industrial policy · nickelsev 4

stage not filed — treated as in force

Turkey 2026 Import Regime — Cumhurbaşkanı Kararı No. 10790 (cross-sectoral surveillance + additional duties up to 48% on non-EU)🇹🇷 Tariff · copper, aluminiumsev 4

stage not filed — treated as in force

Kazakhstan amends Subsoil Code to grant Kazatomprom statutory priority over uranium blocks and reorganises subsoil-use governance🇰🇿 Industrial policy · coppersev 4

stage not filed — treated as in force

DRC Arrêté 00964/2025 — Immediate suspension of all artisanal copper-cobalt processing and marketing entities🇨🇩 Regulatory · coppersev 4

stage not filed — treated as in force

Indonesia Permen ESDM 17/2025 — RKAB annual cycle and MinerbaOne quota system🇮🇩 Regulatory · copper, nickel, aluminiumsev 4

stage not filed — treated as in force

Australia Net Zero Plan 2050 and Six Sector Emissions Reduction Plans🇦🇺 Industrial policy · nickelsev 4

stage not filed — treated as in force

US-EU Joint Framework on Reciprocal, Fair and Balanced Trade (15% all-inclusive tariff ceiling on EU goods)🇺🇸 Tariff · aluminiumsev 4

stage not filed — treated as in force

Vietnam Decree 193/2025/ND-CP: Comprehensive Implementing Decree for the Law on Geology and Minerals🇻🇳 Regulatory · coppersev 4

stage not filed — treated as in force

Indonesia PP 28/2025 risk-based business licensing — Appendix 1F embeds OSS moratorium on intermediate-nickel smelters (matte, MHP, NPI, FeNi)🇮🇩 Industrial policy · nickelsev 4

stage not filed — treated as in force

Gabon Raw Manganese Export Ban (Effective 1 January 2029)🇬🇦 Export control · manganesesev 4

stage not filed — treated as in force

CMOC acquires Ecuador's largest gold deposit via Lumina Gold takeover and signs $1.7B exploitation contract🇨🇳 Industrial policy · coppersev 4

stage not filed — treated as in force

Indonesia PP 19/2025 — Tiered Minerba Royalty Regulation🇮🇩 Industrial policy · copper, nickelsev 4

stage not filed — treated as in force

EU Steel and Metals Action Plan — COM(2025) 122 final🇪🇺 Industrial policy · copper, nickel, aluminium, zincsev 4

stage not filed — treated as in force

EU Council Regulation 2025/395 — 16th sanctions package against Russia (primary aluminium import ban, 74-vessel shadow-fleet expansion, 13 banks SWIFT cut, oil-storage and Russian-airport transaction bans)🇪🇺 Sanction · aluminiumsev 4

stage not filed — treated as in force

India Cabinet approves National Critical Mineral Mission with ₹34,300 cr seven-year outlay covering 30 minerals🇮🇳 Industrial policy · copper, nickelsev 4

stage not filed — treated as in force

EU imposes definitive countervailing duties on Chinese battery electric vehicles🇪🇺 Tariff · nickelsev 4

stage not filed — treated as in force

Brazil Lei No. 14.948/2024 — Low-Carbon Hydrogen Legal Framework (PNH2BC, SBCH2, Rehidro)🇧🇷 Industrial policy · nickelsev 4

stage not filed — treated as in force

Indonesia Permen ESDM 6/2024: MEMR smelter-completion framework for copper, iron, lead and zinc concentrate exports🇮🇩 Regulatory · copper, zincsev 4

stage not filed — treated as in force

Indonesia bans copper concentrate and anode sludge exports under Permendag 10/2024🇮🇩 Export control · coppersev 4

stage not filed — treated as in force

US Section 301 tariff hikes on Chinese EVs, batteries, semis, solar, steel🇺🇸 Tariff · nickelsev 4

stage not filed — treated as in force

US Treasury (OFAC) Bans Import of Russian-Origin Aluminum, Copper and Nickel; Bars Exchange/Derivative Servicing🇺🇸 Sanction · copper, nickel, aluminiumsev 4

Panama Ley 407 — Indefinite moratorium on metallic mining concessions nationwide🇵🇦 Industrial policy · coppersev 4

stage not filed — treated as in force

EU CBAM Definitive Phase Entry Into Force🇪🇺 Tariff · aluminiumsev 4

stage not filed — treated as in force

Indonesia bans raw bauxite ore exports under Permendag 18/2022 (hilirisasi extension)🇮🇩 Export control · aluminiumsev 4

stage not filed — treated as in force

Australia Bans Export of Aluminium Ores, Alumina and Aluminium Hydroxide to Russia🇦🇺 Export control · aluminiumsev 4

stage not filed — treated as in force

DRC Loi n° 18/001 — Revised Mining Code: strategic-mineral royalties, state carry doubled, stability curtailed🇨🇩 Regulatory · coppersev 4

stage not filed — treated as in force

Tanzania Natural Wealth and Resources (Permanent Sovereignty) Act, 2017 (Act No. 5 of 2017, Cap. 449)🇹🇿 Industrial policy · nickelsev 4

stage not filed — treated as in force

US OFAC SDN Designations: Cuban Nickel-Sector State Enterprises (CEDINIQ, CEPRONIQUEL, SERCONI, Pinares S.A.)🇺🇸 Sanction · nickelsev 3

stage not filed — treated as in force

Japan imposes provisional anti-dumping duty (3.6%-42.1%) on nickel-added cold-rolled stainless steel from China and Taiwan🇯🇵 Tariff · nickelsev 3

stage not filed — treated as in force

US USTR Section 301 Determination — Proposed 25% Tariff on All Brazilian Goods🇺🇸 Tariff · coppersev 3

stage not filed — treated as in force

EU-US Trade: Political Agreement on Implementing Regulations for Joint Statement Tariff Commitments🇪🇺 Tariff · aluminiumsev 3

stage not filed — treated as in force

Guinea / GAC / EGA: Amicable Settlement Agreement — Bauxite Concession Dispute Resolved🇬🇳 Industrial policy · aluminiumsev 3

stage not filed — treated as in force

US OFAC April 30 2026 — designation of former DRC President Joseph Kabila under EO 13413/13671 for material support to M23 and Congo River Alliance (AFC)🇺🇸 Sanction · coppersev 3

stage not filed — treated as in force

Egypt PM Decree No. 1440/2026 — Executive Regulations of Mineral Resources Law 198/2014🇪🇬 Regulatory · copper, zincsev 3

stage not filed — treated as in force

China Customs Tariff Commission — Zero-Tariff Treatment for All 53 African Diplomatic Partners (May 2026–April 2028)🇨🇳 Tariff · copper, aluminiumsev 3

stage not filed — treated as in force

Tanzania Ministry of Minerals revokes 40 idle mineral exploration licences (188,163 ha; MBT reallocation)🇹🇿 Regulatory · nickelsev 3

Indonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform🇮🇩 Industrial policy · copper, nickel, aluminiumsev 3

stage not filed — treated as in force

Ghana Minerals Commission revokes 300+ small-scale mining licences and launches sector-wide local content reform package🇬🇭 Regulatory · aluminiumsev 3

Zambia: Government/ZEMA conclude Sino-Metals Leach Zambia spillage investigation, opening remediation and compensation process🇿🇲 Regulatory · coppersev 3

stage not filed — treated as in force

Ecuador Decreto Ejecutivo 273 — Reforma al Reglamento General a la Ley de Minería (sliding 3-8% royalty, 100% self-power mandate, tightened exploration timelines)🇪🇨 Regulatory · coppersev 3

stage not filed — treated as in force

Canada implements Buy Canadian Procurement Policy Framework🇨🇦 Industrial policy · aluminiumsev 3

stage not filed — treated as in force

US DOI / USGS Final 2025 List of Critical Minerals — 60-mineral statutory designation under the Energy Act of 2020🇺🇸 Regulatory · manganese, copper, nickelsev 3

stage not filed — treated as in force

Malawi Presidential Executive Order — Prohibition on Export of Raw Unprocessed Minerals (October 2025)🇲🇼 Export control · copper, aluminiumsev 3

stage not filed — treated as in force

US BIS designates 407 HTSUS codes as Section 232 steel/aluminum derivative products (first inclusions cycle)🇺🇸 Tariff · aluminiumsev 3

stage not filed — treated as in force

Guinea: Ministerial Order Revoking 129 Expired Mining Exploration Permits (May 2025)🇬🇳 Regulatory · aluminiumsev 3

stage not filed — treated as in force

Türkiye Opens Anti-Dumping Investigation into Chinese Aluminium Frames for Photovoltaic Panels (Tebliğ 2025/10)🇹🇷 Tariff · aluminiumsev 3

stage not filed — treated as in force

South Africa Mineral Resources Development Bill (MRDB) 2025 — MPRDA amendment gazetted for public comment🇿🇦 Industrial policy · manganesesev 3

stage not filed — treated as in force

Balochistan Mines and Minerals Act 2025 — provincial law centralising Balochistan mineral control under federal SIFC, establishing Mineral Investment Facilitation Authority (MIFA)🇵🇰 Industrial policy · coppersev 3

stage not filed — treated as in force

Lao PDR PM Order No. 06/PM — Permanent Alluvial Gold Ban and Metallic Mineral Project Moratorium🇱🇦 Regulatory · coppersev 3

stage not filed — treated as in force

South Africa adds base-metal tariff headings (iron, steel, copper, aluminium, lead, zinc, tin) to ITAC export-permit list🇿🇦 Export control · copper, aluminium, zincsev 3

stage not filed — treated as in force

Tanzania Written Laws (Miscellaneous Amendments) (No. 4) Act, 2024 — Mining Act critical/strategic minerals classification + USD 5m mining-licence capital floor🇹🇿 Industrial policy · nickelsev 3

stage not filed — treated as in force

EU Council adds seven Iranian entities to Russia-military-support sanctions list (Implementing Regulation 2024/2697)🇪🇺 Sanction · aluminiumsev 3

stage not filed — treated as in force

Japan bans exports of additional industrial goods to Russia (HS 27/28/39/73/81/82/84/85/89/90 lines) and imports of Russian-origin non-industrial diamonds🇯🇵 Export control · aluminiumsev 3

stage not filed — treated as in force

Ghana Minerals Commission issues local-beneficiation requirement: export ban on unprocessed bauxite, lithium, iron ore, and manganese🇬🇭 Export control · manganese, aluminiumsev 3

stage not filed — treated as in force

UK bans acquisition and import of Russian-origin metals (Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023, SI 2023/1364)🇬🇧 Export control · manganese, copper, nickel, aluminium, zincsev 3

Jordan National Mining Sector Strategy 2023-2033 — 10-year MEMR framework targeting JD 2.1bn sector GDP and expanded phosphate, potash, REE, uranium, and copper investment🇯🇴 Industrial policy · coppersev 3

stage not filed — treated as in force

Philippines Maharlika Investment Fund Act (RA 11954) — first national sovereign wealth fund with PHP 500bn target capital🇵🇭 Industrial policy · coppersev 3

stage not filed — treated as in force

Poland: Geological and Mining Law Amendment — Strategic Deposit Framework (Dz.U. 2023 poz. 2029)🇵🇱 Industrial policy · copper, nickelsev 3

stage not filed — treated as in force

Greenland Parliament Act on Mineral Activities (Mining Act) No. 27 of 13 June 2023🇬🇱 Industrial policy · zincsev 3

stage not filed — treated as in force

Namibia Cabinet 8th Meeting — Prohibition on Export of Unprocessed Critical Minerals🇳🇦 Export control · manganesesev 3

stage not filed — treated as in force

Zimbabwe SI 57 of 2023 — Base Minerals Export Control (Unbeneficiated Base Mineral Ores) (Amendment) Order, 2023 (No. 1)🇿🇼 Export control · copper, nickelsev 3

stage not filed — treated as in force

OFAC Burma: Myanmar Mining Enterprise No. 1 and No. 2 Designated as SDNs🇺🇸 Sanction · coppersev 3

stage not filed — treated as in force

Zambia Mines and Minerals Development (Amendment) Act, No. 29 of 2022 — Copper Mineral Royalty Sliding Scale🇿🇲 Tariff · coppersev 3

stage not filed — treated as in force

South Africa imposes 6-month export ban on ferrous/non-ferrous scrap metal, new export and import permits (Notices R.2801-R.2804)🇿🇦 Export control · coppersev 3

stage not filed — treated as in force

Guinea joint-ministerial arrêté — mandatory bauxite reference price mechanism🇬🇳 Regulatory · aluminiumsev 3

stage not filed — treated as in force

Canada: SEMA Russia Regulations amendment (SOR/2022-102) — luxury goods and weapons-production goods export ban🇨🇦 Export control · aluminiumsev 3

stage not filed — treated as in force

Uganda Mining and Minerals Act 2022🇺🇬 Industrial policy · coppersev 3

stage not filed — treated as in force

BIS Entity List: Four Burma-Based Entities Supporting SAC Military Coup🇺🇸 Export control · coppersev 3

stage not filed — treated as in force

5 · Impact — upstream (material inputs)

5scored materials · 5 produced, 0 bought

For a material it buys, a restriction tightens supply and raises input cost — a headwind. For the 5 it produces, the same restriction supports pricing — a tailwind. Scores are footprint-adjusted and buyer-relative (0–100, higher = more exposed).

manganese🇨🇳 CN controls · produces · 15 upcoming · 9 in force83

copper🇨🇳 CN controls · produces · 22 upcoming · 40 in force68

nickel🇨🇳 CN controls · produces · 17 upcoming · 25 in force64

The other 2 materialsShow

aluminium🇨🇳 CN controls · produces · 20 upcoming · 30 in force49

zinc🇨🇳 CN controls · produces · 3 upcoming · 6 in force44

5b · Impact — downstream (its customers)

Its sector (metals recycling) has no downstream edges in our supply-chain adjacency graph — no downstream signal in the register.

6 · Solution / strategy — the moves available

50 bought materials with a tradable substitute bench · 5 produced — benefit route

Every tracked material is on the supply side — the strategy here is positioning, not substitution.

manganesebenefit route

This company sits on the supply side of manganese. Restrictions by 🇨🇳 CN push buyers toward ex-CN producers — the strategy is to be visible where those buyers look: the manganese chokepoint page and the watchlist.

copperbenefit route

This company sits on the supply side of copper. Restrictions by 🇨🇳 CN push buyers toward ex-CN producers — the strategy is to be visible where those buyers look: the copper chokepoint page and the watchlist.

nickelbenefit route

This company sits on the supply side of nickel. Restrictions by 🇨🇳 CN push buyers toward ex-CN producers — the strategy is to be visible where those buyers look: the nickel chokepoint page and the watchlist.

aluminiumbenefit route

This company sits on the supply side of aluminium. Restrictions by 🇨🇳 CN push buyers toward ex-CN producers — the strategy is to be visible where those buyers look: the aluminium chokepoint page and the watchlist.

zincbenefit route

This company sits on the supply side of zinc. Restrictions by 🇨🇳 CN push buyers toward ex-CN producers — the strategy is to be visible where those buyers look: the zinc chokepoint page and the watchlist.

How these claims are derived (method)Show

Likelihood bands are derived deterministically from the legislative stage — announced → low; draft-published → moderate; in-consultation → moderate; consultation-closed → elevated; passed-committee → elevated; passed-vote → high; awaiting-signature → high. We never publish a point probability: no honest per-jurisdiction bill-passage base rate exists.
Upcoming measures come from our forward intake queue, matched to this company's scored materials and sector. Each carries the date we first flagged it and a public source.
Transmission classes are derived from what each instrument does, on explicit signals in its own text (with the taxonomy in 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.
The top-5 ranking is mechanical, not editorial: score = classWeight × (likelihood-band rank + 1) × (1 + Σ touched-material weights), where a material this company produces weighs 2 and one it buys weighs 1, and classWeight reflects severity of effect: supply restriction 4 / 3 / 2 (issuer's production share of a touched material ≥5% / measurable / unmeasured), beneficiation 3 / 2.5 / 1.5 on the same gates, import cost and unclassified 2, investment control 1.5, compliance and support 1. A reporting obligation can therefore never outrank a live supply restriction on a material this company depends on merely by name-checking many materials. Sector-only matches carry the base relevance. Ties break to the higher band, then the most recently flagged.
Issuer production shares come from the USGS-based production-share table (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.
Each chain card is assembled, never authored: step 1 quotes the measure's own expected-impact text (any date shown, including a compliance deadline, comes verbatim from that text or its source — we never synthesize one); step 2 quotes this company's own dossier bullet for the touched material verbatim, and says so plainly when the exposure is only sector-derived; step 3 is derived from the transmission class — for supply restrictions the tradable names shown are alternatives-map entries filtered to the ex-issuer production countries, where a tariff chip means a live register tariff entry by AT or the EU explicitly targets that material and supplier country (rate shown only when recorded), a subsidy/liberalising chip means a support measure by the supplier's own government on that material, and the EU/domestic chip is derived from the EU membership list. Every chip links to its register entry; no chip means no register signal, not "no risk".
In-force restrictions are register entries (stage in-force, effective severity ≥ 3) tagging its materials — every row links to the entry and its primary source.
Upstream scores are the footprint-adjusted, buyer-relative material scores from the company risk engine.
Customer sectors come from a hand-authored supply-chain adjacency graph (analyst judgement, weighted 0–1), the same graph the register's downstream-impact views propagate through. Where the company's sector label has no node of its own, the nearest equivalent node is used and labelled as such. The demand-support / demand-risk tag is a mechanical read of each measure's type and polarity, not a per-company judgement.
Alternatives are the alternatives-map slice: ex-controller-bloc producers tracked in the corpus, with tradability inherited from the verified listing layer.
Alternative viability is gated, not decorative (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.

Home / Companies / Saubermacher Dienstleistungs AG / Outlook

[5]Company ↑ Market

Saubermacher Dienstleistungs AG — policy outlook

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 recycling. Company profile →

18upcoming at elevated+Forward outlook50 in pipeline80 in force (sev ≥ 3)5 tracked materials (5 produced)0 customer sectors

1 · What they make

Rest of the descriptionShow

Verbatim from the dossier's “What they do” section — sources on the company profile.

2 · Where it operates — production footprint

4production countries in its dossier · approx. output shares

🇦🇹 Austria≈40%

Premstätten — wastewater treatment (~20,000t/yr)
Retznei — substitute fuel / RDF production (ThermoTeam)
Graz — plastic packaging sorting
Trofaiach — portable-battery sorting; industrial/hazardous wastewater treatment

🇩🇪 Germany≈30%

Offenbach — household/portable battery recycling — alkaline-manganese, zinc-carbon, NiMH (25,000 t/yr)
Ginsheim-Gustavsburg — household-battery sorting JV with Meinhardt Städtereinigung (AI/X-ray sorted by chemistry, up to 100 t/day, opened Apr-2026)

🇨🇿 CZ≈15%

Havlíčkův Brod — refrigerator/freezer recycling

🇸🇮 SI≈15%

Kidričevo — hazardous waste processing (~51,000t/yr)

3 · Composition — the materials that matter

5tracked critical materials · 5 produced, 0 bought

manganeseproduces🇨🇳 CN controls supply83

copperproduces🇨🇳 CN controls supply68

nickelproduces🇨🇳 CN controls supply64

aluminiumproduces🇨🇳 CN controls supply49

zincproduces🇨🇳 CN controls supply44

Zinc — same Offenbach line, from zinc-carbon and alkaline-manganese battery bodies; a bulk output stream of that process rather than a trace by-product.

Examined and excluded

The dossier also records the materials it investigated and rejected — the list above is narrowed deliberately, not cherry-picked. Its own words:

“Corrected out of the sector-derived defaults: lithium and cobalt. Saubermacher's lithium-ion "active mass" (nickel/cobalt/lithium/copper) production line was always at a different site — Bremerhaven, Germany, operated under the REDUX brand — which was sold to Redwood Materials in 2023. Saubermacher's current EV-battery-recycling service page describes that lithium-ion processing as a partnership with Redwood, not Saubermacher's own operation; Offenbach (which Saubermacher retained) handles a different, non-lithium-ion battery chemistry mix. Silver (also a sector default) is dropped for lack of any source tying it to a Saubermacher site.”