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3 critical materials scored · binding chokepoint: Indium (🇨🇳 CN 69% of refining) · 37 restrictive government measures on record
The binding exposure is Indium — 🇨🇳 CN controls 69% of global refining. On this company's production footprint that scores 38/100 (footprint-hedged; global 64). The register holds 37 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Indium TCL Technology is the 159th-most-exposed of the 166 named companies we track on 🇨🇳 CN's Indium chokepoint; the most-exposed is ispace, Inc. (76/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
TCL Technology ranks 177th of 181 verified electronics companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 26 further electronics companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 37/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 3 scored materials. Buyer-relative (first-order): weighted by where the company produces (CN 88% · VN 6% · IN 6%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
TCL Technology Group Corporation (SZSE: 000100) is a Shenzhen-listed advanced-manufacturing group with two core industrial segments: semiconductor display — LCD/OLED panel R&D, manufacturing and module assembly through its CSOT (China Star Optoelectronics Technology, majority-owned with Samsung Display as a minority partner) subsidiary — and new-energy photovoltaic silicon materials through TCL Zhonghuan, one of the world's largest producers of monocrystalline silicon ingots, wafers and cells for solar modules. It also runs smaller distribution and industrial-finance businesses. (Note: this is distinct from TCL Electronics, HK:1070, the separately listed TV/consumer-devices brand.)
and slices wafers at multi-hundred-GW annual capacity, one of the largest such operations globally; it has placed multi-year polysilicon supply contracts (~432,000 tonnes, 2023-2028) to secure feedstock. Silicon is the core mass input of the PV wafer business, not a trace component.
conductive electrode layer deposited in every LCD/OLED panel and touch-sensor stack CSOT manufactures. The layer is nanometres thick per panel, but the ITO market as a whole consumes roughly 60% of global primary indium supply, and indium is a by-product-only metal (extracted from zinc-sulfide ores) with no primary mine supply — a concentration risk borne by the whole display-panel industry, CSOT included.
oxide); same transparent-electrode exposure as indium, same panel lines.
cells are metallized with screen-printed silver paste front/rear contacts; silver typically represents a meaningful share of non-silicon cell cost industry-wide. As a top-tier wafer/cell producer, TCL Zhonghuan's silver demand scales directly with its GW capacity.
and display-panel wiring/circuitry across both core segments; a bulk industrial input rather than a specialty risk on its own, but its supply correlates with the same PV/electronics demand cycle as the metals above.
Dropped from the sector-default stub (no company-specific evidence found): tantalum, neodymium, cobalt, lithium, tungsten, antimony — these are typical of battery/motor/capacitor bills-of-materials in consumer electronics, not of TCL Technology's actual segments (display panels + PV silicon).
Source: TCL Technology FY2025 annual report, filed with the Shenzhen Stock Exchange via cninfo 2026-03-28 — static.cninfo.com.cn/finalpage/2026-03-28/1225045623.PDF (§(8) 主要销售客户和主要供应商情况, pp.21-22; §十一 关联方关系及其交易, financial-statement notes pp.148-150). Reporting period: FY2025 (year ended 2025-12-31). Confidence: primary-source (audited annual report).
Top-5 customers = RMB 62.17bn = 33.77% of annual sales, of which 12.55% is related-party. The five customers are individually coded (客户A-E), each with an exact revenue figure:
| Coded customer | Revenue | % of sales |
|---|---|---|
| 客户A | ¥23.091bn | 12.55% |
| 客户B | ¥16.775bn | 9.11% |
| 客户C | ¥14.060bn | 7.64% |
| 客户D | ¥4.698bn | 2.55% |
| 客户E | ¥3.542bn | 1.92% |
The filing's own related-party disclosure line states related-party sales are exactly 12.55% of annual revenue — identical to Customer A's individual share. The separate mandatory related-party-transaction note (§十一.3(1), p.149) lists TCL Industries Holding Co., Ltd. and its subsidiaries (TCL实业 控股股份有限公司及其子公司) selling RMB 23,090,794 千元 in FY2025 — the same figure to the yuan as Customer A's RMB 23,090,793,448. That is not coincidence at this precision: Customer A is TCL Industries Holding, the group's own consumer-electronics/TV holding company (parent of the separately-listed TCL Electronics, HK:1070) buying CSOT display panels from this dossier's subject. This is the R164-adjacent technique this wake specializes in — cross-referencing a coded top-5 line against the named related-party note to resolve an identity the top-5 table itself withholds — applied here via an amount match rather than a name exemption.
Customers B-E carry 0% related-party and no cross-referencing entity was found for them; they stay coded.
Top-5 suppliers = RMB 25.17bn = 18.02% of annual procurement, and the filing shows no related-party overlap in that top-5 (the related-party-share line reads "-"). The five suppliers are also individually coded (供应商A-E, 5.89/4.42/3.67/2.15/1.88%) but none of them cross-references to a named related party the way Customer A did.
The same related-party-transaction note separately discloses procurement from related parties, none of which appear large enough to be in the anonymized top-5 (18.02%/RMB 25.17bn) but which are directly material-relevant:
电子显示玻璃(深圳)有限公司) — RMB 3.440bn (FY2025), RMB 3.289bn (FY2024), an associate (联营公司). 艾杰旭 is AGC Inc.'s (Asahi Glass, Tokyo: 5201) current Chinese trade name; supplies display-panel glass substrate directly into TCL 华星's (CSOT) panel lines.
硅能科技有限公司) — RMB 2.283bn (FY2025, up from RMB 1.206bn FY2024, nearly doubling YoY), an associate. Inner Mongolia is TCL Zhonghuan's primary wafer/ingot production base — direct silicon-exposure link.
zero in FY2025** (the filing does not explain why). A globally-known Western solar-module maker (former SunPower spinoff) as a related-party PV customer of TCL Zhonghuan's silicon materials is the clearest Western-facing named link found in this filing — flagged even though the relationship appears to have lapsed within the reporting period.
The 2004 TCL Group IPO prospectus (searchkey=招股说明书, filed 2004-01-05, static.cninfo.com.cn/finalpage/2004-01-05/16445545.PDF) was pulled and rejected as a source for this dossier: it describes TCL Group's original CRT-television and mobile-phone businesses under the same 000100 ticker — a reverse-merger shell reuse (the parser's own resolved-name check flagged the title page as 集团股份有限公司, not TCL科技). TCL Technology's current segments (semiconductor display via CSOT, PV silicon via TCL Zhonghuan) did not exist as this company's business in 2004 — CSOT was established 2009, TCL Zhonghuan was acquired 2020 — so any named counterparty in that prospectus would describe the wrong business entirely. Do not re-pull this filing for this dossier; the historical-baseline technique that worked for 300750-sz (CATL) does not apply when the listed shell's business changed completely, not just its scale.
From the company’s own mandatory filings — the CSRC top-5 customer/supplier concentration disclosure and the related-party tables. This is a disclosure, not a netting: a named supplier concentration is shown beside the exposure score and never adjusts it. Figures are the fiscal years labelled, not a current snapshot.
Read the arm's-length column, not the headline. Enough of the disclosed top-5 is intra-group that the company's genuine third-party customer concentration is 21.22%, not the 33.77% the filing reports. The arm's-length figure is arithmetic on the two disclosed numbers — derived, not reported.
Top-5 customer table codes each slot (客户A-E) but the related-party line (12.55%) exactly equals Customer A's own share (23,090,793,448 元 / 12.55%), and the separate related-party-transaction note names the identical RMB amount (23,090,794 千元) against TCL Industries Holding Co., Ltd. — a rare case where the amounts, not a name exemption, resolve the code. Customers B-E (9.11/7.64/2.55/1.92%) stay anonymous: 0% of their revenue is related-party. Suppliers A-E (18.02% total) show '-' (no related-party overlap) in the top-5 table itself; the named supplier rows below are BELOW-top5 related-party procurement lines from the separate mandatory note, not part of this 18.02%.
Largest named related-party supplier in the FY2025 '采购原材料和产成品' note: RMB 3,439,574 千元 (FY2024: 3,289,267 千元), an 联营公司 (associate). 艾杰旭 is AGC Inc.'s (Asahi Glass, Tokyo: 5201) current Chinese trade name; entity supplies display-panel glass substrate — direct material link to this dossier's semiconductor-display segment. Route: the supplying entity is AGC's Shenzhen (CN) glass plant, selling to TCL CSOT's Chinese panel fabs — domestic China, not a Japan-to-China shipment. No share_pct: this is a below-top5 related-party line from the transaction note, not part of the anonymized 18.02% top-5 supplier aggregate.
Second-largest named related-party supplier in the same note: RMB 2,283,472 千元 (FY2024: 1,205,811 千元, nearly doubled YoY), an 联营公司 (associate) — direct material link to this dossier's silicon exposure via the TCL Zhonghuan wafer/ingot business (Inner Mongolia is TCL Zhonghuan's primary production base). No share_pct, same below-top5 caveat as the AGC row.
Resolved from the coded 'Customer A' slot (23,090,793,448 元, 12.55% of FY2025 sales) via exact RMB-amount match to the 关联方关系及其交易 note's '销售原材料和产成品' line for TCL实业控股股份有限公司及其子公司 (23,090,794 千元) — group's own consumer-electronics/TV holding company (parent of the separately-listed TCL Electronics, HK:1070) buying CSOT display panels from this dossier's subject, a vertically-integrated related-party sale. FY2024 comparative in the same note: 21,401,268 千元 — not converted to a %, since FY2024's own top-5 customer table (a different filing) was not pulled this tick, so no FY2024 revenue base is confirmed for a joinable share_of.
FY2024-only related-party sales line in the FY2025 annual report's comparative column: RMB 913,689 千元, dropping to zero in FY2025 (relationship apparently lapsed or was reclassified during the year — not explained in the filing). Maxeon (former SunPower solar-module spinoff) is a globally-known Western solar manufacturer; a related-party PV-materials sale from TCL Zhonghuan is the direct material link (silicon). No share_pct/share_of: RMB amount only, not disclosed as a % of any total.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: A-share issuers anonymise counterparties they are not required to name. · section source filing ↗
Ranked by buyer-relative risk, highest first.
1 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Indium | 🇨🇳 CN 69% refining | 38 | 64 | Low | — | Low | limited | 2 | ▲ rising |
| Silicon | 🇨🇳 CN 80% refining | 34 | 64 | Low | EXCEEDS 80% | High | limited | 19 | ▲ rising |
| Tin | 🇨🇳 CN 55% refining | 33 | 56 | Low | — | Low | ready | 18 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Indium | 4 | 3 | 5 | 3 | 4 | company input |
| Silicon | 4 | 4 | 1 | 4 | 4 | company input |
| Tin | 4 | 2 | 5 | 2 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
Two independent lenses: USGS official puts China at 55% of global refining output (by tonnage); US filers' own disclosures independently name China for 28% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| China Tin Group Co., Ltd.CID1070 | China | 20 | SEC |
| PT Mitra Stania PrimaCID1453 | Indonesia | 18 | SEC |
| Gejiu Kai Meng Industry and Trade LLCCID942 | China | 18 | SEC |
| PT ATD Makmur Mandiri JayaCID2503 | Indonesia | 17 | SEC |
| PT Prima Timah UtamaCID1458 | Indonesia | 17 | SEC |
Source: US SEC Form SD / Conflict Minerals Report exhibits (EDGAR full-text search), aggregated from RMI smelter tables. “US filers naming it” = distinct US-listed companies whose most-recent CMR names that refiner — disclosure-derived presence, not verified throughput. Link opens the SEC exhibit.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 22 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Counterfactual: the 50%-ownership automatic extension of Entity List designations runs to its full perimeter (one-year suspension at 2025-11-10 lifted on schedule). Direct-hit lines are basket issuers in semiconductor / chip-equipment / AI-compute sectors — the perimeter where the rule's 50% controller-affiliate test compounds with existing Entity List names.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 38 → 42 (+4) — a relative official policy-pressure magnitude, not a price drawdown.
You hold exposure to 2 of these 7 materials (Silicon, Indium) — your binding Indium exposure is one of them.
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime | 38 | 42 | +4 |
| Concentration | Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly) | 38 | 46 | +8 |
| Policy | Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime | 34 | 35 | +1 |
| Concentration | Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly) | 34 | 39 | +5 |
| Policy | Tin — 🇨🇳 CN escalates tin controls to a full export-licensing / ban regime | 33 | 34 | +1 |
| Concentration | Tin — 🇨🇳 CN becomes the single source for tin — the second source is lost (full 55%+ monopoly) | 33 | 42 | +9 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the materials this company buys. The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Indium).
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | Yes — 3 scored SRMs on the input side (binding: Indium) |
| Manufactures a listed strategic technology | electronics (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-22; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-06
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.