3 critical materials scored · binding chokepoint: Neodymium (🇨🇳 CN 85% of refining) · 69 restrictive government measures on record
Subject
000660.KS · 🇰🇷 KR
Sector
semiconductors
Materials scored
3
As of
2026-09-30
Risk Office verdict
High · 73/100Company supply-risk index
The binding exposure is Neodymium — 🇨🇳 CN controls 85% of global refining. On this company's production footprint that scores 79/100 (adversarial chokepoint; global 72). The register holds 69 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · NeodymiumSK Hynix Inc. is the 311th-most-exposed of the 516 named companies we track on 🇨🇳 CN's Neodymium chokepoint; the most-exposed is Alta Resource Technologies (86/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · semiconductors
SK Hynix Inc. ranks 1st of 3 verified semiconductors companies.
73🇰🇷 SK Hynix Inc.Neodymium
71🇰🇷 Samsung Electronics Co., Ltd.Graphite
47🇺🇸 AXT Inc.Gallium
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 73/100 — 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 (KR 78% · CN 15% · US 7%, 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.
Also listed in the dossier but not platform-scored: Photoresist-euv — no supply-risk series is tracked for it here.
Disclosed production sites
KR · Icheon — DRAM and HBM memory fabrication (M14/M16)silicon-wafers
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
SK Hynix Inc.
What they do
SK Hynix is the world's second-largest DRAM producer and the dominant supplier of high-bandwidth memory (HBM) for AI training and inference accelerators. Three revenue franchises sit on top of a deliberately geographically-concentrated manufacturing base: (1) advanced DRAM — HBM3 / HBM3E / HBM4 stacks (62% of global HBM shipments and 57% of HBM revenue as of Q2/Q3 2025 per Counterpoint Research, cited in SK Hynix's own 2026 market outlook; NVIDIA H100 / H200 / B100 / B200 / GB200 lead-supplier position), plus DDR5 / LPDDR5(X) into hyperscaler and mobile platforms; (2) NAND flash — post-Solidigm acquisition the enterprise-SSD franchise ranks #2 globally (Solidigm at Rancho Cordova / Folsom + legacy Hynix M11 / M14 / M15 lines in Korea + the Wuxi China DRAM fab's limited NAND adjuncts); (3) CXL / next-generation memory R&D — compute-express-link DRAM modules and processing-in-memory (PIM) samples shipping FY25-26. Manufacturing concentrates at four primary clusters: Icheon (M14 / M16 — leading-edge DRAM and HBM3E core production), Cheongju (M15 / M15X — HBM packaging and advanced DRAM; the strategically irreplaceable HBM-packaging node), Yongin Semiconductor Mega Cluster (planned, 4 fabs, KRW 600 trillion total capex per SK Hynix's own disclosed mid-to-long-term investment plan, first fab ground-breaking March 2025, fourth fab targeted for completion by 2033), and SK Hynix Semiconductor (China) Ltd. Wuxi (DRAM, principally DDR4 / LPDDR / legacy DDR5 nodes — no HBM). The customer base concentrates into NVIDIA (the largest single HBM3E customer through CY2026), AMD (HBM3E into MI300X / MI325X / MI350), Intel (Gaudi-series), Apple / Samsung Mobile / Xiaomi for LPDDR, Microsoft / Amazon / Google / Meta as direct DDR5 hyperscaler accounts, and Solidigm-channel enterprise-SSD buyers.
Material and trade exposures
Named counterparties — who actually buys and sells
From the company’s own filings and dated disclosures — top-5 concentration and related-party tables where the filer’s regime compels them, named supply and offtake agreements where it does not. 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.
The full counterparty breakdownShowHide
Named suppliers (2)
Air Products & Chemicals Inc. · long-term contract signed ~2026-04, per The Elec 2026-04-08arm's lengthtrade-presssecondarysource ↗
The Elec (2026-04-08): '린데와 에어프로덕츠는 이란의 카타르 라스라판 공습 이후 삼성전자와 SK하이닉스에 헬륨 공급 부족에 전면 대응하기로 하고 별도 장기 계약을 맺었다' (Linde and Air Products signed separate long-term contracts with Samsung Electronics and SK hynix); '두 업체 모두 미국 현지에서 원료 헬륨을 가져오는 비중이 높아' and a presidential-office official said the secured volumes are US-origin ('이번에 확보한 물량은 미국산'). Origin US helium sources; destination the buyer's Korean fabs. Trade press only; the article names both suppliers and both buyers jointly without an itemised supplier-buyer matrix. Air Products sources helium in the US.
Linde plc · long-term contract signed ~2026-04, per The Elec 2026-04-08
The exposure register
Ranked by buyer-relative risk, highest first.
2 of 2 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
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.
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.
An analyst traced these register actions to a specific, named effect on this company — date and severity below are read live from the register, not hand-typed.
The October-2022 anchor rule first put SK Hynix Wuxi inside the US-origin SME licensing perimeter. The original FN4 (Footnote-4) Entity-List concept that later propagated into the HBM control architecture begins here. Every subsequent Wuxi-side compliance step (US-person extraction, license-by-rule for advanced-node tooling) traces from this rule.
Single most material fiscal instrument for SK Hynix's Korea-side memory capex. The 15% large-corporate facility ITC (plus 10% incremental credit through 2025) on Icheon / Cheongju / Yongin-build qualifying capex is the canonical sell-side modelling input; the K-Chips Act was Korea's KORUS-paired response to the US CHIPS Act and is the Tier-1 fiscal floor under which all subsequent KR industrial policy is layered.
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:
Both stress-test scenariosShowHide
Policy shock — the controlling country escalates to a full export-licensing / ban regime.
Concentration shock — the supply structure collapses to a single source (second-source loss / full monopoly).
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 79 → 82(+3) — a relative official policy-pressure magnitude, not a price drawdown.
Trace the precedent to its primary source via the link above ().
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
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 — not yet law
Upcoming regulatory threats
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. Market-implied percentages are live external prediction-market prices (alternative/OSINT signal) — an independent read, not our model output and not merged into the official register or the stage-derived band; the gap between the market price and our stage assessment is itself the signal.
The upcoming threatsShowHide
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 68d ago · not yet law·matches Neodymium
If passed — 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 "Ministerial Forum on Critical Minerals Value Chain and Beneficiation: Pathways for African Transformation". The stated ambition is continental: move the bloc off raw-ore exports toward regional value chains and in-country processing, with reporting of a push to HARMONISE African mining legislation by end-2026 around a ban on unprocessed ore exports, alongside a headline mobilisation figure of ~USD 63bn for critical-minerals value-chain investment. Why this matters as axis-2 early warning rather than noise: the register already holds a dense cluster of INDIVIDUAL national instruments moving in exactly this direction — Zimbabwe's 2026-02-25 indefinite raw-mineral/lithium-concentrate export suspension, Guinea's 2026-06-19 raw-gold export ban + domestic-refining mandate, Gabon's announced 2029 crude-manganese export ban, Nigeria's RMRDC 30% value-addition bill, Indonesia-style downstreaming copied across the continent, and CEMAC's regional Common Mining Code (all already filed or queued). A binding AU/AfCFTA-level harmonisation instrument would convert that scattered set into a coordinated continental supply shock across cobalt, copper, bauxite, manganese and lithium simultaneously — which is a materially different exposure event from any single-country ban, because it removes the substitute-jurisdiction escape route that currently absorbs each national ban.
What to watch next
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The watch listShowHide
Neodymium is the line to war-game: 🇨🇳 CN already controls 85% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Silicon carries 19 restrictive measures on record (🇨🇳 CN 80% of refining) — a secondary escalation candidate.
Helium carries 3 restrictive measures on record (🇺🇸 US 43% of mining) — a secondary escalation candidate.
Art. 24(4) · diversification & substitution
Priority mitigations
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 (Neodymium).
The mitigation optionsShowHide
Map your real exposure to Neodymium. Trace it from the component back to the smelter/refiner and country of origin — most buyers discover the dependence is one tier deeper than their direct supplier.
Qualify a non-CN source. Identify and validate at least one supplier outside CN for the binding input before it is needed, even at a cost premium — optionality is the hedge.
Lead-time to re-source is ~9 months (6-12mo). The largest tracked non-CN producer of Neodymium is 🇲🇾 MY (~8% of refining); scaling it into a replacement is roughly a 6-12mo ramp. A share-of-stage substitution heuristic derived from current production share, not a firm supplier quote.
Design for substitution where feasible. Neodymium has at least partial substitutes; specify them into next-generation products to cut the dependence structurally.
Hold strategic inventory / contract forward. For materials with no substitute and active export controls, a buffer stock or long-dated offtake converts a shock into a managed cost.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.
Annex A · regulatory basis
CRMA Art. 24 compliance crosswalk
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)).
The full crosswalkShowHide
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)
Annex B · Art. 24(1) · Art. 2(29)
Scope & applicability
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.
Scope detailsShowHide
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: Neodymium)
Manufactures a listed strategic technology
semiconductors (confirm against Annex)
Formally identified by a Member State authority
company input
Evidence & sources
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 2026-09-30; the register is continuously maintained and should be re-pulled against each new policy action.
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).
Refresh SLA
New government measures — polled hourly; a filed action can appear on this report within the hour it's picked up.
Dossier verification (this company's exposure list, sourced against its own disclosures) — the auto-onboarded backlog drains on a 30-minute cycle; a specific company's upgrade timing depends on queue position, not a fixed date.
Live-quoted materials (currently: neodymium, praseodymium, dysprosium, terbium, indium, tellurium — see the price row on each material's page) — refreshed daily.
Other material prices — hand-maintained; flagged STALE on the minerals index past 45 days without a fresh source, rather than left silently out of date.
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.
SK Hynix's bill of materials and capex envelope concentrate in a small number of inputs and infrastructure dependencies that have become structurally policy-exposed:
Silicon wafers (300mm / 200mm) — Shin-Etsu, SUMCO, Siltronic + Korea-side SK Siltron (sister Group company). Designated candidate "selected critical material" under the 2024-02 KR Resource Security Special Act stockpile framework.
HBM-stack inputs (TSV interposers, Cu-pillar µbumps, MUF underfill, EMC mould) — Samsung, Kioxia affiliates, Showa Denko / Resonac. Trace Ga-compound use in optical-interconnect test-bed lines sits inside the China MOFCOM Ga/Ge perimeter (2024-12-03-china-mofcom-ge-ga-sb-export-ban-us).
Photoresist (EUV grades) + high-NA-EUV consumables — sole-sourced JSR, TOK, Shin-Etsu (Japan). Covered by 2023-07 METI overhaul + 2025-10 catch-all expansion; SK Hynix relies on Japanese supply for the DRAM 1a / 1b / 1c node transition.
EUV lithography equipment — sole-sourced ASML. SK Hynix is one of three globally licensed EUV buyers. Cross-reference: docs/intelligence/dossiers/asml.md.
Rare-earth permanent magnets (Nd / Dy / Tb) — fab vacuum pumps, wafer-handling robotics, clean-room HVAC servo motors run on NdFeB. China ≥85% of heavy-rare-earth refining; 2025-04 PRC licensing + 2025-10 extraterritorial regime sit upstream.
Electricity — the most under-priced input on the SK Hynix forward capex envelope. Yongin Mega Cluster requires an estimated 10 GW of dedicated capacity at full ramp; the National Power Grid Expansion Special Act (2025-03-25-south-korea-national-power-grid-expansion-special-act) is the load-side enabling instrument.
Policy actions touching them (last 24 months)
Rendered live from the register below, driven by this dossier's action_relevance: frontmatter (migrated 2026-08-21, queue #128) — date, severity and severity_basis are read directly from each action's current frontmatter and can never drift from the hand-typed table this replaced.
Pending / discussed actions
Five ongoing policy processes carry asymmetric SK Hynix exposure and warrant active monitoring:
Section 232 derivative-products list expansion. The 14 Jan
2026 Proclamation directs Commerce to enumerate "derivative products" in subsequent FR notices. Each addition expands the HTS-classification perimeter under which HBM-bearing AI systems (or, eventually, HBM modules themselves) landed in the US carry the 25% tariff. The 90-day Commerce comment cycles are the watch event — particularly any inclusion of HBM stacks as a named derivative category.
**KR Semiconductor Special Act enforcement-decree finalisation
(Q3 2026)**. Promulgation by the Cabinet expected shortly after passage; effectiveness contingent on enforcement-ordinance details — including the cluster-designation criteria under which Yongin's relocation-incentive package would crystallise and the special-account disbursement-priority rules.
2026-11-10 BIS Affiliates Rule re-armament. The Affiliates
Rule one-year suspension expires by default unless extended. SK Hynix's principal exposure is on the distribution-channel KYC perimeter for HBM module sales (where any China-affiliated customer with a ≥50%-listed-parent tree would need re-screening).
PRC dual-use catch-all enforcement first cases. The
October-2024 dual-use framework operationalises starting 2024-12-01. The first set of enforcement cases — particularly any concerning Korea-routed Ga / Ge / graphite re-export — will set the de-facto compliance perimeter for SK Hynix's HBM-substrate supply chain.
High-NA-EUV second-tool delivery to SK Hynix M16 / M15X.
Not a regulatory action per se, but the first High-NA-EUV delivery from ASML to SK Hynix is the watch event for whether the EUV-photoresist supply chain (JSR / TOK / Shin-Etsu, Japan- origin) is positioned to support DRAM 1c-node ramp on time.
Strategic alternatives
Four credible adjustment paths under further policy stress, with the trade-off costs visible:
**Accelerate the Wuxi capacity wind-down via Cheongju / Icheon
expansion**. With the bilateral capacity freeze on Wuxi (US VEU revocation + MOTIE NCT designation), the rational forward path is to migrate Wuxi's DDR4 / LPDDR / legacy-DDR5 output back to Korea. M15X expansion at Cheongju is the principal vehicle. Trade-off: Korea-side capex is fiscally subsidised (K-Chips Act 15% ITC + Semiconductor Special Act special account) but Wuxi's already-paid-for fixed capital becomes stranded once the migration completes. The implicit decision is whether Wuxi runs to end-of-life on legacy nodes (~2030-32 practical horizon under the case-by-case license regime) or is decommissioned earlier to reallocate engineering attention.
**Productise Solidigm as the US-domiciled enterprise-SSD
channel**. The Solidigm acquisition (closed 2021) provides SK Hynix a US-domiciled NAND-flash production base (Rancho Cordova / Folsom) that is fully outside the Korean outbound- investment-screening perimeter, the China VEU perimeter and potentially outside the most restrictive scenarios under Section 232 derivative-products expansion. The strategic question is whether to lift Solidigm's revenue contribution toward parity with the legacy Hynix NAND franchise as a US-jurisdiction hedge — material to FY27-28 capital allocation.
HBM4 lead-supplier position consolidation vs. Samsung.
HBM4 sampling cycles (NVIDIA Rubin / B300 / GB300 ramp) are the highest-leverage commercial battle. SK Hynix's HBM3E lead was structural (qualified first into H100 / H200) and partially policy-vulnerable (Wuxi DRAM bit-output capacity). The HBM4 qualification cycle is more contested — Samsung HBM4 was a Q1-2026 qualification race that SK Hynix won by ~4-6 months into NVDA's Rubin platform. Maintaining the lead through HBM4 is the principal margin-line defence under the policy stack.
Yongin Mega Cluster ramp-cadence acceleration. The Power
Grid Special Act unlocks the load-side; the question is whether SK Hynix accelerates the first-fab in-service date from the original 2027 target. Capex-burn velocity is the watch signal; the implicit decision is whether to compress the 4-fab build into ~16 years from the original ~22-year programme to harvest the K-Chips ITC window and the Semiconductor Special Act cluster-incentive package while both are politically durable.
The single highest-leverage open management decision is how aggressively to compress the Yongin Mega Cluster ramp under the post-2025-03 Power Grid Special Act. The cluster is SK Hynix's 20-year forward capex envelope; the 3-year-ish grid-build compression unlocked by the statute creates an arbitrage between accelerating the first-fab in-service date (capturing the K-Chips Act ITC window and pre-empting Samsung Pyeongtaek's parallel HBM-class ramp) versus pacing the build to preserve balance-sheet flexibility through the post-2026 HBM cycle. Q3 2026 capex guidance and the Yongin first-fab in-service disclosure are the signals to watch.
How this dossier is maintained
Refreshed quarterly by default, or on any of: (a) a new IPTM-registered action by US BIS, USTR, KR MOTIE / MOTIR / MSIT, JP METI, or PRC MOFCOM with target_sectors including semiconductors, dram, nand, hbm, ai-compute or chipmaking-equipment; (b) a Section 232 derivative-products list expansion FR notice; (c) an SK Hynix capital-allocation event (Yongin ground-break milestone, HBM4 qualification disclosure, Solidigm-segment carve-out, Wuxi production-mix disclosure); (d) a KR Semiconductor Special Act enforcement- decree publication or cluster-designation event; (e) a BIS Affiliates Rule re-armament or extension decision before the 2026-11-10 default expiry. Re-write triggers the last_refreshed field above and a new entry in the §Sources section below.
`docs/intelligence/cases/2025-us-chip-control-architecture-export.md` — closes the memory / HBM-supply vertex of the chip-control architecture alongside ASML (DUV/EUV equipment) + TSM (foundry / CoWoS) + NVDA (demand-side counterparty) + GLEN (Marketing-perimeter trader). The Dec-2024 HBM control + Sep-2025 Wuxi VEU revocation are the SK Hynix-specific cells in the case-#4 matrix.
SK hynix — Explainer: Mid-to-Long-Term Investment Strategy — states "total investment in the Yongin Semiconductor Cluster is expected to reach KRW 600 trillion," fourth fab targeted for completion by 2033. Corrects this dossier's prior "KRW 122 trillion... full ramp targeted 2046" figure, which did not match any SK Hynix disclosure found.
The Elec (2026-04-08): '린데와 에어프로덕츠는 이란의 카타르 라스라판 공습 이후 삼성전자와 SK하이닉스에 헬륨 공급 부족에 전면 대응하기로 하고 별도 장기 계약을 맺었다' (Linde and Air Products signed separate long-term contracts with Samsung Electronics and SK hynix); '두 업체 모두 미국 현지에서 원료 헬륨을 가져오는 비중이 높아' and a presidential-office official said the secured volumes are US-origin ('이번에 확보한 물량은 미국산'). Origin US helium sources; destination the buyer's Korean fabs. Trade press only; the article names both suppliers and both buyers jointly without an itemised supplier-buyer matrix. Linde FY2025 report: helium sourced from helium-rich gas streams in the United States.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
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 ↗
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.
Material factors (scored 4–5) — evidence
Neodymium
4Geopolitical: 50 restrictive actions, peak severity 5, 35 in last 24mo, less 4 liberalising actions
4Concentration: refining HHI 7306 (extreme); top CN 85%
5Price / market: price up, as of 2026-10-07
Silicon
4Geopolitical: 19 restrictive actions, peak severity 4, 14 in last 24mo
4Concentration: refining HHI 6498 (extreme); top CN 80%
4Substitutability: limited substitutes in electronics/electrical steel
4Import reliance: Eurostat Comext 2025: 63% extra-EU imports, top partner NO 47% (partner HHI 2698)
Helium
5Substitutability: no substitute in cryogenics/MRI and most lifting/leak-detection uses
Tightened the FDP and end-use rules under which the Samsung/SK Hynix VEU expansion (same-day) was calibrated. The substrate of the October-2024 / December-2024 / September-2025 escalation cycle.
The two-year calibrated safe harbour. SK Hynix's Wuxi DRAM fab was granted VEU coverage of "all items subject to the EAR" except EUV for memory production — a deliberate carve-out that let Wuxi continue running on DUV-class equipment and node migration through CY2024 H1. The eventual 2025-09-02 revocation has to be read against this baseline: the Wuxi node ceiling that was already capped under the carve-out has now been moved from "all-EAR ex-EUV" to "individual license per item." Materially compresses the optionality space, not the production envelope on Day 1.
Establishes the statutory framework under which Korean strategic stockpiles, mandatory-disclosure obligations and crisis-import authorities operate for fab-relevant materials (silicon wafers, hydrogen, helium, photoresist precursors). The Act's "selected critical materials" designation framework is the procedural vehicle for any future SK Hynix stockpile-eligibility classification.
Decree 792's transit/transhipment/re-export framework and explicit extraterritorial reach over PRC items downstream is the regulatory chassis under which any Ga / Ge / graphite re-export from Korea via Korea-to-Taiwan or Korea-to-US channels would be policed. SK Hynix's HBM3E shipments to TSMC for CoWoS assembly traverse this perimeter — a structurally durable license-risk vector independent of any single material control.
The under-priced bilateral half of the Wuxi capacity freeze. By designating HBM, advanced DRAM/NAND and silicon-wafer technologies as National Core Technologies (NCT) requiring MOTIE approval for outbound investment, the rule prohibits SK Hynix from expanding or migrating Wuxi onto more advanced DRAM nodes — *regardless of US licensing posture*. Combined with the 2025-09-02 US VEU revocation, Wuxi is now under a **bilateral** ceiling that no single regulatory thaw can lift.
The single highest-severity action in the SK Hynix register. The HBM performance-threshold control puts all HBM3 / HBM3E / HBM4 stacks meeting the BIS performance bar under license for export to China. The principal direct effect is foreclosure of any future China-domiciled HBM-customer channel (Huawei Ascend HBM-stack supply was already cut off de facto since 2022; this codifies it de jure as an HBM-side rule). The structural effect: HBM stack export licensing is now an EAR-classified item independent of the chip it pairs with, which is the regulatory architecture under which any future "HBM-class export to non-China non-Tier-1 destinations" would be calibrated.
Same-day-following retaliation to the Dec-2024 BIS package. Direct US-destination ban; Korea is not named. The under-read consequence: by exempting non-US destinations from the country-targeted ban, MOFCOM preserved Korea-routed material flows — meaning SK Hynix's Ga / Ge inputs into HBM advanced-packaging test lines remain compliant for non-US-destination production. But any HBM3E / HBM4 stack ultimately landed in the US under the Section 232 perimeter (action 2026-01-14) creates a fresh end-destination disclosure obligation under the MOFCOM transit-control regime.
Demand-side counterparty. The MSIT National AI Computing Center procures NVIDIA B200 / H200 systems running ~13,000 GPUs at first tranche — every one of which carries SK Hynix HBM3E. Direct domestic-channel revenue, plus a forward proxy for KR sovereign-AI HBM demand at the centralised-procurement layer.
The single most under-priced statutory change for SK Hynix's Yongin Mega Cluster valuation. The Act consolidates 35 previously separate trunk-transmission approvals into one streamlined procedure and targets >30% reduction in build timelines. Yongin's 10-GW projected load was the binding physical constraint on the cluster's 4-fab ramp schedule; the Act is the load-side enabling instrument. Sell-side has not modelled the discount-rate effect on the Yongin NPV envelope of compressing the grid-build cycle by ~3 years on a 22-year capex programme.
The GP10 guidance presumptively classifies any global Huawei Ascend 910B/910C/910D deployment as EAR-violative. SK Hynix exposure is via the HBM-stack supply layer: any future Huawei-Ascend-class HBM supply (which had been the most plausible China-domiciled HBM customer path) is now extraterritorially gated. Pairs with the 2024-12-02 BIS HBM control to extinguish the Huawei-Ascend HBM channel architecturally. Structurally pro-SK-Hynix on legal-risk allocation across the global HBM franchise (the BIS guidance constrains the only credible substitute for SK Hynix HBM in the PRC market).
The most-headlined SK Hynix-specific action of the cycle. Revokes the all-EAR-ex-EUV VEU at Wuxi as of 2025-12-31; from that date every restricted shipment requires an individual license, reviewed case-by-case under the 2022/2023 advanced-computing controls. The under-priced read: Wuxi production today is principally DDR4 / LPDDR / legacy DDR5 — *not* HBM — and the post-Busan BIS license practice has trended toward case-by-case approval for non-leading-edge memory tooling, so the day-1 production-envelope effect is materially less than press-headline severity suggested. The binding loss is the *optionality* to migrate Wuxi onto more advanced DRAM nodes (already capped by the 2024-11-15 MOTIE NCT designation in any case).
The bilateral umbrella under which the KR reciprocal-tariff ceiling is set at 15% (versus the 25% default) and KR-origin semiconductors are granted "no less favourable than MFN" treatment in any future sectoral deal. Cross-references the Section 232 chip tariff (next row) — the 15% cap is a partial offset on any HBM-stack-derivative US-destination shipment, but only at the IEEPA-reciprocal-tariff layer; the Section 232 tariff is technically separate. Korean side commits USD 350bn (USD 150bn shipbuilding + USD 200bn strategic industries) with USD 20bn annual cap — a notional ceiling that, if directed toward US-based fab capacity, would compete for SK Hynix's own Yongin-vs-US capex allocation decision.
Post-Busan softening. The H200-and-below case-by-case licence pivot is principally an NVDA / AMD event, but the second-order effect for SK Hynix is that the *HBM-bearing accelerator* channel back into PRC hyperscalers via reviewable license is no longer presumption-of-denial. Every approved H200-class shipment is a 192-GB HBM3E forward booking that SK Hynix lead-supplies.
The most ambiguous near-term exposure on the SK Hynix register. KR is explicitly named as a target country alongside TW / CN / MY / VN. The "derivative products" mechanism is the operative question — HBM stacks landed in the US either standalone or integrated into AI systems sit within plausible HTS-classification scope. SK Hynix's primary export path is *not* direct-to-US (HBM ships to TSMC Taiwan or to NVIDIA-contracted ODM lines in Mexico / Taiwan / Vietnam for system assembly), but each Commerce derivative-list expansion is a new vector under which the HBM stack is first imported into the US. The KR-US 15% cap (action above) partially offsets the IEEPA-reciprocal layer but not the Section 232 layer; the 90-day Commerce comment cycles on derivative-list scope are the watch event.
The capstone of the Korean industrial-policy stack and the highest-leverage structural statute since K-Chips. Establishes a Presidential Commission for Semiconductor Competitiveness, statutory five-year master plan + annual implementation plans, dedicated KRW 2tn special account (disbursement gated on companion National Finance Act amendments expected 2027) and statutory authority to designate clusters outside greater Seoul with relocation incentives. The cluster-designation authority is the binding statutory instrument under which Yongin's "national strategic cluster" status sits. Pairs with the 2025-03-25 Power Grid Act and the 2024-02-06 Resource Security Act to form the **three-Act statutory stack** under which SK Hynix's Korea-side fab economics are now anchored — a degree of statutory entrenchment no other major chip jurisdiction has matched.
🇨🇳 CN has issued 13 restrictive actions on Neodymium since 2024 — cadence accelerating (mean gap 103d → 29d), severity flat (3.8 → 3.4).A descriptive trajectory of past official actions — not a forecast.
🇨🇳 CN's demonstrated restriction sequence — has restricted 27 materials since 2021, in this demonstrated order:
You hold exposure to 2 of these 27 materials (Silicon, Neodymium) — your binding Neodymium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 5.8 months apart across 6 distinct restriction dates since 2021 (n=5 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
🇺🇸 US has historically countered a median of 3.9 months later (n=23 recorded episodes since 2024). Counter-move intensity: median severity 3/5 (3 of 23 via quantified basis).
🇮🇳 IN has historically countered a median of 9.9 months later (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5 (0 of 4 via quantified basis).
Descriptive history of recorded counter-actions in our causal register — not a forecast; the gap is what the controller's past moves drew in response.
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
when 🇨🇳 CN restricts your Silicon, 🇺🇸 US has historically countered (median 3.8 months later) — and those counter-moves have also restricted Neodymium, which you also depend on (n=16 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 of 16 via quantified basis).
when 🇺🇸 US restricts your Helium, 🇪🇺 EU has historically countered (median 21 months later) — and those counter-moves have also restricted Silicon, which you also depend on (n=4 recorded episodes since 2023). Counter-move intensity: median severity 3.5/5, hardest 4/5 (0 of 4 via quantified basis).
Descriptive history of recorded counter-actions in our causal register, intersected with your dependency basket — not a forecast; it shows where a controller's past retaliations have landed across your materials.
The ordered history of what this controller has restricted, each step traced to /actions/{id} — a descriptive sequence, not a forecast.
Type
Scenario
Today
Stressed
Δ
Policy
Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime
79
82
+3
Concentration
Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly)
79
88
+9
Policy
Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime
70
75
+5
Concentration
Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly)
70
83
+13
Policy
Helium — 🇺🇸 US escalates helium controls to a full export-licensing / ban regime
41
49
+8
Concentration
Helium — 🇺🇸 US becomes the single source for helium — the second source is lost (full 43%+ monopoly)
41
59
+18
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.
Caveat — DELIBERATELY likelihood=low, not moderate. com) is low-quality and was NOT relied on. AU-level harmonisation instruments historically take years and frequently stall at the model-law stage (cf. the known ecb-spf 400 pattern) to establish whether a formal Abidjan Declaration text exists and what it actually commits signatories to.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Neodymium🇨🇳 today 79→82+3
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 100d ago · not yet law·matches Neodymium, Helium
If passed — 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 official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
Caveat — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Neodymium🇨🇳 today 79→82+3
Helium🇺🇸 today 41→49+8
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 100d ago · not yet law·matches Neodymium
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 79→82+3
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 110d ago · not yet law·matches Neodymium
If passed — 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
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 79→82+3
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 114d ago · not yet law·matches Neodymium, Silicon
If passed — Second wave of CRMA Art. 14 strategic projects (drawn from 160+ applications: 95 EU-domestic + 66 third-country including 40 from strategic-partnership countries) gains fast-track permitting (27-month EU cap, 15-month Member State cap), EIB/EBRD financing-hub priority, and off-taker certainty; 75 battery-value-chain projects + 21 REE-for-permanent-magnets in pool; widens the EU's 2030 extraction/processing benchmarks pipeline beyond the first 60 projects
Caveat — Second call for applications closed January 15, 2026 (September 2025 launch). Commission stated ~4-month assessment period → designation expected May–June 2026. As of 2026-06-15, no Commission press release or OJ publication confirmed. EUR-Lex CELEX 32026D0923 verified via web search to be an unrelated EU animal-disease implementing decision. Moved from filing. md 2026-06-15. Distinct from: 2025-03-25-eu-crma-strategic-projects-first-designation (60 projects, first round) and 2024-05-23-eu-crma-entry-into-force (base regulation). Severity 3 expected (same as first-round designation).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Neodymium🇨🇳 today 79→82+3
Silicon🇨🇳 today 70→75+5
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 115d ago · not yet law·matches Neodymium
If passed — 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; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 79→82+3
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 114d ago · not yet law·matches Neodymium, Silicon
If passed — 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 States, financial institutions, and industrial consumers to assess strategic supply risk; mandated every 2 years, so this is the first edition setting the baseline; informs CRMA Art. 23 monitoring obligations and is the evidential basis for Art. 24 corporate-reporting thresholds
Caveat — The May 24, 2026 deadline set by Parliament and Council in Reg. (EU) 2024/1252 has now passed. No OJ publication confirmed as of June 15, 2026 — Commission may have adopted quietly or is overdue. This is the first CRMA Art. 22 benchmark cycle and is legally distinct from: (1) the CRMA base regulation (filed 2024-05-23); (2) the Strategic Projects first designation (filed 2025-03-25); (3) the RESourceEU Amendment — CRMA revision (filed 2026-03-04). If confirmed adopted, severity=2 (establishes the measurement baseline for EU strategic material supply risk assessment and directly feeds corporate Art. 24 reporting obligations). Distinct from all filed EU-CRMA actions. Not in filing. md or upcoming. md.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 79→82+3
Silicon🇨🇳 today 70→75+5
🇹🇼 Taiwan proposed comprehensive AI chip export controls on China — MOEA/ITA considering extending SHTC licensing requirements beyond blacklisted entities (Huawei, SMIC) to cover ALL Chinese customers for advanced AI chips and AI servers; would give Taiwanese regulators broader authority to block diversion of AI hardware (NVIDIA-powered servers, advanced AI chips) from Taiwan to China via third-country routing; MOEA stated June 9, 2026 "will continue strengthening oversight of strategic high-tech exports in line with global export-control trends"; discussions between Taiwan and US officials ongoing on controls for advanced chips
announced→low likelihood·flagged 114d ago · not yet law
If passed — If enacted, first Taiwan restriction covering all Chinese customers (not just blacklisted entities); would require Taiwanese OEMs (Foxconn, Pegatron, ASUS, Quanta, Wiwynn), server makers, and component suppliers to seek export licences before any AI hardware shipment to China — affects ~$15-20bn/yr of Taiwan-to-China AI server/component flows; raises costs for Taiwanese firms with significant China revenue
Caveat — Distinct from filed 2025-06-15-taiwan-moea-shtc-entity-list-expansion (Huawei/SMIC-specific, +599 entities) and 2025-11-18-taiwan-moea-ita-shtc-controlled-goods-list-expansion (quantum computers/3D printers). This is a proposed expansion to entity-neutral coverage. Low-to-elevated likelihood: confirmed that US lawmakers pressed Taiwan (2026 defence legislation); Taiwan-US synchronisation pattern well-established (aligned with US BIS controls on China); but MOEA has not publicly announced a formal rulemaking process.
awaiting-signature→high likelihood·flagged 114d ago · not yet law·matches Neodymium
If passed — Framework agreed "in principle" between Trump and Xi following June 5, 2026 call and subsequent negotiations; Trump stated June 11, 2026 "Our deal with China is done, subject to final approval with President Xi and me" — China to supply "full magnets, and any necessary rare earths, up front" to US; if formally enacted, would suspend or ease China's April 2025 rare earth export licensing regime (filed 2025-04-04-china-mofcom-rare-earth-export-licensing) for US-bound shipments; China's Vice Commerce Minister Li Chenggang confirmed "in principle" framework consensus from the June 5 Trump-Xi call; tariff framework: US 55% / China 10%; China April 2025 rare earth controls (heavy/medium REEs, including Dy/Tb NdFeB magnets, SmCo magnets) remain formally active — no MOFCOM suspension announcement found as of June 15, 2026; the deal is political but not yet implemented as a formal regulation or bilateral MOU
Caveat — Distinct from filed 2025-11-09-china-mofcom-announcement-72 (which suspended October 2025 US-targeted controls but left April 2025 REE licensing in place). Distinct from filed 2025-04-04-china-mofcom-rare-earth-export-licensing (April 2025 seven-REE licensing, which this deal may eventually suspend/amend). If formally enacted, this represents a structural easing of the most consequential REE supply-risk action in the register. Severity estimate: 3 if enacted (direct re-routing of ~$3–5bn/yr US rare earth magnet imports; reshapes REE concentration score for US/China interdependence axis).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 79→82+3
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 111d ago · not yet law·matches Neodymium
If passed — 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 border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Neodymium🇨🇳 today 79→82+3
🇹🇼 Taiwan ITA — Dual-Use Export Control List Revision: AI Chips and Advanced Semiconductors Targeting China (June 2026)
in-consultation→moderate likelihood·flagged 109d ago · not yet law
If passed — Taiwan ITA (International Trade Administration, MOEA) launched a 60-day public consultation on planned revisions to the SHTC (Sensitive High-Tech Commodity) controlled-goods export list to add AI chips and advanced semiconductor categories specifically targeting exports to China; if enacted, would extend Taiwan's existing sub-14nm chip / advanced packaging export controls (SHTC list 2025-11-18) to include AI-application chips sold for China use — the measure is designed to align Taiwan's export controls with US BIS advanced-chip restrictions and close the gap on AI server / Nvidia chip diversion from Taiwan to China; Bloomberg June 9, 2026 cites Taiwan authorities "considering much stricter export controls on AI chip sales to China to further align with US measures"; ITA confirmed a 60-day review period for planned revisions; if enacted, would add legal tools to address diversion of AI servers and Nvidia chips through Taiwan to China; affects global AI hardware supply chains and Taiwan-domiciled chip distributors, system integrators, and ODM/OEM assemblers
Caveat — Distinct from 2025-11-18-taiwan-moea-shtc-controlled-goods-expansion (that amendment added quantum computers and advanced semiconductor equipment to the SHTC list — this proposed revision targets AI application chips and AI server hardware for China specifically, different commodity scope and different policy driver); distinct from 2025-06-10-taiwan-moea-shtc-entity-list-huawei-smic (entity list addition, not commodity list revision). Timeline: 60-day review likely closes August 2026; if enacted, new SHTC amendment would take effect Q3/Q4 2026. Likelihood elevated: the ITA has formally initiated the review process and the stated policy driver (US BIS alignment) is official; Taiwan government has consistently tightened SHTC controls in line with US export control strategy since 2022. Filed upcoming 2026-06-20.
If passed — Requires US allies — primarily the Netherlands (ASML) and Japan (Tokyo Electron, Shin-Etsu) — to align their national export controls on advanced semiconductor manufacturing equipment with US BIS restrictions targeting China; strips DoC discretionary licensing authority for chipmaking tools; DUV immersion lithography machines (ASML TWINSCAN NXT series) would face mandatory licensing denial for China-bound sales/servicing; includes anti-circumvention provisions to block third-country re-export through Malaysia, Singapore, or UAE; if enacted, would overturn the bilateral US-Netherlands arrangement on DUV servicing and pressure Japan to expand its April 2023 / January 2024 semiconductor-equipment controls beyond current scope; diplomatic friction: NL Trade Minister Sjoerdsma was in Washington the same week opposing this bill while simultaneously signing Pax Silica
Caveat — Senate bill introduced April 8, 2026 (bipartisan: Risch R-ID, Ricketts R-NE, Kim D-NJ, Schumer D-NY); House companion H. R. 8170 introduced April 2, 2026 (Baumgartner R-WA); House Foreign Affairs Committee passed April 22, 2026 in what HFAC members described as "the largest significant export-control markup in the history of Congress" (20 bills advanced in single markup). Full House and Senate chamber votes still pending as of June 24, 2026. Key contested provision removed pre-committee: country-wide ban on cryogenic etching tool exports — DUV restrictions remain. Administration position unclear — DoC has been resistant to losing licensing discretion; USTR and State potentially prefer diplomatic alignment (Pax Silica model) over binding legislation. If enacted, directly targets ASML NL: estimated ~USD 3–5bn annual China DUV machine revenue at risk. Distinct from: filed 2025-01-15-netherlands-export-control-metrology-inspection-semiconductor (Dutch national expansion, not US law); filed 2024-09-07-netherlands-export-control-expansion-asml-duv-1970i-1980i (Dutch unilateral DUV controls — MATCH Act would mandate further alignment); filed 2025-12-12-us-pax-silica-initiative (non-binding multilateral cooperation — MATCH Act is the binding-legislation complement). If passed, would become the first US law explicitly requiring allied-country export-control harmonisation on semiconductor equipment. Severity 4 expected if enacted.
Reference-class base rate
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — a base rate for comparable bills, not a forecast for this one. source ↗
▲Bipartisan lead sponsors incl. Senate leadership (strong) — S.4281 introduced by Risch (R-ID, SFRC Chair), Ricketts (R-NE), Kim (D-NJ) and Schumer (D-NY, Minority Leader) — cross-party and leadership-level backing raises floor-time odds.source ↗
▲Bicameral — House companion exists (H.R.8170) (moderate) — Rep. Baumgartner (R-WA) introduced the House companion Apr 2, 2026; a live measure in both chambers is further along than a single-chamber bill.source ↗
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 103d ago · not yet law·matches Neodymium
If passed — 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
Caveat — Tanzania fiscal year starts July 1; the Finance Act signature typically occurs last week of June. Budget speech delivered June 11, 2026 by Finance Minister Khamis Mussa Omar; Parliament approved June 23. Mining provisions in §§ amending Income Tax Act (Cap. 332) and VAT Act (Cap. 148) and establishing the Mineral Research Fund. Distinct from: filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year), filed 2026-03-24-tanzania-panda-hill-niobium-ferroniobium-development-agreement (the specific project DA), and filed 2026-04-15-tanzania-ministry-of-minerals-revokes-40-idle-mineral-exploration-licences. Severity 2: institutional reform that de-risks the investor regime rather than a direct trade restriction.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 79→82+3
🇹🇿 Tanzania Finance Bill 2026/27 — NEW raw-mineral EXPORT LEVY on quartz (HS 25.06) and feldspar (HS 2529.10.00) under the Export Tax Act, Cap. 196
awaiting-signature→high likelihood·flagged 101d ago · not yet law·matches Silicon
If passed — The same Finance Bill 2026/27 already tabled (Parliament-passed 23 June 2026, effective 1 July 2026) inserts a NEW export levy of "10% of the FOB value of the cargo OR TZS 200 per kilogram, whichever is higher" on exports of quartz minerals (HS 25. 06) and feldspar (HS 2529. 10. 00) via amendment to the Export Tax Act, Cap. 196 — a distinct beneficiation-forcing EXPORT-TAX instrument that pushes raw quartz/feldspar exporters toward in-country value-addition. 196), and neither existing entry mentions it; (2) material-relevant — quartz HS 25. 06 covers high-purity/silica quartz feeding the silicon→semiconductor/solar value chain, so a Tanzanian export tax re-prices a raw-silica supply node; the same "rocks to riches" beneficiation logic Tanzania applies elsewhere; (3) part of the wider African raw-mineral-export-tax wave (cf. Zimbabwe 10% lithium-concentrate levy, Namibia unprocessed-mineral ban, Guinea bauxite reference price).
Caveat — On enactment, fold into that one TZ Finance Act 2026 action with action_type capturing both the fiscal-incentive and the export-levy (export-control/tariff) provisions; do NOT double-file. Distinct from filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year — no quartz/feldspar export levy). Severity 2 (sectoral raw-mineral export tax, niche HS lines).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Silicon🇨🇳 today 70→75+5
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 103d ago · not yet law·matches Neodymium
If passed — 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 (~USD 600M) incentive envelope to states; key components: (i) ₹250 crore one-time incentive to any state where ≥10% of pre-March-2026 auctioned major mineral blocks begin production+dispatch by end-2026; (ii) ₹100 crore baseline for systemic reforms (Unified Mining Portal integration, Pre-Auction Committees); (iii) ₹20 crore per block auctioned with pre-embedded forest and environmental clearances; scheme targets removing the "auction gap" — India has auctioned hundreds of mineral blocks since 2015 MMDR amendments but operationalisation lag remains a structural bottleneck; critical minerals relevance: India is running parallel programme of critical+strategic mineral auctions (7 tranches, 56 blocks auctioned by June 24, 2026) and this scheme incentivises states to bring those blocks into production faster; directly accelerates lithium (Rajasthan), REE (Andhra Pradesh, Tamil Nadu), graphite (Odisha), and nickel (Odisha, Jharkhand) pipelines
Caveat — Source is secondary (PolicyEdge news aggregator). To migrate to filing. md, filer must verify the primary notification on mines. gov. in or pib. gov. in (search "SASCI Mining 2026-27" on PIB search). India BHAVYA industrial parks scheme (₹33,660 crore, March 18, 2026) is separately filed — SASCI is a distinct scheme targeting state-level mining-sector governance reform. Distinct from filed India Union Budget 2026-27 Customs notifications and Semiconductor Mission 2. 0. Severity 2 (supply-side demand-unlock rather than export control or FDI gate).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Neodymium🇨🇳 today 79→82+3
🇪🇺 EU Permanent-Magnet Scrap & Waste Export Restriction
announced→low likelihood·flagged 102d ago · not yet law·matches Neodymium
If passed — Under the RESourceEU action plan (COM(2025) 945, adopted 3 Dec 2025 and already filed as 2025-12-03-eu-resourceeu-action-plan-com-2025-945), the European Commission committed to PROPOSE, by Q2 2026, restrictions on the export of scraps and waste of permanent magnets — an essential feedstock for European NdFeB recyclers that is increasingly shipped abroad (notably to China). Recycling could meet ~20% of the EU's ~20,000 t/yr permanent-magnet demand, so retaining end-of-life and pre-consumer magnet scrap in the EU is framed as a supply-security measure to reduce China dependence. Accompanying measures: a new EU-level Combined Nomenclature sub-code + European Waste Catalogue entry to identify/track permanent magnets and EoL products containing them, plus a targeted CRMA amendment on product-labelling and pre-consumer-waste recycling. If enacted as a binding export restriction this would be the EU's first outbound control on a critical-mineral waste stream — directly relevant to anyone in the EU/China REE-magnet recycling loop, and a mirror-image to China's REE/magnet export controls (re-prices intra-bloc vs ex-bloc scrap flows). The European recycling industry (BIR) has publicly warned the measure risks market distortion, so adoption/scope is contested.
Caveat — As of 2026-06-27 (end of Q2) no formal proposal or regulation has been located — still at the action-plan-commitment stage, hence axis-2/upcoming not filing. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella plan announcing the intent — this item tracks the specific export-restriction instrument that the plan promised), from filed 2026-03-04-eu-council-crma-general-approach-resourceeu (Council general approach on the CRMA amendment), and from the EU dual-use export-control regime (2021-821 / 2025-2003). Distinct from the US-China REE deal (line 78) and EU CRMA strategic-projects round (line 58). Severity 2-3 if enacted (first EU outbound control on an REE waste stream; re-prices the EU↔China magnet-scrap loop).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Neodymium🇨🇳 today 79→82+3
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 102d ago · not yet law·matches Neodymium
If passed — 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 holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Neodymium🇨🇳 today 79→82+3
🇨🇳 China unpublished 50% domestic-equipment local-content mandate for new/expanded semiconductor fabs
announced→low likelihood·flagged 95d ago · not yet law
If passed — Reuters (exclusive, multiple sources) reported 31 Dec 2025 that Chinese authorities have been requiring domestic chipmakers to source at least 50% of equipment spend from Chinese toolmakers when applying for approval to build or expand fab capacity — enforced administratively (approval rejected if the threshold isn't met) rather than via any published law or ministry order; strictest on mature-node lines, with temporary carve-outs for advanced-node lithography where local tools don't yet exist; officials reportedly want the floor higher over time, with a stated long-run goal of 100% domestic tooling. Directly squeezes foreign equipment suppliers (Lam Research, Applied Materials, Tokyo Electron, ASML) out of incremental Chinese fab capacity and is already lifting order books at domestic tool makers Naura Technology and AMEC (Naura H1 2025 revenue +30% YoY to RMB16bn; AMEC +44% YoY to RMB5bn). GTA logged this as a state act (state-act/95890) but provides no primary source; no MIIT/NDRC/MOFCOM document, gazette notice, or on-the-record government confirmation has surfaced in any outlet reviewed.
Caveat — Charter §6 verify-or-don't-file: GTA state-act/95890 provides zero primary source (page states only "reportedly mandated," no gov link, no gazette reference) and exhaustive web search (Reuters exclusive + 7 corroborating outlets: Modern Diplomacy, IBS Electronics, ExportComplianceDaily, Seeking Alpha, Stocktwits, Hawaii Tribune-Herald) confirms this is deliberately UNPUBLISHED administrative practice (enforced via approval-rejection, not a public instrument) rather than a not-yet-enacted proposal — it is arguably already in force but structurally opaque, so it does not fit filing. md's primary-source bar. Flagging as upcoming/announced rather than rejecting: multiple independent, well-sourced outlets corroborate a specific, falsifiable mechanism (50% threshold, mature-node-strict/advanced-node-exempt split, approval-rejection enforcement) with observable market effects (Naura/AMEC revenue growth) — this is credible policy, not speculation; likelihood HIGH reflects that the practice already appears to be in effect, with the open question being whether/when a public document ever surfaces to cross the register's verification bar. If no primary source ever emerges, this may need a standing "policy tracked, never promotable" annotation rather than eventual promotion — flag for a future strategy wake. Distinct from all filed CN semiconductor entries (export-control/entity-list actions on the inbound side); this is an outbound-directed, tooling-localisation industrial-policy instrument. Severity 3-4 expected if a primary document surfaces (broad fab-capex-shaping local-content rule); severity_basis would be quant (explicit 50% floor).
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 69d ago · not yet law·matches Neodymium
If passed — 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 on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Neodymium🇨🇳 today 79→82+3
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 55d ago · not yet law·matches Neodymium
If passed — 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.
Caveat — ENACTED (signed order, in force since 21 Oct 2025) but parked here rather than filing. gov. mw directly (TLS cert mismatch: cert is issued for agriculture. gov. mw, not statehouse. gov. mw) and the malawiace. com implementation-analysis piece cites no gov URL either. Same park-lot convention as the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines above (real, already-enacted action; primary URL not independently locatable this wake). Dedup: action-index has only 1 Malawi action total, none overlapping (no prior MW export-ban or beneficiation-mandate action exists). Severity 3-4 expected given the breadth of minerals covered and MW's fast-growing REE/graphite production profile.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 79→82+3
🇲🇬 Madagascar — Council of Ministers lifts 16-year moratorium on new mining-permit issuance (except gold), effective ~29 Jan 2026
passed-vote→high likelihood·flagged 55d ago · not yet law·matches Neodymium
If passed — 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 speculation). Roughly 1,650-3,000 pending permit applications accumulated during the freeze can now be processed — Mining Cadastre Bureau (BCMM) confirmed first-come-first-served processing with a maximum 3-month target for first issuances. Covers nickel, cobalt, graphite, rare earths, mineral sands/ilmenite, bauxite, sapphire, quartz and mica; GOLD remains explicitly excluded pending further review. Legal basis: implementation of the 2023 mining code (Loi n°2023-007, promulgated 27 Jul 2024) following mining-cadastre cleanup. SUPPLY-RELIEF — opens Madagascar's graphite (6 large projects, ~3% of global production / 8% of global reserves), nickel-cobalt (Ambatovy) and rare-earth potential to new entrants after a 16-year freeze; MG is currently one of the thinnest countries in the register (2 prior actions) despite this graphite/nickel relevance.
Caveat — ENACTED (Cabinet approved, permits already being processed per BCMM statements) but parked here rather than filing. primature. gov. mg returned a self-signed-certificate error on direct fetch, and app. primature. gov. mg's Conseil des Ministres listing did not surface a January 2026 session in the portion fetched. Same park-lot convention as the Malawi entry above and the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines earlier in this file. Dedup: action-index has only 2 Madagascar actions total, neither about the permit moratorium. Severity 3 expected — moratorium lift affects licensing for nickel/cobalt/graphite/REE projects nationwide.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 79→82+3
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 33d ago · not yet law·matches Neodymium
If passed — 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. Three structural changes: (1) a National Commission for Strategic and Critical Minerals empowered to designate an official list of "strategic and critical minerals" — Morocco's first formal legal mechanism to do so, which would sit upstream of and interact directly with the phosphate chokepoint (Morocco holds ~70% of world phosphate-rock reserves via OCP); (2) the digital mining cadastre (governance/transparency layer — this component has ALREADY gone live, launched 2026-04-07, and is queued separately to filing. md as an enacted action); (3) sharply increased penalties for illegal mining/prospecting (unauthorised prospecting: MAD 100k-1m; illegal extraction/transport/sale: up to MAD 2m). Morocco is chokepoint-tier and thinly covered (only 4 prior MA actions: 2022 Investment Charter, an AfDB agriculture loan, the 2026 Loi de Finances, and a Feb-2026 mining-tender notice — none creates a minerals-designation regime).
Caveat — distinct from the already-filed 2026-04-07 digital-cadastre launch (enacted, queued to filing. Dedup: no MA action in the index covers a strategic-minerals designation commission or mining-code amendment; the 3 other MA entries (Investment Charter 2022, Loi de Finances 2026, Feb-2026 mining tender) are distinct instruments.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Neodymium🇨🇳 today 79→82+3
🇮🇳 India–Myanmar rare-earths cooperation — elevated to formal bilateral agenda at Modi–Min Aung Hlaing summit
announced→low likelihood·flagged 31d ago · not yet law·matches Neodymium
If passed — At Myanmar military-government head Min Aung Hlaing's early-June-2026 New Delhi visit (his first India visit since the 2021 coup), critical minerals and rare earths featured explicitly on the formal bilateral agenda for the first time — India's Foreign Secretary Vikram Misri confirmed both sides "agreed to stay in touch" on critical minerals/rare earths and "take cooperation forward. " This is India seeking an alternative heavy-rare-earth source (Kachin State/Wa State artisanal mining, currently ~all exported to China) amid China's 2025 rare-earth export controls. No formal supply contract, MOU, or binding mineral-cooperation instrument has been signed — this is government-to-government dialogue only, elevated from background technical talks to official summit-agenda status. Analysts place realistic commercial-scale sourcing in the 2028-2035 window, contingent on Kachin conflict resolution and connectivity infrastructure. Chokepoint-tier (MM heavy rare earths, only 4 prior MM actions in the index, all domestic Myanmar mining/export regulation — none touching an India bilateral angle).
Caveat — Dedup: no existing IN or MM action in filing. md/upcoming. md/action-index covers India-Myanmar rare-earth cooperation (checked "india. *myanmar" across all three — only hit was an unrelated DPIIT Press Note 2/2026 land-border-FDI action that separately still requires prior approval for Myanmar-domiciled investors). Distinct from the 3 filed Myanmar domestic actions (Wa State tin suspension/restart licensing, MOC Notification 93/2024, KIO rare-earth regulation) which are host-country supply-side instruments, not this demand-side sourcing-diversification angle. Severity 1-2 while at dialogue stage.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Neodymium🇨🇳 today 79→82+3
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.
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.
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.
Why this dependence is structural, not transitional. The EU's own external auditor — the European Court of Auditors, Special Report “Critical raw materials for the energy transition — Not a rock-solid policy” (Feb 2026) — judges the bloc's 2030 extraction, processing and recycling targets to be out of reach (recycling runs 1–5% for 7 of 26 materials, and diversification shows no measurable effect). A separate industry-analyst assessment (Adamas Intelligence & Tradium, EU CRMA report, Apr 2024 — an interested-party commercial view, not an independent verdict) reaches a compatible conclusion that the 2030 rare-earth targets will be missed without an expedited push. The chokepoint this report maps is therefore a durable constraint the Act has not yet closed, not a gap that resolves on its own.
▲Organized industry coalition support (weak) — AI Policy Network led a coalition letter backing the MATCH Act — organized outside support, though narrow.source ↗
▼Senate side still in committee (Banking) (moderate) — S.4281 was read twice and referred to Senate Banking, Housing & Urban Affairs; no Senate committee markup or floor calendaring reported as of Jul 2026.source ↗
▼Executive-branch resistance (Commerce) (moderate) — The bill strips DoC discretionary licensing authority; Commerce has been resistant to losing that discretion, and State/USTR may prefer diplomatic alignment (Pax Silica) over binding legislation.source ↗
Sourced OSINT observations, not a forecast — a qualitative second read beside the stage-derived band. We do not publish a passage probability of our own until the accrual record proves it is calibrated (never a fabricated %).