15 critical materials scored · binding chokepoint: Graphite (🇨🇳 CN 85% of refining) · 182 restrictive government measures on record
Subject
005930.KS · 🇰🇷 KR
Sector
semiconductors
Materials scored
15
As of
2026-09-30
Risk Office verdict
High · 71/100Company supply-risk index
The binding exposure is Graphite — 🇨🇳 CN controls 85% of global refining. On this company's production footprint that scores 79/100 (neutral exposure; global 77). The register holds 182 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · GraphiteSamsung Electronics Co., Ltd. is the 128th-most-exposed of the 201 named companies we track on 🇨🇳 CN's Graphite chokepoint; the most-exposed is Leading Edge Materials (Norra Kärr) (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
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 71/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 15 scored materials. Buyer-relative (first-order): weighted by where the company produces (KR 35% · VN 28% · CN 12% · IN 10% · US 10% · BR 5%, 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 · Pyeongtaek (P1-P6 campus) — memory and foundry-logic chip fabrication — world's largest single semiconductor fab sitesilicon
KR · Hwaseong/Giheung — memory and System LSI chip fabrication — original 1983 memory fab campus, foundry R&Dsilicon
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.
Samsung Electronics Co., Ltd.
What they do
Samsung Electronics is the only company in the world simultaneously operating five revenue franchises each individually material to global industrial policy: (1) memory (DRAM #1 globally with ~42% share, NAND #1 globally with ~33% share; HBM trailing SK Hynix on HBM3E qualification but pulled level on the HBM4 NVIDIA Rubin race); (2) foundry (#2 globally after TSMC, ~12% market share, persistently loss-making at the Samsung Foundry segment level through FY24-FY25, 3nm GAA process running below internal yield targets); (3) System LSI (mobile application processors — Exynos 2400/2500 lines, image sensors — the Galaxy + Apple iPhone CIS share split); (4) Samsung Display (wholly-owned subsidiary, ~85% global flexible-OLED share, primary OLED panel supplier to Apple's premium iPhone line, expanding into automotive cockpit and tablet displays); (5) Device eXperience — Galaxy mobile (#1 global smartphone shipments through FY25), Samsung TVs / appliances, and the Harman International US-incorporated automotive-electronics + audio-brands subsidiary (JBL, Harman Kardon, AKG, Bang & Olufsen licensing, plus automotive-OEM infotainment + telematics — acquired 2017 for ~USD 8bn). Manufacturing concentrates at Giheung / Hwaseong (historical leading-edge fab campus and Samsung Foundry's 3nm/4nm ramp), Pyeongtaek (the world's largest single semiconductor manufacturing complex; six-fab P1–P6 envelope, P3 + P4 partially in service, the bulk of incremental HBM3E and HBM4 capacity), Yongin Semiconductor Mega Cluster (5 fabs targeted at 3nm-and-below logic + HBM, KRW 360tn 20-year cumulative capex plan, first-fab ground- break 2024, full ramp through 2042), Taylor, TX (Samsung Foundry USA's CHIPS Act anchor fab — preliminary award USD 6.4bn, 4nm/2nm process, original 2026 in-service slipped to 2027+), (Samsung's principal NAND-flash output node — ~40% of Samsung's global NAND wafer starts), and (Bac Ninh, Thai Nguyen — flexible-OLED modules + Galaxy assembly).
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.
5 of 9 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.
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.
The named refinersShowHide
Tungsten
China = 54% of filer-disclosed refiner mentions · 291 named refiners
Two independent lenses: USGS official puts China at 90% of global refining output (by tonnage); US filers' own disclosures independently name China for 54% of their refiners (by facility count). Different metrics — both rank China first.
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.
Actions specifically flagged for Samsung Electronics Co., Ltd.
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.
Samsung Foundry USA's **Taylor TX** preliminary award is USD 6.4bn — the second-largest under the §39B manufacturing-grant programme after Intel. §48D's 25% facility ITC stacks on the Taylor capex base. The 10-year guardrails clause binds Samsung MORE than SK Hynix because Samsung China Semiconductor Xi'an NAND is ~40% of Samsung's global NAND wafer starts (versus SK Hynix Wuxi which is legacy DRAM). The CHIPS Act recipient relationship places Samsung Foundry's domestic-Korean vs. Taylor-TX capital-allocation decision under a Commerce / NSC bilateral oversight that no other Asian foundry carries on this scale.
The October-2022 anchor rule first placed Samsung Xi'an NAND 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 Xi'an-side compliance step (US-person extraction, license-by-rule for advanced-node NAND tooling) traces from this rule.
Art. 24(2)(c) · vulnerability to disruption
Stress test — two plausible scenarios
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 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: 79 → 84(+5) — 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
This assessment identifies 1 significant vulnerability — Graphite — each a High/Critical exposure that is hard to substitute and already under at least one in-force restrictive measure. This engages the duty under Art. 24(4) to take mitigating efforts, including assessing diversification of the supply chain or substitution of the material (see Priority mitigations below).
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.
announced→low likelihood·flagged 27d ago · not yet law·matches Lithium
If passed — On 11 May 2026 Huayou Cobalt announced an all-cash agreement to acquire ASX/AIM-listed Atlantic Lithium for USD 210m, taking control of the Ewoyaa project (~1. 13Mt LCE JORC resource, ~110km from Takoradi port) whose mining lease Ghana's Parliament ratified in March 2026 (already filed as 2026-03-19-ghana-ewoyaa-lithium-mining-lease-ratification). This is a distinct instrument from that ratification — a change-of-control transaction giving a Chinese battery-materials producer direct upstream ownership of Ghana's first lithium mine, the same cn-outbound-mining-fdi pattern already tracked for CMOC/Zijin/Ganfeng (cf. the parked CMOC–Equinox Gold entry above). Deal awaits Atlantic Lithium shareholder vote scheduled November 2026; no MOFCOM/NDRC outbound-investment approval confirmed yet in reporting. Ghana has no China-outbound-FDI action filed to date, closing a first-coverage gap for a chokepoint-adjacent material (Ghana is a new, non-priority-tier lithium source; polarity is acquisition/control, not a host-country restriction).
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
Graphite 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.
Tungsten carries 16 restrictive measures on record (🇨🇳 CN 90% of refining) — a secondary escalation candidate.
Gallium carries 9 restrictive measures on record (🇨🇳 CN 98% of refining) — 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 (Graphite).
The mitigation optionsShowHide
Map your real exposure to Graphite. 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 Graphite is 🇯🇵 JP (~5% 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. Graphite 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 — 15 scored SRMs on the input side (binding: Graphite)
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.
Samsung China Semiconductor Co. Ltd. Xi'an
Samsung Display Vietnam
Material and trade exposures
Samsung's bill of materials and capex envelope concentrate in inputs that have become structurally policy-exposed across five distinct policy regimes — broader than any of the prior eight dossiers in this register:
group SK Siltron. Designated candidate "selected critical material" under the 2024-02 KR Resource Security Special Act stockpile framework (action 2024-02-06).
underfill)** — Resonac, Kioxia affiliates, Korean second-tier packaging supply chain. Trace Ga / Ge use in optical-test-bed lines sits inside the MOFCOM Ga / Ge perimeter (action 2024-12-03).
EUV photoresist and high-NA-EUV consumables — sole-sourced
JSR, TOK, Shin-Etsu (Japan). Covered by 2023-07 METI overhaul.
EUV lithography equipment — sole-sourced ASML. Samsung is one
of three globally licensed EUV buyers. Cross-reference: docs/intelligence/dossiers/asml.md.
OLED glass substrates and fine-metal-mask (FMM) consumables
— Samsung Display sits inside the EU Critical Raw Materials Act (CRMA) "strategic technology" perimeter via display-panel classification; downstream-recovery and substitution obligations apply.
Rare-earth permanent magnets (Nd / Dy / Tb) — fab servo
motors, OLED-deposition tooling, automotive-infotainment voice-coils (Harman line). China ≥85% of heavy-rare-earth refining; 2025-04 PRC licensing + 2025-10 extraterritorial regime sit upstream.
006400.KS, group-affiliated) is the cell supplier; EU Battery Regulation 2023/1542 obligations (action 2023-08-17) reach Samsung Mobile and Samsung Galaxy hardware via SDI.
state load >12 GW at full ramp; the National Power Grid Expansion Special Act (action 2025-03-25) is the load-side enabling instrument shared with SK Hynix.
The above covers the fab/policy-registered chokepoints. Samsung's Galaxy consumer-hardware bill of materials carries a broader, company-disclosed mineral footprint that is not yet the subject of an IPTM-registered action but is worth tracking as a pending-exposure watchlist:
cells for Galaxy phones, tablets, wearables and laptops (supplied by Samsung SDI, see above) use cobalt- and nickel-bearing cathodes, lithium electrolyte/cathode material, and graphite anodes. Samsung runs its own annual responsible-sourcing surveys on cobalt, lithium, nickel and natural graphite across its supplier base, and has stood up a circular cobalt-recycling chain (Galaxy S25) specifically because cobalt is a named concentration risk (DRC-dominated mine supply).
3TG conflict minerals (tin, tantalum, tungsten) — tin solder
joints run through every board; tantalum capacitors and tungsten (vibration-motor weights, some contacts) are smaller by mass but supply-chain-critical. Samsung holds 100% RMAP (Responsible Minerals Assurance Process) certification for 3TG plus cobalt.
transparent conductive film is used across Galaxy and Samsung Display touchscreens, a thin-film role rather than a bulk consumer, but present in essentially every unit shipped.
chromium)** — aluminium and stainless (chromium-bearing) device chassis, copper PCB traces and wiring, and silver conductive paste/contacts, surveyed under the same Samsung responsible- minerals program as the battery and 3TG lines above.
Gallium / V-NAND sputtering targets (China-sourced inputs) — beyond the
trace Ga/Ge optical-test-bed use noted above, TrendForce (2025-10-13) reports Samsung recently sourced sputtering-target materials from China for its 300-layer V-NAND and that its ninth-generation V-NAND is likely to see one-to-two-quarter production delays under China's October-2025 export rules. That is TrendForce's assessment, not a Samsung statement, and the article does not name gallium as the affected input.
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
Six ongoing policy processes carry asymmetric Samsung exposure:
Section 232 derivative-products list expansion. Each
Commerce FR notice expands the HTS-classification perimeter under which Samsung-system-bearing products landed in the US carry the 25% tariff. Particularly material: any inclusion of consumer SSDs, mobile handsets, or display-panel-bearing finished goods as named derivative categories.
**KR Semiconductor Special Act enforcement-decree finalisation
(Q3 2026).** Cluster-designation criteria + special-account disbursement-priority rules are the operational unlocks for Samsung's Yongin phases 2-5 relocation-incentive package.
2026-11-10 BIS Affiliates Rule re-armament. The one-year
suspension expires by default unless extended. Samsung's principal exposure is on the distribution-channel KYC perimeter for HBM modules + Galaxy / Harman finished-goods sales (where any China-affiliated counterparty with a ≥50%-listed-parent tree would need re-screening).
Samsung Foundry NVIDIA Rubin HBM4 qualification cycle. The
HBM4 (16-Hi stack, custom base-die) qualification is the highest-leverage commercial battle for the Samsung memory franchise. NVIDIA's dual-supplier policy historically required qualifying both Samsung and SK Hynix; Samsung's HBM3E miss cost FY24-FY25 share. HBM4 qualification announcement is expected Q3-Q4 2026.
**Samsung Foundry 2nm GAA customer qualification at TSMC-
competitive yield.** Tesla AI5/HW6, Qualcomm Snapdragon 8 Gen 5, Google Tensor G6 — each is an active sourcing decision. The Samsung 3nm SF3P process held losses through FY25; 2nm SF2 is the strategic reset.
**Commerce / NSC review of Samsung Foundry Taylor TX timeline
slippage.** The original 2026 in-service date has been publicly walked back to 2027+. Whether Commerce reopens the USD 6.4bn award terms (re-tranching, milestone covenants) is the watch event under the CHIPS Act's award oversight regime.
Strategic alternatives
Four credible adjustment paths under further policy stress:
Carve out Samsung Foundry from Samsung Electronics
(recurring sell-side proposal since FY24). The structural case has hardened: foundry's negative segment margin remains a drag on the Samsung Electronics consolidated EBIT line, and a foundry carve-out + dedicated capital structure would (i) clarify the CHIPS Act recipient relationship for Taylor TX, (ii) ring-fence Samsung Foundry's Yongin allocation under the KR Semiconductor Special Act cluster designation, (iii) free the parent's balance sheet for HBM capex, (iv) potentially attract strategic foundry-customer equity (NVIDIA / Apple / Qualcomm participation) that TSMC's structural position prevents. The Semiconductor Special Act's presidential-commission machinery is the institutional vehicle under which such a carve-out clears state-aid / national- security review (Samsung Foundry technology is on the 2024-11-15 MOTIE NCT list).
**Accelerate the Xi'an NAND wind-down via Pyeongtaek and
Yongin Phase 1.** With the 2025-09-02 VEU revocation effective 2025-12-31, the rational forward path is to migrate Xi'an's NAND output back to Korea. Trade-off: Korea-side capex is fiscally subsidised (K-Chips Act 15% ITC + Semiconductor Special Act special account) but Xi'an's already-paid-for fixed capital becomes stranded once the migration completes.
**Productise Galaxy AI's on-device LLM stack as a Sovereign-
AI Hardware SKU.** The KR AI Basic Act + Samsung's vertical integration (Galaxy + Exynos NPU + Samsung Foundry process) create a Korean-sovereign-AI stack that is conceptually symmetric with the NVIDIA G42 RTE compliance-wrapper product. If executed, Samsung captures the Sovereign-AI consumer- hardware perimeter that NVIDIA has captured on the data- centre side.
display stack as the EU-CRMA strategic-project anchor.** Per the EU-Vietnam CSP (2026-01-29) and CRMA strategic-project designation, Samsung Display Vietnam panels could enter the EU market under CRMA sourcing preference. The trade-off is EU-state-aid conditionality (joint-venture obligations, technology-transfer covenants under CRMA Article 7).
The single highest-leverage open management decision is whether to carve out Samsung Foundry. The combination of the CHIPS Act Taylor TX recipient relationship, the MOTIE NCT outbound-investment screening, the Semiconductor Special Act's cluster authority, the foundry segment's persistent loss-making at the consolidated EBIT line, and the parent balance sheet's competing demand for HBM4 capex makes 2026-2027 the structural decision window. Q3 2026 Samsung corporate restructuring announcement (or its explicit absence at the Q3 capex guidance) is the signal 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, US Commerce, KR MOTIE / MOTIR / MSIT / KCC, JP METI, or PRC MOFCOM with target_sectors including semiconductors, foundry-logic, dram, nand, hbm, ai-compute, display-oled, or mobile-handsets; (b) a Section 232 derivative-products list expansion FR notice; (c) a Samsung corporate-restructuring event (Samsung Foundry carve-out announcement, Harman divestiture, Samsung Display demerger); (d) a CHIPS Act award-oversight event affecting Samsung Taylor TX (milestone re-tranching, covenant breach, supplemental award); (e) a KR Semiconductor Special Act enforcement-decree publication or cluster-designation event; (f) any further OFAC enforcement action against a Samsung-affiliated US entity. 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 + foundry + handset cross-section of the chip-control architecture. Samsung is the only company in the system simultaneously sitting in the demand-side (Samsung Foundry as a TSMC alternative for AI accelerators), the supply-side (Samsung HBM3E / HBM4), and the consumer-hardware (Galaxy AI handset, Samsung TV) cells of case #4's matrix.
[docs/intelligence/dossiers/000660-ks.md](./000660-ks.md) — direct comparator on memory; structural contrast on foundry, display, mobile, automotive-electronics
[docs/intelligence/dossiers/tsm.md](./tsm.md) — Samsung Foundry's principal competitor for advanced-node logic; TSMC's CoWoS lock-in is the binding constraint on Samsung Foundry's AI-accelerator customer acquisition
[docs/intelligence/dossiers/asml.md](./asml.md) — sole-source EUV supplier to Samsung DRAM (Pyeongtaek) and Samsung Foundry (Hwaseong 3nm GAA + Yongin 2nm SF2)
[docs/intelligence/dossiers/nvda.md](./nvda.md) — Samsung's principal HBM3E / HBM4 customer for the Rubin platform; also the dominant counterparty for Samsung Foundry's external-customer AI-accelerator pipeline competitive against TSMC
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.
Named customers (1)
Direction NOT READABLE — 1 counterparty is disclosed across two filings, but none carries figures that can honestly be compared. This is a gap in what the filer published, not a finding that nothing moved.
Read from the filer's own disclosed shares across vintages — what the company did, not pressure applied to it. Separate from every score on this page. “Unchanged” means every comparable move is under 2.0 points — a stated, arbitrary band, not a fitted one.
Apple Inc.202452.90% of Samsung Display's computed unit share of Apple's combined 2024 iPhone OLED panel shipments (Samsung 124m / LG Display 67.5m / BOE 43m per UBI Research) → 202553.30% of Samsung Display's computed residual share of Apple's 2025 iPhone OLED panel supply (UBI Research, reported via Display Daily 2026-02-13: LG Display 30.3%, BOE 16.4%, Samsung's own unit volume not publicly disclosed)not comparable · shares of different bases2024 ↗2025 ↗arm's lengthwebsearchsecondary
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
2024 · UBI Research unit-shipment figures reported via OLED-Info (2025-08-29): Samsung Display shipped 124 million OLED panels to Apple in 2024 versus LG Display's 67.5 million and BOE's 43 million — a computed 52.9% unit share, not a company-disclosed percentage. Neither Samsung nor Apple names the other or discloses a per-customer percentage directly; Samsung's own 2025 Sustainability Report states only that the Americas (where Apple is based) is 45.6% of Display-segment revenue, an aggregate that is NOT a per-customer share and is not used as one here. (Trade-pairs refresh 2026-09-29: OLED display panels are a finished component, not trade in any raw material; no plant-to-plant route is stated, so no corridor is credited.)source ↗
2025 · DIFFERENT BASIS from the 2024 row above — not a directly comparable vintage pair, so no delta is claimed. The 2024 figure is a unit-count share computed from raw shipment totals; this 2025 figure is Samsung's residual (100% − LG Display 30.3% − BOE 16.4%) because UBI/Display Daily reported LG's and BOE's shares directly but stated Samsung's absolute 2025 unit volume was not publicly disclosed. The residual is arithmetic on two disclosed percentages, not an invented number, but it inherits any imprecision in those two figures and assumes no fourth supplier. Confirms Samsung remained the largest of the three suppliers through 2025. (Trade-pairs refresh 2026-09-29: OLED display panels are a finished component, not trade in any raw material; no plant-to-plant route is stated, so no corridor is credited.)source ↗
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
Graphite
4Geopolitical: 27 restrictive actions, peak severity 5, 16 in last 24mo, less 5 liberalising actions
4Concentration: refining HHI 7302 (extreme); top CN 85%
5Price / market: price up, as of 2026-09-01
4Substitutability: silicon-blend anodes emerging but graphite still dominant
4Geopolitical: 37 restrictive actions, peak severity 5, 24 in last 24mo, less 4 liberalising actions
Lithium
4Geopolitical: 40 restrictive actions, peak severity 5, 21 in last 24mo, less 3 liberalising actions
5Price / market: price up, as of 2026-09-01
Copper
4Geopolitical: 52 restrictive actions, peak severity 5, 33 in last 24mo, less 3 liberalising actions
5Price / market: price up, as of 2026-09-01
4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 70/100 (long-horizon, all major uses). Prior analyst short-run rating 0.50: USGS: aluminium substitutes in some electrical/heat-exchange uses
Tin
4Geopolitical: 18 restrictive actions, peak severity 4, 13 in last 24mo
5Price / market: price up, as of 2026-09-01
Nickel
4Geopolitical: 29 restrictive actions, peak severity 5, 18 in last 24mo, less 4 liberalising actions
5Price / market: price up, as of 2026-09-01
Tantalum
4Geopolitical: 12 restrictive actions, peak severity 4, 8 in last 24mo, less 2 liberalising actions
Helium
5Substitutability: no substitute in cryogenics/MRI and most lifting/leak-detection uses
Chromium
4Geopolitical: 13 restrictive actions, peak severity 5, 9 in last 24mo, less 2 liberalising actions
4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 76/100 (long-horizon, all major uses). Prior analyst short-run rating 0.95: USGS: no substitute in stainless steel or superalloys
Aluminium
4Geopolitical: 43 restrictive actions, peak severity 5, 26 in last 24mo, less 1 liberalising action
China = 28% of filer-disclosed refiner mentions · 879 named refiners
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.
China = 43% of filer-disclosed refiner mentions · 243 named refiners
Two independent lenses: USGS official puts China at 50% of global refining output (by tonnage); US filers' own disclosures independently name China for 43% of their refiners (by facility count). Different metrics — both rank China first.
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.
2026-09-11amendedIndonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform— Kepmen ESDM No. 363.K/MB.01/MEM.B/2026 supersedes the Kepmen 144/2026 HPM formula for low-grade limonite: the nickel Correction Factor (CF) for 1.2%-Ni-or-lower ore is reset to 14% (falling 1pp per 0.1pp of grade below that), and the cobalt by-product coefficient is cut from 30% to 17%. Net effect on 1.2%-Ni ore: HPM falls ~45%, from USD 44.97/wmt to USD 24.89/wmt. The change targets the low-grade limonite/HPAL feedstock segment specifically — the 1.6%-grade CF set by 144/2026 is not disclosed as changed in available reporting.
Largest single fiscal lever for Samsung Electronics' Korean capex envelope. Samsung's domestic semiconductor capex runs KRW 25-30tn per annum; the 15% ITC implies KRW 3.75-4.5tn (~USD 3bn) of annual tax savings — materially larger absolute support than SK Hynix receives. The Korea–US ITC parity (K-Chips 15% large-corp / 25% incremental vs. US §48D 25%) is the calibrated incentive under which Samsung's 2023 announcement of the KRW 300tn 20-year Yongin programme was made.
Tightened FDP + end-use rules under which the same-day Samsung / SK Hynix VEU expansion was calibrated; substrate of the October-2024 / December-2024 / September-2025 escalation cycle.
Two-year calibrated safe harbour. Samsung China Semiconductor Co. Ltd. (Xi'an NAND fab) was granted VEU coverage of "all items subject to the EAR" except EUV for memory production — the explicit carve-out that let Xi'an run on DUV-class tooling and continue node migration through CY2024 H1. The 2025-09-02 revocation has to be read against this carve-out as the baseline; the binding loss is the *optionality* to migrate Xi'an onto more advanced NAND nodes, not the production envelope on Day 1.
Technical correction to the 2023-10-17 VEU expansion text; included here only as evidence of the procedural touch-points between BIS and Samsung China Semiconductor through the calibration window.
Statutory framework under which Korean strategic stockpiles, mandatory-disclosure obligations and crisis-import authorities operate for fab-relevant materials. Samsung is named in the early stakeholder consultation cycle; the "selected critical materials" designation framework is the vehicle for any future Samsung-side stockpile-eligibility classification.
The under-priced bilateral half of the Xi'an + Taylor TX freeze. MOTIE-designated National Core Technologies (NCT) cover HBM, advanced DRAM, advanced NAND, **and Samsung-distinctive: System LSI 3nm-and-below logic + Samsung Foundry GAA process**. Outbound investment for *any* Samsung Foundry overseas advanced-node expansion (including Taylor TX) is now technically subject to MOTIE approval — a procedural overlay on top of the US-side CHIPS Act award oversight that no other foundry carries. Combined with the 2025-09-02 BIS Xi'an VEU revocation, Samsung's overseas advanced-process footprint is now under bilateral state oversight from both source and destination jurisdictions.
Highest-severity action on the Samsung register. The HBM performance-threshold control puts all HBM3 / HBM3E / HBM4 stacks meeting the BIS performance bar under license for China export. Samsung's HBM3E qualification at NVIDIA had been the principal commercial battle; the BIS bar fully extinguishes any future Chinese-domiciled HBM customer (Huawei Ascend / Cambricon stack-supply), foreclosing a route that Samsung-side strategy had partially relied upon to absorb HBM3 yield. The structural effect: HBM stack export licensing is now an EAR-classified item independent of the chip it pairs with — the regulatory architecture under which any future "HBM-class export to non-China non-Tier-1 destinations" would be calibrated.
Same-day retaliation to the Dec-2024 BIS package. By exempting non-US destinations, MOFCOM preserved Korea-routed Ga / Ge flows for HBM advanced-packaging test lines. 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 MOFCOM's transit-control regime — Samsung-Galaxy-AI shipments to US consumer markets are inside the same disclosure perimeter.
The Pillar-2-driven shift from Vietnam tax holidays to direct subsidy puts **Samsung Vietnam** (the largest single FDI investor in Vietnam — Bac Ninh + Thai Nguyen handset/display assembly, Ho Chi Minh ATMP) at the front of the ISF eligibility queue. Samsung's Vietnam operations carry the Pillar-2 incremental burden but are also the most credible candidate for ISF direct grants. Cross-references the 2023-11-29 Vietnam Pillar-2 resolution. SK Hynix has zero Vietnam exposure; this is a Samsung-distinctive line in the register.
Establishes the foundry-side Approved / Authorized IC Designer framework under ECCN 3A090.a. Samsung Foundry is explicitly named alongside TSMC and GlobalFoundries as a covered fabricator. Samsung Foundry's customer base (NVIDIA Tegra historical, Qualcomm legacy 4nm, Tesla HW4 / FSD chip, IBM Power, plus Korean fabless ecosystem) is now subject to designer-due-diligence in a way that creates direct customer-acquisition friction relative to TSMC (whose Approved Designer list rolled out faster). The 2026-04-09 deadline extension (action below) is the procedural relief.
The Galaxy / Bixby / Samsung Sovereign-AI vector that no other chipmaker dossier touches. The AI Basic Act's "high-impact AI" tier (healthcare, employment, public-service applications) applies to Samsung Health, Samsung SDS enterprise-AI services, and Galaxy AI's on-device LLM where it intersects high-impact use. Extraterritoriality + mandatory local-representative obligations apply to Samsung's overseas-developed AI features incoming back to the Korean market. Pairs symmetrically with the 2024-08 EU AI Act exposure on Galaxy hardware sold into the EU.
Demand-side counterparty. MSIT procures NVIDIA B200 / H200 systems carrying SK Hynix-dominated HBM3E; **Samsung HBM3E ramp is the second-supplier challenger** — the NAICC procurement is the demonstration channel under which Korean sovereign-AI demand pulls Samsung HBM into NVIDIA's qualified-supplier rotation.
Critical for Samsung's combined Pyeongtaek-P3-through-P6 + Yongin-5-fab >12 GW projected load envelope. Materially under-priced: per the action's own commentary, the Act removes "fab energisation risk on Yongin cluster phases 2–5" — phases 2-5 are the *Samsung Foundry* portion of Yongin (SK Hynix occupies phase 1). The discount-rate effect on Samsung's 20-year KRW 360tn capex envelope from compressing the grid-build cycle by ~3 years is sell-side under-modelled.
**Samsung-distinctive. The only IPTM-registered direct OFAC enforcement against a covered company in the chip-architecture cluster.** Harman International (Samsung's US subsidiary, ~USD 8bn 2017 acquisition value) agreed to a USD 1,454,145 total settlement for 11 apparent "egregious" violations of the Iranian Transactions and Sanctions Regulations (UAE distributor → Iran diversion, May 2018–Oct 2020) — corrected 2026-08-22 verification pass: of that total, USD 1,054,145 was paid to OFAC and the remaining USD 400,000 was suspended, conditioned on Harman investing an equivalent amount in sanctions-compliance improvements (not an additional payment on top of the $1.45m as the prior wording implied). The OFAC determination established the precedent that overseas employees of a US subsidiary acting under "actual knowledge" are imputed to the US person. Creates an ongoing case-precedent risk for Samsung's broader US distribution and Middle-East-regional sales network that no peer chipmaker carries.
Materially MORE impactful for Samsung than for SK Hynix: Samsung Xi'an represents ~40% of Samsung's global NAND wafer starts, whereas SK Hynix Wuxi is legacy DRAM only. From 2025-12-31, every restricted shipment to Xi'an requires an individual case-by-case license. The post-Busan license-practice trend toward case-by-case approval softens the day-1 production-envelope effect but the binding optionality loss is the migration path for Samsung Xi'an onto sub-200-layer NAND nodes — and Samsung's principal Korean NAND fab (Pyeongtaek) is already running near full utilisation, so any Xi'an-to-Korea NAND-output migration carries a clear capex bill.
The bilateral umbrella under which the KR reciprocal-tariff ceiling is set at 15% (vs. 25% default) and KR-origin semiconductors receive "no less favourable than MFN" treatment. 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 Samsung Taylor's already-disclosed but partially-stalled USD 25bn+ capex programme.
KR explicitly named as a target country. Samsung's exposure profile is broader than SK Hynix's because the "derivative products" mechanism plausibly reaches: (a) HBM stacks landed in US AI systems, (b) NAND-flash SSDs landed in US datacentre / consumer products, (c) Samsung Foundry-fabbed advanced AI accelerator chips (Tesla HW4 / FSD, IBM Power, Korean fabless customer parts) sold into US OEM channels, (d) Samsung Mobile handsets and Galaxy tablets landed in US consumer channels. The KR-US 15% cap partially offsets the IEEPA-reciprocal layer; the §232 layer is technically separate. Commerce derivative-list FR notices are the watch event.
Capstone of the Korean industrial-policy stack. Presidential Commission for Semiconductor Competitiveness + statutory five-year master plan + KRW 2tn dedicated special account + statutory cluster-designation authority. Per the Act's own discussion, the cluster-designation authority **gives Samsung Foundry's Yongin (3nm+) build-out additional institutional backing** — directly named in the legislation's downstream-impact analysis. Pairs with the Power Grid Act + Resource Security Act to form the three-Act statutory stack under which Samsung's Korea-side fab economics are now anchored.
Procedural extension of the FDD IFR deadlines from 2026-04-13 to 2026-12-31. Samsung Foundry is explicitly named in the action commentary as an intended beneficiary — buys ~8 months of breathing room for the Korea / Taiwan / Japan design ecosystem feeding Samsung Foundry through License Exception AIA / ACM.
🇨🇳 CN has issued 5 restrictive actions on Graphite since 2023 — cadence accelerating (mean gap 360d → 129d), severity flat (4.5 → 2.3).A descriptive trajectory of past official actions — not a forecast.
🇨🇳 CN's demonstrated restriction sequence — has restricted 34 materials since 2016, in this demonstrated order:
You hold exposure to 11 of these 34 materials (Cobalt, Copper, Chromium, Lithium, Aluminium, Gallium, Graphite, Neodymium, Tungsten, Indium, Silver) — your binding Graphite exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 3.5 months apart across 15 distinct restriction dates since 2016 (n=14 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 Graphite, 🇺🇸 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 🇨🇳 CN restricts your Graphite, 🇺🇸 US has historically countered (median 6.8 months later) — and those counter-moves have also restricted Gallium, which you also depend on (n=5 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 of 5 via quantified basis).
when 🇨🇳 CN restricts your Graphite, 🇺🇸 US has historically countered (median 2.6 months later) — and those counter-moves have also restricted Tungsten, which you also depend on (n=4 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 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
Graphite — 🇨🇳 CN escalates graphite controls to a full export-licensing / ban regime
79
84
+5
Concentration
Graphite — 🇨🇳 CN becomes the single source for graphite — the second source is lost (full 85%+ monopoly)
79
87
+8
Policy
Tungsten — 🇨🇳 CN escalates tungsten controls to a full export-licensing / ban regime
78
82
+4
Concentration
Tungsten — 🇨🇳 CN becomes the single source for tungsten — the second source is lost (full 90%+ monopoly)
78
84
+6
Policy
Gallium — 🇨🇳 CN escalates gallium controls to a full export-licensing / ban regime
76
80
+4
Concentration
Gallium — 🇨🇳 CN becomes the single source for gallium — the second source is lost (full 98%+ monopoly)
76
78
+2
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 — Definitive agreement signed, not yet closed — same board-approval/pre-MOFCOM stage as the parked CMOC-Equinox Gold entry above; distinct target (lithium, Ghana) and acquirer. Do not conflate with the already-filed Ghana mining-lease ratification (host-government instrument, different actor).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Lithium🇨🇳 today 62→68+6
🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)
passed-vote→high likelihood·flagged 56d ago · not yet law·matches Copper, Cobalt
If passed — On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
Caveat — ENACTED / already in force (signed 29 June 2026, five independent Congolese/international outlets corroborate the ministers, date and substance) but parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. cd unreachable per prior wakes — same constraint noted on the DRC Strategic Mineral Reclassification, ARECOMS forfeiture, and 5% Worker Equity entries elsewhere in this file). DISTINCT from: 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (ARECOMS sectoral cobalt-hydroxide quota system, cobalt-only), 2025-12-19-drc-artisanal-copper-cobalt-processing-suspension (artisanal-sector only), the queued ARECOMS H1-2026 quota-forfeiture entry above (operationalises the ARECOMS quota, not this arrêté), 2026-04-10-drc-strategic-reserve-minerals-arecoms, and 2026-05-29-drc-strategic-mineral-expansion-decree. This arrêté is the FIRST instrument in the register banning concentrate exports for BOTH copper and cobalt jointly and replacing the 2023 commercialisation/export/nomenclature framework wholesale — a materially broader legal basis than any of the above. Re-check mines. gouv. cd and jocc.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 60→64+4
Cobalt🇨🇳 today 64→69+5
🇬🇳 Guinea — Ministry of Mines plan to reduce bauxite export volumes to support prices (differential quota/allocation tied to downstream-investment commitments)
announced→low likelihood·flagged 67d ago · not yet law·matches Aluminium
If passed — On 18 March 2026 Guinea's Minister of Mines Bouna Sylla told Reuters that Guinea — the world's top bauxite exporter (~40% of global seaborne supply, 2025 exports ~183 Mt, +25% y/y) — would reduce export volumes "in the coming weeks" to support prices and protect small producers, explicitly declining to call it a formal quota ("it is not really a quota, but we will reduce the volumes we export") and ruling out an outright ban. The plan requires major miners (SMB, Chalco/Winning-linked entities, CBG) to submit three-year production plans aligned with their downstream/alumina-investment commitments, with an unofficial target of cutting annual exports toward ~150 Mt. As of end-June 2026 no formal decree had been issued; market reporting through June/July 2026 still describes the mechanism as pending/rumoured. Distinct from all filed Guinea actions (bauxite reference-price arrêté 2022, GUITRAM freight mandate, GAC/EGA concession revocation+settlement, Chalco/SPIC alumina refinery deals, June 2026 raw-gold export ban) — none of which is a bauxite export-volume/quota control. Materiality: Guinea is the Step-0. 5 priority-tier chokepoint for bauxite (feeds the aluminium value chain); a formal quota would be the first-ever volume control on Guinea's dominant bauxite export stream.
Caveat — gov. gn/Journal Officiel instrument or a specific quota tonnage figure attributed to government.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 42→47+5
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 67d ago · not yet law·matches Copper, Cobalt
If passed — Minister of Finance, acting under s. 89 of the Customs and Excise Act, cut the copper-concentrate export duty to ZERO for tariff headings 2603. 00. 21 / 2603. 00. 22 / 2603. 00. 23 / 2603. 00. 29, capped at 271,742 t, effective 1 June 2026 with automatic lapse 30 September 2026, with per-entity tonnage caps and (per one secondary) a requirement that exempt shipments channel through Industrial Resources Limited. This is a SUPPLY-RELIEF (liberalising) action — a net EASING of a copper/cobalt chokepoint for ~4 months, explicitly to clear stockpiled unprocessed concentrate while Zambia's major smelters are down for extended maintenance. It is the "(No. 2)" successor instrument to the already-filed 2026-03-05-zambia-si-15-2026-copper-concentrates-export-duty-suspension (a distinct SI with its own number, tonnage cap and validity window). Severity ~2 expected.
Caveat — ENACTED / already in force per multiple independent secondary sources (all agree on SI number, exact citation title, s. org URL pattern that resolves for the parent SI 15/2026 (`/akn/zm/act/si/2026/43/eng@<date>`) across several plausible dates, all 404; zambialii's SI-list index page for 2026 also 404s directly. Parked here per the standing verify-or-don't-file convention (cf. DRC ARECOMS, Pakistan chloroform, China sulfuric-acid entries below) rather than filed on secondaries alone. Re-check zambialii.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 60→64+4
Cobalt🇨🇳 today 64→69+5
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 67d ago · not yet law·matches Cobalt, Copper, Lithium, Aluminium, Graphite, 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.
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)
Cobalt🇨🇳 today 64→69+5
Copper🇨🇳 today 60→64+4
Lithium🇨🇳 today 62→68+6
Aluminium🇨🇳 today 42→47+5
Graphite🇨🇳 today 79→84+5
Neodymium🇨🇳 today 74→78
🇨🇩 DRC — ARECOMS forfeiture & reallocation of unused H1-2026 cobalt export quotas to the state strategic reserve (in force ~29 June 2026)
passed-vote→high likelihood·flagged 78d ago · not yet law·matches Cobalt
If passed — On ~29 June 2026 the Autorité de Régulation et de Contrôle des Marchés des Substances Minérales Stratégiques (ARECOMS) ordered that all first-half-2026 cobalt export quotas left unused by 30 June 2026 be forfeited and recovered, with a 5 July 2026 cutoff, and reallocated into ARECOMS's discretionary "strategic quota" pool (already ~10% of the 96,600 t/yr authorised volume) earmarked for national-interest local-processing projects. This is an escalation/operationalisation of the filed 2025-02-22 ARECOMS cobalt quota system: it concentrates additional volume under state discretionary control, tightens the effective free-market allocation for producers (Glencore/KCC, CMOC, ERG) on the world's dominant cobalt chokepoint (~76% of mine supply), and — via the linked customs-notification malfunction that blocked quota-linked export declarations after 1 July 2026 — created a real short-run supply interruption. IPTM action would be an AMENDMENT to 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system.
Caveat — ENACTED / already in force (not speculative) — parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. com, lentrevuemagazine, HCN Times). DISTINCT from filed 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (the quota framework this amends), 2026-04-10-drc-strategic-reserve-minerals-arecoms (the reserve's legal creation — this is the first operational feeding of that reserve via forfeited quotas), and 2026-05-29-drc-strategic-mineral-expansion-decree. Severity 3 expected.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Cobalt🇨🇳 today 64→69+5
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 73d ago · not yet law·matches Copper
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 60→64+4
🇳🇨 New Caledonia (France) — "renewed nickel doctrine" + nickel-industry recovery pact under the Bougival Accord
announced→low likelihood·flagged 84d ago · not yet law·matches Nickel
If passed — The 12 July 2025 Bougival Accord (13-page political agreement creating a "State of New Caledonia" within France, pending a 2026 referendum + French organic law) contains an economic-rebuilding pact that proposes a "renewed nickel doctrine" — reversing the long-standing New Caledonian export restriction that barred selling raw/unprocessed nickel ore, so as to *facilitate* raw-ore exports (incl. to Korean/Chinese offshore smelters) alongside a renewal of local processing capacity; paired with continued French state energy-price support for the territory's nickel plants (previously up to ~EUR 200m/yr). New Caledonia is a top-4 global nickel producer (SLN/Eramet, Prony Resources, KNS/Koniambo) and currently has 0 actions in the register, so this is a first-coverage chokepoint item. A doctrine that *loosens* raw-ore export controls is the mirror image of the African beneficiation/export-ban wave (Indonesia nickel, Zimbabwe lithium, Gabon manganese) — it would re-open Caledonian ore to the seaborne market and re-price the nickel supply chain. As of the latest reporting the nickel-specific "pacte nickel" is described as "in limbo," with France having set an end-March deadline for a nickel deal — so this is announced/negotiated, NOT yet enacted in a decree or organic law.
Caveat — NOT speculative — the renewed nickel doctrine is an explicit named component of the signed Bougival Accord and the ~EUR 200m/yr state energy support and end-March nickel-deal deadline are on-record — but the nickel-specific pact is unfinalised ("in limbo") and the accord as a whole is contingent on a 2026 referendum and a French organic law, so no enacted primary instrument exists to file yet. First NC action of any kind in the register (0 existing). Distinct from all filed nickel actions (Indonesia downstream mandates, Philippines ore-export debates) — this is a *liberalising* doctrine on a French-territory chokepoint. Watch the 2026 referendum timeline and Légifrance/gouv. nc for the implementing text.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Nickel🇨🇳 today 56→62+6
🇨🇱 Chile — outgoing Boric government's fast-tracked batch of 5 additional CEOL lithium salt flats (Ascotán, Quillagua Sur, Hilaricos, Piedra Parada, Agua Amarga) submitted to the Contraloría for toma de razón
awaiting-signature→high likelihood·flagged 84d ago · not yet law·matches Lithium
If passed — In March 2026 the outgoing Boric administration reportedly fast-tracked and submitted to the Contraloría General de la República (Chile's comptroller) a batch of ~5 further Contratos Especiales de Operación de Litio (CEOL) covering the Ascotán, Quillagua Sur, Hilaricos, Piedra Parada and Agua Amarga salares — extending the state-controlled-lithium footprint of the National Lithium Strategy (2023-04-20, filed) beyond the already-filed CEOLs (ENAMI Salares Altoandinos 2025-09-05, Codelco–Rio Tinto Maricunga 2026-02-12, CleanTech Laguna Verde 2026-03-10). Codelco separately moved on Ascotán brine assets in April 2026. Each CEOL, once it clears toma de razón and is decreed, gates who may extract lithium (a designated strategic substance in Chile, reserved to the state) at that salar and on what state-participation terms — incrementally re-pricing the Chilean (Andean lithium-triangle) chokepoint and locking in state operational control before the incoming government.
Caveat — floated), nor the exact toma-de-razón status per salar. Not speculative (named salares + submitting government + instrument type + March-2026 date are corroborated across two outlets, and the Ascotán move is independently reported), but below register-grade precision — hence parked here as an early-warning batch marker rather than filed. DISTINCT from all filed CL CEOL/lithium actions: 2023-04-20 National Lithium Strategy, 2025-09-05 ENAMI Salares Altoandinos CEOL, 2025-12-27 NovaAndino Codelco–SQM JV, 2026-01-27 National Critical Minerals Strategy, 2026-02-12 Maricunga CEOL definitivo, 2026-03-10 Laguna Verde CEOL. A future wake/GTA will likely catch each of the five as it is formally decreed — resolve this batch marker salar-by-salar as they promote.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Lithium🇨🇳 today 62→68+6
🇬🇳 Guinea — Nimba Mining Company (NMC, 100% state-owned) / Glencore bauxite pre-financing and marketing agreement
announced→low likelihood·flagged 14d ago · not yet law·matches Aluminium
If passed — On 7 September 2026 Guinea's state-owned Nimba Mining Company and Glencore signed a five-year pre-financing agreement, announced by the government and Glencore on 10 September 2026, worth over USD 300 million and covering marketing of 10-12 Mt/yr of bauxite (50-60 Mt over the contract term) — a trader advance repaid via physical bauxite delivery rather than conventional debt. Minister of Mines and Geology Bouna Sylla is quoted on-record calling the signing a milestone for Guinean state participation in the mining value chain, and Guinea is separately reported discussing alumina-refining and energy investment with Glencore. This sits alongside the register's other Guinea bauxite-sector state-control instruments (2022 reference-price arrêté, GUITRAM freight mandate, GAC/EGA concession revocation, the parked export-volume-reduction plan below) and is part of the government's "Simandou 2040" push to expand national participation in extractives. Theme candidate: em-resource-upstream-capture. Polarity: none declared (a financing/offtake deal, not a restrictive or liberalising regulatory measure — but materially entrenches state-company control of a bauxite export stream at Guinea's dominant chokepoint, ~40% of global seaborne bauxite supply).
Caveat — gov. gn directly (reachable, HTTP 200) and searched its site for "Nimba Glencore" (no results); a mining. com direct fetch also 403'd. Parked here per verify-or-don't-file rather than filed on secondaries alone. Distinct from the already-parked "Guinea — Ministry of Mines plan to reduce bauxite export volumes" entry below (a volume-quota policy proposal, not this specific NMC-Glencore commercial financing/offtake contract).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 42→47+5
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 99d ago · not yet law·matches Graphite, Nickel, Neodymium, Lithium, Cobalt, 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)
Graphite🇨🇳 today 79→84+5
Nickel🇨🇳 today 56→62+6
Neodymium🇨🇳 today 74→78+4
Lithium🇨🇳 today 62→68+6
Cobalt🇨🇳 today 64→69+5
Helium🇺🇸 today 44→54
🇰🇿 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 99d ago · not yet law·matches Copper, Neodymium, Chromium
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)
Copper🇨🇳 today 60→64+4
Neodymium🇨🇳 today 74→78+4
Chromium🇨🇳 today 43→49+6
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 100d ago · not yet law·matches Copper, Nickel, Cobalt
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in advanced negotiations to acquire a 15-20% equity stake (deal value ~USD 1. 5-2bn) in First Quantum Minerals' Zambian copper and nickel operations — i. e. the Kansanshi and Sentinel/Trident copper complex (Zambia's largest copper mines, ~0. 4-0. 5 Mt/yr combined) plus nickel. This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) directly into a binding African copper chokepoint, paralleling Manara's filed Vale Base Metals 10% stake (2024-03-01-sa-manara-minerals-vale-metals-10pct-stake) and its in-negotiation Reko Diq stake (queued below), and mirroring UAE IRH's Mopani (Zambia) acquisition. Gives Saudi Arabia an equity claim on a major non-China copper supply source and injects fresh capital into FQM as it recovers from the Cobre Panamá shutdown — a Gulf-capital re-pricing of Zambian copper supply risk that the exposure engine should track.
Caveat — As of 2026-06-28 this is in advanced negotiation, no signed SPA — hence announced/upcoming not enacted. DISTINCT from the Reko Diq (Pakistan) Manara stake queued below (different asset, different host country) and from the filed Vale Base Metals 10% stake. If completed, severity 2-3.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 60→64+4
Nickel🇨🇳 today 56→62+6
Cobalt🇨🇳 today 64→69+5
🇮🇩 Indonesia NPI/Ferronickel/MHP Export Duty — ESDM Commitment, April 2026 Launch Postponed Indefinitely
announced→low likelihood·flagged 103d ago · not yet law·matches Nickel
If passed — Indonesia = ~50% global nickel mine supply and dominant producer of NPI/ferronickel/MHP; export duty on downstream nickel products (NPI, ferronickel, nickel matte, MHP) would add a material cost layer to ~$15B/yr Indonesian processed-nickel export chain; reprices stainless-steel and EV-battery Class 1 nickel supply for Chinese RKEF operators and global buyers; shifts relative competitiveness of Indonesian vs Filipino/Russian/Canadian nickel supply
Caveat — Government originally planned April 1, 2026 implementation; ESDM Minister Bahlil Lahadalia confirmed postponement in April 2026 pending resolution of unresolved questions about calculation mechanisms, price thresholds, and product-specific rates for NPI/ferronickel/nickel-matte/MHP; Nickel Miners Association and Indonesian Nickel Smelters Association both formally requested delay citing thin margins; no alternative implementation date set as of June 2026. Distinct from: filed 2025-04-11-indonesia-pp-19-tiered-minerba-royalty (royalty regime for extraction, not export duties on processed products); filed 2019/2023 nickel ore export bans (ore, not downstream); 2026-05-20-indonesia-dsi-sole-exporter (export-channel monopoly, not price levy). This is a new instrument type — first-ever export duty proposed on downstream/processed nickel products. Severity 3 expected if enacted.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Nickel🇨🇳 today 56→62+6
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 109d ago · not yet law·matches Lithium, Neodymium, Copper, Cobalt, Graphite
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)
Lithium🇨🇳 today 62→68+6
Neodymium🇨🇳 today 74→78+4
Copper🇨🇳 today 60→64+4
Cobalt🇨🇳 today 64→69+5
Graphite🇨🇳 today 79→84+5
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 113d ago · not yet law·matches Lithium, Cobalt, Neodymium, Nickel
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)
Lithium🇨🇳 today 62→68+6
Cobalt🇨🇳 today 64→69+5
Neodymium🇨🇳 today 74→78+4
Nickel🇨🇳 today 56→62+6
🇨🇩 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 114d ago · not yet law·matches Lithium, Tantalum, Tungsten, 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)
Lithium🇨🇳 today 62→68+6
Tantalum🇨🇳 today 45→51+6
Tungsten🇨🇳 today 78→82+4
Neodymium🇨🇳 today 74→78+4
🇬🇳 Guinea Bauxite Export Volume Controls 2026
announced→low likelihood·flagged 115d ago · not yet law·matches Aluminium
If passed — GN ≈ 60% global seaborne bauxite; a ~150 Mt/yr cap (vs 183 Mt 2025) tightens the alumina→aluminium chain — direct hit to EU aluminium-vertical names
Caveat — ministerial-announcement stage since 2026-06-01; repeatedly skipped by filing for lack of a gazetted decree — relocated here 2026-06-13. Sev 3 if decree issued, sev 2 if still announcement-stage.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 42→47+5
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 115d ago · not yet law·matches Tin, Tungsten, Tantalum
If passed — Mandates 15% free-carried interest for Uganda National Mining Company (UNMC) in all new mining licences; introduces mandatory mineral buying centres; tightens local-content and value-addition obligations — changes joint-venture economics for all new Ugandan mining operations, raising effective cost-of-entry for foreign miners
Caveat — Amends the already-filed Uganda Mining and Minerals Act 2022 (UG action 1); expected to be enacted before end of 2025/26 parliamentary session per legal commentary; Bank of Uganda gold purchase programme and new mineral buying centres already being piloted — regulatory infrastructure being built ahead of formal enactment. Distinct from filed Uganda Gold Export Regulations 2024 (SI No. 30 of 2024).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Tin🇨🇳 today 57→61+4
Tungsten🇨🇳 today 78→82+4
Tantalum🇨🇳 today 45→51+6
🇳🇦 Namibia new Minerals Bill (Minerals Prospecting and Mining Act overhaul)
in-consultation→moderate likelihood·flagged 114d ago · not yet law·matches Lithium
If passed — 10% free-carried state equity in ALL new mining and energy projects (no-cost government stake via Epangelo Mining); consultations on 51% Namibian ownership in new mining ventures; maximum royalty rate rise from 5% to potentially 10% for strategic minerals; introduction of profit-based windfall-tax mechanism; tighter local-content and environmental obligations; affects Uranium One/NamCor (uranium), Osino Resources, B2Gold, and lithium juniors in Namibia
Caveat — Reforms the 1992 Minerals (Prospecting and Mining) Act — the foundational mining law since independence. MME announced that Government is also consulting on mechanisms to promote 51% Namibian ownership in new ventures (more aggressive than the 10% headline). The Extractor Magazine (July 17, 2025) and Veridicor (Sep 16, 2025) also confirm reform scope. Distinct from already-filed NA actions: 2023-06-06 Cabinet export ban on unprocessed critical minerals; 2024-12-04 National Upstream Petroleum Local Content Policy; 2025-09-23 Nuclear Industry Strategy. The 2025 Nuclear Strategy covers uranium value-chain capture but not the broader Minerals Act reform. Namibia is the 3rd-largest uranium producer globally (Rössing, Husab) and an emerging lithium jurisdiction.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Lithium🇨🇳 today 62→68+6
🇮🇩 Indonesia Tin Export Ban — Downstreaming Initiative
announced→low likelihood·flagged 114d ago · not yet law·matches Tin
If passed — Indonesia = ~20% of global refined tin exports (Bangka Belitung); a ban on refined-tin exports would force downstream solder/semiconductor-packaging manufacturing domestically; disrupts global electronics and EV supply chains dependent on Indonesian tin solder and specialty alloys
Caveat — Minister of Energy and Mineral Resources Bahlil Lahadalia announced government "studying" tin export ban on February 13, 2026 at the Indonesia Economic Outlook, Jakarta; framed as replication of 2020 nickel ore ban which claimed 10x value-add uplift; key complication — Indonesia already exports refined tin (not raw ore), so a ban would require immediate creation of advanced downstream industries (solder, electronic-grade tin, semiconductor components) that don't yet exist at scale; Mining Weekly (Feb 13 2026) and BERNAMA (Feb 2026) confirm announcement; no Perpres, PP, or Kepmen issued as of June 14, 2026; government described as "studying" — not yet in formal regulatory drafting. Distinct from filed Indonesia nickel ore export bans (2019, 2023), filed bauxite export ban, and filed Permendag export-licensing amendments.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Tin🇨🇳 today 57→61+4
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 114d ago · not yet law·matches Tin, Lithium
If passed — Prohibits raw mineral exports unless 30% value-addition achieved domestically; affects Chinese mining companies (dominant in Nigerian critical minerals sector), Western offtake agreements, and all foreign-invested mining JVs; builds on existing eMC+ digital cadastre and mandatory value-addition plans introduced Nov 2024; could force processing-plant investment or suspension of raw mineral shipments from Africa's most populous economy; RMRDC = Raw Materials Research and Development Council (the sponsoring agency)
Caveat — Bill passed third reading in House of Representatives; multiple Nov 2025 sources confirm both chambers approved; as of 2026-06-14 presidential signature not yet confirmed. Distinct from filed Nigeria Tax Reform Acts 2025 (Loi n°1/19 tax restructuring) and Mining Cadastral licence revocations (2025-06-19). Applies to ALL raw materials, not minerals only — IPTM relevance is the mineral export provisions.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Tin🇨🇳 today 57→61+4
Lithium🇨🇳 today 62→68+6
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 114d ago · not yet law·matches Copper, Silver
If passed — Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mining concessions for first time in Peruvian law history, making concessions revocable by administrative authority; introduces higher annual fees and stronger production/investment requirements; threatens legal certainty for Peru's undeveloped copper and silver project pipeline — Peru = #2 copper, #4 silver, #1 lead, #2 zinc globally
Caveat — Approved by Energy and Mining Commission March 17, 2026 by 11 votes to 1 with 3 abstentions — driven by left-aligned Juntos por el Perú (JPP) and Podemos Peru majority. Bill also introduces "comuneros como accionistas" (community shareholders) in mining concessions — first legislative insertion of indigenous community equity rights. MINEM, SNMPE, ComexPerú, and Ingemmet publicly opposed; MINEM warns reform would incentivise illegal mining expansion. Full plenary debate pending as of June 2026. Distinct from all filed PE actions (all executive/regulatory decrees — no prior legislative amendment to Ley General de Minería in register). Also distinct from filed PE actions on REINFO extension (2025-12-26), illegal-mining criminalization (2026-01-20), and Tía María revocation (2026-03-19).
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Copper🇨🇳 today 60→64+4
Silver🇲🇽 today 41→50+9
🇸🇱 Sierra Leone No Raw Minerals Export Commitment (VP Jalloh, Mining Week May 2026)
announced→low likelihood·flagged 114d ago · not yet law·matches Aluminium
If passed — VP declared no new large-scale mining agreement will be concluded without a binding value-addition commitment; Mines Minister referenced Zimbabwe, Tanzania, Ghana, and Malawi precedents for raw-mineral export bans; if codified as a Statutory Instrument or Finance Act amendment, would impose export duties or licensing requirements on unprocessed rutile (Sierra Rutile / Iluka/Anglo American), ilmenite, zircon, bauxite, and diamond rough from new concessions; SL = world's top-5 rutile producer — a value-addition mandate on rutile concentrates would affect the entire global TiO2/titanium feedstock supply chain
Caveat — Declared May 2026 at Mining Week (coinciding with 2026-2031 National Critical Minerals Strategy launch, already filed). VP wording "new large-scale mining agreement" suggests concession-by-concession contract conditionality rather than a blanket statutory export ban; no bill, statutory instrument, or gazette reference found as of 2026-06-14. Distinct from SL CI national strategy (2026-05-20, filed) and SI 11/2024 SLMMDMC asset allocation (2026-06-02, filed as amendment to SLMMDMC Act).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 42→47+5
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches Lithium, Cobalt, Nickel, Neodymium, Graphite, Tungsten, Gallium, Indium
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)
Lithium🇨🇳 today 62→68+6
Cobalt🇨🇳 today 64→69+5
Nickel🇨🇳 today 56→62+6
Neodymium🇨🇳 today 74→78+4
Graphite🇨🇳 today 79→84+5
Tungsten🇨🇳 today 78→82+4
Gallium
🇹🇼 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 113d 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 113d 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 74→78+4
🇪🇺 EU CBAM Scope Expansion to ~180 Downstream Steel/Aluminum Products (COM(2025) 989 final)
draft-published→moderate likelihood·flagged 112d ago · not yet law·matches Aluminium
If passed — Extends the Carbon Border Adjustment Mechanism from the existing Regulation (EU) 2023/956 sectors (steel, aluminium, cement, fertilisers, hydrogen, electricity) to approximately 180 downstream products with high steel and/or aluminium content — including car parts, domestic appliances (refrigerators, washing machines), power transformers, cables, farming machinery, construction products, and a wide range of industrial equipment; ~2. 5% additional EU imports brought into CBAM scope; entry-into-force proposed from 1 January 2028; also introduces new anti-circumvention provisions (concept of "abusive practices" in proposed Art. 3(35)) targeting operators who split shipments or route via third countries to avoid CBAM liability; affects manufacturers in third countries (China, India, Vietnam, Turkey, ASEAN) that export steel- and aluminium-intensive goods to the EU; raises cost of embedded carbon in European supply chains for all downstream industrial inputs; structurally adjacent to CBAM definitive-phase commencement (January 1, 2026, already filed) — this is a legislative extension, not an implementing regulation
Caveat — Public consultation on downstream scope extension ran July 1 – August 26, 2025 (taxation-customs. ec. europa. eu); Commission adopted proposal December 17, 2025 alongside CBAM implementing acts package; Parliament lead committee is ENVI; Council working group active as of early 2026; no trilogue date announced. Distinct from: filed 2023-05-10-eu-carbon-border-adjustment-mechanism-2023-956 (base regulation, original scope) and 2023-05-10-eu-cbam-definitive-phase-entry-into-force (January 1, 2026 definitive-phase transition). Likelihood is elevated (not high): political consensus on CBAM base regulation was strong, but downstream expansion faces pushback from importing industries and some Member States worried about competitiveness. Secondary: https://taxation-customs. ec. europa. eu/news/cbam-public-consultation-extension-cbam-downstream-products-2025-07-02_en
▲Extends an already-in-force regime (not a new law) (strong) — This amends the existing CBAM Regulation (definitive period live since 2026) rather than creating a new instrument — extensions of in-force EU regulations carry high passage odds vs. novel files.source ↗
▲Council general approach adopted (strong) — The Council reached a general approach on the downstream extension on Jun 12, 2026 — the Council leg of the ordinary legislative procedure is aligned, leaving EP plenary + trilogue.source ↗
▲EP rapporteur appointed and progressing (moderate) — MEP Mohammed Chahim named rapporteur Feb 23, 2026; the Parliament file is moving through committee, not stalled.source ↗
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Aluminium🇨🇳 today 42→47+5
🇿🇦 South Africa DTIC Industrial Development Strategy 2026 — chrome export tax/quota + beneficiation licensing conditions
passed-committee→elevated likelihood·flagged 113d ago · not yet law·matches Chromium
If passed — If enacted, chrome ore export tax and/or quota would disrupt South Africa's ~2. 4 Mt/yr chrome ore export stream (≈45% of global seaborne supply); beneficiation licensing conditions attached to mineral rights allocations would require FTSE/JSE-listed chrome miners (Samancor/Merafe, Assore, Glencore) to build local ferrochrome and stainless-steel capacity before new rights are allocated; PGMs and other minerals may follow chrome as the test-case model, expanding scope to the full South African mining portfolio
Caveat — DMPR Director-General Jacob Mbele publicly described DTIC's beneficiation licensing proposal as outside DMPR's agreed jurisdiction ("a proposal, not agreed policy") — inter-departmental tension signals implementation risk; Minerals Council SA (90% of output by value) stated June 9, 2026 it will "engage" but expressed significant concern about policy uncertainty (TimesLive / Engineering News June 9, 2026). Cabinet approval makes this official government strategy direction; implementing instruments require separate legislative/regulatory action. Secondary: https://www. engineeringnews. co. za/article/minerals-council-to-engage-dtic-on-beneficiation-element-of-new-industrial-development-strategy-2026-06-09
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Aluminium
If passed — Guinea = world's #2 bauxite producer (183 Mt exported in 2025, ~45% of China's bauxite imports); Mines Minister Bouna Sylla confirmed in March 2026 that export volume curbs will be applied by early April 2026 to halt a ~50% price collapse from 2025 overproduction; target cap ~150 Mt/yr (≈18% reduction from 2025 actual); enforced via licence compliance — operators exceeding feasibility-study production ceilings face volume restrictions, not an outright export ban; formal policy instrument expected June 2026 per Bloomberg/Mining. com; mechanism: production-cap enforcement rather than new legislation, but a ministerial arrêté is the likely vehicle
Caveat — Distinct from all 7 filed GN actions: distinct from 2025-07-14-guinea-guitram-freight-mandate (state shipping — different instrument), 2025-08-05-guinea-presidential-decrees-gac-ega (concession revocations — different target), 2026-05-21-guinea-chalco-alumina-refinery-boffa (investment agreement — not export control). This action is the first GN volume-cap mechanism targeting all bauxite exporters. Severity estimate: 3 (affects ~45% of China's bauxite import supply; price-floor mechanism with direct feedthrough to aluminium production costs for smelters globally). Filed in upcoming queue 2026-06-16 per chokepoint-tier gap (Guinea = key bauxite chokepoint). No formal arrêté confirmed as of 2026-06-16.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Aluminium🇨🇳 today 42→47+5
🇬🇳 Guinea Alumina Refinery Ultimatum — SMB and CBG 10-Day Deadline to Submit Construction Timeline (June 2026)
announced→low likelihood·flagged 112d ago · not yet law·matches Aluminium
If passed — Guinea's CNRD junta gives Societe Minière de Boke (SMB, China-linked, ~50% of Guinea's bauxite output) and Compagnie des Bauxites de Guinée (CBG, joint venture: Halco Mining/Alcoa/Rio Tinto/Dadco) 10 days to present binding alumina refinery construction timelines; May deadline was missed; government stated "the companies had already committed to developing local refineries"; failure to comply risks concession revocation or conditions — the August 2025 GAC/EGA revocation provides the enforcement precedent; Guinea government has publicly stated intent to move up the bauxite value chain toward alumina and aluminum
Caveat — Distinct from 2025-08-05-guinea-presidential-decrees-gac-ega (that action revoked GAC/EGA specifically; this action targets SMB and CBG, which are Guinea's two largest bauxite operators — combined ~70% of Guinea's total bauxite exports). Distinct from 2026-05-21-guinea-chalco-alumina-refinery-boffa (Chalco/Chinalco positive investment agreement — contrast: that was a new investor welcomed in; this is a threat to incumbents). If a revocation or binding condition follows, severity = 4 (SMB + CBG together = dominant share of global seaborne bauxite supply). Filed upcoming 2026-06-16.
announced→low likelihood·flagged 112d ago · not yet law·matches Nickel, Copper, Tin, Silver
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Nickel🇨🇳 today 56→62+6
Copper🇨🇳 today 60→64+4
Tin🇨🇳 today 57→61+4
Silver🇲🇽 today 41→50+9
🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining Policy
passed-committee→elevated likelihood·flagged 111d ago · not yet law·matches Aluminium, Lithium
If passed — Cabinet-cleared bill to replace the 2006 Minerals and Mining Act, Act 703: raises mining royalties from current 3–5% range to 9–12% (price-linked sliding scale), introduces a new medium-scale mining licence category bridging artisanal and large-scale operations, mandates district-level community and traditional-authority consultation before applications reach national regulators, scraps unlimited concession renewals (currently indefinitely renewable), and strengthens Ghanaian ownership provisions; National Mining Policy approved by Cabinet simultaneously; affects Newmont (Ahafo/Akyem), AngloGold Ashanti, Kinross (Chirano), Gold Fields (Tarkwa, post-Damang reversion), and Atlantic Lithium (Ewoyaa lithium project); royalty more than doubles at current gold prices — material cost increase for large-scale operators
Caveat — Distinct from all 6 filed GH actions: distinct from 2025-12-19-ghana-minerals-mining-royalty-regulations-2025 (those set sliding royalty under existing Act 703 — this bill replaces Act 703 entirely and raises the ceiling well beyond current regulations); distinct from 2026-03-13-ghana-growth-sustainability-levy-amendment (profit-based tax, not royalty); distinct from 2026-03-19-ghana-atlantic-lithium-ewoyaa-mining-lease and 2026-04-07-ghana-damang-engineers-planners-lease (specific lease grants, not legislation). The Green Minerals Policy (cabinet-approved July 2023, banning raw mineral exports) has not been separately enacted as of June 2026 — if the new Mining Act incorporates its provisions, that becomes the first statutory export restriction for Ghana's lithium and critical minerals. Filed upcoming 2026-06-17.
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Aluminium🇨🇳 today 42→47+5
Lithium🇨🇳 today 62→68+6
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 111d ago · not yet law·matches Lithium, Tin, Silver, Copper
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Lithium🇨🇳 today 62→68+6
Tin🇨🇳 today 57→61+4
Silver🇲🇽 today 41→50+9
Copper🇨🇳 today 60→64+4
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 110d ago · not yet law·matches Lithium, Cobalt, Neodymium, Nickel, Graphite, Copper
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)
Lithium🇨🇳 today 62→68+6
Cobalt🇨🇳 today 64→69+5
Neodymium🇨🇳 today 74→78+4
Nickel🇨🇳 today 56→62+6
Graphite🇨🇳 today 79→84+5
Copper🇨🇳 today 60→64
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 110d ago · not yet law·matches Copper, Nickel, Cobalt
If passed — Full replacement of the Mining Act 1992 with sweeping new statute: state acquires up to 30% equity in any new mining project (Kumul Minerals free-carry); special mining leases (SML) issued for initial 30-month periods with FID requirement to renew; mandatory landowner and community consultation before licence grant; Mining Development Authority (MDA) replaces current Mineral Resources Authority (MRA) as the sector regulator; CGT on extractive asset transfers now in force since the 2025 Income Tax Act (separate filed action); bill as drafted would reshape FDI terms for all existing and future mining permits including Wafi-Golpu (Newmont/Harmony 26 Moz Au, 4. 8 Mt Cu — SML long-delayed), Frieda River copper-gold (PanAust), and Ok Tedi expansion; PNG's 2023 Mining (New Porgera) Amendment Act handled Porgera separately
Caveat — The public-consultation-draft stage is already filed in the register as 2025-02-25-papua-new-guinea-mining-bill-2025 (filed action records the consultation launch). This upcoming entry tracks the NEXT stage: parliamentary enactment. Consultations closed April 4, 2025; minister aimed for September 2025 tabling but no confirmed passage found as of June 2026. Likelihood moderate — bill has broad government backing and a 15-year development history, but PNG legislative timelines are frequently extended; the May 2025 Marape cabinet reshuffle may have shifted ministerial priorities. Distinct from: 2023-10-13-papua-new-guinea-mining-new-porgera-amendment-act (single-mine statute); 2025-03-12-papua-new-guinea-national-petroleum-authority-act (petroleum, not mining); 2025-03-20-papua-new-guinea-income-tax-act-2025 (CGT on extractive transfers — already enacted separately).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 60→64+4
Nickel🇨🇳 today 56→62+6
Cobalt🇨🇳 today 64→69+5
🇹🇼 Taiwan ITA — Dual-Use Export Control List Revision: AI Chips and Advanced Semiconductors Targeting China (June 2026)
in-consultation→moderate likelihood·flagged 108d 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.
🇬🇳 Guinea Ministry of Mines — Bauxite Export Volume Cap (~150 Mt/yr, 2026)
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Aluminium
If passed — ~25% reduction in Guinea's annual bauxite shipments to China (150 Mt target vs. 183 Mt in 2025 and projected ~200 Mt unconstrained); directly re-prices alumina feedstock costs for Chinese refineries (Guinea supplies ~70% of China's imported bauxite); raises spot bauxite prices; affects CBG/Rio Tinto, SMB-Winning Consortium, Emirates Global Aluminium, UC RUSAL affiliates
Caveat — As of June 19, 2026 no formal decree text confirmed; mechanism described as "licence enforcement" (operators aligned to three-year production plans) not new legislation — formal finalisation expected June 2026. Once decree confirmed, migrate to filing. md as new action (action_type=export-control; sub: export-volume-cap / quota-allocation / bauxite; severity=3). Dedup gate: DISTINCT from 2025-07-14-guinea-guitram-bauxite-shipping-mandate (maritime routing mandate, not volume cap); DISTINCT from 2025-05-26-guinea-ministerial-order-129-mining-permits-revoked (permit revocations); DISTINCT from 2026-05-21-guinea-chalco-alumina-refinery-boffa (downstream investment, not export restriction). Filed upcoming 2026-06-19.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Aluminium🇨🇳 today 42→47+5
CEMAC Common Mining Code — 6-member regional harmonisation (April 2026)
draft-published→moderate likelihood·flagged 108d ago · not yet law·matches Cobalt
If passed — If adopted, creates a unified mining regulatory framework across Cameroon, CAR, Congo-Brazzaville, Gabon, Equatorial Guinea, and Chad — harmonising licensing regimes, fiscal terms, transparency obligations (EITI, KP, ICGLR), and environmental standards; would affect Eramet/Comilog manganese operations (Gabon), Sundance Resources iron ore (CAR), Chinese mining JVs (Congo-Brazzaville, CAR), and uranium projects across the region; if enacted, creates a regional investment-guarantee architecture that could facilitate cross-border mining finance and reduce individual-country treaty risk; structural precedent for pooled resource sovereignty in a region where individual states are renegotiating contracts (Gabon post-coup Décret 0276/2024 sovereign-equity mandate, CAR post-KP-readmission, Congo-Brazzaville mining-code review)
Caveat — Consultation meetings held April 2024 (Brazzaville), July 2024 (Riaba/Malabo), February 2025 (regional review workshop), April 2026 (Douala finalization session) — code still in draft form as of April-May 2026; CEMAC has a historically slow ratification track record (Tariff Union took ~15 years to operationalise); likelihood low until formal adoption at heads-of-state summit; DISTINCT from individually filed national mining code reforms: Gabon Décret 0276/2024 (sovereign substances regime), CAR Law 24-008 (new mining code). Filed upcoming 2026-06-20.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Cobalt🇨🇳 today 64→69+5
🇹🇿 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 102d ago · not yet law·matches Graphite, Nickel, Cobalt, Copper, 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)
Graphite🇨🇳 today 79→84+5
Nickel🇨🇳 today 56→62+6
Cobalt🇨🇳 today 64→69+5
Copper🇨🇳 today 60→64+4
Neodymium🇨🇳 today 74→78+4
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 105d ago · not yet law·matches Cobalt, Copper
If passed — All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension; effectively forces equity restructuring across the entire DRC copper-cobalt belt; miners seeking moratorium as of June 18, 2026 — enforcement outcome by August 2026 will set the precedent
Caveat — Ministerial enforcement letter issued January 30, 2026 by Mines Minister Louis Watum Kabamba — activates dormant Art. 71 bis (5% employee equity in mining company capital) and Art. 144 bis (mechanics) of DRC Mining Code (Loi n° 18/001). Filed here (not filing. md) because DRC government websites (mines. gouv. cd, primature. gouv. cd) remain inaccessible per prior wakes — same constraint as the DRC Strategic Mineral Reclassification entry. Action IS already in effect and enforcement is underway (July 31, 2026 deadline); this is NOT speculative. DRC Chamber of Mines convened June 11, 2026 industry response meeting; companies arguing retroactive application is legally contested. Severity 3 expected if enforced. Distinct from: 2018-01-27-drc-mining-code-revision (underlying law), 2026-04-10-drc-strategic-reserve (ARECOMS mechanism), 2026-04-24-drc-tshisekedi-mining-export-revenue-audit.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Cobalt🇨🇳 today 64→69+5
Copper🇨🇳 today 60→64+4
🇬🇭 Ghana Minerals and Mining Act 703 Amendment — Cabinet-Approved Proposal (Royalty 9-12%, Lease Cuts, DA Abolition)
draft-published→moderate likelihood·flagged 105d ago · not yet law·matches Aluminium
If passed — Gold mining royalties rise from 3-5% to 9-12% sliding-scale (price-indexed); mining lease maximum cut 30→15 years with renewals limited to 2×10-year additional terms; Development Agreements and Investment Agreements abolished; stability period capped 30→5 years with labour/environment/H&S issues removed from stability protection scope; affects Newmont (Ahafo/Akyem), Gold Fields (Damang/Tarkwa), AngloGold Ashanti (Obuasi) and all major operators in Ghana's ~120 t/yr gold sector
Caveat — Cabinet approved proposed amendments and targeted parliamentary tabling by March 2026; as of June 2026 still pending Parliament (not yet enacted). The amendment is a primary statute overhaul of the Minerals and Mining Act 2006 (Act 703). DISTINCT from: 2025-12-19-ghana-minerals-mining-royalty-regulations (that LI set royalty rates under existing Act 703 — the amendment SUPERSEDES this LI's royalty structure AND adds structural changes); 2026-03-13-ghana-growth-sustainability-levy-amendment (mining levy reduction, separate statute); 2026-03-19-ghana-parliament-atlantic-lithium (individual mining lease ratification); 2026-04-07-ghana-ministry-lands-damang-mining-lease (lease award). Also distinct from the Minerals Commission localisation enforcement already filed (2026-02-18). Q2 2026 was the target passage window per King & Spalding — the bill may be delayed into H2 2026. Severity 3 expected (structural fiscal change affecting all DM gold producers with Ghana operations).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Aluminium🇨🇳 today 42→47+5
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 105d ago · not yet law·matches Nickel, Cobalt, Copper
If passed — Revises 30 CFR Part 580 to streamline 10 provisions governing prospecting, leasing, and operations for hard minerals (manganese nodules, cobalt-rich crusts, seafloor massive sulfides) on the US Outer Continental Shelf; eliminates environmental notification to adjacent state governors (§580. 31) and BOEM's own environmental review requirement (§580. 29); accelerates OCS hard mineral leasing pipeline in line with EOs 14285 and 14154 ("unleashing" OCS resources); comment period closed April 27, 2026; awaiting final rule
Caveat — First substantive revision of US OCS hard minerals regulatory framework in ~35 years; distinct from all filed US actions (no prior OCS hard minerals action in register). Severity 2: regulatory infrastructure that enables future OCS leasing rather than a direct production/export instrument; secondary-boem: https://www. boem. gov/newsroom/press-releases/boem-proposes-rule-changes-support-critical-mineral-exploration-and
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 ↗
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 ↗
🇬🇳 Guinea Bauxite Exchange (GBX) — Mines Minister Bouna Sylla announced July 2025 national bauxite price index targeting FOB pricing transparency and closing gap between declared export values and market prices; planned launch end-2025; Prospect Intel confirmed Guinea-Conakry launched GBX to reclaim pricing control; no enacted arrêté/décret confirmed in primary gazette sources
announced→low likelihood·flagged 103d ago · not yet law·matches Aluminium
If passed — Supersedes 2022 bauxite reference price arrêté; establishes real-time FOB benchmark for all Guinea bauxite exports (~182 Mt/yr, world's largest supplier); estimated >$1bn/yr additional government revenue if fully enforced; directly constrains Chinese alumina refinery price negotiating leverage (60%+ of Guinea bauxite goes to China)
Caveat — Announcement-only at this stage; no decree number or OJ publication found. The 2022 bauxite reference price arrêté (queued separately in filing. md) is the last enacted instrument; GBX is positioned as its successor and upgrade. Distinct from filed 2025-07-14-guinea-guitram-bauxite-shipping-mandate (freight mandate, separate instrument). Severity 3 expected if enacted: Guinea accounts for ~55% of global bauxite trade; mandatory FOB index would restructure all supply contracts for European and Chinese aluminium producers.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 42→47+5
🇪🇺 STAGE UPDATE — EU CBAM COM(2025)989 Downstream Extension: Council adopts general approach June 12, 2026
passed-committee→elevated likelihood·flagged 102d ago · not yet law·matches Aluminium
If passed — Council's general approach expands the Commission's proposed downstream scope further (more products than Commission proposed); mandates annual Commission review for future scope additions; adds anti-circumvention provisions targeting operators who split shipments or route via third countries; Council position now feeds into EP committee and trilogues; entry into force still targeted at 2028 under the proposal
Caveat — Stage advance from "draft-published" to "passed-committee" for the COM(2025)989 proposal flagged 2026-06-16. Council refined the downstream product list beyond Commission's original proposal. EP lead committee ENVI has yet to report; no trilogue date announced as of June 26, 2026. Likelihood remains elevated: Council political consensus secured June 12 — strongest signal since Commission proposal December 2025. Distinct from filed actions: 2023-05-10-eu-cbam-regulation-2023-956 (base regulation) and 2023-05-10-eu-cbam-definitive-phase-entry-into-force. Secondary: https://www. esgtoday. com/eu-member-states-agree-to-expand-cbam-carbon-import-tax-to-downstream-products/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Aluminium🇨🇳 today 42→47+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 102d ago · not yet law·matches Aluminium, Graphite, Lithium, Copper, Cobalt, Nickel, 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)
Aluminium🇨🇳 today 42→47+5
Graphite🇨🇳 today 79→84+5
Lithium🇨🇳 today 62→68+6
Copper🇨🇳 today 60→64+4
Cobalt🇨🇳 today 64→69+5
Nickel🇨🇳 today 56→62
🇪🇺 EU Permanent-Magnet Scrap & Waste Export Restriction
announced→low likelihood·flagged 101d 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 74→78+4
🇲🇳 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 101d ago · not yet law·matches Copper, Neodymium, Cobalt, Lithium, Graphite, Tungsten, Nickel
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)
Copper🇨🇳 today 60→64+4
Neodymium🇨🇳 today 74→78+4
Cobalt🇨🇳 today 64→69+5
Lithium🇨🇳 today 62→68+6
Graphite🇨🇳 today 79→84+5
Tungsten🇨🇳 today 78→82
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 101d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one of the world's largest undeveloped Cu-Au deposits (phase-1 ~200,000 t/yr copper concentrate + 250,000 oz/yr gold, first production targeted end-2028, ~USD 5. 5bn phase-1 capex). The stake would be purchased from the Pakistani state's half of the project (Pakistan federal SOEs + Balochistan hold 50%; Barrick Gold holds 50% and operates). This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) into a strategic copper chokepoint, paralleling Manara's Vale Base Metals 10% stake and IRH's Mopani (Zambia) acquisition; gives Saudi Arabia an equity claim on a major future non-China copper supply source.
Caveat — As of 2026-06-27 the deal is in negotiation — Pakistan's Petroleum Minister Musadik Malik said publicly he expected a deal "within the next six months," hence announced/upcoming not enacted. Distinct from filed 2025-09-08-pakistan-us-ussm-fwo-critical-minerals-mou (US EXIM/USSM financing angle on Reko Diq), filed 2025-03-14-pakistan-balochistan-mines-and-minerals-act (the provincial mining law), and filed 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake (Manara's Vale Base Metals deal). Severity 2-3 if completed.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 60→64+4
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 100d ago · not yet law·matches Copper
If passed — Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring the interest from the Government of Pakistan (Pakistan + Balochistan together own 50%; Barrick Gold holds the other 50% as operator). Reko Diq is one of the world's largest undeveloped copper-gold deposits (~$74bn projected free cash flow over a ~37-yr life). IPTM relevance: a GCC sovereign-capital upstream-mining-FDI entry (theme gcc-mining-upstream-fdi) into COPPER — a binding chokepoint material — extending the Saudi diversification-of-supply strategy beyond the filed 2024-03-01 Manara→Vale Base Metals 10% stake; would also be a Pakistan host-state instrument (federal divestment of part of its Reko Diq equity to a Gulf SWF, complementing the 2025-09-08 Pakistan–US USSM critical-minerals MoU already filed). Distinct GCC third-party capital base separate from Chinese-SOE capture and Western MSP/CRMA-aligned investment.
Caveat — As of mid-2025 the deal was reported by Pakistan's Petroleum Minister as expected "within six months" but NO binding SPA or primary gov instrument has surfaced as of 2026-06-28 — hence announced/moderate, not enacted. Dedup: only the 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake Manara action is filed; no Reko Diq/Manara slug in action-index; the filed Reko Diq item (2025-09-08 Pakistan–US USSM–FWO MoU) is a DIFFERENT instrument (US bilateral MoU, not a Saudi equity purchase). Severity 2-3.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 60→64+4
🇨🇳 Zhejiang Huayou Cobalt — US$210M acquisition of Atlantic Lithium (control of the Ewoyaa lithium project, Ghana) via Australian scheme of arrangement
awaiting-signature→high likelihood·flagged 100d ago · not yet law·matches Lithium
If passed — Chinese battery-materials major Zhejiang Huayou Cobalt (603799. SH) signed a BINDING Scheme Implementation Deed (7 May 2026) to acquire 100% of Atlantic Lithium Ltd (AIM/ASX: ALL) for ~US$210M all-cash (US$0. 25486/share; 26. 6% premium), gaining control of the Ewoyaa lithium project — Ghana's first parliament-ratified lithium mine (Central Region, 15-yr lease ratified Mar 2026). The Atlantic Lithium board unanimously recommends; largest holder Assore (~26. 4%) supports; deed has no financing/DD conditions. This is a Chinese-SOE-adjacent capture of a West-African hard-rock lithium chokepoint that had been positioned as a NON-China / Western-aligned supply source (Atlantic Lithium previously had US DFC / Piedmont offtake-JV ties), so the transaction re-prices Ewoyaa from a diversification asset into Chinese-controlled lithium supply — directly relevant to the cn-outbound-mining-fdi exposure series and to Ghana's local-ownership/beneficiation policy.
Caveat — As of 2026-06-28 the binding deed is signed but the deal is NOT consummated (shareholder vote Nov 2026, completion targeted Dec 2026, multiple regulatory approvals + Australian court order outstanding), hence awaiting-signature/upcoming not enacted. Likelihood ELEVATED: binding deed, unanimous board + 26. 4%-holder support, no financing/DD conditions — but Chinese-acquirer FIRB risk, MOFCOM outbound approval, and Ghanaian political resistance to foreign control of Ewoyaa's local-ownership model are real gates. Huayou has 0 records in the register. Severity 3 if completed.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Lithium🇨🇳 today 62→68+6
🇯🇵 Japan METI/MOF Anti-Dumping Duty on Nickel-Added Cold-Rolled Stainless Steel Coil/Sheet/Strip from China and Taiwan
awaiting-signature→high likelihood·flagged 99d ago · not yet law·matches Nickel, Chromium
If passed — Japan's METI + MOF made an affirmative PRELIMINARY determination in an anti-dumping investigation (initiated 22 Jul 2025 on an application from Nippon Steel, Nippon Yakin Kogyo, NAS Stainless Steel Strip and Nippon Kinzoku) into nickel-added cold-rolled stainless steel coil, sheet and strip originating in the People's Republic of China and the separate customs territory of Taiwan (Penghu, Kinmen, Matsu); Trade Minister Ryosei Akazawa indicated provisional duties of ~45% on Chinese product and ~21% on Taiwanese product, expected to take effect as soon as July 2026. On 19 Jun 2026 METI/MOF EXTENDED the investigation period by four months to 21 Nov 2026 (final determination pending). IPTM relevance: (1) a RARE Japan-issuer trade remedy — JP has ZERO trade-remedy actions on the register and seldom uses AD, so a Japanese AD wall is a notable issuer + instrument-bloc gap; (2) China/Taiwan-target on nickel-added stainless steel, a nickel+chromium chokepoint-adjacent material; re-prices a China/TW->Japan stainless flow into a major downstream manufacturing base; (3) parallels the active 2025-26 Asian steel-AD wave the register is now capturing (Thailand DFT aluminium-extrusions, Indonesia KADI HRC, Malaysia MITI galvanised steel).
Caveat — As of 2026-06-29 only an affirmative PRELIMINARY determination exists; the provisional-duty cabinet order is not yet promulgated and the final determination is deferred to 21 Nov 2026 (investigation extended 19 Jun 2026) — hence awaiting-signature/upcoming, not enacted. Likelihood HIGH: preliminary affirmative + minister-stated rates + provisional duties imminent; the open question is final rate/scope, not whether duties happen. COMPANION lead for a future wake: METI/MOF separately INITIATED (1 Jun 2026) an AD investigation into cold-rolled steel coil/sheet/strip (carbon) from Korea, China and Taiwan (https://www. meti. go. jp/english/press/2026/0601_002. html) — earlier stage (initiation only), track separately. action_type=trade-remedy (sub: anti-dumping / preliminary-determination / stainless-steel / China / Taiwan); target_countries=[CN, TW]; sectors=[steel, trade-remedies, manufacturing]; materials=[stainless-steel, nickel, chromium]. Severity 2 expected.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Nickel🇨🇳 today 56→62+6
Chromium🇨🇳 today 43→49+6
🇨🇳 China unpublished 50% domestic-equipment local-content mandate for new/expanded semiconductor fabs
announced→low likelihood·flagged 94d 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).
🇧🇷 Brazil BNDES "Mais Inovação" loan to Wave Aluminium Brasil SA (New Wave) — BRL 221m demonstration plant financing for bauxite-residue processing (Barcarena, Pará)
announced→low likelihood·flagged 88d ago · not yet law·matches Aluminium
If passed — On 16 November 2025 Brazil's national development bank BNDES signed a BRL 221 million (~USD 41. 4m) loan under its "Mais Inovação" program with Wave Aluminium Brasil SA (trading arm of New Wave, founded 2019 by Gustavo Emina) to help finance a semi-industrial demonstration plant that recovers metallic "green iron" from bauxite residue (red mud) using a proprietary microwave-based extraction process. The plant is being built on land inside Hydro Alunorte's Barcarena (Pará) alumina refinery site — which itself generates ~5m tonnes/year of bauxite residue — with total project cost ~BRL 250m and >70% physical progress as of the announcement; commissioning targeted H2 2026. GTA logged this as two linked interventions (a state loan + a local-content incentive) off the same state-act. Relevant to bauxite/alumina residue-valorisation industrial policy — an emerging sub-theme distinct from primary bauxite mining/export actions already in the register (Guinea, Indonesia).
Caveat — Charter §6 verify-or-don't-file: exhausted GTA state-act/intervention pages (sign-in-gated, no primary link exposed even via fetch), searched agenciadenoticias. bndes. gov. br directly (no matching press release — BNDES appears not to have issued a news release for this smaller/startup-scale operation, unlike its R$700m+-class loans which do get releases, e. g. the filed CBA/Eldorado/Suzano BNDES actions), and could not construct a direct link into BNDES's JS-rendered "Consulta a operações" transparency panel. This is NOT speculative: BRL amount, program name pattern (Mais Inovação — confirmed as a real BNDES product at bndes. gov. br/wps/portal/site/home/financiamento/produto/programa-bndes-mais-inovacao), signing date, beneficiary, plant location and physical-progress detail are corroborated by two independent Pará/mining trade outlets and match GTA's independently-logged state-act — so it does not fit the "reject, not credible" bucket. Parked here per the same precedent as the Sudan PM-directive / Egypt 548/2025 / Morocco lines above (real, already-implemented action; primary gov URL not independently locatable this wake). If a working primary URL is found, promote directly to filing. md — likely as TWO linked actions (state loan + local-content incentive) mirroring the two GTA intervention IDs, or one action with both instruments described if a single BNDES source covers both; action_type subsidy; issuer_agency BNDES; severity 1-2 (single mid-size demonstration-plant loan), severity_basis quant off the BRL 221m figure. The second filing. md queue item (local content incentive, intervention 150840) covers the same underlying signing — when promoting/rejecting, resolve both filing. md lines together rather than re-researching from scratch.
announced→low likelihood·flagged 84d ago · not yet law·matches Aluminium
If passed — Guinea — the world's largest bauxite exporter (~single-largest feed to China's alumina/aluminium chain) — is preparing a sector-wide measure to CAP/reduce bauxite exports to stabilise falling prices (benchmark cargoes down 20-35% from 2025 highs, ~$60-70/t). Mines & Geology Minister Bouna Sylla publicly stated (March 2026, reiterated May-June 2026 to Bloomberg) that the government would align each company's 2026 production/export volumes with the levels committed in their feasibility-study reports / mining conventions, using a compliance-based enforcement mechanism (rewarding operators who honoured downstream railway/port/refinery investment pledges, penalising pure-volume extractors) rather than a uniform hard quota. All producers were ordered to submit three-year production plans now under government review; the top-two producers SMB (Société Minière de Boké) and CBG (Compagnie des Bauxites de Guinée) face a parallel refinery ultimatum (government wants 5 new alumina refineries, ~7. 2 Mt/yr combined capacity). If enacted this re-prices a binding aluminium-supply-chain chokepoint and would join the register's existing GN bauxite actions as a NEW export-control instrument.
Caveat — As of end-June 2026 NO formal decree has been issued — total quota, per-company allocations and any retroactive clauses remain pending official confirmation, so this is announced/early-warning, NOT enacted (hence upcoming. md, not filing. md). Distinct from filed GN actions: 2022-09-01 bauxite reference-price arrêté (price mechanism, not volume cap), 2025-07-14 GUITRAM 50% freight mandate (shipping, not export volume), 2025-05-26 Order revoking 129 expired permits, 2026-06-19 raw-gold export ban (different material). The refinery-ultimatum strand overlaps the register's alumina-refinery actions (2025-03-26 SPIC Boffa, 2026-05-21 Chalco Boffa) but the export-cap instrument itself is new.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 42→47+5
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 68d ago · not yet law·matches Lithium, Cobalt, Nickel, Neodymium, Graphite, Gallium, Tungsten, Copper
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)
Lithium🇨🇳 today 62→68+6
Cobalt🇨🇳 today 64→69+5
Nickel🇨🇳 today 56→62+6
Neodymium🇨🇳 today 74→78+4
Graphite🇨🇳 today 79→84+5
Gallium🇨🇳 today 76→80
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 54d ago · not yet law·matches Neodymium, Graphite, Tantalum, Aluminium, Copper
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 74→78+4
Graphite🇨🇳 today 79→84+5
Tantalum🇨🇳 today 45→51+6
Aluminium🇨🇳 today 42→47+5
Copper🇨🇳 today 60→64+4
🇲🇬 Madagascar — Council of Ministers lifts 16-year moratorium on new mining-permit issuance (except gold), effective ~29 Jan 2026
passed-vote→high likelihood·flagged 54d ago · not yet law·matches Nickel, Cobalt, Graphite, Neodymium, Aluminium
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)
Nickel🇨🇳 today 56→62+6
Cobalt🇨🇳 today 64→69+5
Graphite🇨🇳 today 79→84+5
Neodymium🇨🇳 today 74→78+4
Aluminium🇨🇳 today 42→47+5
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 32d ago · not yet law·matches Lithium, 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)
Lithium🇨🇳 today 62→68+6
Neodymium🇨🇳 today 74→78+4
🇨🇦 Canada — Attorney General Federal Court enforcement application vs. Gator Capital Ltd re: Investment Canada Act s.40 (first-ever ICA divestiture enforcement litigation)
announced→low likelihood·flagged 30d ago · not yet law·matches Lithium
If passed — On 11 Feb 2025 the Attorney General of Canada filed a Notice of Application (Federal Court file T-472-25) seeking a court order under ICA s. 40 directing Gator Capital Ltd to divest its ~20% stake in Lithium Chile Inc within 30 days to a trustee (subject to Minister approval of purchaser/terms), or alternatively to compel Gator to respond to outstanding information demands within 30 days; also seeks an injunction against Gator disposing of its shares and monetary penalties (up to C$10,000/day, potentially rising to C$50,000/day). This is the first time the Government of Canada has gone to court to enforce the ICA's national-security-review regime. Background: Chengze Lithium International Limited was ordered in Nov 2022 to divest its Lithium Chile stake (already in the register's ISED national-security-decisions record); Chengze sold to Gator in Feb 2023; the government's Notice of Application alleges it never confirmed Gator met the qualifications required of a divestiture buyer and that Gator (led by Wing Hong Chan, reportedly paid ~USD 34m for the 20% stake) has not complied with subsequent information demands (a "Third Demand" under a Sept 2024 FIRES administrative note). FDI-screening vs. Chinese-linked lithium/critical-minerals investment (thin action_type: investment-screening, ~71 filed). Severity 3-4 expected (first-ever court enforcement, direct critical-minerals/lithium chokepoint, but the underlying stake is a single ~20% minority position in one junior miner).
Caveat — Charter §6 verify-or-don't-file: ran 2 searches + fetched the ISED national-security-decisions page (only lists the Nov-2022 Chengze order, not this Feb-2025 enforcement application) + the ISED ICA Annual Report 2024-2025 (no mention) + probed the Federal Court's own file-search page (fct-cf. ca — no stable per-file docket URL exists; file search is a form/query tool, not a linkable record). Dedup: no existing CA action in filing. md/upcoming. md covers Gator Capital or this enforcement filing; the 2022 Chengze divestiture order itself does not appear to be in the register either (checked docs/iptm/actions/ for "gator"/"lithium chile"/"chengze" — no match), so a filer who later locates its primary source should consider filing that antecedent action too.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Lithium🇨🇳 today 62→68+6
🇮🇳 India–Myanmar rare-earths cooperation — elevated to formal bilateral agenda at Modi–Min Aung Hlaing summit
announced→low likelihood·flagged 30d 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 74→78+4
🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)
in-consultation→moderate likelihood·flagged 27d ago · not yet law·matches Lithium, Nickel, Aluminium
If passed — Minister of Mines, Petroleum and Energy Mamadou Sangafowa-Coulibaly formally launched the revision of Côte d'Ivoire's 2014 Mining Code on 13 June 2026, standing up an expert team drawn from his ministry, other state institutions and international bodies to rewrite Loi n° 2014-138 du 24 mars 2014. Stated goals: raise state revenue share, fix "disparate and sometimes poorly negotiated" mining conventions, and modernise the mining cadastre. No draft bill text published yet — this is a mandate/committee-formation stage, distinct from and earlier than the already-filed 2026-02-04 Assafou/Doropo gold-permit decrees and the 2025-12-03 PIRME minerals-energy policy (2025-2040), both of which operate under the CURRENT 2014 code rather than proposing to replace it. Chokepoint-relevant: register's only prior CI code-minier-lineage entries are the 2014 code itself and a 2022 local-content oil/gas law — no entry tracks this active rewrite.
Caveat — Dedup: checked action-index and both queues for "code minier"/"mining code" + CI — only hits are the already-filed 2014 code, the 2022 local-content petroleum law, and the 2024-12 gold-royalty finance law, none of which is this revision effort. Distinct from Senegal's and Morocco's already-queued mining-code amendments (different issuer/instrument).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Lithium🇨🇳 today 62→68+6
Nickel🇨🇳 today 56→62+6
Aluminium🇨🇳 today 42→47+5
🇬🇳 Guinea — Nimba Mining Company (NMC SA) Signs First Base Mining Convention (Tinguilinta Bauxite Concession, Boké)
passed-vote→high likelihood·flagged 26d ago · not yet law·matches Aluminium
If passed — On 6 August 2026, at a ceremony at the Petit Palais of the Presidency chaired by Djiba Diakité (Minister Chief of Staff, chair of the Simandou 2040 Strategic Committee), Guinea's wholly state-owned Nimba Mining Company (NMC SA) signed its first mining convention, covering bauxite extraction at Tinguilinta and export via the Port of Kamsar — a 690. 20 km² concession in Boké Prefecture, 25-year term, refinery requirement, no tax exemptions. This operationalises NMC, which was created by the 5 August 2025 presidential decree revoking GAC/EGA's bauxite concession (already filed: 2025-08-05-guinea-presidential-decree-gac-nimba-mining-sa) — since start-up NMC has extracted ~5 Mt bauxite, exported ~4 Mt in 2026, and the Mines Ministry projects 8-10 Mt for 2026, 12 Mt 2027, 14 Mt 2028. Executive-signed and in force operationally, but multiple outlets state the convention text still requires National Transition Council ratification before Journal Officiel publication — parked on axis 2 rather than filed as enacted pending that primary text. Guinea = priority-tier chokepoint (bauxite, ~world's top exporter).
Caveat — Dedup: checked action-index and both queues for "Nimba"/"NMC"/"Tinguilinta" — the only existing GN hits are the Aug-2025 NMC-creation decree and the May-2026 GAC/EGA settlement, neither of which covers this specific convention signing. No primary Guinean government URL (mines. gov.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Aluminium🇨🇳 today 42→47+5
🇨🇿 Czech Republic — €360M Government Grant for Cinovec Lithium Project (European Metals Holdings / CEZ JV)
awaiting-signature→high likelihood·flagged 17d ago · not yet law·matches Lithium
If passed — On 28-Nov-2025 European Metals Holdings announced the Czech government approved a grant of up to EUR 360M under the Ministry of Industry and Trade's "Strategic Investments for a Climate-Neutral Economy" programme for the Cinovec lithium/tin project (EU Critical Raw Materials Act strategic project, Czech-designated strategic deposit) — one of the largest single-project CRM grants in the EU. Award is government-approved in principle but "subject to completion of administrative processes, after which a formal grant decision would be issued" (final amount could be lower). Liberalising/supply-relief polarity: EU-domestic lithium capacity build, not a restriction. Genuine gap: CZ carries only 4 actions in the register, none touching lithium/CRMA-strategic-project funding — thin Central European coverage flagged in Step 0. 5. action_type: subsidy; yet assigned (CRMA-strategic-project funding). Primary-ish source: company RNS/ASX announcement — https://www. miningweekly. com/article/360m-grant-for-cinovec-lithium-project-2025-11-28; https://www. miragenews. gov. cz (Ministry of Industry and Trade) before filing — no MPO. gov.
Caveat — Dedup: checked "cinovec" and "czech. *lithium" across filing. md, upcoming. md, and action-index — zero hits, not previously queued.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Lithium🇨🇳 today 62→68+6
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 2d ago · not yet law·matches Copper
If passed — State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar's ambassador that it will resume the Jebel Ohier copper-gold project (Red Sea State) with an $800M commitment. Third GCC sovereign upstream-mining entry after Manara Minerals/Vale Base Metals 10% stake (2024-03-01, filed) and QIA/Ivanhoe Mines strategic placement (2025-09-17, filed) — extends the GCC-as-third-capital-base pattern (theme gcc-mining-upstream-fdi) to African copper, not just battery metals.
Caveat — gov. sd not independently reachable; QMSD's own project page does not yet mention the resumption) — parked here per the same convention used for the Malawi executive-order entry above (real/firm commitment, primary URL not yet locatable). Dedup: checked "qatar mining", "jebel ohier", "qmsd" across filing. md, upcoming. md, and action-index — zero hits. Likelihood=high reflects a confirmed government-to-government commitment, not a prediction of eventual gazettal.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 60→64+4
🇿🇼 Zimbabwe — ban on new mining licences for single-mineral ("isolated") operations; VP Chiwenga, Zimbabwe-China Business Forum
announced→low likelihood·flagged 2d ago · not yet law·matches Chromium
If passed — VP Constantino Chiwenga announced at the Zimbabwe-China Business Forum (Hangzhou) that Zimbabwe will no longer issue new mining licences for operations that extract only one mineral from a deposit — future licensees must demonstrate capacity to identify, separate and process the full mineral suite present, or be barred from operating. Framed as beneficiation policy, layered on Zimbabwe's Feb-2026 raw-mineral/lithium-concentrate export ban (filed). Raises the entry bar specifically for Great Dyke chrome/PGM claims, which are frequently single-mineral operations — a licensing-stage chokepoint action, distinct instrument type from the export-ban actions already in the register.
Caveat — Likelihood kept LOW per the discovery brief's calibration caution (a forum announcement with no SI number is exactly the channel that has previously stalled — e. g. the chrome-concentrate extension signalled since Feb-2026, entry below, remains unenacted 8 months on). Dedup: checked "chiwenga", "single mineral", "single-mineral", "zimbabwe chrome licence" across filing. md, upcoming. md, and action-index — zero hits; distinct from filed Zimbabwe lithium/chrome export-ban actions (different instrument: licensing bar on NEW operations, not export control on existing ones).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Chromium🇨🇳 today 43→49+6
🇿🇼 Zimbabwe — signalled extension of the raw-mineral export ban to chrome CONCENTRATE (currently exempt)
announced→low likelihood·flagged 2d ago · not yet law·matches Chromium
If passed — Zimbabwean officials have signalled intent ("raw chrome exports obsolete") to expand the 25-Feb-2026 raw-mineral/lithium-concentrate export ban (filed) to cover chrome CONCENTRATE specifically — concentrate was exempt under the original order, which targeted raw ore only. This is the same ore/concentrate carve-out pattern that made Zimbabwe's 2022 SI 213 lithium ban a non-event (everyone exported the exempt concentrate instead). If the concentrate carve-out is closed, it would hit Zimbabwe's ~$1. 5-2bn/yr chrome sector feeding South African and Chinese ferrochrome smelters. No SI number, no date, no gazette found.
Caveat — Calibration caution per the discovery brief's instrument-vs-flow-fit lesson (this is Zimbabwe's own prior lithium-ban non-event, recurring): an ore ban that exempts concentrate is not a magnitude claim until the concentrate carve-out itself closes — kept likelihood LOW, not moderate. Dedup: checked "chrome concentrate", "zimbabwe concentrate" across filing. md, upcoming. md, and action-index — zero hits. Distinct from the licensing-ban entry above (new-operation licensing bar vs. scope-extension of an existing export ban) and from the filed Feb-2026 export ban itself (this flags a scope-extension TO that ban, not a restatement of it).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Chromium🇨🇳 today 43→49+6
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.
Metals industry broadly supportive (asks for more)
(weak)
EU metals producers publicly called for the downstream scope to go even further — the affected domestic industry is not the opposition here, reducing blocking risk.
▼Large new compliance burden (~7,500 importers) (weak) — Extending to ~180 downstream codes pulls in ~7,500 new importers; downstream-importer pushback could slow (not block) the file in trilogue.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 %).
+4
Cleared House Foreign Affairs Committee
(moderate)
HFAC passed the House companion Apr 22, 2026 in a large export-control markup — the first committee gate is behind it on the House side.
▲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 %).