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1 critical material scored · binding chokepoint: Lithium (🇨🇳 CN 65% of refining) · 40 restrictive government measures on record
The binding exposure is Lithium — 🇨🇳 CN controls 65% of global refining. On this company's production footprint that scores 32/100 (inside the chokepoint; global 61). The register holds 40 restrictive government measures touching this company's materials — each traced to its primary source below.
Where the 166 verified automotive companies we track sit.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 68 further automotive companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 32/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 1 scored material. Buyer-relative (first-order): weighted by where the company produces (CN 100%, 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.
Beiqi Foton Motor Co., Ltd. (SSE: 600166) is a Chinese commercial-vehicle manufacturer — medium/heavy trucks (Auman), light/mini trucks, vans, pickups (Tunland), buses, and construction-vehicle chassis — and a subsidiary of the state-owned BAIC Group (BAIC is Foton's controlling/largest shareholder). Foton sold over 650,000 vehicles in 2025, the large majority still diesel-powered, alongside a fast-growing new-energy (electric/hybrid/hydrogen) line that reached 101,000 units in full-year 2025 (~15% of volume, up 87.2% y/y) toward a stated goal of 50% NEV mix by 2030. Foton
<!-- corrected 2026-08-17 (overnight audit topic 01, F2): this clause read "roughly 82,000 units in the first ten months of 2025 (~13% of volume, up ~99% y/y)" — volume, period and growth rate all wrong. The cited chinatrucks.org report says "Foton sold more than 650,000 vehicles in 2025, ranking first in the industry. New energy vehicle sales reached 101,000 units, up 87.2% year on year." The share is recomputed from those two figures (101,000 / >650,000 ≈ 15%); the source does not state a share itself. -->
builds its own battery, motor, and electronic-control systems in-house per its own disclosures, and signed a ten-year strategic partnership with CATL (signed 8 Feb) covering battery supply, leasing, and aftermarket services for its electrified trucks and buses.
volume).** Foton's ten-year strategic partnership with CATL covers commercial-vehicle electrification and power-battery supply/aftermarket. The source does not state cell chemistry.
Re-check 2026-10-05: rare-earth (Nd/Pr/Dy/Tb), graphite, copper, aluminium, silicon, tin and chromium/niobium/vanadium rows were removed — their only sources were generic industry pages showing the materials are concentrated, not that Foton uses them, and no Foton datasheet, filing or product page was found for Foton's motor magnets or steel grades.
Source: 北汽福田汽车股份有限公司 (Beiqi Foton Motor Co., Ltd.) 2025 annual report, filed with the Shanghai Stock Exchange via cninfo 2026-04-25 — dataclouds.cninfo.com.cn/shgonggao/hsomarket/2026/20260424/22237e3bd17f48d7b434dade7bd3cf96.PDF (MD&A §7④ "主要销售客户及主要供应商情况", p.19; related-party note 十四.3 "关联方交易情况" purchase/sales tables, pp.227-233), cross-checked against the 2024 annual report — static.cninfo.com.cn/finalpage/2025-04-26/1223327299.PDF — for the FY2024 comparative vintage. Confidence: primary-source (audited annual reports).
The MD&A top-5 table itself is aggregate-only (no individual names): FY2025 top-5 customer sales were 25.75% of revenue (22.21 points of that related-party), and top-5 supplier purchases were 30.47% of procurement (21.8 points related-party) — both up from FY2024's 21.69%/14.83% and 30.77%/23.85% respectively on the customer and supplier side. Individual names come instead from the separate related-party-transaction note, which lists every joint venture and associate by name with a per-entity RMB figure. Two of those dwarf the rest and, given how much of the aggregate related-party share they alone represent, plainly sit inside the top-5 sets the MD&A table declines to name:
— Foton's largest single customer. A heavy-truck joint venture with Daimler Truck AG (Germany) building the Auman brand, carried in the filing's own related-party register as a 合营企业 (joint venture). FY2025 sales of RMB 10.67bn = 17.42% of consolidated revenue (RMB 61.247bn total), up from FY2024's 13.28% (RMB 6.34bn of RMB 47.70bn) — +4.14 points.
— Foton's largest single supplier. An engine joint venture with Cummins Inc. (US), also carried as a 合营企业. FY2025 purchases of RMB 7.33bn ≈ 13.29% of total procurement (a figure this dossier derives — see the share_of note on the frontmatter row — since the company discloses the top-5-supplier aggregate PERCENTAGE but not the total procurement RMB figure itself), up slightly from FY2024's derived 12.93% — +0.36 points.
Both relationships are structural rather than a raw-material supply chain: Daimler Truck buys assembled/co-developed trucks and components from the JV, and Cummins supplies engines into Foton's diesel and CNG lines. They are recorded here under this wake's clarified role: supplier/customer scope (component/equipment/JV relationships, not raw-material flows only) because they are Foton's two largest disclosed counterparties by a wide margin and tie to this dossier's own chromium/niobium/vanadium HSLA-steel engine-and-chassis exposure narrative above. No named gas/mineral/battery supplier (e.g. for the CATL partnership, which the filing does not mention by name at all — consistent with Foton's own statement that it builds battery/motor/ECU systems in-house) was found in either filing.
1. Foton Motor — "Who We Are" (official corporate site, NEV technology and product lineup): https://www.fotonmotor.com/aboutUs-2.html 2. CATL–Foton ten-year strategic partnership announcement (Gasgoo, 2026): https://www.technologykhabar.com/2025/05/29/202826/ 3. Foton Motor 2025 sales/NEV volume reporting (chinatrucks.org): https://m.chinatrucks.org/news/11367.html 4. Beiqi Foton Motor 2025 annual report (SSE filing via cninfo, 2026-04-25): http://dataclouds.cninfo.com.cn/shgonggao/hsomarket/2026/20260424/22237e3bd17f48d7b434dade7bd3cf96.PDF 5. Beiqi Foton Motor 2024 annual report (SSE filing via cninfo, 2025-04-26): http://static.cninfo.com.cn/finalpage/2025-04-26/1223327299.PDF
From the company’s own mandatory filings — the CSRC top-5 customer/supplier concentration disclosure and the related-party tables. This is a disclosure, not a netting: a named supplier concentration is shown beside the exposure score and never adjusts it. Figures are the fiscal years labelled, not a current snapshot.
Read the arm's-length column, not the headline. Enough of the disclosed top-5 is intra-group that the company's genuine third-party customer concentration is 3.54%, not the 25.75% the filing reports. The arm's-length figure is arithmetic on the two disclosed numbers — derived, not reported.
FY2024 comparative (2024 annual report, http://static.cninfo.com.cn/finalpage/2025-04-26/1223327299.PDF): customers_top5_pct 21.69, customers_related_party_pct 14.83, suppliers_top5_pct 30.77, suppliers_related_party_pct 23.85. No individual customer/supplier names or per-entity percentages are given in this MD&A table (standard aggregate-only disclosure) — the named rows below come from the separate related-party-transactions note (十四、关联方及关联交易), whose entries are individually smaller than the top-5 threshold in dollar terms but, for the two largest, plainly fall inside the top-5 set given how much of the related-party aggregate they alone account for.
FY2024 · FY2024 comparative, same derivation method from the 2024 annual report: purchases RMB 5,388,585,800 (538,858.58万元) against a derived FY2024 total procurement of RMB 41.672bn (RMB 12,821,030,000 top-5-supplier aggregate ÷ 30.77%). +0.36 pts FY2024->FY2025.source ↗
FY2025 · Foton's single largest supplier — an engine JV with Cummins Inc. (US); listed as a 合营企业 (joint venture) related party in note 十四.3. Purchases RMB 7,328,107,900 (732,810.79万元). Total FY2025 procurement is not itself a disclosed line item; derived as RMB 55.143bn from the filing's own statement that the top-5-supplier aggregate of RMB 16,803,026,100 (1,680,302.61万元) equals 30.47% of the year's total procurement — a two-step derivation, not a company-stated figure, flagged for transparency.source ↗
FY2024 · FY2024 comparative, from the 2024 annual report's own related-party transaction table: sales RMB 6,335,704,500 (633,570.45万元) against FY2024 total revenue RMB 47.703bn (derived from the same report's stated top-5-customer aggregate: RMB 10,346,660,000 = 21.69% of the year's total sales). +4.14 pts FY2024->FY2025.source ↗
FY2025 · Foton's single largest customer — a heavy-truck JV with Daimler Truck AG (Germany, spun off from Daimler AG in 2021) producing the Auman brand; listed as a 合营企业 (joint venture) related party in note 十四.3. Sales RMB 10,666,742,800 (1,066,674.28万元) against FY2025 total revenue RMB 61.247bn (612.47亿元, stated directly in the filing's financial-highlights section).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: A-share issuers anonymise counterparties they are not required to name. · section source filing ↗
Ranked by buyer-relative risk, highest first.
0 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Lithium | 🇨🇳 CN 65% refining | 32 | 61 | Low | within 65% | Med | some | 40 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Lithium | 4 | 3 | 5 | 3 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
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.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 25 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Counterfactual: Indonesia extends the hilirisasi ore-ban template (2020 nickel → 2023 bauxite) to the next rung of battery-mineral exports — tightening upstream supply for cobalt intermediates, lithium feedstock and graphite alongside the existing nickel + aluminium regime. Direct-hit lines are basket issuers whose binding material is a battery-cell input (nickel, cobalt, lithium, graphite) — irrespective of controller, since the template-export is global supply-chain pressure not bilateral targeting.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 32 → 34 (+2) — a relative official policy-pressure magnitude, not a price drawdown.
🇨🇳 CN has issued 6 restrictive actions on Lithium since 2021 — cadence accelerating (mean gap 339d → 306d), severity flat (3.3 → 2.7).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 1 of these 13 materials (Lithium) — your binding Lithium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 20.8 months apart across 4 distinct restriction dates since 2021 (n=3 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime | 32 | 34 | +2 |
| Concentration | Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly) | 32 | 39 | +7 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the materials this company buys. The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
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 ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Lithium).
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | Yes — 1 scored SRM on the input side (binding: Lithium) |
| Manufactures a listed strategic technology | automotive (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-08-06; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-07
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.