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5 critical materials scored · binding chokepoint: Dysprosium (🇨🇳 CN 99% of refining) · 61 restrictive government measures on record
A verification pass re-checked this dossier's ownership/corporate-structure fields against their cited sources. It did not re-read the material_exposures claim the score, band and stress figures below are built on — treat those as not yet independently re-checked.
Shenghe Resources Holding Co., Ltd. produces 5 of the 5 scored materials above (Dysprosium, Terbium, Neodymium, Praseodymium, Titanium). For those, a supply restriction by the controlling country is a tailwind, not a headwind — the exposure is to disruption of a market this company supplies, not to a chokepoint it depends on. Every scored material here sits on its output side, so the Moderate · 44/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-07) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Dysprosium — 🇨🇳 CN controls 99% of global refining. On this company's production footprint that scores 48/100 (inside the chokepoint; global 88). The register holds 61 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Dysprosium Shenghe Resources Holding Co., Ltd. is the 248th-most-exposed of the 262 named companies we track on 🇨🇳 CN's Dysprosium chokepoint; the most-exposed is TdVib (95/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Shenghe Resources Holding Co., Ltd. ranks 385th of 459 verified mining metals companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 132 further mining metals 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 44/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 5 scored materials. 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.
Disclosed production sites
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.
> The exposure report this dossier powers is at > /intelligence/dossiers/600392-ss/report.
Shenghe Resources Holding Co., Ltd. (SSE: 600392) is a partly state-owned Chinese rare-earth mining and processing group, founded in 1998 and listed in Shanghai. Its own corporate site organises the business into four groups: Sichuan (Leshan Shenghe Rare Earths — light rare-earth separation and metals), Jiangxi (Ganzhou Chenguang — "medium & heavy rare earths", separation, metals and recycling), Mineral Sands (beneficiation of "zirconium, titanium, monazite and heavy mineral concentrates"), and Overseas ("rare earths trading, recycling, and metals"). It sits in the midstream of the rare-earth chain — it buys concentrate, separates it into oxides and salts, and reduces those to metals and alloys for downstream magnet and alloy makers.
Its distinguishing feature is reach outside China. Shenghe is a minority shareholder in MP Materials and has been the purchaser of the rare-earth concentrate from MP's Mountain Pass mine in California; it holds a stake in Peak Rare Earths (Ngualla, Tanzania), took 9.9% of Vital Metals in 2023, and holds a stake in Energy Transition Minerals (Kvanefjeld, Greenland). Its largest shareholder (14.06% as of the 2026-06-30 filing) is the Institute of Comprehensive Utilization of Mineral Resources, Chinese Academy of Geological Sciences — a Ministry of Natural Resources-affiliated public research institute, which is what secondary sources shorthand as "Ministry of Natural Resources" ownership. Aluminum Corporation of China holds a board seat and participates in strategic decision-making but does not appear in the top-10 shareholder list — influence short of control, so no parent_slug is set (chinalco.md exists in this corpus, but a board seat is not a parent-subsidiary relationship). GLEIF returns no LEI record for the company, so no lei: is recorded.
Shenghe is an upstream/midstream producer of these materials rather than a consumer of them, so the exposure runs the other way from a manufacturer's: its revenue and its policy risk are both concentrated in the materials below, and it sits inside the jurisdiction that controls them.
group's Leshan operation is a light-rare-earth separation and metal plant, and Nd/Pr are the commercially dominant light-RE outputs of that route (the feed is bastnaesite, which the company describes as "fluorocarbon cerium" ore). These are the magnet-grade elements, and Chinese export licensing on rare-earth separation technology and products makes Shenghe's position a policy exposure in both directions — as a beneficiary of concentration and as a company whose overseas sales are licensable.
group (Ganzhou Chenguang), which the company describes explicitly as "medium & heavy rare earths" separation, metals and recycling. Ganzhou is the centre of China's ion-adsorption heavy-RE processing. Dy and Tb are the heavy additives that hold NdFeB magnet coercivity at temperature, are the most supply-concentrated of the magnet rare earths, and have no demonstrated substitute at equivalent performance.
business group, whose stated activity is beneficiation of "zirconium, titanium, monazite and heavy mineral concentrates"; the company's product list includes titanium concentrate and rutile. This is a genuine second product line, not a trace input, though it is smaller than the rare-earth business.
Materials named by the company but not scored in this register: cerium, lanthanum and zirconium (and the monazite/zircon-sand concentrates themselves) are real Shenghe products but are not members of SCORED_MATERIALS in lib/minerals-supply-risk.ts, and none of them resolve to a scored slug through the synonym table — checked against the live list on 2026-08-31, not carried forward from another dossier. They are therefore absent from the scored exposure set rather than dropped as unverified. Samarium is scored and would be plausible for a Chinese separation operator, but no Shenghe source names it, so it is deliberately left out rather than assumed.
Dropped from the sector default: cobalt, copper, chromium, manganese, nickel, aluminium, niobium and vanadium. These were the generic mining-metals sector guesses; Shenghe is a rare-earth and mineral-sands specialist and no company source ties it to any base or ferro-alloy metal. The Chinalco board seat is an ownership fact, not an aluminium exposure, and is not treated as one here.
Source for this entire section: 盛和资源控股股份有限公司2025年年度报告 (Shenghe Resources Holding Co., Ltd. 2025 annual report), filed with the Shanghai Stock Exchange via cninfo 2026-04-30 — static.cninfo.com.cn/finalpage/2026-04-30/1225258047.PDF (§(7) 主要销售客户及主要供应商情况, p.17; Note 十四 关联方及关联交易, pp.230-234). Reporting period: FY2025 (year ended 2025-12-31), with FY2024 comparatives from the same filing. Confidence: primary-source.
Top-5 customers: RMB 5,455,849,500 (545,584.95万元), 36.39% of annual sales; related-party share = 0%. Top-5 suppliers: RMB 4,325,298,900 (432,529.89万元), 31.75% of annual purchases; related-party share = 0%. Unlike Zijin's FY2025 annual report, this filing names no individual top-5 constituent in prose either — no "主要客户包括…等" sentence — so the top-5 counterparties themselves stay unnamed here. A full-text search of the 259-page filing also returned zero hits for "MP Materials" or "Mountain Pass" — Shenghe's reported purchase relationship with MP Materials' Mountain Pass concentrate (cited on this dossier's Wikipedia source) is not independently confirmed in this year's primary filing and is NOT written as a named-counterparty row on that basis alone.
The filing's mandatory related-party-transaction note (separate from the top-5 table) names three operating counterparties below the top-5 threshold, each with a quantified current-year and prior-year RMB figure — a real supply/offtake relationship even though none individually clears the top-5 cutoff:
associate/JV) — goods sales more than doubled, RMB 112.1m (FY2024) to RMB 254.8m (FY2025), +127.2%.
Ltd.** (supplier, 10%-owned by Shenghe subsidiary Shenghe Resources (Hainan)) — goods purchases RMB 127.1m (FY2024) to RMB 328.7m (FY2025), +158.6%, still under its RMB 400m board-approved quota.
(customer, related via a Shenghe director's key-management role at its parent) — goods sales RMB 131.2m (FY2024) to RMB 269.0m (FY2025), +105.1%.
Two of the three carry the 中核 (CNNC / China National Nuclear Corporation) name prefix common to CNNC-system subsidiaries — an unconfirmed corporate tie between Shenghe's rare-earth output and China's nuclear-industry state conglomerate, flagged as an inference from the name alone, not verified against a CNNC ownership register.
Smaller/declining related-party relationships found but not written as structured rows (all below RMB 65m and each already captured in the filing's own comparative column, so a future pass can promote any of them without a new fetch): 广西域潇西骏稀土功能材料有限公司 (both customer and supplier, both legs shrank FY2024→FY2025), 四川和地矿业发展有限公司 (supplier, purchases fell -19.6%). Sparse-but-declining is a legitimate finding, not an omission.
Source for this update: 盛和资源控股股份有限公司2026年半年度报告 (H1-2026 semi-annual report), filed with the Shanghai Stock Exchange via cninfo 2026-08-29 — static.cninfo.com.cn/finalpage/2026-08-29/1225525089.PDF, 关联交易 (related-party transactions) note. Reporting period: H1-2026 (six months ended 2026-06-30), with H1-2025 comparatives from the same filing where the filing itself provides one. Confidence: primary-source.
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.
The top-5 lists themselves are 0% related-party and the filing names no individual top-5 constituent (no name exemption invoked — Shenghe simply did not volunteer names the way Zijin's MD&A did for Trafigura/Jinchuan). The named rows below are BELOW top-5, drawn from the separate mandatory related-party-transaction note instead.
FY2024 · FY2024 comparative from the same filing: goods purchases RMB 127,141,694.43 (+158.6% to the FY2025 figure above).source ↗
FY2025 · Related party via Shenghe subsidiary Shenghe Resources (Hainan) holding a 10% stake in this entity. Goods purchases RMB 328,721,957.12 against a board-approved FY2025 quota of RMB 400,000,000.00 (not exceeded). Also carries the 中核 (CNNC) name prefix, same unconfirmed-tie caveat as the row above.source ↗
H1-2026 semi-annual report (filed 2026-08-29): goods sales (Shenghe→CNNC Huasheng) RMB 138,501,957.86 (H1-2025 comparative RMB 52,631,640.16, +163.1%), processing income RMB 1,025,540.73 (H1-2025: RMB 10,098,972.23, -89.8%), handling-service income RMB 392,654.87 (no H1-2025 comparative shown). Newly disclosed this filing: CNNC Huasheng is ALSO a goods supplier to Shenghe, RMB 41,784,677.71 against a board-approved annual quota of RMB 150,000,000.00 (H1-2025: RMB 25,251,465.07, +65.5%) — a dual customer/supplier relationship not visible in the FY2025/FY2024 rows above, which captured only the sales side.
New counterparty, not previously named in this dossier — a separate legal entity from 中稀（凉山）稀土有限公司 above (its trading subsidiary; related via the same director, Yang Zhenhai, as key management at its parent). H1-2026: goods sales (Shenghe→entity) RMB 45,859,115.05 (H1-2025: RMB 32,528,141.60, +41.0%); goods purchases (entity→Shenghe) RMB 13,861,696.29 (H1-2025: RMB 11,920,353.98, +16.3%) — both flows carry clean H1-over-H1 comparatives in the filing's own table.
New counterparty row (previously only in this dossier's prose as a declining FY2024→FY2025 sales relationship). H1-2026 flips the picture on the purchase side: goods purchases (Shenghe buys from this associate) RMB 145,846,550.44 vs H1-2025 RMB 30,709,734.51, +374.9%, plus a new processing-fee line of RMB 17,906,011.50 (no H1-2025 comparative shown). Sales side (Shenghe→entity) RMB 31,915,863.96 this period, also with no comparative column shown. 联营企业 (equity-method associate) per the filing's own related-party classification.
FY2024 · FY2024 comparative from the same FY2025 annual report's related-party table: goods sales RMB 112,105,413.29 (+127.2% to the FY2025 figure above).source ↗
FY2025 · Associate/JV of Shenghe (联营企业). Goods sales RMB 254,780,624.07 (+ processing income RMB 18,568,675.97 + handling-service income RMB 392,654.87) — roughly 1.70% of FY2025 consolidated revenue (RMB 14,990,898,214.29), computed here from the filing's own two disclosed figures, not itself a disclosed ratio. Below the top-5 threshold individually. Name carries the 中核 (CNNC/China National Nuclear Corporation) prefix common to CNNC subsidiaries — an unconfirmed corporate tie, not asserted as proven.source ↗
FY2024 · FY2024 comparative from the same filing: goods sales RMB 131,176,327.43 (+105.1% to the FY2025 figure above); processing income RMB 35,360,211.85 (-89.9% to the FY2025 figure above).source ↗
FY2025 · Related party via director overlap, not equity: Shenghe director Yang Zhenhai (杨振海) is disclosed as key management personnel at this entity's parent. Goods sales RMB 269,002,129.65 (+ processing income RMB 3,584,070.81, which moved the opposite direction, -89.9% YoY). Below the top-5 threshold individually.source ↗
H1-2026 · H1-2026 semi-annual report: goods sales RMB 144,359,534.06 and a processing fee Shenghe paid this entity of RMB 1,991,150.45, both shown with no H1-2025 comparative column in the filing's own table (unlike the CNNC Huasheng and Zhongxi Trading rows in this same filing, which do carry one) — read as immaterial/absent in H1-2025 rather than confirmed zero. Same director-overlap tie (Yang Zhenhai, key management at the parent) as the FY2025/FY2024 rows above.source ↗
H1-2026 semi-annual report (filed 2026-08-29): goods sales (Shenghe→CNNC Huasheng) RMB 138,501,957.86 (H1-2025 comparative RMB 52,631,640.16, +163.1%), processing income RMB 1,025,540.73 (H1-2025: RMB 10,098,972.23, -89.8%), handling-service income RMB 392,654.87 (no H1-2025 comparative shown). Newly disclosed this filing: CNNC Huasheng is ALSO a goods supplier to Shenghe, RMB 41,784,677.71 against a board-approved annual quota of RMB 150,000,000.00 (H1-2025: RMB 25,251,465.07, +65.5%) — a dual customer/supplier relationship not visible in the FY2025/FY2024 rows above, which captured only the sales side.
New counterparty, not previously named in this dossier — a separate legal entity from 中稀（凉山）稀土有限公司 above (its trading subsidiary; related via the same director, Yang Zhenhai, as key management at its parent). H1-2026: goods sales (Shenghe→entity) RMB 45,859,115.05 (H1-2025: RMB 32,528,141.60, +41.0%); goods purchases (entity→Shenghe) RMB 13,861,696.29 (H1-2025: RMB 11,920,353.98, +16.3%) — both flows carry clean H1-over-H1 comparatives in the filing's own table.
New counterparty row (previously only in this dossier's prose as a declining FY2024→FY2025 sales relationship). H1-2026 flips the picture on the purchase side: goods purchases (Shenghe buys from this associate) RMB 145,846,550.44 vs H1-2025 RMB 30,709,734.51, +374.9%, plus a new processing-fee line of RMB 17,906,011.50 (no H1-2025 comparative shown). Sales side (Shenghe→entity) RMB 31,915,863.96 this period, also with no comparative column shown. 联营企业 (equity-method associate) per the filing's own related-party classification.
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.
5 of 5 of your scored CRMA-strategic materials 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 |
|---|---|---|---|---|---|---|---|---|---|
| Dysprosium | 🇨🇳 CN 99% refining | 48 | 88 | Moderate | EXCEEDS 99% | Med | none | 51 | ▲ rising |
| Terbium | 🇨🇳 CN 99% refining | 42 | 84 | Moderate | EXCEEDS 99% | Med | limited | 51 | ▲ rising |
| Neodymium | 🇨🇳 CN 85% refining | 36 | 72 | Low | EXCEEDS 85% | High | some | 50 | ▲ rising |
| Praseodymium | 🇨🇳 CN 85% refining | 36 | 72 | Low | EXCEEDS 85% | High | some | 48 | ▲ rising |
| Titanium | 🇨🇳 CN 70% refining | 27 | 59 | Low | EXCEEDS 70% | Med | limited | 14 | ▲ 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 |
|---|---|---|---|---|---|---|
| Dysprosium | 4 | 5 | 5 | 5 | 3 | company input |
| Terbium | 4 | 5 | 5 | 4 | 3 | company input |
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Praseodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Titanium | 4 | 3 | 1 | 4 | 4 | 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.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 46 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:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Dysprosium exposure:
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
The binding exposure this precedent lands on — Dysprosium — is a material Shenghe Resources Holding Co., Ltd. produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-07) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 4 restrictive actions on Dysprosium since 2024 — cadence accelerating (mean gap 483d → 152d), severity flat (3.5 → 3.5).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 4 of these 26 materials (Neodymium, Dysprosium, Praseodymium, Terbium) — your binding Dysprosium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 4.7 months apart across 5 distinct restriction dates since 2024 (n=4 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Dysprosium — 🇨🇳 CN escalates dysprosium controls to a full export-licensing / ban regime | 48 | 49 | +1 |
| Concentration | Dysprosium — 🇨🇳 CN becomes the single source for dysprosium — the second source is lost (full 99%+ monopoly) | 48 | 48 | 0 |
| Policy | Terbium — 🇨🇳 CN escalates terbium controls to a full export-licensing / ban regime | 42 | 43 | +1 |
| Concentration | Terbium — 🇨🇳 CN becomes the single source for terbium — the second source is lost (full 99%+ monopoly) | 42 | 42 | 0 |
| Policy | Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime | 36 | 37 | +1 |
| Concentration | Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly) | 36 | 39 | +3 |
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 on the input side — every scored material here is one Shenghe Resources Holding Co., Ltd. produces, and Art. 24 addresses the use of a strategic raw material as an input. 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 0 materials this company buys (the 5 it produces are excluded from the test and listed above). 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.
Every scored material here is one Shenghe Resources Holding Co., Ltd. produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
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 | company input — all 5 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | mining-metals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-30; 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.