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2 critical materials scored · binding chokepoint: Dysprosium (🇨🇳 CN 99% of refining) · 51 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.
Aclara Resources produces 2 of the 2 scored materials above (Dysprosium, Terbium). 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 Critical · 88/100 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 89/100 (neutral exposure; global 88). The register holds 51 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Dysprosium Aclara Resources is the 169th-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.
Aclara Resources ranks 21st of 458 verified mining metals companies, tied with 4 others at 88.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 133 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 88/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 2 scored materials. Buyer-relative (first-order): weighted by where the company produces (BR 55% · CL 30% · US 15%, 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.
Aclara Resources Inc. (TSX: ARA) is a Toronto-domiciled, pre-production rare-earth developer building a vertically integrated "mine-to-magnet" supply chain outside China. Rather than conventional hard-rock mining, it uses a patented low-impact leaching method ("Circular Mineral Harvesting") on ionic-clay deposits — the same deposit type China has historically dominated for heavy rare earths. It holds two projects: the flagship Carina Project in Goiás, Brazil (feasibility-study stage, first declared Mineral Reserves for an ionic-clay project) and the earlier-stage Penco Module in Chile's Biobío region (developed with local industrial group Grupo CAP). It is not yet a producer at either site.
Unlike most rare-earth juniors, Aclara's strategic focus is explicitly the two heaviest, scarcest magnet rare earths — Dy and Tb — rather than the more abundant light REEs (Nd/Pr). These two elements are essential, non-substitutable additives that let permanent magnets retain coercivity at high temperature, making them critical for EV traction motors, wind-turbine generators, and defense/aerospace actuators. China controls the large majority of global heavy-REE separation capacity, so a non-Chinese Dy/Tb source is itself the scarce, policy-relevant asset here — Aclara sits on the supply side of that concentration risk rather than being exposed to it as a buyer.
and financing-dependent.** Carina's feasibility study (effective 2026-03-20) shows an after-tax NPV8 of ~US$1.7B and targets first production as early as 2027-2028, subject to permits and financing. Penco is materially earlier-stage (last public economics are a 2021 Preliminary Economic Assessment) but cleared a Chilean regional environmental-impact approval on 2026-06-09. Both remain execution risks, not operating supply.
~US$277M heavy-REE separation facility in Louisiana to process ore/clay concentrate from both Carina and Penco, backed by ~US$46.4M in Louisiana state incentives — this would relocate the China-concentrated separation stage (not just mining) onto US soil, if built on schedule (~2027-2028).
Finance Corporation (DFC) has put ~US$5M toward Carina's feasibility work with priority-investment rights; trade press (not independently verified against primary contract text) reports this comes with restrictions limiting future export sales to US-allied markets — consistent with a Western-aligned, non-China-facing supply chain, though no offtake agreements have been finalized yet.
messaging emphasizes Dy/Tb specifically; no verified production figures for Nd/Pr or other elements were found, so they are omitted from material_exposures rather than assumed.
1. Aclara Resources — Mine to Magnet / Vertical Integration: https://www.aclara-re.com/vertical-integration 2. Access Newswire — Aclara filing and results of Feasibility Study for Carina Project (2026-03-20 effective date): https://www.accessnewswire.com/newsroom/en/metals-and-mining/aclara-announces-filing-and-results-of-feasibility-study-for-its-flagship-carina-1156947 3. Mining.com — Aclara gets environmental OK for Chile rare earths project (2026-06-09): https://www.mining.com/aclara-resources-gets-environmental-ok-for-chile-rare-earths-project/ 4. Mining.com — Aclara jumps on US heavy REE separation plant plan: https://www.mining.com/aclara-jumps-on-us-rare-earth-plant-plan/ 5. BNamericas — Aclara secures financing support from US DFC for Carina rare earths project: https://www.bnamericas.com/en/news/aclara-secures-financing-support-from-us-dfc-for-carina-rare-earths-project-in-brazil
Ranked by buyer-relative risk, highest first.
2 of 2 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Dysprosium | 🇨🇳 CN 99% refining | 89 | 88 | Critical | EXCEEDS 99% | — | none | 51 | ▲ rising |
| Terbium | 🇨🇳 CN 99% refining | 86 | 84 | Critical | EXCEEDS 99% | — | limited | 51 | ▲ 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 |
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.
+ 36 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, these disclosed plants carry 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 Aclara Resources 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 sector-derived, not a company disclosure. 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 2 of these 26 materials (Dysprosium, 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 —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Dysprosium — 🇨🇳 CN escalates dysprosium controls to a full export-licensing / ban regime | 89 | 91 | +2 |
| Concentration | Dysprosium — 🇨🇳 CN becomes the single source for dysprosium — the second source is lost (full 99%+ monopoly) | 89 | 90 | +1 |
| Policy | Terbium — 🇨🇳 CN escalates terbium controls to a full export-licensing / ban regime | 86 | 88 | +2 |
| Concentration | Terbium — 🇨🇳 CN becomes the single source for terbium — the second source is lost (full 99%+ monopoly) | 86 | 86 | 0 |
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 Aclara Resources 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.
Reported separately (not an Art. 24(4) trigger): Dysprosium clears the same numeric bar but is a material Aclara Resources produces. That is an output-market concentration — relevant to revenue and to counterparties who buy from this company — not an input dependency the company must mitigate under Art. 24(4).
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 2 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.
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 Aclara Resources 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 2 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.