6 critical materials scored · binding chokepoint: Manganese (🇨🇳 CN 90% of refining) · 131 restrictive government measures on record
Subject
akkuser · 🇫🇮 FI
Sector
metals-recycling
Materials scored
6
As of
2026-09-30
Risk Office verdict
High · 77/100Company supply-risk index · consumer-side read
Role check · this company is a producer, not a buyer
AkkuSer Oy produces 6 of the 6 scored materials above (Manganese, Cobalt, Lithium, Copper, Nickel, Aluminium). 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 High · 77/100 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 2026-10-05) — 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 Manganese — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 83/100 (adversarial chokepoint; global 69). The register holds 131 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · ManganeseAkkuSer Oy is the 113th-most-exposed of the 447 named companies we track on 🇨🇳 CN's Manganese chokepoint; the most-exposed is Rivian Automotive, Inc. (83/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · metals recycling
AkkuSer Oy ranks 12th of 56 verified metals recycling companies, tied with 7 others at 77.
90🇺🇸 Momentum TechnologiesDysprosium
85🇹🇼 Lianyou Metals Co., Ltd.Tungsten
83🇬🇧 Altilium Group Ltd / Altilium Metals LtdGraphite
81🇳🇱 NovocycleGraphite
79🇺🇸 Ascend Elements, Inc.Manganese
79🇺🇸 Cirba Solutions, LLCManganese
79🇺🇸 EcobatManganese
79🇨🇦 American Manganese Inc. (RecycLiCo Battery Materials)Manganese
79🇬🇧 Recyclus Group LtdManganese
Company supply-risk index 77/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 6 scored materials. Buyer-relative (first-order): weighted by where the company produces (FI 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
FI · Nivala — portable battery recycling (Dry-Technology mechanical separation to metal concentrates + metal fractions)cobaltlithiumnickelmanganesecopperaluminium
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.
AkkuSer Oy, founded in 2005 and based in Nivala, Finland, is a portable-battery recycler that receives essentially all spent portable batteries collected in Finland plus imported waste-battery volumes from elsewhere in Europe. It runs a proprietary "Dry-Technology" mechanical process — two-stage crushing followed by magnetic and mechanical separation, with no water, chemicals, or heat — that sorts and processes high- and low-grade cobalt Li-ion, Ni-MH, alkaline, and other portable battery chemistries into separated metal fractions and metal concentrates delivered to refineries, recovering more than half of the input battery mass for reuse.
Critical-material exposure
Cobalt — AkkuSer's core value stream: the company runs a dedicated
"high-grade cobalt Li-ion battery" process line, and its own process- description page states these batteries "contain a notable amount of cobalt and other important metals such as copper," recovered via two-stage crushing plus magnetic/mechanical separation into metal concentrates delivered to metal refineries. (Correction: AkkuSer's own site uses "metal concentrates," not the industry-shorthand term "black mass," for this output — the earlier dossier text used the latter without a supporting citation.) Cobalt refining is geographically concentrated (DRC mine supply, China-dominant midstream refining), so AkkuSer's cobalt-concentrate output is a rare non-China-refining-dependent EU cobalt stream — but the business itself is exposed to the same cobalt-price and battery-feedstock cycle as the rest of the chain.
— not individually named on AkkuSer's own site (no page states
The exposure register
Ranked by buyer-relative risk, highest first.
2 of 6 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
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.
The laws that threaten it
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
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).
Which of your plants carries the binding exposure
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Manganese exposure:
🇫🇮 FI · Nivala — portable battery recycling (Dry-Technology mechanical separation to metal concentrates + metal fractions)
Disclosed plant-level detail matched to the binding material — descriptive, from the company's own disclosures; a plant not listed here is undisclosed, not unexposed. Country weights still drive the score above.
Type
Scenario
Today
Stressed
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one AkkuSer Oy 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): Manganese clears the same numeric bar but is a material AkkuSer Oy 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 6 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 — 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.
announced→low likelihood·flagged 26d 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
Manganese is the line to war-game: 🇨🇳 CN already controls 90% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Cobalt carries 37 restrictive measures on record (🇨🇳 CN 78% of refining) — a secondary escalation candidate.
Lithium carries 40 restrictive measures on record (🇨🇳 CN 65% of refining) — a secondary escalation candidate.
Art. 24(4) · diversification & substitution
Priority mitigations
Every scored material here is one AkkuSer Oy 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.
The mitigation optionsShowHide
Track demand-side substitution against your own book. The buyer levers listed for consumers of Manganese, Cobalt, Lithium, Copper, Nickel, Aluminium — qualifying alternative suppliers, designing the material out — are the demand risk to AkkuSer Oy's revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by CN on a material AkkuSer Oy produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The materials above are concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
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
company input — all 6 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology
metals-recycling (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.
79
🇫🇷 Veolia Environnement SA
Manganese
78🇱🇻 EcollectTungsten
77🇫🇮 AkkuSer OyManganese
77🇯🇵 DOWA Holdings Co., Ltd.Gallium
77🇮🇹 Feralpi Group (Feralpi Holding S.p.A.)Manganese
77🇨🇭 Librec AGManganese
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 3 further metals recycling 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.
Lithium
a lithium recovery/output figure), but inferred with high confidence: AkkuSer explicitly processes NMC-type Li-ion cells, and lithium is a structural component of NMC (Lithium-Nickel-Manganese-Cobalt-oxide) cathode chemistry, well-established battery science independent of any AkkuSer-specific claim. Lithium chemical supply and refining is concentrated in a small number of producers (Australia mining, China refining/conversion), so AkkuSer's economics track upstream lithium-price and policy swings even though it does not mine lithium itself.
Nickel — confirmed by AkkuSer's own site for both routes it processes:
the Ni-MH process-description page states these batteries' "most valuable" recovered metals are "nickel and cobalt," and nickel is also a structural component of the NMC-type Li-ion cells in the cobalt Li-ion stream. Nickel sulfate/refined-nickel supply for battery-grade material is concentrated in Indonesia/China processing capacity.
Manganese — not individually named on AkkuSer's own site; inferred as a
standard component of NMC-type Li-ion cathode chemistry recovered alongside cobalt/nickel/lithium in the metal-concentrate output, same basis as the lithium entry above; low per-unit value but relevant to feedstock-mix economics.
Copper — recovered mechanically as a separated metal fraction (current
collectors, wiring) during the crushing/sorting stages; less supply- concentrated than the battery-cathode metals but a real output stream.
Aluminium — recovered as a separated metal fraction (cell casings, foil
current collectors) during mechanical processing; standard byproduct of Li-ion battery disassembly.
No credible public source ties AkkuSer to silver, rare-earth, or other sector-default exposures carried over from the initial auto-onboarded stub, so those have been dropped.
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
Manganese
4Geopolitical: 12 restrictive actions, peak severity 5, 6 in last 24mo
4Concentration: refining HHI 8134 (extreme); top CN 90%
5Substitutability: Graedel et al. 2013 PNAS Fig. 5: 96/100 (long-horizon, all major uses). Prior analyst short-run rating 0.92: USGS: no satisfactory substitute in its major steel applications
Cobalt
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
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
Aluminium
4Geopolitical: 43 restrictive actions, peak severity 5, 26 in last 24mo, less 1 liberalising action
Manganese — 🇨🇳 CN escalates manganese controls to a full export-licensing / ban regime
83
88
+5
Concentration
Manganese — 🇨🇳 CN becomes the single source for manganese — the second source is lost (full 90%+ monopoly)
83
88
+5
Policy
Cobalt — 🇨🇳 CN escalates cobalt controls to a full export-licensing / ban regime
75
81
+6
Concentration
Cobalt — 🇨🇳 CN becomes the single source for cobalt — the second source is lost (full 78%+ monopoly)
75
89
+14
Policy
Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime
72
78
+6
Concentration
Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly)
72
91
+19
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 72→78+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 55d 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 68→74+6
Cobalt🇨🇳 today 75→81+6
🇬🇳 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 66d 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 49→55+6
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 66d 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 68→74+6
Cobalt🇨🇳 today 75→81+6
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 66d ago · not yet law·matches Cobalt, Copper, Lithium, Manganese, Aluminium
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 75→81+6
Copper🇨🇳 today 68→74+6
Lithium🇨🇳 today 72→78+6
Manganese🇨🇳 today 83→88+5
Aluminium🇨🇳 today 49→55+6
🇨🇩 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 77d 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 75→81+6
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 72d 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 68→74+6
🇳🇨 New Caledonia (France) — "renewed nickel doctrine" + nickel-industry recovery pact under the Bougival Accord
announced→low likelihood·flagged 83d 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 64→71+7
🇨🇱 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 83d 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 72→78+6
🇬🇳 Guinea — Nimba Mining Company (NMC, 100% state-owned) / Glencore bauxite pre-financing and marketing agreement
announced→low likelihood·flagged 13d 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 49→55+6
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Nickel, Lithium, Cobalt
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)
Nickel🇨🇳 today 64→71+7
Lithium🇨🇳 today 72→78+6
Cobalt🇨🇳 today 75→81+6
🇰🇿 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 98d ago · not yet law·matches Copper
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 68→74+6
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 99d 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 68→74+6
Nickel🇨🇳 today 64→71+7
Cobalt🇨🇳 today 75→81+6
🇮🇩 Indonesia NPI/Ferronickel/MHP Export Duty — ESDM Commitment, April 2026 Launch Postponed Indefinitely
announced→low likelihood·flagged 102d 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 64→71+7
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Lithium, Copper, Manganese, Cobalt
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 72→78+6
Copper🇨🇳 today 68→74+6
Manganese🇨🇳 today 83→88+5
Cobalt🇨🇳 today 75→81+6
🇬🇦 Gabon — Government Announcement: Ban on Crude Manganese Ore Exports from January 1, 2029
announced→low likelihood·flagged 108d ago · not yet law·matches Manganese
If passed — Gabon = ~25% world manganese reserves, world's 2nd largest manganese ore exporter (~8 Mt/year via COMILOG/Eramet); ban on raw ore exports forces domestic processing investment (silicomanganese, EMD, battery-grade HPMSM) or cessation of shipments; reprices global manganese ore supply for steel alloy and NMC/LMFP battery cathode precursor markets; Eramet (dominant operator through COMILOG subsidiary and Setrag railway) confirmed impact; 3-year transition period gives industry until 2029
Caveat — Announced by President Brice Oligui Nguema (CTRI military transitional government, in power since August 2023 coup) in late May/June 2025; Eramet's June 2, 2025 official response at eramet. com confirms the government announcement; aligned with "Industrial Gabon 2035" strategy; no formal gazette decree text found as of June 2026. GA has 0 prior actions in IPTM register. Secondary source: https://www. eramet. com/en/news/eramets-response-to-the-gabonese-governments-an-nouncement-on-crude-manganese-export-ban-starting-in-2029/
If passed & escalated to a full control regime — modelled impact (low likelihood)
Manganese🇨🇳 today 83→88+5
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Lithium, Cobalt, Manganese, 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 72→78+6
Cobalt🇨🇳 today 75→81+6
Manganese🇨🇳 today 83→88+5
Nickel🇨🇳 today 64→71+7
🇨🇩 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 113d ago · not yet law·matches Lithium
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 72→78+6
🇬🇳 Guinea Bauxite Export Volume Controls 2026
announced→low likelihood·flagged 114d 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 49→55+6
🇳🇦 Namibia new Minerals Bill (Minerals Prospecting and Mining Act overhaul)
in-consultation→moderate likelihood·flagged 113d ago · not yet law·matches Lithium, Manganese
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 72→78+6
Manganese🇨🇳 today 83→88+5
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches 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)
Lithium🇨🇳 today 72→78+6
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 113d ago · not yet law·matches Copper
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 68→74+6
🇸🇱 Sierra Leone No Raw Minerals Export Commitment (VP Jalloh, Mining Week May 2026)
announced→low likelihood·flagged 113d 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 49→55+6
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Lithium, Cobalt, Nickel, Manganese
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 72→78+6
Cobalt🇨🇳 today 75→81+6
Nickel🇨🇳 today 64→71+7
Manganese🇨🇳 today 83→88+5
🇪🇺 EU CBAM Scope Expansion to ~180 Downstream Steel/Aluminum Products (COM(2025) 989 final)
draft-published→moderate likelihood·flagged 111d 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 ↗
in-consultation→moderate likelihood·flagged 111d 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 49→55+6
🇬🇳 Guinea Alumina Refinery Ultimatum — SMB and CBG 10-Day Deadline to Submit Construction Timeline (June 2026)
announced→low likelihood·flagged 111d 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 111d ago · not yet law·matches Nickel, Copper
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 64→71+7
Copper🇨🇳 today 68→74+6
🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining Policy
passed-committee→elevated likelihood·flagged 110d ago · not yet law·matches Aluminium, Manganese, 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 49→55+6
Manganese🇨🇳 today 83→88+5
Lithium🇨🇳 today 72→78+6
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 110d ago · not yet law·matches Lithium, 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 72→78+6
Copper🇨🇳 today 68→74+6
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Lithium, Cobalt, Nickel, Copper, Manganese
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 72→78+6
Cobalt🇨🇳 today 75→81+6
Nickel🇨🇳 today 64→71+7
Copper🇨🇳 today 68→74+6
Manganese🇨🇳 today 83→88+5
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 109d 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 68→74+6
Nickel🇨🇳 today 64→71+7
Cobalt🇨🇳 today 75→81+6
🇬🇳 Guinea Ministry of Mines — Bauxite Export Volume Cap (~150 Mt/yr, 2026)
in-consultation→moderate likelihood·flagged 108d 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 49→55+6
CEMAC Common Mining Code — 6-member regional harmonisation (April 2026)
draft-published→moderate likelihood·flagged 107d ago · not yet law·matches Manganese, 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)
Manganese🇨🇳 today 83→88+5
Cobalt🇨🇳 today 75→81+6
🇹🇿 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 101d ago · not yet law·matches Nickel, Cobalt, Copper
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)
Nickel🇨🇳 today 64→71+7
Cobalt🇨🇳 today 75→81+6
Copper🇨🇳 today 68→74+6
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 104d 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 75→81+6
Copper🇨🇳 today 68→74+6
🇬🇭 Ghana Minerals and Mining Act 703 Amendment — Cabinet-Approved Proposal (Royalty 9-12%, Lease Cuts, DA Abolition)
draft-published→moderate likelihood·flagged 104d 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 49→55+6
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 104d ago · not yet law·matches Nickel, Cobalt, Manganese, 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 & escalated to a full control regime — modelled impact (elevated likelihood)
Nickel🇨🇳 today 64→71+7
Cobalt🇨🇳 today 75→81+6
Manganese🇨🇳 today 83→88+5
Copper🇨🇳 today 68→74+6
🇬🇳 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 102d 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 49→55+6
🇪🇺 STAGE UPDATE — EU CBAM COM(2025)989 Downstream Extension: Council adopts general approach June 12, 2026
passed-committee→elevated likelihood·flagged 101d 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 49→55+6
🇬🇦 Gabon — Government to Subscribe to Eramet €500M Capital Increase, Acquiring Equity Stake in French Parent Company
passed-vote→high likelihood·flagged 101d ago · not yet law·matches Manganese
If passed — Gabon (CTRI transitional government, President Oligui Nguema) announced at Africa Forward Summit in Nairobi (May 2026) its intention to subscribe to Eramet SA's €500M capital increase, giving the Gabonese state direct equity in the French-listed parent of COMILOG (its primary manganese mining subsidiary in Moanda). Gabon already holds 29% of COMILOG; a stake in Eramet SA itself would give Gabon leverage over the global operations of the parent group (smelting, nickel, lithium, manganese across France, Norway, Senegal, and Indonesia) and a seat at the Eramet Board. Eramet AGM (May 27, 2026) approved the capital raise resolution. Capital raise planned for H2 2026. Distinct from: filed 2025-05-30-gabon-raw-manganese-export-ban-2029 (the export ban forcing value-addition); filed 2024-07-02-gabon-decret-0276-regimes-des-substances-souveraines (35% state free-carry in new mines) — this is an equity purchase in the parent company, not a free-carry in a Gabonese concession; new vector of state resource-control
Caveat — Eramet capital raise planned for H2 2026; no decree number or gazette reference from Gabon available as of June 26, 2026. Gabon's National Strategic Investment Fund (FONSIG) or CTRI Council of Ministers would be the authorising body. Eramet SA (Euronext Paris: ERA) is ~37% owned by French state arm BPIFRANCE as at 2025 — a Gabon stake would create a two-sovereign ownership structure over the world's second-largest manganese ore exporter. Severity 3 expected if completed: creates direct state leverage over COMILOG's pricing, capex, and processing decisions, going beyond the 2029 ore export ban.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Manganese🇨🇳 today 83→88+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 101d ago · not yet law·matches Aluminium, Manganese, Lithium, Copper, Cobalt, Nickel
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 49→55+6
Manganese🇨🇳 today 83→88+5
Lithium🇨🇳 today 72→78+6
Copper🇨🇳 today 68→74+6
Cobalt🇨🇳 today 75→81+6
Nickel🇨🇳 today 64→71
🇲🇳 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 100d ago · not yet law·matches Copper, Manganese, Cobalt, Lithium, 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 68→74+6
Manganese🇨🇳 today 83→88+5
Cobalt🇨🇳 today 75→81+6
Lithium🇨🇳 today 72→78+6
Nickel🇨🇳 today 64→71+7
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 100d 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 68→74+6
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 99d 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 68→74+6
🇨🇳 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 99d 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 72→78+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 98d ago · not yet law·matches Nickel
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 64→71+7
🇧🇷 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 87d 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 83d 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 49→55+6
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Lithium, Cobalt, Nickel, Manganese, 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 72→78+6
Cobalt🇨🇳 today 75→81+6
Nickel🇨🇳 today 64→71+7
Manganese🇨🇳 today 83→88+5
Copper🇨🇳 today 68→74+6
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 53d ago · not yet law·matches 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)
Aluminium🇨🇳 today 49→55+6
Copper🇨🇳 today 68→74+6
🇲🇬 Madagascar — Council of Ministers lifts 16-year moratorium on new mining-permit issuance (except gold), effective ~29 Jan 2026
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Nickel, Cobalt, 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 64→71+7
Cobalt🇨🇳 today 75→81+6
Aluminium🇨🇳 today 49→55+6
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 31d ago · not yet law·matches Lithium
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 72→78+6
🇨🇦 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 29d 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 72→78+6
🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)
in-consultation→moderate likelihood·flagged 26d ago · not yet law·matches Manganese, 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)
Manganese🇨🇳 today 83→88+5
Lithium🇨🇳 today 72→78+6
Nickel🇨🇳 today 64→71+7
Aluminium🇨🇳 today 49→55+6
🇬🇳 Guinea — Nimba Mining Company (NMC SA) Signs First Base Mining Convention (Tinguilinta Bauxite Concession, Boké)
passed-vote→high likelihood·flagged 25d 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 49→55+6
🇨🇿 Czech Republic — €360M Government Grant for Cinovec Lithium Project (European Metals Holdings / CEZ JV)
awaiting-signature→high likelihood·flagged 16d 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 72→78+6
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 1d 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 68→74+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 %).