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1 critical material scored · binding chokepoint: Lithium (🇨🇳 CN 65% of refining) · 40 restrictive government measures on record
Albemarle Corporation produces 1 of the 1 scored material above (Lithium). 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 Elevated · 61/100 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 2026-10-06) — 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 Lithium — 🇨🇳 CN controls 65% of global refining. On this company's production footprint that scores 61/100 (neutral exposure; global 61). The register holds 40 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Lithium Albemarle Corporation is the 393rd-most-exposed of the 489 named companies we track on 🇨🇳 CN's Lithium chokepoint; the most-exposed is Momentum Technologies (72/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Albemarle Corporation ranks 2nd of 2 verified critical minerals companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 61/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 1 scored material. Buyer-relative (first-order): weighted by where the company produces (CL 45% · AU 28% · US 15% · CN 8% · JO 5%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Also listed in the dossier but not platform-scored: Bromine, Cesium — no supply-risk series is tracked for these here.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
Albemarle (NYSE: ALB) is the largest Western pure-play lithium producer by global production share and the only US-domiciled major with integrated exposure across both major lithium chemistries (brine in Chile's Atacama; spodumene in Western Australia via Greenbushes) and both major battery-grade end products (lithium carbonate, lithium hydroxide). Three reporting segments: Energy Storage (lithium, 56% of FY24 revenue), Specialties (bromine + cesium + catalysts; significant operations in Arkansas + Jordan via the Jordan Bromine JV), and Ketjen (refinery catalysts; minority-owned spin retained from the 2024 separation).
<!-- corrected 2026-08-17 (overnight audit topic 01, F2): Energy Storage read "~80% of FY24 revenue". The cited FY2024 10-K's own segment net-sales table prints Energy Storage $3,015,121 thousand = 56.1% of total net sales of $5,377,526 thousand for 2024 (the 73.6% share is the FY2023 column, which is the likely source of the drift). -->
Customer mix is concentrated among the top-five EV battery cell makers (LG Energy Solution, Samsung SDI, SK On, CATL, Panasonic) plus Tesla and select cathode/precursor specialists. Asset base spans four jurisdictions structurally — US (Silver Peak NV, Kings Mountain NC, Magnolia AR), Chile (La Negra + Salar de Atacama lease through 2043), Australia (49% Talison/Greenbushes JV with IGO + Tianqi; 100% Kemerton WA hydroxide refinery, fully idled/care-and-maintenance since February 2026 — confirmed still idle as of this 2026-08-22 recheck, no restart announced), and China (Chengdu, Meishan, Qinzhou and Xinyu lithium-conversion plants).
ALB is structurally the most policy-instrument-exposed single company in the global lithium supply chain because each of its four jurisdictional pillars sits inside a different active industrial-policy regime, and the FEoC perimeter under IRA §30D mechanically slices the Australian asset base via the Tianqi stake in Talison.
holds 49% of Talison directly; the remaining 51% is held by Tianqi Lithium Energy Australia (TLEA), itself a JV of Tianqi Lithium Corporation (51% of TLEA) and IGO Limited (49% of TLEA) — indirect Talison stakes of Tianqi 26.01% / IGO 24.99% (corrected 2026-08-22 recheck: this dossier previously read "IGO (24.99%) and Tianqi (24.99%)", an even split that is not what either ALB's or IGO's own disclosure states; verified against albemarle.com/au "Mining Interests" and igo.com.au "Lithium HoldCo Joint Venture" pages 2026-08-22. The correct split matters to Surface 1 below: Tianqi's indirect stake is 26.01%, i.e. it clears the >25% FEoC ownership threshold outright rather than sitting just under it). Greenbushes is the world's largest hard-rock lithium mine by reserves grade and the single most strategically-contested lithium asset because the Tianqi stake makes JV-routed spodumene FEoC-tainted for IRA §30D battery-credit eligibility unless re-routed via ALB's wholly-owned Kemerton/Magnolia conversion footprint. Kings Mountain NC (brownfield restart, EIA/DOE loan-eligible). Wodgina (WA) is the second Australian hard-rock position — 50%-held via the MARBL joint venture with Mineral Resources — and is a separate spodumene asset from Greenbushes with a different partner and therefore a different FEoC posture (merged from albemarle-corporation.md 2026-08-14).
CCHEN-issued, parallel to and distinct from the SQM-Codelco NovaAndino JV); La Negra hydroxide/carbonate complex (Antofagasta region) — Chile's only privately-controlled at-scale integrated brine-to-chemical footprint outside the new state-JV model. Silver Peak NV (US, sole operating domestic brine asset pre-Thacker-Pass).
DOE LPO process), Chengdu + Meishan + Qinzhou + Xinyu China. Kemerton status, reconciled 2026-08-14: this dossier's May-2026 pass recorded Train 1 ramping with Trains 2-3 deferred; albemarle-corporation.md's August-2026 pass records the hydroxide-conversion plant as fully idled (care and maintenance) from February 2026, citing Albemarle's own idling announcement and mining.com's coverage of it. The later reading is carried because it is the better-sourced and more recent of the two; both are stated rather than one silently overwriting the other, and the "Kemerton Train 2/3 restart vs. permanent close" watch item below is now a restart-vs-close question for the whole site, not just Trains 2-3. (Also merged from albemarle-corporation.md: additional Chinese `lithium-carbonate`/`lithium-hydroxide` conversion capacity beyond Meishan and Xinyu.)
<!-- corrected 2026-08-17 (overnight audit topic 01, F2): the merged note read "conversion capacity at Chengdu and Jiangsu, China". Checked against the cited FY2024 10-K Item 2 "Properties", whose Energy Storage rows are "Chengdu, China — Production of technical and battery-grade lithium hydroxide", "Meishan, China — …lithium hydroxide", "Qinzhou, China — Production of lithium carbonate and technical and battery-grade lithium hydroxide" and "Xinyu, China — …lithium hydroxide": Chengdu IS a real ALB site (contrary to the audit's reading, which was taken from the albemarle.com supply page — that page names no sites in text at all), but Jiangsu is not, and Qinzhou was missing from this dossier. The 10-K's own risk factor confirms the count: "we own four production facilities located in China". All four are now named above. -->
Bromine JV (clean-room ICs, flame retardants, oilfield brines). Specialties segment is the cyclical-but-uncorrelated hedge against the lithium-price line.
See /minerals/lithium, /minerals/bromine.
| Date | Action | Issuer | Type | Sev | Why it touches ALB |
|---|---|---|---|---|---|
| 2022-08-16 | Inflation Reduction Act | US | subsidy | 5 | §45X production credit on US-produced LiOH/Li₂CO₃ (Silver Peak, Magnolia AR, Kings Mountain restart); §30D battery-credit FEoC perimeter slices Greenbushes-via-Tianqi routing. |
| 2023-04-20 | Chile National Lithium Strategy | CL | regulatory | 4 | State-JV model on new salars; ALB's Atacama lease grandfathered to 2043 but re-negotiation cycle now anchored to NovaAndino terms. |
| 2025-02-14 | Australia FMIA Production Tax Credits Act | AU | subsidy | 4 | AUD 2/kg CMPTI on Kemerton WA hydroxide conversion from 2027 — direct production-side subsidy on the JV-output diversion pathway. |
| 2025-03-20 | US EO 14241 DPA Domestic Mineral Production | US | industrial-policy | 4 | DPA Title III demand-pull + LPO loan-program reinforcement for Kings Mountain + Magnolia restart capex. |
| 2025-04-24 | Australia Critical Minerals Strategic Reserve | AU | industrial-policy | 4 | AUD 1.2bn government offtake floor for AU-produced critical minerals; Greenbushes spodumene + Kemerton LiOH structurally first-list-eligible. |
| 2025-06-16 | US OFAC UniCat Catalyst settlement | US | sanctions | 3 | Catalyst-industry compliance precedent — Ketjen exposure to similar diversion risk via refinery-catalyst end-users. |
| 2025-07-04 | OBBB IRA Rollback (P.L. 119-21) | US | regulatory | 5 | §30D consumer EV credit gutted; §45X production credit retained for critical minerals — directional mismatch creates structural US-LiOH oversupply risk against compressed end-market. |
| 2025-09-18 | Australia Net Zero Plan 2050 Sector Plans | AU | industrial-policy | 4 | Industrial-decarbonisation cost passes through to Greenbushes + Kemerton operating envelope. |
| 2025-10-20 | US-Australia Critical Minerals Framework | US/AU | industrial-policy | 4 | Bilateral offtake architecture that AU-produced ALB output (Greenbushes spodumene, Kemerton LiOH) is first-list eligible for, contingent on JV-Tianqi-routing fix. |
| 2025-12-27 | Chile NovaAndino Litio (Codelco-SQM JV closing) | CL | regulatory | 4 | State-aligned competitor adjacent to ALB Atacama lease with explicit margin-capture targets; anchors the 2043 re-negotiation benchmark. |
| 2026-01-14 | US Section 232 Critical Minerals Proclamation | US | tariff | 4 | Deferred-tariff regime; Kings Mountain + Magnolia US-domestic production gains a structural arbitrage premium if Commerce/USTR triage falls into binding-tariff outcome. |
| 2026-01-27 | Chile National Critical Minerals Strategy | CL | industrial-policy | 4 | 30% salar protection network + DLE technology preference — eliminates brownfield-expansion alternatives outside the existing Atacama lease perimeter. |
| 2026-02-04 | US State FORGE Critical Minerals Launch | US | industrial-policy | 4 | Multilateral offtake-guarantee overlay above §232; ALB's IRA-eligible US production is the natural anchor SKU. |
| 2026-02-12 | Chile Codelco Maricunga CEOL Definitivo | CL | regulatory | 4 | Forecloses Maricunga as a brownfield expansion alternative — ALB Chile production envelope is now structurally capped to the Atacama lease. |
| 2026-02-25 | Zimbabwe Raw Lithium Concentrate Export Ban | ZW | export-control | 4 | Removes 2-3% of global spodumene supply for 6-12mo — re-rates the Greenbushes JV's clearing price. |
| 2026-04-22 | Chile National Reconstruction Bill | CL | regulatory | 3 | Mining royalty + windfall-tax overlay; cost-base impact on Salar de Atacama operations. |
These are the structural reads a sell-side equity analyst working from the 10-K + commodity-spot-price model would systematically miss.
The Talison Lithium JV (49% ALB / 24.99% IGO / 24.99% Tianqi via TLEA holding) is widely modelled as a clean Australian hard-rock asset. Under IRA §30D's FEoC perimeter and Treasury's October 2024 final regulations on "foreign entity of concern" — which extend to entities with >25% direct + indirect Chinese-government-affiliated ownership of upstream battery materials — every tonne of Greenbushes spodumene routed through a JV-controlled offtake allocation cannot count toward the §30D battery-mineral source requirement. Tianqi is a Chinese-government-affiliated entity under the standard CFIUS lens; TLEA's economic interest in Greenbushes output crosses the FEoC threshold mechanically. The sole workaround is to route ALB's 49% share of Greenbushes spodumene through ALB's wholly-owned Kemerton WA hydroxide refinery (or its US converters), where ALB is the sole legal title-holder on the resulting LiOH and the §30D-eligible volume can be reconstructed downstream. The JV-output / Kemerton-Magnolia throughput differential is therefore the binding production envelope for ALB's IRA §30D-eligible LiOH revenue line — not the gross Greenbushes mine output that equity research cites. The US-Australia Critical Minerals Framework (2025-10-20) and the FMIA CMPTI (2025-02-14) are first-list-eligibility levers contingent on the same diversion architecture.
Public attention focused on SQM-Codelco NovaAndino's headline 30%/70%-→-85% post-2030 state-take schedule. The structural read that equity research misses: the NovaAndino + Maricunga CEOL (2026-02-12) + Critical Minerals Strategy (2026-01-27) salar- protection network jointly eliminate every brownfield expansion alternative inside Chile outside ALB's existing Atacama lease. ALB's separate Atacama lease is grandfathered to 2043 but is now ringed by a state-aligned competitor (NovaAndino) with explicit margin-capture targets to defend, with no parallel salar available for substitution build-out (Maricunga locked to Codelco; 30% protected reserve withdrawn from grant under the 2026-01-27 strategy). ALB's announced Chile expansion via DLE technology is therefore structurally a defensive operating-life-extension play on the existing Atacama lease, not a volume-growth play. The implicit through-cycle modelling assumption (perpetuity-NPV on Chile brine) is contingent on the 2043 re-negotiation under a Chilean political environment that has hardened structurally against private-operator royalty terms — and the new Reconstruction Bill (2026-04-22) anchors the windfall-tax / royalty benchmark above the SQM-Codelco JV terms. Cross-axis: case #2 (hilirisasi ladder) by structural template — Chile has adopted state-JV-with-extension-in-exchange-for-share architecture as the lithium-equivalent of Indonesia's nickel forced-downstream ladder.
ALB is the only US-domiciled lithium pure-play with both a brownfield spodumene asset (Kings Mountain NC, idle since 1990s, restart announced 2022 with DOE LPO co-funding pathway) AND a multi-site domestic conversion footprint (Magnolia AR greenfield + Silver Peak NV brine + Kings Mountain converters). The 2026-01-14 §232 proclamation defers the binary tariff outcome by 180+ days, giving Commerce/USTR time to triage sectors — which gives ALB a structurally bounded window of certainty to lock in DOE Title III + LPO funding for Kings Mountain restart capex BEFORE the tariff regime crystallises. If the eventual §232 outcome is binding (rather than partnership-substitution-driven), ALB's domestically-produced LiOH commands a structural §232- arbitrage premium over Australia/Chile-routed competitors that sell-side models do not price. The State FORGE launch (2026-02-04) overlays an additional offtake-guarantee mechanism above §232 from FORGE signatory governments — an invisible revenue stream in current research models. The EU-US Critical Minerals Strategic Partnership (2026-04-24) adds a third leg because the framework's bilateral first-list mechanism explicitly contemplates US-produced LiOH as a tariff-and-CBAM-free EU import flow.
The 2025-07-04 OBBB IRA Rollback (P.L. 119-21) is widely modelled as a binary "IRA gutted" event. The structural read: the OBBB retained the §45X advanced-manufacturing production credit on critical minerals (including lithium hydroxide and lithium carbonate) while gutting the §30D consumer EV credit. This directional mismatch creates a supply-pull / demand-collapse divergence: ALB's US-produced LiOH at Magnolia, Silver Peak, and the planned Kings Mountain restart retains its production-side IRR uplift, but the end-market demand (US EV battery cells sourcing IRA-compliant materials) collapses because the consumer credit that gave OEMs the IRR to source US-produced minerals at premium prices is gone. Net effect: US-LiOH could become oversupplied relative to compressed US EV demand within the 2027-2029 ramp window of ALB's announced US restart capex — a margin headwind that ALB's last capital-allocation guidance has not explicitly modelled. Cross-reads: the State FORGE multilateral offtake architecture (2026-02-04) is the policy escape valve because it adds non-US-EV-OEM demand pull (allied military stocks, non-IRA-dependent industrial users) above the now-thinner US-EV demand line.
triage decision by 2026 Q3-Q4 — binding tariff vs. partnership-substitution determines whether ALB's US-produced LiOH captures the structural arbitrage premium described above.
application status; the 2025-03-20 EO 14241 DPA Title III funding stream and the 2025-07-04 OBBB §45X retention are the binding-eligibility levers. Watch Q3 2026 DOE LPO announcements.
Chilean government extends ALB's lease under the NovaAndino template (30%-→-85% state-take) vs. a private-operator-retained framework. The 2026-04-22 Reconstruction Bill's royalty/windfall schedule anchors the re-negotiation benchmark — political pressure to anchor above the SQM-NovaAndino terms is rising.
and-maintenance / ramp-down status; the CMPTI 2027 effective date and the Greenbushes-JV-Tianqi diversion economics jointly determine whether full Kemerton ramp is value-accretive.
ALB's highest-leverage open management decision is whether to divert all of ALB's 49% Greenbushes spodumene allocation through the wholly-owned Kemerton/Magnolia/Silver-Peak conversion path (capturing §30D + §45X jointly via IRA-eligible LiOH) versus selling Greenbushes spodumene into the open seaborne market (capturing higher spot prices but losing the IRA premium). Q4 2026 capex-guidance update is the watch event. The diversion architecture is the structurally correct move under the OBBB §45X-retained / §30D-gutted directional mismatch (surface 4) and the §232 + State FORGE + EU-US partnership stack (surface 3), but it requires Kemerton Train 2/3 ramp + Magnolia commissioning to be re-prioritised against open-market spodumene sale tonnage. A second-order structural choice is between the Chile defensive- hold (DLE technology + 2043 lease defence + accept reduced margin perpetuity) versus a Chile partial-exit (sell or partner the Atacama lease back to a Codelco-aligned vehicle ahead of the 2043 re-negotiation while terms are still favourable). Specialties (bromine + cesium + catalysts) is the structurally underpriced cyclical-uncorrelated hedge — the Magnolia AR + Jordan Bromine JV cash-flow line gains an additional optionality layer under the §232 + DOE LPO co-funding regime if ALB chooses to ring-fence the segment for separate disclosure or carve-out.
Refreshed when (a) Commerce/USTR publishes the §232 critical- minerals triage outcome, (b) Chile finalises the Atacama 2043 re-negotiation framework, (c) DOE LPO awards Kings Mountain or Magnolia loan, (d) ALB's quarterly capex guidance materially shifts Kemerton/Magnolia ramp scheduling, OR (e) new IPTM action fires touching the ALB asset base. Tracks alongside case #2 (hilirisasi ladder — Chile state-JV template), case #1 (minor-metals architecture for cross-reference on Specialties segment exposure), and the Eramet/VNP.TO/Vale dossiers for the critical-minerals pure-play vs. integrated-major contrast.
URL added 2026-08-17 (it was cited by name only, which made the segment-share and China-site claims above unspot-checkable): https://www.sec.gov/Archives/edgar/data/915913/000091591325000026/alb-20241231.htm
releases, Tianqi Lithium SEHK 9696 filings)
From the company’s own filings and dated disclosures — top-5 concentration and related-party tables where the filer’s regime compels them, named supply and offtake agreements where it does not. This is a disclosure, not a netting: a named supplier concentration is shown beside the exposure score and never adjusts it. Figures are the fiscal years labelled, not a current snapshot.
Albemarle's own press release (announced 2023-05-22): 5-year supply agreement, 2026-2030, for more than 100,000 metric tons of battery-grade lithium hydroxide, enough for roughly 3 million Ford EV batteries, sourced from US-produced or US-FTA-country lithium. No revenue percentage or dollar value is disclosed.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
0 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Lithium | 🇨🇳 CN 65% refining | 61 | 61 | Elevated | within 65% | High | some | 40 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Lithium | 4 | 3 | 5 | 3 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 25 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, these disclosed plants carry the binding Lithium exposure:
Counterfactual: Indonesia extends the hilirisasi ore-ban template (2020 nickel → 2023 bauxite) to the next rung of battery-mineral exports — tightening upstream supply for cobalt intermediates, lithium feedstock and graphite alongside the existing nickel + aluminium regime. Direct-hit lines are basket issuers whose binding material is a battery-cell input (nickel, cobalt, lithium, graphite) — irrespective of controller, since the template-export is global supply-chain pressure not bilateral targeting.
The binding exposure this precedent lands on — Lithium — is a material Albemarle Corporation produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-06) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 6 restrictive actions on Lithium since 2021 — cadence accelerating (mean gap 339d → 306d), severity flat (3.3 → 2.7).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 1 of these 13 materials (Lithium) — your binding Lithium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 20.8 months apart across 4 distinct restriction dates since 2021 (n=3 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime | 61 | 66 | +5 |
| Concentration | Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly) | 61 | 80 | +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.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Albemarle Corporation produces, and Art. 24 addresses the use of a strategic raw material as an input. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the 0 materials this company buys (the 1 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one Albemarle Corporation produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | critical-minerals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-08-06; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-06
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.