Loading…
Loading…
2 critical materials scored · binding chokepoint: Tungsten (🇨🇳 CN 90% of refining) · 28 restrictive government measures on record
Almonty Industries produces 2 of the 2 scored materials above (Tungsten, Tin). 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 · 84/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-07) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Tungsten — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 76). The register holds 28 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Tungsten Almonty Industries is the 34th-most-exposed of the 449 named companies we track on 🇨🇳 CN's Tungsten chokepoint; the most-exposed is Elbit Systems (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Almonty Industries ranks 29th of 459 verified mining metals companies, tied with 4 others at 84.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 132 further mining metals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 84/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 2 scored materials. Buyer-relative (first-order): weighted by where the company produces (PT 40% · KR 50% · ES 10%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
Almonty Industries is a Canada-domiciled (Toronto Stock Exchange + Nasdaq: ALM) tungsten mining company with no downstream manufacturing — it is a pure upstream producer/developer. It operates the Panasqueira tungsten-tin mine in Portugal (running since 1896) and, as of early 2026, has restarted the Sangdong tungsten mine in Gangwon Province, South Korea, after a 30-year closure. It is also developing the Valtreixal tin/tungsten project in Spain and a molybdenum project on the Sangdong deposit.
consumer, of tungsten concentrate (ammonium paratungstate feedstock for hard metals, cutting tools, and defense/aerospace alloys). China supplies roughly 88% of world tungsten output, making non-Chinese tungsten supply itself the scarce, policy-relevant asset. Sangdong's Phase 1 plant (commissioned 2026) processes ~640,000 t of ore/year for ~2,300 t of tungsten concentrate annually; a Phase 2 expansion planned for 2027 would roughly double that to ~4,600 t/year and processing capacity to ~1.2 million t of ore/year. At full capacity Sangdong alone is expected to supply a large share (industry estimates run as high as ~40%) of tungsten demand outside China — the reason the mine has drawn attention from U.S. government researchers and allied supply-chain diversification efforts. Panasqueira separately processes 700,000–800,000 t of ore/year for roughly 50 t/month of tungsten concentrate.
vein system is wolframite (tungsten) and cassiterite (tin) together, so tin concentrate is a co-product of existing operations. The Valtreixal project in northwestern Spain is being developed explicitly as a tin/tungsten deposit. Tin is not separately scored as a China-concentration risk for Almonty in the way it is for electronics buyers — here the company sits on the supply side of a 3TG (tin/tantalum/tungsten/gold) conflict-mineral category that downstream electronics and auto makers must source responsibly.
developing a molybdenum project on the Sangdong deposit, with a life-of-mine offtake agreement signed with SeAH Group (Korean steelmaker) at a floor price of US$19/lb, aimed partly at South Korea's domestic molybdenum supply shortage. Molybdenum is not in this platform's scored critical-material list, so it is noted here but not included in material_exposures.
1. Almonty Industries — Global Projects (Panasqueira, Sangdong, Valtreixal): https://almonty.com/project/ 2. Almonty Industries — Sangdong Molybdenum offtake with SeAH Group (BusinessWire, 2025-01-29 — corrected from a prior mis-dated "2026-01-29" citation; the release itself and its URL slug both date to 2025-01-29): https://www.businesswire.com/news/home/20250129315431/en/Almonty-Industries-Has-Entered-Into-an-Offtake-Agreement-with-SeAH-Group-the-Korean-Steel-Giant-and-SpaceX-Contractor-to-Supply-SeAH-with-the-Entire-Production-of-Molybdenum-from-Almontys-Sangdong-Molybdenum-Project-for-the-Life-of-Mine 3. Mining.com — "Sangdong tungsten mine in South Korea returns to production after 30 years": https://www.mining.com/sangdong-tungsten-mine-in-south-korea-returns-to-production-after-30-years/ 4. Almonty Industries — binding offtake agreement with Tungsten Parts Wyoming Inc. and Metal-Tech Ltd. for tungsten oxide, exclusively for U.S. defense applications (2025-05-07): https://almonty.com/binding-offtake-agreement-to-supply-tungsten-oxide-solely-for-us-defense-applications/ 5. Almonty Industries — Annual Information Form for FY2024, filed as Exhibit 4.1 to SEC Form F-10 (2025-03-20): the Panasqueira Mine's customer(s) under its long-term Supply Agreements (dated 2011-09-23 and 2014-09-22, as amended) are disclosed only as "the Customer" — Almonty does not publicly name its Panasqueira offtake counterparty(ies) in this filing, so no named_counterparties row is recorded for Panasqueira; a web-search-derived claim naming Sumitomo Electric Industries and Wolfram Bergbau und Hütten AG as Panasqueira customers could NOT be corroborated in this primary filing and was deliberately not added on that basis (verify-or-don't-file). Update 2026-10-02: US customs bills of lading (2026-06/07, Sines to Newark) now name Sumitomo Electric Industries as consignee of Beralt tungsten concentrates, so that row was added on the customs record, not on the AIF. https://www.sec.gov/Archives/edgar/data/1670061/000164117225017947/ex4-1.htm
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.
GTP (Towanda, PA) is a subsidiary of Austria's Plansee Group -- the same corporate family as Plansee Holding AG / GTP Europe S.a r.l., already recorded in this dossier's ownership block as Almonty's largest disclosed shareholder (9.78%, via SEC Schedule 13G); flagged related_party true on that basis. 21-year offtake (extended from 15yr), 4,410,000 MTU total contracted, min. 210,000 MTU/yr post ramp-up, ~US$490M/yr contracted revenue at current APT pricing. Disclosed via Almonty's own SEC Form 6-K exhibit and Business Wire release, 2026-07-14 (re-confirmed 2026-09-26 via search snippets; the SEC host returns 403 to automated fetches).
Binding offtake for tungsten oxide, minimum 40 metric tons/month, hard-floor price with no upside cap; material restricted to exclusive use in US defense applications (missile, drone, ordnance systems). TPW is a US defense contractor; mine of origin not specified in the release. Israeli tungsten processor Metal-Tech is named in the same agreement -- see separate row. Date corrected 2026-09-26: the release is dated 2025-05-07 (previously recorded as 2026).
Israeli tungsten processor, named as a party in the same binding offtake agreement as Tungsten Parts Wyoming (see that row for volume/term/price). The release does not itself state the conversion role or location; earlier text calling Metal-Tech a toll-converter (oxide to metal powder, Israel or US) is not supported by the fetched release text and is dropped.
Long-term take-or-pay tungsten concentrate supply agreement with Wolfram Bergbau und Hutten AG (WBH), Sandvik Group's Austrian tungsten subsidiary: minimum ~1,720 tonnes contained WO3 recovered by retreating/recycling Almonty's existing tailings stockpile at the Los Santos Mine (Spain), plus a conditional US$3.0M one-time upfront payment for the offtake rights. Press release: 'long-term tungsten concentrate supply agreement with Wolfram Bergbau und Hutten AG (\"WBH\"), a subsidiary of the Sandvik Group'; WBH processes concentrate at its St. Martin im Sulmtal, Styria (Austria) smelting plant.
US BoLs, shipper BERALT TIN AND WOLFRAM (PORTUGAL) (Barroca Grande, Minas da Panasqueira = Almonty's Panasqueira mine, Portugal), consignee SUMITOMO ELECTRIC INDUSTRIES, LTD., notify Navigational Logistics Inc, commodity 'BERALT TUNGSTEN CONCENTRATES HS CODE 261100', 20,040 kg per container, sea freight Sines (Portugal) to Newark NJ; dated arrivals 2026-06-01 (MSC CALYPSO), 2026-06-24 (MSC AUDREY), 2026-07-02 (BREMEN), 2026-07-26 (MSC VANDYA). Corroborates the Panasqueira customer the FY2024 AIF leaves unnamed (see source 5). Same page lists Global Tungsten and Powders, Niagara Refining and Kennametal as associated consignees in 2026 but shows no dated BoL for them. Sumitomo Electric's US tungsten-carbide arm (Sumitomo Electric Carbide) is in Mt Prospect IL.
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.
1 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 |
|---|---|---|---|---|---|---|---|---|---|
| Tungsten | 🇨🇳 CN 90% refining | 88 | 76 | Critical | EXCEEDS 90% | High | some | 16 | ▲ rising |
| Tin | 🇨🇳 CN 55% refining | 66 | 56 | Elevated | — | Low | ready | 18 | ▲ 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 |
|---|---|---|---|---|---|---|
| Tungsten | 4 | 4 | 5 | 3 | 3 | company input |
| Tin | 4 | 2 | 5 | 2 | 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.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
Two independent lenses: USGS official puts China at 90% of global refining output (by tonnage); US filers' own disclosures independently name China for 54% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| Jiangwu H.C. Starck Tungsten Products Co., Ltd.CID2551 | China | 15 | SEC |
| Chongyi Zhangyuan Tungsten Co., Ltd.CID258 | China | 14 | SEC |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd.CID2315 | China | 14 | SEC |
| Ganzhou Seadragon W & Mo Co., Ltd.CID2494 | China | 14 | SEC |
| Jiangxi Gan Bei Tungsten Co., Ltd.CID2321 | China | 14 | SEC |
Two independent lenses: USGS official puts China at 55% of global refining output (by tonnage); US filers' own disclosures independently name China for 28% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| China Tin Group Co., Ltd.CID1070 | China | 20 | SEC |
| PT Mitra Stania PrimaCID1453 | Indonesia | 18 | SEC |
| Gejiu Kai Meng Industry and Trade LLCCID942 | China | 18 | SEC |
| PT ATD Makmur Mandiri JayaCID2503 | Indonesia | 17 | SEC |
| PT Prima Timah UtamaCID1458 | Indonesia | 17 | SEC |
Source: US SEC Form SD / Conflict Minerals Report exhibits (EDGAR full-text search), aggregated from RMI smelter tables. “US filers naming it” = distinct US-listed companies whose most-recent CMR names that refiner — disclosure-derived presence, not verified throughput. Link opens the SEC exhibit.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 13 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 Tungsten exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Tungsten — 🇨🇳 CN escalates tungsten controls to a full export-licensing / ban regime | 88 | 91 | +3 |
| Concentration | Tungsten — 🇨🇳 CN becomes the single source for tungsten — the second source is lost (full 90%+ monopoly) | 88 | 92 | +4 |
| Policy | Tin — 🇨🇳 CN escalates tin controls to a full export-licensing / ban regime | 66 | 71 | +5 |
| Concentration | Tin — 🇨🇳 CN becomes the single source for tin — the second source is lost (full 55%+ monopoly) | 66 | 90 | +24 |
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 Almonty Industries 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 2 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one Almonty Industries produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 2 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | mining-metals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-17; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-07
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.