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6 critical materials scored · binding chokepoint: Silicon (🇨🇳 CN 80% of refining) · 79 restrictive government measures on record
AMG Critical Materials N.V. produces 6 of the 6 scored materials above (Silicon, Lithium, Vanadium, Antimony, Tantalum, Chromium). 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 · 72/100 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 Silicon — 🇨🇳 CN controls 80% of global refining. On this company's production footprint that scores 77/100 (adversarial chokepoint; global 64). The register holds 79 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Silicon AMG Critical Materials N.V. is the 327th-most-exposed of the 830 named companies we track on 🇨🇳 CN's Silicon chokepoint; the most-exposed is aerodyn Engineering GmbH (77/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Company supply-risk index 72/100 — 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 (BR 30% · US 25% · DE 20% · MZ 10% · GB 8% · FR 5% · CN 2%, 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.
AMG Critical Materials N.V. (AMG.AS, Euronext Amsterdam, headquartered Amsterdam; rebranded from "AMG Advanced Metallurgical Group" in May 2022) is the only listed European pure-play critical-materials processor — its revenue base sits almost entirely inside the 17-material CRMA strategic list (lithium, vanadium, silicon, tantalum, antimony, chromium, graphite), with no defence-prime, no construction-aggregates, and no consumer-products diversification softening the policy-cycle beta. Three reporting segments since the FY2024 segment realignment (per AMG FY2024 Annual Report, published 12 March 2025 — corrected 2026-08-22; AMG's own press release (amg-nv.com/investors/press-release/amg-critical-materials-n-v-publishes-2024-annual-report/) dates the Annual Report to 12 March 2025, not 18 February 2025 as previously stated here; the FY2024 preliminary earnings release was 26 February 2025, a different document):
1. AMG Lithium — Mibra spodumene mine (Minas Gerais, Brazil) operated by AMG Brasil, producing spodumene concentrate and tantalum / niobium byproduct; LIVA-1 lithium hydroxide monohydrate refinery in Bitterfeld, Germany (first crystals produced March 2024 per AMG press release; first commercial cell-grade qualification batches 2024-25; Phase-1 nameplate 20kt LiOH/year). AMG Lithium GmbH was the project vehicle until 2024 IPO discussion; Bitterfeld is the only operational merchant-market LiOH refinery on EU soil. 2. AMG Vanadium — spent-petroleum-catalyst recycling at Cambridge, Ohio (FeV + V₂O₅; the largest spent-catalyst V recycler in the western hemisphere per AMG investor day disclosure 2024); ferro-vanadium primary production at AMG Brasil (Mibra co-product); Saudi vanadium JV with Ma'aden (Saudi Arabian Mining Company) — announced March 2022, Project "Saudi Recycle" / SARCO with $300M+ envelope, designed to recycle spent catalyst from Aramco/SABIC refineries (status: construction phase per FY2024 Annual Report). 3. AMG Technologies — silicon metal at Hauzenberg, Germany (Silicon Metallurgy GmbH; ferrosilicon + silicon metal for chemical-grade, electronics-grade precursor, and aluminium alloy use); chromium metal (electrolytic, Cambridge OH); antimony (byproduct from Cambridge OH spent-catalyst stream); titanium-aluminides + advanced ceramics (Aerospace Materials); engineering systems (vacuum-induction-melting furnaces sold to alloy-makers globally).
AMG is structurally unusual in three respects: (a) its vanadium business is dominated by spent-catalyst recycling, not primary mining — the upstream supply is a waste stream from refineries and petrochemicals, which insulates the economics from primary-V price cycles and converts oil-refining decarbonisation pressure into a structural feedstock- availability question; (b) the Bitterfeld LiOH refinery is the only EU-located lithium hydroxide refinery currently operational (Albemarle Frankfurt is closed; Eramet-Tsingshan Argentina-Indonesia is downstream- located; British Lithium / Imerys is permitting; Vulcan Energy Insheim is demo-scale; Talga Luleå is graphite not lithium) — Bitterfeld sits inside the EU's most exposed CRMA "≥40% processing by 2030" gap with no peer-set comparable; (c) the Maaden-Saudi vanadium JV plugs AMG into the US-Saudi Strategic Framework on Critical Minerals Supply Chains (18 Nov 2025) architecture as one of the named industrial vehicles. Major shareholders (corrected 2026-08-22 — MarketScreener shareholder registry, checked against the previous claim's Norges Bank/Janus Henderson/ BlackRock/Schroders ~3% figures, which have drifted): Van Eck Associates Corporation ~4%, Heinz Schimmelbusch (Executive Chairman & co-founder) ~3.9%, Norges Bank Investment Management ~2.5%, BlackRock ~2.5%, Janus Henderson ~1.9%; Schroders no longer appears among current top holders. The prior "no anchor strategic / industrial shareholder" framing was itself inaccurate independent of the drift — Schimmelbusch's near-4% insider/founder stake is exactly that kind of anchor holder, alongside otherwise-diffuse institutional ownership (~35% held by the top ten institutional investors combined).
Annual Report disclosure: AMG Vanadium segment revenue ≈ $440M of $1.46bn group total, 30%+). The exposure is almost entirely spent-catalyst recycling, not primary mining — the Cambridge OH facility processes ~30% of global spent-petroleum-catalyst V output, and the Saudi Maaden JV is designed to capture the equivalent Saudi/Gulf refinery feedstock stream. Vanadium is on the 2025 USGS Critical Minerals List (2025-11-06 action) and on the EU CRMA strategic-raw-materials list. Two demand-side vectors: (a) traditional high-strength-low-alloy steel (~80% of global V demand, slow secular growth), (b) vanadium-redox-flow batteries (VRFB) for grid-scale energy storage — the structurally-asymmetric demand vector if China's 100GWh-class VRFB build-out (per the 14th Five-Year Plan grid-storage targets) holds.
vertical chain: Mibra spodumene concentrate (Brazil; concentrate volumes reported in AMG quarterlies) → Bitterfeld LiOH refinery (Germany; first cell-grade qualification batches 2024-25). The Bitterfeld project is designated as a CRMA Strategic Project under the 25 March 2025 first 47-project list (AMG in company_refs; DG GROW project list source url) — fast-track permitting cap, Article 16 priority financing access, Member State priority status. Mibra is an open-pit hard-rock spodumene operation in Minas Gerais — the same Brazilian lithium geological province as Sigma Lithium (SGML), Atlas Lithium (ATLX), and the Lithium Vale do Jequitinhonha cluster — and the Brazilian Mining Plan (PNM 2050; Portaria MME 891 consultation 9 Jan 2026) explicitly names AMG Brasil as a Brazilian lithium-producer subject to the new strategic-mineral governance pillar.
silicon-metal smelter (electric-arc-furnace; chemical-grade + photovoltaic- precursor + aluminium-alloy-grade output). Silicon is on the EU CRMA strategic-raw-materials list and on the 2025 USGS Critical Minerals List. Hauzenberg is one of three EU silicon-metal smelters operating in 2026 (the others being Ferroglobe Sabón ES + Wacker Chemie Burghausen DE), and AMG Hauzenberg is structurally a CRMA-processing-target reference asset within the EU "≥40% processing by 2030" benchmark.
byproduct. Tantalum is on the USGS 2025 critical-minerals list and the EU CRMA strategic list. Globally constrained supply (DRC, Rwanda, Brazil dominate); AMG Brasil is the largest Western non-conflict tantalum source.
antimony as a byproduct (antimony enters the V₂O₅ refinery feed via FCC catalyst metal-passivator additives). Quantities are modest in absolute terms but strategically positioned: China imposed an antimony export control in August 2024 and tightened the regime in 2025, and the US/EU/Japan have explicit antimony-supply-chain anxiety. AMG's antimony output is the only stand-alone Western-controlled secondary-stream Sb source of scale.
small in revenue terms but on the USGS 2025 critical-minerals list and CRMA strategic list. AMG is one of two Western producers of electrolytic chromium metal (the other being Delachaux France).
What is deliberately not in this list: graphite (the Graphit Kropfmühl GmbH legacy graphite-mining business in Sri Lanka was retained for a period post-2008 acquisition but is not a current AMG segment focus per the FY2024 Annual Report; flagging this absence honestly because some secondary-source databases still attribute graphite to AMG — the duplicate dossier merged into this file on 2026-08-14 was one such attribution, and it was not carried across); rare earths (no AMG REE position on record); cobalt (no AMG cobalt position on record).
| Date | Action (filed slug) | Issuer | Sev | Why it touches AMG |
|---|---|---|---|---|
| 2025-03-25 | eu-crma-strategic-projects-first-designation | EU | 4 | AMG in company_refs; the AMG Lithium Bitterfeld LiOH refinery is one of the 22 lithium projects on the first 47-EU-project list (per DG GROW project list source url). 27-month permitting cap + Article 16 priority financing + Member State priority queue apply. |
| 2024-05-23 | eu-crma-entry-into-force | EU | 4 | Frame regulation under which Bitterfeld qualifies (lithium-hydroxide is a CRMA strategic raw material); silicon-metal (Hauzenberg) qualifies as a CRMA strategic material; vanadium qualifies as a CRMA critical raw material. AMG operates inside ≥3 of the 17 CRMA strategic categories. |
| 2026-01-09 | brazil-portaria-mme-891-pnm-2050-consultation | BR | 3 | AMG Brasil named in body text as a Brazilian lithium producer (alongside Sigma Lithium, Atlas Lithium) within the PNM 2050 strategic-governance scope. Brazilian CFEM royalty regime + ANM permitting modernisation + processing-incentive fiscal architecture all bear on Mibra economics. |
| 2026-05-06 | brazil-pl-2780-pnmce-critical-minerals-policy | BR | 3 | AMG Brasil in company_refs; PL 2780 (Política Nacional de Minerais Críticos e Estratégicos) brings AMG Brasil's tantalum and lithium production inside the new CMCE (Conselho Nacional de Minerais Críticos e Estratégicos) foreign-acquisition clearance perimeter — near-term M&A pipeline harder to close cleanly. |
| 2025-11-06 | us-doi-usgs-critical-minerals-list-2025 | US | 3 | Vanadium, silicon, tantalum, antimony, chromium ALL on the revised 2025 USGS critical-minerals list (vanadium tagged explicitly in target_materials). AMG's US-located segments (Cambridge OH vanadium + chromium + antimony) become Section 232 / DPA Title III eligible offtake counterparties. |
| 2025-11-18 | us-saudi-strategic-framework-critical-minerals-supply-chains | US/SA | 3 | The US-Saudi Strategic Framework re-frames the bilateral critical-minerals architecture; AMG-Ma'aden Saudi vanadium recycling JV (SARCO) operates inside this envelope. The framework's joint-investment provisions create a new financing-architecture pathway for the Saudi-side build-out. |
| 2026-04-24 | eu-us-critical-minerals-strategic-partnership | EU/US | 3 | Bitterfeld LiOH output is FTA-partner-equivalent for US IRA §30D under the partnership's mineral-sourcing recognition pathway — converts Bitterfeld from a EU-internal commodity into a EU-US dual-bloc battery-supply asset. Expands offtake universe from EU OEMs only to EU + North-American §30D-claimant OEMs. |
| 2026-02-25 | zimbabwe-raw-mineral-lithium-concentrate-export-ban | ZW | 4 | Zimbabwe (Prospect / Premier African / Sabi Star) is a primary rival lithium-concentrate origin; export ban tightens Brazilian-spodumene relative supply and supports Mibra concentrate pricing. AMG Brasil is a structural beneficiary of African export restrictions on raw lithium. |
| 2025-08-21 | india-mmdr-amendment-act-2025 | IN | 3 | India Mines & Minerals (Development & Regulation) Amendment Act 2025 explicitly lists lithium, vanadium, tantalum among strategic minerals subject to the new exclusive-Centre-auction regime. AMG-equivalent processors are India's offtake counterparties for the auction-winners' upstream output. |
| 2026-01-14 | us-section-232-critical-minerals-proclamation | US | 4 | The Section 232 critical-minerals proclamation establishes the US national-security perimeter for critical-mineral imports; AMG's US-located Cambridge OH stream (vanadium / chromium / antimony) is on the domestic-production side, structurally credit-eligible under DPA / IRA / Section 232 import-substitution facilities. |
| 2026-02-02 | us-exim-project-vault-strategic-critical-minerals-reserve | US | 3 | EXIM Project Vault sets up a strategic-critical-minerals reserve financing vehicle; AMG's Cambridge OH vanadium / antimony recycling stream is structurally credit-eligible as a domestic critical-minerals processing facility under the Project Vault financing perimeter. |
Jan 2026; >160 applications per Commission press release IP/26/* sequence): announcement window late H1 2026. Watchlist for AMG: is AMG Vanadium Cambridge OH (or its potential EU mirror) designated as a third-country Strategic Project under the 4 June 2025 third-country- pathway architecture? Is Hauzenberg silicon-metal designated as a second-round Strategic Project under the substitution / processing category? Either designation triggers the Article-7 permitting compression + Article-16 priority financing access for the named asset.
product-passports for permanent magnets and supply-risk notification duties on large CRM-using companies. AMG is a CRM-using company on the silicon-metal demand side (precursor purchases from primary silicon smelters); the notification regime could become a downstream-cost amplifier if not carefully implemented.
The 14 Jan 2026 Section 232 critical-minerals proclamation establishes the framework; specific commodity-level proceedings remain at agency rule-making stage in 2026. AMG is structurally protected if vanadium / silicon-metal tariffs are imposed (Cambridge OH + future-Saudi-JV output benefits relative to imported primary V from China / Russia / South Africa).
9 Jan 2026 ninth mining-licensing round and the 9 Dec 2025 LCGPA mandatory-list (mineral-processing categories) reinforce Saudi domestic-content preference; AMG-Ma'aden SARCO JV is the structural beneficiary on the recycling-V side, but if domestic-content procurement rules require Saudi-domiciled value-add, the JV's capex tranche timing matters.
/ FY2024 Investor Day disclosures, AFM filings) a potential carve-out of the AMG Lithium segment into a separately-listed entity once Bitterfeld reaches commercial production cadence. Timing has slipped multiple times; the CRMA Strategic-Project designation (Mar 2025) and the EU-US Critical Minerals Strategic Partnership (Apr 2026) materially improve the carve-out's standalone-listing valuation envelope.
The management decision tree AMG faces over 2026-2027 (highest leverage first):
1. Bitterfeld LiOH offtake mix. Bitterfeld's 20kt/yr Phase-1 LiOH output is the highest-margin lithium chemical AMG sells. The structural question is whether AMG signs EU OEM offtake at below-spot fixed prices (cost-plus economics, security-of-supply premium — captures CRMA legitimacy and unlocks Commission / EIB grant tranches) or holds capacity for spot exposure (commodity- cycle economics, maximises upside if lithium prices recover from the 2024-25 trough). The first preserves Article-16 priority- financing access; the second maximises post-2026 cash-flow realisation if the lithium-deficit thesis holds. The EU-US Critical Minerals Strategic Partnership (24 Apr 2026) materially expanded the offtake counterparty universe to include US §30D-claimant OEMs. 2. AMG Lithium carve-out timing. Separating the lithium segment (Mibra + Bitterfeld + future LIVA-2 expansion) into a standalone AMG-Bitterfeld N.V. or AMG Lithium AG listing would unlock pure- play valuation upside (Bitterfeld is the only operational EU LiOH refinery; the comp-set is private / pre-revenue and trades on strategic-asset premium). Trade-off: AMG corporate loses the cross-segment cost-of-capital advantage; the residual AMG-Vanadium + AMG-Technologies entity faces a "stub" multiple compression. The right execution window is post-Bitterfeld commercial-production qualification (2026-Q4 / 2027-H1). 3. Saudi SARCO JV capex tranche timing. The Ma'aden JV's commercial-production cadence depends on Saudi domestic spent- catalyst feedstock availability + Saudi labour cost + Aramco / SABIC offtake contracts. AMG's tactical question: accelerate capex into 2026 (capture the US-Saudi Strategic Framework architecture window and the Ma'aden state-balance-sheet co- investment) vs. phase capex to match feedstock-development cadence (lower execution risk, slower market-share capture). The first option assumes US-Saudi alignment holds through the Strategic Framework's implementation phase (2026-2027). 4. AMG Vanadium VRFB-demand positioning. Vanadium-redox-flow batteries are the structurally-asymmetric demand vector but China dominates VRFB stack manufacturing. AMG could (a) sign long-dated V₂O₅ leasing contracts with VRFB operators (the AMG-equivalent of "electrolyte leasing" — converts capex sale into operating-lease royalty), or (b) maintain merchant V₂O₅ trading at spot. The first captures VRFB-share economics; the second maintains optionality but caps upside.
EU and national state-aid facilities AMG qualifies for: CRMA Article 16 (Bitterfeld designation triggers priority access to EIB / EBRD / EIF / national-promotional-bank coordinated lending against the EUR 22.5bn first-round Strategic-Project envelope); German Federal Ministry of Economic Affairs decarbonisation / hydrogen / battery funding lines (Bitterfeld + Hauzenberg are both Bavarian / Saxony- Anhalt industrial-priority locations); EU Innovation Fund (under the CRMA's STEP coordination); US Section 232 / DPA Title III (Cambridge OH vanadium / chromium / antimony are structurally import-substitution-eligible under the 14 Jan 2026 Section 232 proclamation); EXIM Project Vault (2 Feb 2026 reserve-financing vehicle covers domestic critical-minerals processing capacity).
(Dossier README quality bar requires ≥3 surfaces a senior sector analyst would have missed. Four are listed below.)
Surface 1 — AMG sits inside three different state-aid architectures simultaneously (EU CRMA, US Section 232 / EXIM Project Vault, Saudi Ma'aden / LCGPA), and the structural cross-subsidisation of capex risk via that triple-alignment is sell-side-invisible. Bitterfeld is on the EU CRMA Article-7 fast-track-permit + Article-16 priority- financing list. Cambridge OH (vanadium / chromium / antimony) is domestically-credit-eligible under DPA / Section 232 / EXIM Project Vault. The Saudi SARCO JV plugs into the LCGPA domestic-content preference and the US-Saudi Strategic Framework joint-investment pathway. No comp-set processor sits in all three simultaneously — Albemarle (US, no EU asset), Ganfeng / Tianqi (CN, no EU/US/SA asset), Pilbara (AU, no processing footprint), Sociedad Química y Minera (CL, no EU/US/SA processing). The structural read is that AMG's effective cost-of-capital across the three locations is substantially lower than its standalone balance-sheet cost-of-capital would imply.
Surface 2 — Vanadium is structurally a spent-catalyst-recycling business at AMG, which converts oil-refining decarbonisation pressure into a feedstock-availability question rather than a demand question. The Cambridge OH facility processes ~30% of global spent-petroleum- catalyst V output (AMG investor-day disclosure 2024). Spent FCC catalyst is generated as a refining waste stream — its volume is proportional to global refinery throughput. If oil refining declines faster than primary V mining declines, spent-catalyst feedstock becomes scarce relative to primary V — and AMG's recycling business faces feedstock compression, not demand compression. This is the opposite of the typical investor framing ("vanadium is a battery story"). The Saudi SARCO JV's strategic rationale is precisely to front-run this feedstock compression by capturing Aramco/SABIC refinery-waste streams under long-dated take-or-pay before refinery decarbonisation reduces the feedstock pool.
Surface 3 — Bitterfeld is the only operational merchant-market EU LiOH refinery, but the structural risk is offtake-customer concentration (EU automotive OEMs only have 4-5 battery-grade-LiOH-qualified cell makers; AMG's offtake list is structurally short). The post-CRMA investor narrative treats Bitterfeld as "the EU LiOH refinery" — a strategic-asset-premium story. The operating-economics read is different: Bitterfeld must qualify each LiOH batch through cell-maker qualification protocols (ACC, Verkor, Stellantis-Auto-Battery, CATL- DE, Northvolt-successor, LG Energy Solution Poland) and the qualification cycle is 12-24 months per cell-maker. If 2-3 of the EU cell-makers fail commercially (Northvolt insolvency 2024-25 is the template), Bitterfeld's effective addressable offtake base contracts by 40-60%. The CRMA designation does not protect against demand- side cell-maker mortality — and the EU automotive OEM cell-maker ecosystem has more execution risk than is currently priced into the strategic-asset narrative.
Surface 4 — AMG Brasil's tantalum byproduct from Mibra is the single largest non-conflict Western tantalum source, and the Brazil PNM 2050 / PL 2780 strategic-mineral architecture re-positions it as a sovereign-strategic asset rather than a commodity byproduct. Tantalum is on the USGS 2025 critical-minerals list and the EU CRMA strategic list; global supply is DRC / Rwanda / Brazil dominated, with DRC + Rwanda subject to 3TG conflict-minerals scrutiny under Dodd- Frank Section 1502 and the EU Conflict Minerals Regulation. Mibra's tantalum output is structurally conflict-free, and under the Brazil PL 2780 (Política Nacional de Minerais Críticos e Estratégicos) governance architecture, Brazilian tantalum exports become subject to the new CMCE strategic-mineral oversight — which simultaneously raises domestic licensing friction and enhances the geopolitical-premium pricing for the conflict-free supply chain. Sell-side models that mark Mibra's tantalum output at spot prices miss the post-PL-2780 strategic-mineral premium that downstream electronics OEMs (Apple, Samsung, Cisco) are structurally willing to pay for conflict-free Brazilian Ta over DRC / Rwanda Ta. AMG Brasil is the single largest beneficiary of this re-pricing dynamic.
Refresh trigger: any new CRMA Strategic-Project designation cycle (EU second-round announcement expected H1 2026); any AMG Lithium carve- out announcement; any Saudi SARCO JV material milestone (capex tranche, commercial-production gate); any Section 232 commodity-level proceeding affecting vanadium / silicon / tantalum.
filing, 12 March 2025 — date corrected 2026-08-22, see https://amg-nv.com/investors/press-release/amg-critical-materials-n-v-publishes-2024-annual-report/). Primary source for segment revenue composition, Cambridge OH / Hauzenberg / Bitterfeld / Mibra asset descriptions, and Saudi Ma'aden JV status. https://amg-nv.com/investors/
(checked 2026-08-22; secondary aggregator, no AMG-primary shareholder disclosure page found on amg-nv.com at check time). Basis for the major-shareholders line above; returned HTTP 403 on 2026-09-23 recheck, so those percentages are last-confirmed 2026-08-22, not re-verified this pass. Schimmelbusch's insider stake corroborated directionally (not by exact percentage) by Yahoo Finance coverage of his on-market share purchases, checked 2026-09-23: https://finance.yahoo.com/news/chairman-management-board-ceo-amg-064721830.html
confirms legal name, jurisdiction NL, ISIN NL0000888691; no parent relationship reported on file (checked 2026-08-22).
(Mar 2024); Ma'aden JV initial announcement (Mar 2022) and update cadence (FY2023 / FY2024 Investor Days). https://www.amg-nv.com/news
primary). https://single-market-economy.ec.europa.eu/sectors/raw-materials/areas-specific-interest/critical-raw-materials/strategic-projects-under-crma/selected-projects_en — referenced by action 2025-03-25-eu-crma-strategic-projects-first-designation (AMG in company_refs).
antimony, chromium commodity profiles. https://pubs.usgs.gov/periodicals/mcs2025/mcs2025.pdf
docs/iptm/actions/ for primary-source citations and verification artefacts.
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.
Non-binding MoU for supply/offtake of battery-grade lithium hydroxide monohydrate from AMG Lithium's Bitterfeld-Wolfen, Germany plant to Easpring, a Chinese cathode-active-material producer building a CAM plant in Kotka, Finland. Companies were still negotiating a binding offtake agreement as of the announcement -- downgraded to secondary confidence because nothing binding is signed yet. Checked 2026-09-09 against AMG's own press release.
AMG: 'All tantalum pre-concentrate will be processed at Mibra Mine and subsequently sold to TANIOBIS.' Origin is the Mibra mine, Minas Gerais, Brazil. TANIOBIS processes at Goslar (DE) and Map Ta Phut (TH); the release does not say which plant receives Mibra concentrate, so destination is left open.
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 2 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Silicon | 🇨🇳 CN 80% refining | 77 | 64 | High | EXCEEDS 80% | Med | limited | 19 | ▲ rising |
| Lithium | 🇨🇳 CN 65% refining | 72 | 61 | High | within 65% | Med | some | 40 | ▲ rising |
| Vanadium | 🇨🇳 CN 79% refining | 70 | 64 | High | — | High | limited | 3 | ▲ rising |
| Antimony | 🇨🇳 CN 78% refining | 67 | 60 | Elevated | — | Low | limited | 9 | ▲ rising |
| Tantalum | 🇨🇳 CN 50% refining | 49 | 44 | Moderate | — | Low | some | 12 | ▲ rising |
| Chromium | 🇨🇳 CN 46% refining | 46 | 42 | Moderate | — | Low | hard | 13 | ▲ 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 |
|---|---|---|---|---|---|---|
| Silicon | 4 | 4 | 1 | 4 | 4 | company input |
| Lithium | 4 | 3 | 5 | 3 | 3 | company input |
| Vanadium | 4 | 4 | 5 | 4 | 2 | company input |
| Antimony | 4 | 3 | 1 | 3 | 4 | company input |
| Tantalum | 4 | 2 | – | 3 | 3 | company input |
| Chromium | 4 | 2 | – | 4 | – | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
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 50% of global refining output (by tonnage); US filers' own disclosures independently name China for 43% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| F&X Electro-Materials Ltd.CID460 | China | 14 | SEC |
| Hengyang King Xing Lifeng New Materials Co., Ltd.CID2492 | China | 14 | SEC |
| JiuJiang JinXin Nonferrous Metals Co., Ltd.CID914 | China | 14 | SEC |
| Ningxia Orient Tantalum Industry Co., Ltd.CID1277 | China | 14 | SEC |
| Ulba Metallurgical Plant JSCCID1969 | Kazakhstan | 14 | 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.
+ 64 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Silicon exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime | 77 | 82 | +5 |
| Concentration | Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly) | 77 | 89 | +12 |
| 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 |
| Policy | Vanadium — 🇨🇳 CN escalates vanadium controls to a full export-licensing / ban regime | 70 | 78 | +8 |
| Concentration | Vanadium — 🇨🇳 CN becomes the single source for vanadium — the second source is lost (full 79%+ monopoly) | 70 | 83 | +13 |
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 AMG Critical Materials N.V. 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 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, 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 AMG Critical Materials N.V. 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 6 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | critical-minerals-processing (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 2026-09-22; 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
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