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5 critical materials scored · binding chokepoint: Tungsten (🇨🇳 CN 90% of refining) · 89 restrictive government measures on record
Semiconductor-equipment export controls are the binding exposure — the product itself is the controlled good; material chokepoints (top: Tungsten, 🇨🇳 CN 90% of refining, buyer 88/100) are second-order. The register holds 89 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Tungsten ASML Holding NV is the 141st-most-exposed of the 465 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.
ASML Holding NV ranks 23rd of 61 verified semiconductor equipment companies, tied with 6 others at 81.
Company supply-risk index 81/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 5 scored materials. Buyer-relative (first-order): weighted by where the company produces (NL 72% · US 18% · DE 7% · TW 3%, 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.
Sole commercial supplier of EUV lithography and dominant supplier of high-end DUV immersion — every leading-edge logic, DRAM and advanced- NAND node depends on ASML's tools. The binding policy exposure is not a material chokepoint but the chip-controls regime itself: the BIS Affiliates Rule (suspended Nov 2025, expires by default Nov 2026), the Dutch national export-control list, and the EU Delegated Regulation cascade off Wassenaar 2025 jointly determine which fabs can buy which systems.
Binding thesis. Dual-use regulated output: the lithography system itself is the controlled good under the trilateral US/NL/JP chip-equipment perimeter. Material exposures (tungsten reticle masks, Nd magnets, helium) are second-order; the binding policy regime is end-use / national-security export control, not a critical-mineral chokepoint.
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.
ASML/TSMC joint press release (2026-09-08): TSMC intends to use ASML's High-NA EUV technology in high-volume manufacturing for advanced nodes starting in 2030, and the two companies announced a joint initiative to transition to 12-inch photomasks for High-NA EUV (pilot line targeted 2031, advanced-node production 2033). TSMC and Samsung were reported in contemporaneous press coverage as the second and third High-NA EUV adopters after Intel, but this press release itself names only TSMC -- Samsung's commitment is not independently confirmed to this primary source, so no Samsung row was added.
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.
3 of 3 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 |
|---|---|---|---|---|---|---|---|---|---|
| Tungsten | 🇨🇳 CN 90% refining | 88 | 76 | Critical | EXCEEDS 90% |
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 |
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 |
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.
An analyst traced these register actions to a specific, named effect on this company — date and severity below are read live from the register, not hand-typed.
The October-2022 BIS rule is the root cause of every Western lithography control that followed. FDPR coverage forced ASML to stop shipping EUV to China outright and made every EUV pellicle / parts / service shipment to a China-located fab a US-license item via US-origin sub-components. This action is the policy "anchor" of the entire chip-tools regime.
Japan's trilateral implementation; captures ArF / KrF tools that overlap parts of ASML's DUV portfolio and constrains the Japanese second-source route (Nikon, Canon) for Chinese fabs. Net read for ASML: closes a substitution path that would otherwise have eroded ASML's installed-base monopoly at older nodes.
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:
Counterfactual: the 50%-ownership automatic extension of Entity List designations runs to its full perimeter (one-year suspension at 2025-11-10 lifted on schedule). Direct-hit lines are basket issuers in semiconductor / chip-equipment / AI-compute sectors — the perimeter where the rule's 50% controller-affiliate test compounds with existing Entity List names.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 88 → 91 (+3) — a relative official policy-pressure magnitude, not a price drawdown.
No material crosses the significant-vulnerability threshold. 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 materials this company buys. 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. Market-implied percentages are live external prediction-market prices (alternative/OSINT signal) — an independent read, not our model output and not merged into the official register or the stage-derived band; the gap between the market price and our stage assessment is itself the signal.
Named, datable events on the binding chokepoint and adjacent regimes — each linked to its primary government / multilateral source.
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Tungsten).
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) |
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 | Yes — 5 scored SRMs on the input side (binding: Tungsten) |
| Manufactures a listed strategic technology | semiconductor-equipment (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-30; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-05
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.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 2 further semiconductor equipment 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.
| — |
| some |
| 16 |
| ▲ rising |
| Neodymium | 🇨🇳 CN 85% refining | 86 | 72 | Critical | EXCEEDS 85% | — | some | 50 | ▲ rising |
| Silicon | 🇨🇳 CN 80% refining | 77 | 64 | High | EXCEEDS 80% | — | limited | 19 | ▲ rising |
| Tin | 🇨🇳 CN 55% refining | 66 | 56 | Elevated | — | — | ready | 18 | ▲ rising |
| Helium | 🇺🇸 US 43% mining | 36 | 46 | Low | — | — | none | 2 | ▬ stable |
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 ↗
| 3 |
| company input |
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Silicon | 4 | 4 | 1 | 4 | 4 | company input |
| Tin | 4 | 2 | 5 | 2 | 3 | company input |
| Helium | 3 | 2 | 3 | 5 | 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.
| 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.
+ 74 more in the register.
First Dutch national rule naming ASML hardware (NXT:2000i and above) — formal codification of the trilateral. Material: license for shipments to "countries of concern" is presumption-of-denial. The 2024-09 expansion (next row) is the consequence-completion event.
Demand-side counterpart: the IPF / OEF fast-track permitting regime is what underpins ESMC Dresden (TSMC-Bosch-Infineon-NXP), Intel Magdeburg, Wolfspeed-ZF Ensdorf and the GlobalFoundries / STMicro Crolles 300mm extension — every one of which carries ASML's bookings. The Chips Act flips a chunk of ASML's revenue from China-export-controls-exposed to EU-state-aid-underwritten.
Closed loopholes in the October-2022 rule, expanded TPP/IPR-based control thresholds, narrowed the "datacenter chip" carve-out used by NVIDIA H800/A800. Read-across to ASML: tightened FDPR coverage of EUV pellicles and EUV mask blanks shipped to China by *any* route, including non-US originated.
Often dismissed as "technical": this is actually the more strategically consequential of the two Dutch DUV actions. Until Sept 2024 the older 1970i/1980i variants could still legally ship to China under FDPR carve-outs — that was the substitution window Chinese fabs were exploiting via mature-node DUV. The 2024 expansion transferred control authority from BIS to The Hague and *closed* the substitution window. The market priced this as procedural; the read is structural.
Adds 24 SME items to the CCL covering deposition, etch, advanced packaging and metrology — not lithography directly, but increases the cost-of-compliance for the *entire* litho-deposition-etch-metrology cluster sale, where ASML is the largest-ticket counterparty. The 140+ Entity List additions also include major SMIC affiliates and Chinese tool makers, narrowing ASML's customer set for advanced-node systems.
Sell-side coverage framed this as a "no further sales" event for those fabs. The under-read consequence: *every* installed-base service, parts, software-upgrade and field-engineer shipment to Dalian, SCS (Xi'an) and Wuxi now requires an individual export licence, case-by-case. That hits ASML's most profitable revenue line — Installed Base Management — on three of the largest non-Chinese-owned advanced-node fabs operating in China.
First EU-wide update of Annex I since 2021 to add lithography systems, **EUV pellicles, masks and reticles**, ALD, epitaxial deposition, SEM and etch under EU dual-use control. For ASML this means EU-level controls now layer *on top of* the Dutch national list — Veldhoven's EUV pellicle franchise becomes EU-dual-use-controlled in addition to NL-controlled, and the pellicle business gains the same KYC overhead as the systems. Multi-layer compliance complexity, not headline severity.
The rule extends Entity List restrictions to any unlisted entity ≥50% owned by listed parties. Effect on ASML: the in-house KYC perimeter for spares / services / parts shipments expands materially — every Chinese downstream subsidiary of every Entity-Listed parent has to be re-screened. **Note**: BIS suspended the rule for one year on 2025-11-10 (post-Busan understanding). It re-arms in Nov-2026 by default — that is a calendar event ASML's compliance and customer-services functions have to plan for.
First PRC export-control instrument to name a country other than the US. Direct read for ASML is indirect (Japan-only target) but the *vehicle* is the strategic point: country-specific dual-use catch-all controls on rare earths, tungsten, neodymium, samarium and carbon fibre. If Beijing escalates the same vehicle to the Netherlands — a non-trivial scenario after any further Dutch tightening — ASML's permanent-magnet (Nd/Dy/Tb) and tungsten supply lines fall under the same instrument. Watch closely as a leading indicator of NL-targeted retaliation.
First material rollback of the 2022–24 export-control architecture. Pivots the H200/MI325X-and-below tier from presumption-of-denial to case-by-case. Knock-on for ASML: improves the longer-term demand signal at TSMC and Samsung — fewer "frozen" Chinese hyperscaler customers means more sustainable utilisation upstream of ASML's advanced-node toolset. Modestly positive for the 2026–27 advanced-node booking cadence.
🇨🇳 CN has issued 4 restrictive actions on Tungsten since 2025 — cadence accelerating (mean gap 264d → 103d), severity flat (4.0 → 4.0).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 3 of these 31 materials (Silicon, Neodymium, Tungsten) — your binding Tungsten exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 3.7 months apart across 8 distinct restriction dates since 2021 (n=7 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| 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 | Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime | 86 | 88 | +2 |
| Concentration | Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly) | 86 | 92 | +6 |
| 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 |
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.
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 ↗
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
| Analyse the factors that might affect supply. |
| Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | 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.
Sourced OSINT observations, not a forecast — a qualitative second read beside the stage-derived band. We do not publish a passage probability of our own until the accrual record proves it is calibrated (never a fabricated %).