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3 critical materials scored · binding chokepoint: Gallium (🇨🇳 CN 98% of refining) · 13 restrictive government measures on record
AXT Inc. produces 3 of the 3 scored materials above (Gallium, Indium, Germanium). 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 Moderate · 47/100 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 Gallium — 🇨🇳 CN controls 98% of global refining. On this company's production footprint that scores 49/100 (footprint-hedged; global 74). The register holds 13 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Gallium AXT Inc. is the 109th-most-exposed of the 117 named companies we track on 🇨🇳 CN's Gallium chokepoint; the most-exposed is Appia Rare Earths & Uranium Corp. (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
AXT Inc. ranks 3rd of 3 verified semiconductors 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 47/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 3 scored materials. Buyer-relative (first-order): weighted by where the company produces (CN 72% · US 20% · JP 5% · DE 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.
AXT Inc. (NASDAQ: AXTI) is a US compound semiconductor substrate manufacturer whose entire value proposition rests on three materials — gallium arsenide (GaAs), indium phosphide (InP), and germanium (Ge) — all of which are now subject to Chinese MOFCOM export controls (Ga/Ge: August 2023; In: partial; gallium further tightened April 2025 to zero-quota enforcement). AXT's primary manufacturing is at Beijing Tongmei Xtal Technology (Beijing subsidiary), placing its production inside the Chinese jurisdiction that controls its raw-material inputs. This creates a structural double-bind: the company cannot easily source Ga/Ge/In outside China while manufacturing inside China, nor relocate manufacturing without abandoning the Chinese input-supply chain. The company disclosed in its 10-K that it cannot guarantee supply if export controls are tightened — language that has proven prescient as zero-quota enforcement began in 2025.
Binding thesis. AXT is the cleanest single-company expression of the China Ga/Ge/In export-control thesis on a Western exchange. All three of its primary substrates (GaAs, InP, Ge) depend on materials whose export from China requires MOFCOM licenses issued with zero quota since April 2025. The company's Beijing subsidiary (Tongmei) is simultaneously the manufacturing anchor and the entity most directly exposed to supply disruption — it buys Chinese raw Ga/Ge/In, processes it into substrates, and must obtain export licenses to sell finished wafers outside China. Any escalation of the Ga/Ge regime (quota tightening, entity-list action, subsidiary-level restriction) hits AXT at two simultaneous nodes: raw material input and finished-good export.
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 |
|---|---|---|---|---|---|---|---|---|---|
| Gallium | 🇨🇳 CN 98% refining | 49 | 74 | Moderate | EXCEEDS 98% |
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 |
|---|---|---|---|---|---|---|
| Gallium | 5 | 5 | 3 | 3 |
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.
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.
The binding exposure this precedent lands on — Gallium — is a material AXT Inc. 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.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one AXT Inc. 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 3 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. 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.
Every scored material here is one AXT Inc. 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) |
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 3 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | semiconductors (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 2026-06-29; 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.
| High |
| ready |
| 9 |
| ▲ rising |
| Indium | 🇨🇳 CN 69% refining | 46 | 64 | Moderate | — | Med | limited | 2 | ▲ rising |
| Germanium | 🇨🇳 CN 60% refining | 35 | 54 | Low | within 60% | High | some | 11 | ▲ 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 ↗
| 3 |
| company input |
| Indium | 4 | 3 | 5 | 3 | 4 | company input |
| Germanium | 4 | 3 | 1 | 3 | 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.
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 7 restrictive actions on Gallium since 2023 — cadence accelerating (mean gap 248d → 116d), severity flat (4.3 → 3.0).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 3 of these 13 materials (Gallium, Indium, Germanium) — your binding Gallium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 5.3 months apart across 6 distinct restriction dates since 2023 (n=5 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 | Gallium — 🇨🇳 CN escalates gallium controls to a full export-licensing / ban regime | 49 | 50 | +1 |
| Concentration | Gallium — 🇨🇳 CN becomes the single source for gallium — the second source is lost (full 98%+ monopoly) | 49 | 49 | 0 |
| Policy | Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime | 46 | 52 | +6 |
| Concentration | Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly) | 46 | 57 | +11 |
| Policy | Germanium — 🇨🇳 CN escalates germanium controls to a full export-licensing / ban regime | 35 | 37 | +2 |
| Concentration | Germanium — 🇨🇳 CN becomes the single source for germanium — the second source is lost (full 60%+ monopoly) | 35 | 48 | +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.
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 %).