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2 critical materials scored · binding chokepoint: Neodymium (🇨🇳 CN 85% of refining) · 60 restrictive government measures on record
The binding exposure is Neodymium — 🇨🇳 CN controls 85% of global refining. On this company's production footprint that scores 86/100 (adversarial chokepoint; global 72). The register holds 60 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Neodymium BAE Systems plc is the 128th-most-exposed of the 529 named companies we track on 🇨🇳 CN's Neodymium chokepoint; the most-exposed is Alta Resource Technologies (86/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
BAE Systems plc ranks 2nd of 4 verified defence industrial base 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 83/100 — 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 (GB 52% · US 28% · SE 11% · AU 5% · CA 4%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Also listed in the dossier but not platform-scored: Armour-steel, Submarine-grade-steel — no supply-risk series is tracked for these here.
BAE Systems is the largest UK-domiciled defence prime and the only publicly-listed prime with simultaneous prime-contractor status on both AUKUS pillars — Pillar 1 (SSN-AUKUS submarine construction prime in the UK at Barrow-in-Furness and in Australia at Osborne via ASC partnership) and Pillar 2 (advanced-capability cooperation under the EAR/ITAR license-free trilateral regime that BIS finalised in April 2024). Operations span five structurally distinct verticals: (i) Air (Eurofighter Typhoon consortium 33% workshare and final assembly Warton; F-35 rear-fuselage and tail assembly Samlesbury — sole non-US source; GCAP / Tempest as UK lead under the UK-Italy-Japan Global Combat Air Programme via the GIGO HQ at Reading from Dec-2024); (ii) Maritime (Astute-class SSN, Dreadnought-class SSBN, SSN-AUKUS, Type 26 Global Combat Ship and Type 31 — Glasgow + Barrow); (iii) Land UK (M777 howitzer; the RBSL Challenger 3 / Boxer joint venture with Rheinmetall — 45% BAE / 55% RHM); (iv) Electronic Systems (BAE Systems Inc. — the US subsidiary domiciled in Falls Church VA under the Special Security Agreement governance — Bofors Defense Systems Inc., M109 Paladin self-propelled howitzer, AMPV, Bradley upgrades, BvS10 articulated all-terrain vehicle, electronic warfare suites for F-35, FAS-9 fire-control); and (v) Cyber & Intelligence (BAE Systems Digital Intelligence — formerly Detica — defensive cyber + signals + intelligence). Hägglunds (Sweden — CV90/BvS10) and Bofors AB (Sweden — Archer 155mm SPH, ammunition + propellants) sit inside the EU jurisdictional perimeter despite BAE's UK headquartering. The customer base is dominated by UK MOD, US DoD, Australian DoD, Saudi Arabia (Eurofighter Tranche 4 pending UK export-licensing under the post-Yemen Camm-review constraints), Sweden, Norway, Italy, Japan, Spain and the German Eurofighter consortium partners.
BAE's profitability is unusually sensitive to four material and trade-policy axes that the IPTM register tracks directly, and one trans-jurisdictional structural feature (the BAE Systems Inc. SSA governance) that no other defence prime in the corpus carries.
Sweden) and Glascoed (UK, Munitions Centre of Excellence).** BAE is one of the two scaled Western 155 mm primes (with Rheinmetall); Karlskoga propellants + Glascoed body-forging together place BAE in the head of the NATO 2M-shell collective capacity-target curve.
Dreadnought / SSN-AUKUS Barrow construction is exposed to Sheffield Forgemasters (UK-MOD-acquired 2021) capacity and to AUKUS-track titanium / specialty-alloy supply from Allegheny Technologies (US) and Kobe Steel (JP).
draw on EU steel-safeguard-protected European armour-plate; symmetric exposure to Sheffield Forgemasters and thyssenkrupp Steel as the qualified suppliers.
rear-fuselage/tail-assembly sub-tier electronics, Eurofighter Tranche 4 + GCAP sensors + Type 26 phased-array radar are exposed to the PRC rare-earth extraterritorial export-control regime via the Oct-2025 MOFCOM 14-entity announcement (BAE Systems Inc. is named — see Surface 2 below) and to the broader US-PRC semiconductor perimeter.
| Date | Issuer | Action | Severity | Why it touches BAE |
|---|---|---|---|---|
| 2024-03-05 | EU | European Defence Industrial Strategy (EDIS) JOIN(2024) 10 | 4 | First EU defence industrial strategy; ≥40% cooperative procurement / ≥35% intra-EU / ≥50% European-origin benchmarks for 2030. BAE inside the EU perimeter via Hägglunds + Bofors AB (Sweden) and the Eurofighter consortium share. |
| 2024-04-19 | US | US BIS AUKUS EAR export-control revisions | 3 | Removes NS1/RS1/MT1 license requirements between US/UK/AU. BAE is the only prime with manufacturing and prime-contractor footprint simultaneously in all three jurisdictions; structural Pillar-2 arbitrage beneficiary (see Surface 1). |
| 2025-05-08 | US | US-UK Economic Prosperity Deal (EO 14309) | 3 | Reciprocal trade framework underpinning AUKUS / GCAP supply-chain integration; US-side Section-232 carve-outs for UK steel/aluminium materially relevant to BAE Maritime hull procurement. |
| 2025-05-27 | EU | EU Security Action for Europe (SAFE) — Reg. 2025/1106 | 5 | EUR 150bn defence-procurement loan facility with 65% EU/EEA/Ukraine local-content rule. UK parent excluded; BAE captures share via Hägglunds (SE) + Bofors AB (SE) + Eurofighter (DE/ES/IT) intra-EU vertices (see Surface 4). |
| 2025-06-23 | GB | UK Modern Industrial Strategy IS-8 Defence sector plan | 4 | Defence elevated to IS-8 anchor sector; preferential industrial-strategy treatment for UK-headquartered defence primes; BAE is the canonical IS-8 named beneficiary alongside Rolls-Royce and Babcock. |
| 2025-07-25 | PL | Poland Special Act on Strategic Defence Investments (Dz.U. 2025 poz. 1080) | 4 | 90-day combined administrative decision; €43.7bn PL SAFE allocation. Relevant to any BAE-Hägglunds CV90 traction in Poland's next IFV tranche; secondary to RHM Lynx penetration but structurally available. |
| 2025-09-08 | GB | UK Defence Industrial Strategy 2025 (CP 1388) | 4 | 2.6%-of-GDP defence-spending floor by 2027 (ambition 3% next Parliament); UKDI £400m budget; combat-air + complex-weapons + submarines named priority capabilities — every one of which is a BAE prime line. The single largest sector-policy lever in the register for the UK parent. |
| 2025-09-15 | DK | Denmark Lov nr. 1097/2025 — Defence Construction Fast-Track Act | 3 | Statutory derogation from building/environmental permits; DKK 50bn Defence Acceleration Fund. BAE Hägglunds CV90-DK fleet + BvS10 BvS-12 logistic-vehicle Danish-buy positioned. |
| 2025-09-18 | DE | Germany SVIKG — EUR 500bn Sondervermögen Infrastruktur und Klimaneutralität | 5 | KTF Mikroelektronik EUR 5bn/yr line co-finances semis used in defence electronics; Eurofighter German workshare flows-through via the consortium. |
| 2025-10-09 | CN | [MOFCOM UEL Announcement [2025] No. 10 — 14 foreign entities](/actions/2025-10-09-china-mofcom-uel-announcement-10-2025-14-foreign-entities) | 3 | Names BAE Systems Inc. (US subsidiary) — BAE Systems plc (UK parent) explicitly NOT listed. First UEL designation of any Western prime via the US-sub firewall (see Surface 2). |
| 2025-10-18 | LT | Lithuania Defence and Security Industry Law amendments | 3 | Construction-permit waiver collapses defence-facility permitting from 2.5 yr to notification-of-commencement; relevant to any prospective BAE Hägglunds CV90-LT industrial footprint. |
| 2025-11-22 | GB | UK Critical Minerals Strategy — Vision 2035 | 3 | Government-backstop financing for rare-earth + tungsten + tantalum + germanium supply diversification; directly upstream of BAE's GCAP/Tempest + Type 26 radar sensor chains. |
| 2025-12-08 | GB | UK MoD Atlantic Bastion Undersea Warfare Programme | 3 | BAE Systems Maritime named anchor of the 26-firm UK undersea-defence supply base; revenue-visibility uplift for the Astute → Dreadnought → SSN-AUKUS continuous-build pipeline. |
| 2025-12-08 | EU | EU European Defence Industry Programme (EDIP) — Regulation 2025/2643 | 5 | First horizontal EU defence-industrial regulation; 35% non-EU/EEA component cap. UK parent statutorily capped above the ceiling on EDIP grants; intra-EU sub footprint (Hägglunds + Bofors AB + Eurofighter consortium) captures grant-eligible value. |
| 2025-12-30 | EE | Estonia Ermistu RKIK Defence Industrial Park | 3 | State-financed ammunition/missile/explosives cluster — competitive-tender-selection class. Bofors AB / BAE Systems Munitions AB is a candidate Tier-1 anchor for the ammunition tract. |
| 2026-02-17 | CA | Canada Defence Industrial Strategy — Build–Partner–Buy + ~CAD 500bn 10-year mobilisation | 4 | Canadian Content Value (CCV) requirements + 70% domestic-procurement target; BAE Systems Canada (Ottawa) sits inside the "Partner" tier; the Feb-2026 SAFE-association template is the binding benchmark for an analogous UK-EU SAFE-association outcome. |
| 2026-03-12 | GB | UK NSI Act 2021 — NARS reform (Government Response) | 3 | Narrows Notifiable Acquisition Regulations + raises de-minimis thresholds. Removes a structural FDI screening drag on inbound foreign-defence M&A targeting UK assets; secondary inverse implication: outbound BAE M&A from the UK side benefits from procedural simplification. |
| 2026-03-18 | GB | UK CBAM Finance Act 2026 | 3 | Carbon-border-adjustment on imported steel/aluminium/cement/fertilisers; BAE armour-steel procurement and Sheffield Forgemasters input cost both materially relevant; partial-track imitation of EU CBAM noted in case #3. |
the Rheinmetall dossier. Canada's Feb-2026 association is the template. Outcome determines whether BAE's UK-domiciled manufacturing footprint (Warton, Samlesbury, Barrow, Glasgow, Filton, Glascoed) counts toward SAFE's 65% local-content rule. The structural asymmetry vs. Rheinmetall is that BAE retains Hägglunds + Bofors AB + Eurofighter consortium intra-EU vertices even under SAFE-association denial — BAE is not "hostage" to the binary the way RBSL is (see Surface 4).
government Yemen-conflict policy and the Camm review constrain Saudi BAE Eurofighter / Hawk / Typhoon ammunition exports. Tranche-4 (48 aircraft, ~£7-10bn) is conditional on UK policy direction; outcome is the largest single export-licensing question on BAE's order book.
(Dec-2024 stand-up); IOC targeted 2035. Final workshare allocation among UK/Italy/Japan + JV governance with Mitsubishi Heavy Industries + Leonardo MW; capability-baseline freeze expected during 2026.
share of the trilateral build (10 boats Australian + ~12 UK + Virginia-class augmentation) is to be confirmed in the next AUKUS Defence Ministers' meeting; capacity at Barrow + Devonport is the binding constraint.
Oct-2025 designation of BAE Systems Inc., the open question is whether MOFCOM extends to BAE Systems plc directly. If yes, the Surface-2 firewall theory falls and Eurofighter consortium PRC supply-chain exposure becomes a binding constraint.
BAE's strategic optionality is structurally richer than any other single-prime in the dossier corpus because it operates on four distinct jurisdictional axes simultaneously (UK / US-SSA-governed / EU-via-Sweden+Eurofighter / AUKUS-trilateral-perimeter). Four management levers shape the next 24 months:
US-domiciled entity.** This is the status-quo path; structural firewall benefits (Surface 2) + DoD prime-contractor eligibility + ITAR/CFIUS clean status remain intact; UK parent retains 100% ownership and consolidates earnings. Optionality preserved for a formal NewCo spin-out under conditions described below.
See "Highest-leverage open management decision" below.
acquisitions.** SAFE + EDIP eligibility for grant + procurement via Sweden vertex makes scale-out of the Karlskoga propellants line and the Örnsköldsvik CV90/BvS10 cluster the cleanest capital-allocation play for European-procurement capture under any SAFE-association outcome.
rear-fuselage/tail-assembly dependency.** GCAP gives BAE prime status on a UK-cleared fifth-gen platform with no ITAR/EAR Washington-dependency by design — the structural answer to Samlesbury's F-35 rear-fuselage/tail-assembly Tier-1-sub status. The capability-baseline freeze in 2026 + IGO workshare allocation are the binding milestones.
(Exceeds the README ≥3 quality bar — BAE's multi-vertex structural position naturally produces a fourth surface that no other dossier in the corpus is positioned to make.)
(1) BAE is the only publicly-listed prime with *prime-contractor* status on both AUKUS pillars simultaneously, and the BIS 2024-04-19 EAR revisions are a structural arbitrage the sell-side does not price. Sell-side coverage of AUKUS treats Pillar 1 (SSN-AUKUS construction) as a UK MOD revenue line and Pillar 2 (advanced- capability cooperation) as a generic export-control simplification. The structural read is different: the April 2024 BIS interim final rule removed NS1/RS1/MT1 license requirements (the three primary license-control reasons that gate fifth-gen-defence dual-use movement) only between US/UK/AU. BAE is the only prime with prime-contractor and large-manufacturing-footprint presence in all three jurisdictions — Barrow-in-Furness UK (SSN-AUKUS construction) + Adelaide Osborne AU (Hunter-class frigates + ASC SSN-AUKUS partnership) + Falls Church VA US (BAE Systems Inc. under SSA governance, Pentagon prime contractor on M109/AMPV/ Bradley/EW suites). The licence-free perimeter lets BAE move technical data, components, intellectual property, and personnel between these three centres without licensing friction that every competitor — Lockheed, RTX, Northrop, GD, Boeing-Defense, Saab, Leonardo, Airbus DS, KNDS, Rheinmetall — must continue to navigate case-by-case. This is a multi-year compliance-arbitrage moat that sits below segmental disclosure (no segmental line "AUKUS Pillar 2 arbitrage" reports the benefit; it shows up as below-OPEX compliance-cost differential and as faster time-to-market on dual-use technical-data movements). Watch: the political reversibility of the BIS IFR — the IFR was issued under EAR Section 743.10 amendments and could be unwound by a successor administration; any political signal toward narrowing AUKUS Pillar 2 would compress this surface materially.
(2) BAE Systems Inc. is the structurally-engineered PRC-UEL firewall — and equity research has not internalised the firewall. The October 2025 MOFCOM UEL Announcement [2025] No. 10 designated BAE Systems Inc. — the US subsidiary, Falls Church VA, governed under a Special Security Agreement that already separates it from the UK parent for ITAR/CFIUS/proxy-board reasons. BAE Systems plc (UK parent) is explicitly NOT listed — the IPTM action record itself flags this asymmetry under the "BAE Systems (BAESY)" entity note. The SSA governance — which BAE has carried since the 1999 GEC Marconi acquisition and which sell-side typically frames as a US-CFIUS compliance constraint — turned out to be coincidentally also a structural firewall against PRC UEL contagion to the UK parent. The five designated counter-drone / hybrid US-domiciled product lines (Bofors Defense Systems Inc., BAE C4ISR & EW, Information & Electronic Systems Integration, sub-tier sensor work) sit inside the US sub's perimeter; the UK parent's Eurofighter Tranche 4 / GCAP / SSN-AUKUS Barrow / Type 26 Glasgow lines remain outside the PRC UEL perimeter. This firewall undermines the conventional "BAE = US-defence-prime exposure" sell-side framing — the UK parent is structurally less exposed to PRC UEL contagion than any other prime with US sub footprint (Honeywell Aerospace, RTX, Lockheed, GD, Northrop) because no other US sub has SSA jurisdictional separateness on the same governance grade. Watch: any expansion of PRC UEL designations to include UK parents — if MOFCOM extends to BAE Systems plc directly, the firewall theory falls and Eurofighter consortium PRC rare-earth supply-chain exposure becomes a binding constraint immediately.
(3) GCAP/Tempest is BAE's structurally hedged exit from F-35 rear-fuselage/tail-assembly Tier-1-sub dependency and is mis-classified by equity research as long-dated optionality. Conventional sell-side coverage scopes BAE's UK exposure through the SAFE-association binary and treats GCAP/Tempest as a long-dated pipeline (IOC 2035) of optional upside — generic "future-platform" framing. The structural read is different: GCAP is BAE's hedged-exit from the Tier-1 US-cleared-only platform regime. F-35 rear-fuselage/tail assembly at Samlesbury is sole-source UK content for the global F-35 fleet (~3,500 aircraft over the program lifetime), but the relationship is asymmetric — BAE depends on Lockheed Martin prime-contractor status, ITAR/EAR licence-flow for technical data, and US Tier-1 sub eligibility. The Eurofighter Tranche-4 Saudi-export overhang (under Camm-review constraints) and the Tranche-1 fleet sunset put the Eurofighter program into structural decline through the early 2030s. GCAP gives BAE prime status on a UK-cleared fifth-gen platform with no US ITAR / EAR Washington- dependency by design — even with AUKUS Pillar 2 removing those barriers (Surface 1), the political reversibility of the AUKUS exemption is non-trivial and a sovereign UK-led fifth-gen capability is structural insurance. The IOC-2035 timeline lines up exactly with the Eurofighter Tranche-1 fleet sunset and with Typhoon's end-of-production. GCAP + SSN-AUKUS together let BAE pivot away from F-35 rear-fuselage/tail-assembly contract dependency while retaining the Pillar-1 / Pillar-2 perimeter privilege from Surface 1. Watch: the 2026 GCAP capability-baseline freeze and the GIGO workshare allocation between UK / Italy / Japan — both shape whether GCAP captures lead-prime value or settles into a sub-tier role with MHI/Leonardo MW capturing the prime value.
(4) UK SAFE-association is asymmetric in BAE's favour — *not* in the UK's favour — because BAE's intra-EU footprint already captures the SAFE/EDIP value irrespective of the binary. Conventional reading frames UK SAFE-association as the binary through which UK primes access EUR 70-90bn of SAFE-funded EU procurement perimeter. The structural read is different: BAE — via BAE Systems Hägglunds AB (Örnsköldsvik Sweden — CV90/BvS10), BAE Systems Bofors AB (Karlskoga Sweden — Archer 155 mm SPH + ammunition + propellants), BAE Systems Munitions AB, and the Eurofighter consortium 33% UK workshare cross-tied through Airbus DS (DE/ES) + Leonardo (IT) — already has multi-vertex intra-EU jurisdictional presence. Even if the UK fails to secure a SAFE-association comparable to Canada's Feb-2026 deal, BAE captures SAFE-eligible share via its Swedish and consortium-EU vertices on its own books. The asymmetry vs. Rheinmetall is structural: Rheinmetall's RBSL UK side is hostage to the binary because Rheinmetall has no UK procurement-pull leverage of its own; BAE's UK side has UK MOD pull AND EU sub footprint AND SSA-governed US sub footprint AND AUKUS perimeter footprint. The 45/55 ownership headline of RBSL understates BAE's optionality on dissolution — BAE captures more residual value under SAFE-denial than Rheinmetall does because BAE's intra-EU non-RBSL vertices remain SAFE-eligible. Equity-research framing of "UK SAFE-association binary outcome" is therefore asymmetric: BAE's earnings sensitivity to that binary is materially lower than the prevailing narrative implies. Watch: the EUR-1.5bn EDIP first-tranche grant allocations (2026-Q2-Q3) — if Bofors AB or Hägglunds capture material grant-eligible share, the non-binary intra-EU value flow is demonstrated; if not, the binary framing has more empirical support.
Whether to convert the SSA-governed BAE Systems Inc. into a separately-listed NYSE-traded NewCo while retaining a controlling minority stake from London. The structural case has hardened across three independent vectors. (a) The Oct-2025 MOFCOM UEL designation of BAE Systems Inc. (Surface 2) demonstrates that the US sub is operationally treated as a separate entity in adversarial jurisdictional classification — formalising the separation would harden the firewall rather than weaken it. (b) The persistent multiple compression of UK FTSE-defence (~13-15× P/E) vs. US peer-set NYSE-defence (~22-28× P/E) has held for ~7 years and a separately-listed BAE Systems Inc. would capture the US-defence sector premium directly without requiring full divestiture. (c) State FORGE multilateral, OBBB defence-procurement re-authorisation (still in House-Senate conference as of mid-2026) favouring US-domiciled primes, and AUKUS Pillar 1 SSN-AUKUS dollar- denominated build cost all argue for converting the SSA-governance structural firewall into a corporate separation. The counter-case is non-trivial: SSA-governance already delivers operational separation without the M&A / corporate-actions friction of a spin-out; full separation eliminates the consolidated-earnings benefit; UK government investor protection (the Special Share in BAE Systems plc that gives HMG residual sovereign-control rights) complicates a US-sub spin-out and would require political sign-off. Q3 2026 results post-Trump administration's first full DoD procurement cycle is the natural watch event for management to signal direction; the late-2026 / early-2027 capital-markets day is the most plausible disclosure window for a strategic-review announcement.
BAE is the structurally-densest cross-axis specimen in the dossier corpus alongside Vale and Rio. Connections:
+ GCAP + F-35 rear-fuselage/tail-assembly are downstream of the US-PRC semiconductor perimeter; BAE Systems Inc. EW + sensor suites consume advanced-node compute exposed to BIS Affiliates Rule / 4E091 ECCN / Diffusion Framework precedents — symmetric to NVIDIA on the supply side and Samsung/SK Hynix on the memory side.
RBSL Challenger 3 + Boxer. Surface 4 above is the inverse of Rheinmetall's Surface 3: same JV, opposite asymmetry of optionality, with BAE's intra-EU footprint and US-SSA-governed US sub absorbing the SAFE-denial scenario that RBSL bears most heavily.
the US-UK Economic Prosperity Deal framework (2025-05-08) on the trade-policy axis; both are exposed to the Section 232 steel/aluminium global re-tariff regime via their UK + EU manufacturing footprints.
upstream of BAE's GCAP + Type 26 sensor chains (bismuth, indium, tellurium for IR sensors and rangefinders).
via BAE's Eurofighter consortium share contributing to the EU defence-industrial-pull demand structure that the EU 20th package + EDIP + SAFE jointly underwrite.
Refresh on each new UK MOD / DoD / AUKUS-track action, on any EU SAFE / EDIP implementing-act publication, on each MOFCOM UEL adjustment touching defence primes (escalation to UK parent would invert Surface 2), on GCAP/Tempest IGO milestones, and on each BAE Systems plc capital-markets day or quarterly order-intake disclosure.
Inline citations point to the corresponding IPTM action records in docs/iptm/actions/*.md, which themselves carry primary- source URLs to UK MOD / Cabinet Office publications (CP 1388 DIS 2025, the Atlantic Bastion programme announcement, IS-8 Defence sector plan), BIS Federal Register notices (April 2024 EAR/AUKUS IFR), Council of the EU and Commission press releases (Reg. 2025/1106 SAFE, Reg. 2025/2643 EDIP), Canada-DND DIS publication, MOFCOM Announcement [2025] No. 10 official PDF listing 14 entities including BAE Systems Inc., and the US-UK Economic Prosperity Deal text (EO 14309). Material exposure descriptions cross-reference case #4 (chip-control architecture) for the demand-side semiconductor perimeter affecting Eurofighter / GCAP / Type 26 electronics and case #5 (EU-Russia forking architecture) for the EU-side demand-pull underwriting the EDIP/SAFE envelope BAE captures via its intra-EU footprint.
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.
F-35 program prime contractor. BAE Systems manufactures the rear fuselage and horizontal/vertical tails for every F-35 at its UK facilities (Samlesbury) and supplies them to Lockheed Martin for final assembly at Fort Worth, TX. Correction 2026-09-09: this dossier's body previously described the Samlesbury F-35 work as 'wing assembly' in seven places; f35.com's own partner page and Lockheed/BAE press material (aerotechnews.com, lockheedmartinuk.mediaroom.com 1,000th-fuselage milestone) confirm BAE builds the rear fuselage and tails, not the wings (Lockheed Martin Fort Worth makes the wings and forward fuselage). Wording corrected throughout the dossier; the underlying analytical claims (Tier-1-sub dependency on Lockheed, GCAP as a hedge) are unaffected by the component-name fix.
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.
2 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 |
|---|---|---|---|---|---|---|---|---|---|
| Neodymium | 🇨🇳 CN 85% refining | 86 | 72 | Critical | EXCEEDS 85% | — | some | 50 | ▲ rising |
| Titanium | 🇨🇳 CN 70% refining | 71 | 59 | High | EXCEEDS 70% | — | limited | 14 | ▲ 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 |
|---|---|---|---|---|---|---|
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Titanium | 4 | 3 | 1 | 4 | 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.
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.
+ 45 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:
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 86 → 88 (+2) — a relative official policy-pressure magnitude, not a price drawdown.
🇨🇳 CN has issued 13 restrictive actions on Neodymium since 2024 — cadence accelerating (mean gap 103d → 29d), severity flat (3.8 → 3.4).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 1 of these 26 materials (Neodymium) — your binding Neodymium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 4.7 months apart across 5 distinct restriction dates since 2024 (n=4 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 | 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 | Titanium — 🇨🇳 CN escalates titanium controls to a full export-licensing / ban regime | 71 | 77 | +6 |
| Concentration | Titanium — 🇨🇳 CN becomes the single source for titanium — the second source is lost (full 70%+ monopoly) | 71 | 89 | +18 |
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. 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.
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.
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 (Neodymium).
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 | Yes — 2 scored SRMs on the input side (binding: Neodymium) |
| Manufactures a listed strategic technology | defence-industrial-base (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 2026-10-06
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.