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1 critical material scored · binding chokepoint: Niobium (🇧🇷 BR 89% of refining) · 5 restrictive government measures on record
A verification pass re-checked this dossier's ownership/corporate-structure fields against their cited sources. It did not re-read the material_exposures claim the score, band and stress figures below are built on — treat those as not yet independently re-checked.
CBMM (Companhia Brasileira de Metalurgia e Mineração) produces 1 of the 1 scored material above (Niobium). 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 Low · 28/100 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 2026-10-05) — 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 Niobium — 🇧🇷 BR controls 89% of global refining. On this company's production footprint that scores 28/100 (inside the chokepoint; global 61). The register holds 5 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Niobium CBMM (Companhia Brasileira de Metalurgia e Mineração) is the 229th-most-exposed of the 229 named companies we track on 🇧🇷 BR's Niobium chokepoint; the most-exposed is Sojitz Corporation (61/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
CBMM (Companhia Brasileira de Metalurgia e Mineração) ranks 445th of 446 verified mining metals companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 127 further mining metals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 28/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 1 scored material. Buyer-relative (first-order): weighted by where the company produces (BR 100%, 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.
CBMM mines and refines pyrochlore ore at a single complex in Araxá, Minas Gerais, Brazil, converting it into ferroniobium, niobium oxide and niobium chemicals. It is the world's dominant niobium producer — roughly 75-90% of global supply, depending on the source and year — making it the de facto price-setter in what is otherwise a three-producer oligopoly (CBMM, China's CMOC, and Canada's Magris Performance Materials). Ownership is majority Brazilian: the Moreira Salles family holds 70%, with the remaining 30% split evenly between a Chinese investor consortium and a Japan-Korea consortium (Nippon Steel, JFE, Sojitz, JOGMEC, and two Korean partners) that bought in during 2011.
not exposed to niobium as a scarce input it buys; niobium mining and refining is its entire business. Its exposure is instead concentration and policy risk running the other way: as the single company controlling most of the world's supply, any disruption at the Araxá site (regulatory, labor, environmental, or a change in CBMM's own commercial terms) is itself a global supply-chain event for every downstream buyer of ferroniobium and niobium chemicals. Brazil holds over 97% of the world's exploitable niobium reserves, so there is no near-term alternative geography.
growth bet.** Roughly 85-90% of niobium consumption goes into high-strength low-alloy (HSLA) steel as a microalloying additive (ppm-to low-percent range dosing — a trace additive by mass, but one with an outsized effect on steel strength-to-weight, used in pipelines, auto bodies, and construction). Most of the remainder goes into nickel-based superalloys (e.g. Inconel 718) for jet-engine and turbine components — a structural, non-substitutable role given performance requirements. CBMM is also building a battery-materials business (niobium oxide/niobium- titanium-oxide fast-charge anode and cathode materials, via partnerships with Toshiba, Echion Technologies and NOVONIX), which it has said it wants to grow from roughly 5% of revenue today toward 25% by 2030; it opened an $80M, 3,000-tonne/year niobium oxide refining line in Brazil for this in 2024.
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.
Sojitz states it 'now handles over 90% of the total niobium brought into Japan as CBMM's distributor for niobium products to Japanese steel manufacturers and other consumers' and that the products 'are transported by ship from Brazil'. Origin Araxá, Minas Gerais, Brazil; destination Japan. No volume or value stated. Sojitz holds 2.5% of CBMM via the 2011 consortium.
JOGMEC's own 2011-03-04 press release on the Japan-Korea consortium's CBMM equity purchase: 'In addition to the acquisition of CBMM shares, JFE, NSC, POSCO and Sojitz entered into a long-term niobium supply agreement with CBMM, assuring that the stable relationship these companies have long had with CBMM continues.' Source names JFE Steel Corporation; JFE Holdings is its listed parent. related_party: true because JFE is also a CBMM equity holder (2.5% via the consortium).
Same JOGMEC 2011-03-04 press release: 'JFE, NSC, POSCO and Sojitz entered into a long-term niobium supply agreement with CBMM, assuring that the stable relationship these companies have long had with CBMM continues.' NSC = Nippon Steel Corporation. related_party: true because Nippon Steel is also a CBMM equity holder (2.5% via the consortium).
Same JOGMEC 2011-03-04 press release: 'JFE, NSC, POSCO and Sojitz entered into a long-term niobium supply agreement with CBMM, assuring that the stable relationship these companies have long had with CBMM continues.' related_party: true because POSCO is also a CBMM equity holder (2.5% via the consortium).
CBMM's own 2024 Sustainability Report, CEO letter: 'the recognition of our ESG efforts by three key customers in the Indian market—JSL, JSW, and Tata Steel, affirming that we are on the right path in managing our practices.' No volume or share disclosed.
CBMM's own 2024 Sustainability Report, CEO letter: 'the recognition of our ESG efforts by three key customers in the Indian market—JSL, JSW, and Tata Steel, affirming that we are on the right path in managing our practices.' No volume or share disclosed.
CITIC Metal's SSE IPO prospectus (registered draft, 2023-03-14, p.1-1-389): '报告期内发行人向CBMM及下属企业CBMM（新加坡）、CBMM(欧洲)和CBMM（北美）采购的有色金属产品为其生产的铌产品，金额分别为498,625.36万元、422,035.53万元、488,016.32万元及280,995.80万元，占营业成本比例分别比为8.09%、5.62%、4.37%及4.62%' (2019, 2020, 2021, H1 2022) and 'CBMM是全球最大的铌产品供应商，公司是其铌产品在中国市场的独家分销商'; p.1-1-33: '公司铌产品贸易业务的采购全部来自于CBMM'; p.1-1-16/17: exclusive distributor in China since 1998, latest 《独家分销协议》 effective 2022-01-01, five-year term, renewable. CITIC Metal's H1-2025 interim report (cninfo, 2025-08-28, p.164, related-party purchases table): 巴西矿冶公司 采购铌产品 RMB 3,221,078,548.29 in H1 2025 (H1 2024: RMB 2,791,885,791.73; approved annual cap RMB 7.25bn) — http://static.cninfo.com.cn/finalpage/2025-08-28/1224594001.PDF. related_party: true because CITIC Metal holds 5% of CBMM via the China Niobium Investment Holdings consortium and nominates one CBMM director.
ImportGenius US import records, supplier page Companhia Brasileira De Metalurgia: bill of lading DSVFSAO0097022, 2024-08-14, shipper Companhia Brasileira de Metalurgia (CBMM), consignee Dow Silicones Corporation, origin Brazil, 'NIOBIUM METAL ... PALLETS WITH BOX(ES)', 1,991 kg, sea freight to the US. CBMM's niobium metal is made at its Araxá complex (Minas Gerais, Brazil). Dow Silicones is a wholly owned Dow Inc. subsidiary (Midland, Michigan). No value stated. The same page shows BoL AHGAITJ25080075 of 2025-10-07 (niobium metal, 3,033 kg, Brazil) to CBMM North America Inc, Houston, an intra-group transfer not recorded as a pair.
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.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Niobium | 🇧🇷 BR 89% refining | 28 | 61 | Low | — | High | some | 5 | ▲ 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 |
|---|---|---|---|---|---|---|
| Niobium | 3 | 4 | 3 | 3 | 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.
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:
Under the 🇧🇷 BR shock, your disclosed plant carries the binding Niobium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Niobium — 🇧🇷 BR escalates niobium controls to a full export-licensing / ban regime | 28 | 31 | +3 |
| Concentration | Niobium — 🇧🇷 BR becomes the single source for niobium — the second source is lost (full 89%+ monopoly) | 28 | 31 | +3 |
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 CBMM (Companhia Brasileira de Metalurgia e Mineração) 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 1 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one CBMM (Companhia Brasileira de Metalurgia e Mineração) 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 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | mining-metals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-06-04; 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.