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9 critical materials scored · binding chokepoint: Cobalt (🇨🇳 CN 78% of refining) · 108 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.
Chengtun Mining Group Co., Ltd. produces 9 of the 9 scored materials above (Cobalt, Copper, Nickel, Silver, Tungsten, Indium, Tin, Germanium, Zinc). 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 · 53/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-07) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Cobalt — 🇨🇳 CN controls 78% of global refining. On this company's production footprint that scores 62/100 (neutral exposure; global 62). The register holds 108 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Cobalt Chengtun Mining Group Co., Ltd. is the 505th-most-exposed of the 584 named companies we track on 🇨🇳 CN's Cobalt chokepoint; the most-exposed is Less Common Metals (75/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Chengtun Mining Group Co., Ltd. ranks 53rd of 56 verified metals recycling companies, tied with 1 other at 53.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 3 further metals recycling 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 53/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 9 scored materials. Buyer-relative (first-order): weighted by where the company produces (CD 50% · CN 35% · ID 15%, 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.
Chengtun Mining Group (盛屯矿业, SSE: 600711; rebranded from "Shengtun" to "Chengtun" in August 2025) is a Xiamen-headquartered non-ferrous metals miner and processor with a copper-cobalt-nickel "upstream resources, downstream materials" strategy. It mines copper and cobalt in the Democratic Republic of Congo (flagship BMS mine plus the Kalongwe and Nkoyi projects acquired via its Xuchen International and Preeminence Holdings subsidiaries), runs nickel operations in Indonesia through PT Youshan Nickel, and operates zinc/tin/ tungsten mining and smelting in China, with a workforce spanning China, DRC, Indonesia, Zambia, Zimbabwe, Nigeria, South Africa and Argentina.
operation; the BMS mine alone produced 74,400 mt of contained copper in H1 2026, with 132,200 mt across the DRC copper-cobalt segment as a whole (133,200 mt company-wide including the Chinese zinc/tin/tungsten operations) — SMM, 2026-08.
(BMS, Kalongwe, Nkoyi); cobalt is DRC-concentrated globally and central to the company's stated "upstream resources" strategy.
Nickel in Indonesia, the world's largest nickel-supplying country.
commodity alongside copper, tin and tungsten.
mix.
segment mix; tungsten supply is heavily China-concentrated, which cuts both ways for a China-domiciled producer (upstream security vs. downstream export-control exposure).
byproduct of the company's zinc-smelting circuit.
no germanium ore reserves; germanium is recovered only as a low-volume byproduct of zinc smelting at its Chengtun Zinc & Germanium subsidiary, where recovery rates have been improving. Not a primary revenue driver, but germanium is a China-export-controlled material, so even byproduct exposure is policy-relevant.
byproduct of the same zinc-smelting operations, not mined directly.
Source: Chengtun's FY2025 annual report (SSE 600711, via cninfo, filed 2026-03-20). No IPO prospectus was found on cninfo under a searchkey=招股说明书 query (0 hits) — 600711 appears to have come to market via a route other than a standard A-share IPO, so the usual prospectus-first channel this lane prefers was not available here; the annual report is the primary source instead. The H1-2026 semi-annual report (filed 2026-07-30, 195pp, cninfo 1225446751.PDF) carries no "主要客户/主要供应商" top-5 table — a lighter semi-annual requirement — so FY2025 remains the only top-5 vintage. CORRECTION 2026-09-26: an earlier version of this note said the H1-2026 notes hold only aging tables; they also carry full related-party transaction tables (pp.168-176), which is where the H1-2026 vintage below comes from.
Top-5 customer/supplier concentration (FY2025). Top-5 customers = 47.83% of annual sales (RMB 1,434,735.15万); top-5 suppliers = 23.94% of annual purchases (RMB 580,880.48万). Both tables are fully coded (客户1-5 / 供应商1-5) with no stated reason for the name exemption. The filing separately discloses a related-party subtotal within each top-5 total — RMB 175,549.94万 (5.85% of sales) among customers, RMB 94,918.55万 (3.91% of purchases) among suppliers — and in both cases that subtotal equals exactly one coded row's own disclosed amount, which is how 客户4 and 供应商3 are identified as related parties here even though their actual corporate names are withheld.
Named related parties (from the separate related-party transaction tables, not the coded top-5 table). These are quantified but were not matched to a specific top-5 rank — the filing does not provide enough detail to place them inside vs. outside the top-5 cut:
shareholder of a Chengtun subsidiary. The single largest related-party counterparty in the filing by a wide margin: RMB 1,366.21m of goods + RMB 267.90m of services purchased from it in FY2025 (up from RMB 934.91m + RMB 130.56m FY2024), and RMB 2,318.13m of goods sold to it (down from RMB 2,621.26m). The filing's related-party identity list places this entity's network alongside roughly two dozen Indonesian PT.* companies at the Weda Bay/IWIP nickel industrial park, including PT. Indonesia Tsingshan Stainless Steel and Eternal Tsingshan Group Limited — i.e., this reads as the Tsingshan-linked nickel-park network that Chengtun's own PT Youshan Nickel subsidiary sits inside, not an arm's-length trading counterparty. Material: nickel.
minority shareholder of a Chengtun subsidiary. RMB 1,143.00m of goods + RMB 33.09m of services purchased from it in FY2025 (up from RMB 505.05m + RMB 41.67m FY2024); RMB 6.04m of goods + RMB 21.21m of services sold to it. Its identity-list cluster names Thomas Mining SARL, Brother Metal (China) Co., Ltd., Brother Foodstuff Company SPRL, Brother Transport Congo SARL, Bright Time Logistics Limited and Continental International Resources (H.K.) Limited as under the same ultimate control — a DRC-domiciled network that lines up with Chengtun's own BMS/Kalongwe/Nkoyi copper-cobalt operations there. Material: copper, cobalt.
2024-vintage minority shareholder of a Chengtun subsidiary; RMB 71.50m of goods purchased from it, RMB 324.40m of goods sold to it, FY2025. A same-ultimate-controller affiliate, Huayou Holding Group Co., Ltd. (华友控股集团有限公司), is also named in the identity list without its own transaction line. Cross-dossier link confirmed (2026-09-01 verify pass): this corpus's own huayou-cobalt dossier (SSE 603799, 华友钴业) records "Zhejiang Huayou Holding Group Co., Ltd. (华友控股)" as huayou-cobalt's controlling shareholder (16.2% stake, per huayou-cobalt's own ownership_source) — the same legal name (short-form 华友控股 vs. this filing's 华友控股集团有限公司) named here as a Chengtun-subsidiary minority shareholder under common control. This does not mean Chengtun and Huayou Cobalt are affiliated with each other — it means the Hong Kong counterparty above (华友控股（香港）有限公司) sits inside Huayou Holding Group's own corporate family, the same family that controls the listed cobalt producer. Material: cobalt.
together with three affiliated subsidiaries (四川盛瑞矿业/四川致远锂业/ 四川省盈达锂电新材料) — a controlling-shareholder-controlled entity, not a subsidiary-level tie. Services Chengtun sold it fell from RMB 32.48m (FY2024) to RMB 37,291.28 (FY2025), a >99% collapse — flagged here as an apparently winding-down relationship rather than an active supply line. Material: lithium.
H1-2026 update (semi-annual, filed 2026-07-30; amounts only, no share_pct).
(-99.9%; FY2025 was RMB 2,318.13m) — the RMB 2bn+/yr nickel sales channel disappeared; goods bought RMB 141.42m (vs 228.85m), services bought RMB 175.80m (vs 115.90m). No reason stated in the filing.
balances due to the cluster RMB 382.89m payables + RMB 1,198.62m other payables — the largest related-party liability in the filing.
other payables RMB 223.51m; co-guaranteed a RMB 136.05m Chengtun facility with Brother Metal (HK) (discharged 2026-04-30). Jurisdiction and goods not stated (FZE = UAE free-zone form).
H1-2026 transaction line — a dropped line, not a zero; the H1-2026 filing is silent, so no row is written.
What is absent. No named counterparty was found tied specifically to the DRC copper-cobalt off-take (beyond the Brother Metal cluster above) or to zinc/tin/tungsten/germanium/indium — those material lines carry no named counterparty in this filing. Absence here is not evidence of no relationship; it means this filing's related-party and top-5 disclosures did not happen to name one for those materials.
From the company’s own mandatory filings — the CSRC top-5 customer/supplier concentration disclosure and the related-party tables. 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.
FY2025 annual report (SSE 600711, filed 2026-03-20). Top-5 customer/supplier tables are fully coded (客户1-5 / 供应商1-5) with no exemption reason stated; the filing's separately-disclosed related-party subtotal exactly matches one coded slot in each table, so the related-party seat is identifiable by amount even though the coded label alone would not disclose it. Original cninfo PDF (static.cninfo.com.cn) now returns 403 to automated fetches; re-verified 2026-09-20 against a Sina Finance mirror of the same filing text, which reproduces the identical top-5/related-party figures (客户4 = RMB 175,549.94万 / 5.85% confirmed).
H1-2025 · Prior-year comparative column of the H1-2026 semi-annual (pp.169-170): goods bought RMB 228.85m, services bought RMB 115.90m, goods sold to it RMB 1,435,020,560.82. Written as its own vintage row per R164; amounts only, no share_pct disclosed. Material: nickel.source ↗
FY2025 · Minority shareholder of a Chengtun subsidiary (same ultimate controller). By far the largest related-party counterparty disclosed: Chengtun bought RMB 1,366.21m of goods + RMB 267.90m of services from it in FY2025 (up from RMB 934.91m + RMB 130.56m in FY2024) and sold it RMB 2,318.13m of goods (down from RMB 2,621.26m). The filing's related-party identity list groups this entity's network with a cluster of ~25 Indonesian PT.* companies operating the Weda Bay/IWIP nickel industrial park (incl. PT.Indonesia Tsingshan Stainless Steel, PT.Indonesia Weda Bay Industrial Park, Eternal Tsingshan Group Limited) under the same ultimate control — consistent with Chengtun's own PT Youshan Nickel Indonesia operation sitting inside that park. Material: nickel. Not material-attributed with certainty — the filing discloses common control, not a line-item breakdown by counterparty within the cluster.source ↗
H1-2026 · H1-2026 semi-annual (SSE 600711, filed 2026-07-30, pp.169-170, related-party tables; period ended 2026-06-30). Goods bought RMB 141.42m + services bought RMB 175.80m; goods SOLD to it RMB 0.85m; services provided to it RMB 46.51m. The sales line collapsed against the H1-2025 comparative (RMB 1,435.02m, next row) — the FY2025 finding of a RMB 2.3bn/yr nickel sales channel did not continue into 2026 (a -99.9% H1-over-H1 swing; the filing gives no reason). Purchases of goods fell (RMB 228.85m in H1-2025) while services bought rose (RMB 115.90m in H1-2025). Period-end balances: prepayment RMB 96.47m (nil at start of year, bad-debt provision RMB 51.68m), payables RMB 38.44m (RMB 76.09m at start). Same common-control nickel-park network as the FY2025 row. Material: nickel.source ↗
H1-2025 · Prior-year comparative column of the H1-2026 semi-annual (p.169-170): goods bought RMB 250,438,682.94; goods sold to it RMB 5,584,189.15. Own vintage row per R164; amounts only. Material: copper, cobalt.source ↗
FY2025 · Minority shareholder of a Chengtun subsidiary (same ultimate controller). FY2025: Chengtun bought RMB 1,143.00m of goods + RMB 33.09m of services from it (up from RMB 505.05m + RMB 41.67m FY2024) and sold it RMB 6.04m of goods + RMB 21.21m of services. The filing's related-party identity list groups this entity's network with Thomas Mining SARL, Brother Metal (China) Co., Ltd., Brother Foodstuff Company SPRL, Brother Transport Congo SARL, Bright Time Logistics Limited and Continental International Resources (H.K.) Limited under the same ultimate control — a DRC-domiciled cluster matching Chengtun's own BMS/Kalongwe/Nkoyi copper-cobalt operations. Material: copper, cobalt.source ↗
H1-2026 · H1-2026 semi-annual (filed 2026-07-30, pp.169-170, 176): goods bought RMB 714.06m (RMB 250.44m in H1-2025 comparative, ~2.9x) + services bought RMB 15.82m. Period-end payables RMB 382.89m (RMB 35.24m at start of year) and other payables RMB 1,198.62m (RMB 806.33m at start) to the same-ultimate-controller cluster — the largest related-party balance in the filing. H1-2026 goods purchases alone are already ~62% of the FY2025 full-year figure (RMB 1,143.00m). Material: copper, cobalt.source ↗
Same identification method as 客户4: related-party purchases within the top-5 total (RMB 94,918.55万) equal 供应商3's own disclosed RMB 94,918.55万 (3.91%) line exactly.
2024-vintage minority shareholder of a Chengtun subsidiary; the filing's identity list also names a same-ultimate-controller affiliate, 华友控股集团有限公司 (Huayou Holding Group Co., Ltd.), without its own transaction line. FY2025: Chengtun bought RMB 71.50m of goods from it and sold it RMB 324.40m of goods. Cross-dossier link confirmed 2026-09-01: this corpus's huayou-cobalt dossier records Zhejiang Huayou Holding Group Co., Ltd. (华友控股) as huayou-cobalt's own controlling shareholder (16.2%, per its ownership_source) — same legal family as this filing's 华友控股集团有限公司, not a coincidental name match. This links the counterparty's controlling group to huayou-cobalt's controlling group; it does not make Chengtun and Huayou Cobalt affiliated with each other. Material: cobalt.
New name vs the FY2025 filing. Listed in the H1-2026 identity list (p.168) as a 子公司少数股东 (minority shareholder of a Chengtun subsidiary). Goods bought RMB 266,766,840.00 in H1-2026 (no H1-2025 comparative line); other payables RMB 223.51m (RMB 147.70m at start of year); payables RMB 137.92m (column as printed; ambiguous in text extraction). Co-guaranteed with Brother Metal (Hong Kong) a RMB 136,053,896.07 facility for Chengtun, 2023-05-29 to 2026-04-30, discharged — the identical amount/dates suggest a joint guarantee but the filing does not state a corporate tie between the two, so none is asserted. The FZE suffix denotes a UAE free-zone entity; the filing does not state the jurisdiction or the goods traded, so no material is attributed.
H1-2025 · Prior-year comparative column of the H1-2026 semi-annual (pp.169-170): goods bought RMB 228.85m, services bought RMB 115.90m, goods sold to it RMB 1,435,020,560.82. Written as its own vintage row per R164; amounts only, no share_pct disclosed. Material: nickel.source ↗
FY2025 · Minority shareholder of a Chengtun subsidiary (same ultimate controller). By far the largest related-party counterparty disclosed: Chengtun bought RMB 1,366.21m of goods + RMB 267.90m of services from it in FY2025 (up from RMB 934.91m + RMB 130.56m in FY2024) and sold it RMB 2,318.13m of goods (down from RMB 2,621.26m). The filing's related-party identity list groups this entity's network with a cluster of ~25 Indonesian PT.* companies operating the Weda Bay/IWIP nickel industrial park (incl. PT.Indonesia Tsingshan Stainless Steel, PT.Indonesia Weda Bay Industrial Park, Eternal Tsingshan Group Limited) under the same ultimate control — consistent with Chengtun's own PT Youshan Nickel Indonesia operation sitting inside that park. Material: nickel. Not material-attributed with certainty — the filing discloses common control, not a line-item breakdown by counterparty within the cluster.source ↗
H1-2026 · H1-2026 semi-annual (SSE 600711, filed 2026-07-30, pp.169-170, related-party tables; period ended 2026-06-30). Goods bought RMB 141.42m + services bought RMB 175.80m; goods SOLD to it RMB 0.85m; services provided to it RMB 46.51m. The sales line collapsed against the H1-2025 comparative (RMB 1,435.02m, next row) — the FY2025 finding of a RMB 2.3bn/yr nickel sales channel did not continue into 2026 (a -99.9% H1-over-H1 swing; the filing gives no reason). Purchases of goods fell (RMB 228.85m in H1-2025) while services bought rose (RMB 115.90m in H1-2025). Period-end balances: prepayment RMB 96.47m (nil at start of year, bad-debt provision RMB 51.68m), payables RMB 38.44m (RMB 76.09m at start). Same common-control nickel-park network as the FY2025 row. Material: nickel.source ↗
H1-2025 · Prior-year comparative column of the H1-2026 semi-annual (p.169-170): goods bought RMB 250,438,682.94; goods sold to it RMB 5,584,189.15. Own vintage row per R164; amounts only. Material: copper, cobalt.source ↗
FY2025 · Minority shareholder of a Chengtun subsidiary (same ultimate controller). FY2025: Chengtun bought RMB 1,143.00m of goods + RMB 33.09m of services from it (up from RMB 505.05m + RMB 41.67m FY2024) and sold it RMB 6.04m of goods + RMB 21.21m of services. The filing's related-party identity list groups this entity's network with Thomas Mining SARL, Brother Metal (China) Co., Ltd., Brother Foodstuff Company SPRL, Brother Transport Congo SARL, Bright Time Logistics Limited and Continental International Resources (H.K.) Limited under the same ultimate control — a DRC-domiciled cluster matching Chengtun's own BMS/Kalongwe/Nkoyi copper-cobalt operations. Material: copper, cobalt.source ↗
H1-2026 · H1-2026 semi-annual (filed 2026-07-30, pp.169-170, 176): goods bought RMB 714.06m (RMB 250.44m in H1-2025 comparative, ~2.9x) + services bought RMB 15.82m. Period-end payables RMB 382.89m (RMB 35.24m at start of year) and other payables RMB 1,198.62m (RMB 806.33m at start) to the same-ultimate-controller cluster — the largest related-party balance in the filing. H1-2026 goods purchases alone are already ~62% of the FY2025 full-year figure (RMB 1,143.00m). Material: copper, cobalt.source ↗
First vintage this dossier holds — code_stability unproven across years. Identity as the related party is inferred from an exact amount match: the filing states related-party sales within the top-5 total at RMB 175,549.94万, which equals 客户4's own disclosed RMB 175,549.94万 (5.85%) line to the centavo. Name withheld by the filer; no exemption reason stated. Re-verified 2026-09-20 via Sina Finance mirror (original cninfo PDF now 403s to automated fetches).
2024-vintage minority shareholder of a Chengtun subsidiary; the filing's identity list also names a same-ultimate-controller affiliate, 华友控股集团有限公司 (Huayou Holding Group Co., Ltd.), without its own transaction line. FY2025: Chengtun bought RMB 71.50m of goods from it and sold it RMB 324.40m of goods. Cross-dossier link confirmed 2026-09-01: this corpus's huayou-cobalt dossier records Zhejiang Huayou Holding Group Co., Ltd. (华友控股) as huayou-cobalt's own controlling shareholder (16.2%, per its ownership_source) — same legal family as this filing's 华友控股集团有限公司, not a coincidental name match. This links the counterparty's controlling group to huayou-cobalt's controlling group; it does not make Chengtun and Huayou Cobalt affiliated with each other. Material: cobalt.
Controlling-shareholder-controlled entity (same ultimate controller as Chengtun, not a subsidiary tie). Services Chengtun provided to it collapsed to RMB 37,291.28 in FY2025 from RMB 32.48m in FY2024 — a >99% drop, disclosed here as a relationship that appears to be winding down rather than growing. Material: lithium.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: 2 further counterparties in this filing are disclosed with exact figures but name-exempted by the filer. · section source filing ↗
Ranked by buyer-relative risk, highest first.
2 of 5 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 |
|---|---|---|---|---|---|---|---|---|---|
| Cobalt | 🇨🇳 CN 78% refining | 62 | 62 | Elevated | EXCEEDS 78% | High | some | 37 | ▲ rising |
| Copper | 🇨🇳 CN 48% refining | 59 | 59 | Elevated | within 48% | High | limited | 52 | ▲ rising |
| Nickel | 🇨🇳 CN 36% refining | 55 | 55 | Elevated | within 36% | High | limited | 29 | ▲ rising |
| Silver | 🇲🇽 MX 24% mining | 43 | 43 | Moderate | — | Low | some | 5 | ▲ rising |
| Tungsten | 🇨🇳 CN 90% refining | 38 | 76 | Low | EXCEEDS 90% | Med | some | 16 | ▲ rising |
| Indium | 🇨🇳 CN 69% refining | 35 | 64 | Low | — | Low | limited | 2 | ▲ rising |
| Tin | 🇨🇳 CN 55% refining | 30 | 56 | Low | — | Med | ready | 18 | ▲ rising |
| Germanium | 🇨🇳 CN 60% refining | 23 | 54 | Low | within 60% | Low | some | 11 | ▲ rising |
| Zinc | 🇨🇳 CN 32% mining | 19 | 37 | Low | — | Med | ready | 7 | ▲ 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 |
|---|---|---|---|---|---|---|
| Cobalt | 4 | 3 | 3 | 3 | 3 | company input |
| Copper | 4 | 2 | 5 | 4 | 3 | company input |
| Nickel | 4 | 2 | 5 | 3 | 3 | company input |
| Silver | 3 | 1 | 5 | 3 | 3 | company input |
| Tungsten | 4 | 4 | 5 | 3 | 3 | company input |
| Indium | 4 | 3 | 5 | 3 | 4 | company input |
| Tin | 4 | 2 | 5 | 2 | 3 | company input |
| Germanium | 4 | 3 | 1 | 3 | 4 | company input |
| Zinc | 4 | 2 | 3 | 3 | 2 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
Two independent lenses: USGS official puts China at 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 |
| 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.
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.
+ 93 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Cobalt exposure:
Counterfactual: Indonesia extends the hilirisasi ore-ban template (2020 nickel → 2023 bauxite) to the next rung of battery-mineral exports — tightening upstream supply for cobalt intermediates, lithium feedstock and graphite alongside the existing nickel + aluminium regime. Direct-hit lines are basket issuers whose binding material is a battery-cell input (nickel, cobalt, lithium, graphite) — irrespective of controller, since the template-export is global supply-chain pressure not bilateral targeting.
The binding exposure this precedent lands on — Cobalt — is a material Chengtun Mining Group Co., Ltd. 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.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-07) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 2 restrictive actions on Cobalt since 2016, severity flat (5.0 → 3.0).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 6 of these 22 materials (Cobalt, Copper, Tungsten, Indium, Silver, Germanium) — your binding Cobalt exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 2.6 months apart across 10 distinct restriction dates since 2016 (n=9 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 | Cobalt — 🇨🇳 CN escalates cobalt controls to a full export-licensing / ban regime | 62 | 67 | +5 |
| Concentration | Cobalt — 🇨🇳 CN becomes the single source for cobalt — the second source is lost (full 78%+ monopoly) | 62 | 76 | +14 |
| Policy | Copper — 🇨🇳 CN escalates copper controls to a full export-licensing / ban regime | 59 | 63 | +4 |
| Concentration | Copper — 🇨🇳 CN becomes the single source for copper — the second source is lost (full 48%+ monopoly) | 59 | 84 | +25 |
| Policy | Nickel — 🇨🇳 CN escalates nickel controls to a full export-licensing / ban regime | 55 | 61 | +6 |
| Concentration | Nickel — 🇨🇳 CN becomes the single source for nickel — the second source is lost (full 36%+ monopoly) | 55 | 81 | +26 |
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 Chengtun Mining Group Co., Ltd. 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 9 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
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.
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 Chengtun Mining Group Co., Ltd. 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 9 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | metals-recycling (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 2026-10-07
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