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1 critical material scored · binding chokepoint: Lithium (🇨🇳 CN 65% of refining) · 40 restrictive government measures on record
Chengxin Lithium produces 1 of the 1 scored material above (Lithium). 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 · 32/100 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 Lithium — 🇨🇳 CN controls 65% of global refining. On this company's production footprint that scores 32/100 (inside the chokepoint; global 61). The register holds 40 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Lithium Chengxin Lithium is the 480th-most-exposed of the 491 named companies we track on 🇨🇳 CN's Lithium chokepoint; the most-exposed is Momentum Technologies (72/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Chengxin Lithium ranks 428th of 447 verified mining metals companies, tied with 10 others at 32.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 128 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 32/100 — 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 (CN 100%, HQ proxy), applied across all materials — it does not yet trace each input to its specific sourcing step.
Chengxin Lithium Group (SZSE: 002240) is a Chinese lithium-salt processor. It buys spodumene concentrate, largely from Australia, and converts it into lithium chemicals (lithium carbonate and lithium hydroxide) at plants in western China, with a further lithium-salt plant in Indonesia. Yicai (Feb 2024) reports that Chengxin has lithium mine projects in China, Zimbabwe and Argentina. Its named overseas customers are Korean battery and cathode makers (LG Chem, SK On, Posco Chemical) plus Hyundai Motor under a four-year hydroxide supply deal.
the main feedstock and lithium salts are the product, so this is the core of the business, not a trace exposure. The chokepoint is the AU→CN leg: the 385,000 t Pilbara Minerals offtake ties the company's ore supply to Western Australian hard rock, and its hydroxide output feeds non-Chinese cell makers. That puts it on both sides of Chinese processing-technology export controls and Western IRA/FEOC-style sourcing rules.
sourcing rules that destination applies, is not disclosed in these sources.
sales_geography isleft blank.
Source for this section: Chengxin Lithium Group Co., Ltd. (盛新锂能) 2026 semi-annual report, filed with the Shenzhen Stock Exchange via cninfo 2026-08-25 — static.cninfo.com.cn/finalpage/2026-08-25/1225496204.PDF (重大关联交易, pp.31-32; 应收账款/应付账款关联方明细, p.135). Reporting period: H1-2026 (six months ended 2026-06-30). Confidence: primary-source (unaudited interim report, per the filing's own disclosure). This is domestic-China trade the buyer-side/customs lane cannot see at all, alongside the corpus's existing overseas customer list (Hyundai Motor, LG Chem, SK On, Posco Chemical) sourced from a 2024 press item.
All five counterparties below are disclosed as related parties, not from an anonymized top-5 table — this filing carries no 前五名客户/前五名供应商 section at all (checked; absent from all 146 pages). The related-party trigger differs by row and matters for how durable each relationship is:
| Counterparty | Role | H1-2026 amount (含税) | % of same-type related-party txns | Why related |
|---|---|---|---|---|
| BYD and subsidiaries | customer | ¥709,190,600 | 8.53% | a BYD board secretary sits as a Chengxin director |
| Sichuan Langsheng New Energy + New Materials | customer | ¥891,187,000 | 10.72% | both controlled by Chengxin's own controlling shareholder, Shengtun Group |
| CALB (中创新航, HKEX 3931) | customer | ¥1,625,974,400 | 19.55% | conditional share-subscription agreement (2025-10-31), terminated 2026-07-13 |
Huayou Holding Group (parent of huayou-cobalt, SSE 603799) | customer | ¥1,388,004,800 | 16.69% | same subscription agreement as CALB, also terminated 2026-07-13 |
| PT. Huayue Nickel Cobalt (Huayou Holding Group subsidiary, Indonesia) | supplier (sulfuric acid) | ¥39,027,300 | 0.75% | subsidiary of a party to the same terminated agreement |
Total disclosed related-party trade this half: ¥4,653,384,100 across the five counterparties (465,338.41万元 in the filing's own units) — a substantial share of a company whose FY2025 total revenue has not been re-checked against this figure in this pass.
Two honesty notes:
Both were classified as related parties solely because of a share-subscription agreement that Chengxin's own board terminated 2026-07-13 (adjusting a 2025 private-placement plan). If the trading relationship continues into H2-2026 without the equity tie, the next filing may report the same counterparties as ordinary (non-related) customers — re-check at the next vintage rather than assuming continuity of the related_party: true label.
counterparty** — the only supplier-side row in this batch, and the material traded (硫酸, an HPAL/leaching reagent) is not itself a scored material. It is recorded because role: supplier covers any input the subject depends on, not raw lithium feedstock alone.
Huayou Holding Group is the controlling shareholder of Zhejiang Huayou Cobalt Co., Ltd. (SSE 603799, tracked in this corpus as huayou-cobalt) but is a distinct, privately-held legal entity — per huayou-cobalt.md's own ownership note, Huayou Holdings has no dossier of its own, so this row is NOT linked via dossier_slug to avoid conflating parent and listed subsidiary.
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.
Yicai 2024-02-08: Chengxin Lithium 'inked a deal to buy 385,000 tons of spodumene concentrate from a unit of Australian lithium miner Pilbara Minerals'. Smallcaps (2024-03-12) confirms an amendment to Pilbara's existing offtake with Chengxin executed early February 2024.
Chengxin's 2026 H1 report (p.32): purchases of sulfuric acid (硫酸, a processing reagent, not a lithium feedstock) from PT. Huayue Nickel Cobalt, an Indonesian subsidiary of Huayou Holding Group, RMB 39,027,300 (含税) in H1-2026, 0.75% of same-type related-party transactions. Material corrected to sulfur (sulfuric acid is the traded reagent), not lithium; the source names no plant-to-plant route, so no corridor is credited.
Yicai 2024-02-08: 'a four-year lithium hydroxide supply deal with South Korean carmaker Hyundai Motor' signed January 2024.
Yicai, citing Chengxin's website: overseas lithium salt clients include LG Chem, SK On and Posco Chemical.
Same Yicai client list (LG Chem, SK On, Posco Chemical).
Same Yicai client list. Posco Chemical is the former name of POSCO Future M.
Chengxin's 2026 H1 report (filed 2026-08-25, p.31): sales of lithium products to BYD and its subsidiaries, RMB 709,190,600 (含税, tax-inclusive) in H1-2026, 8.53% of same-type related-party transactions. Related party because a BYD board secretary sits as a Chengxin director. Corroborates an accounts-receivable balance from 深圳比亚迪汽车实业有限公司 (Shenzhen BYD Auto Industry Co., Ltd.) on the same filing's related-party note (p.135).
Chengxin's 2026 H1 report (p.31-32): sales/processing of lithium products to the two Langsheng entities, combined RMB 891,187,000 (含税) in H1-2026, 10.72% of same-type related-party transactions. Related party: both are controlled by Chengxin's own controlling shareholder, Shengtun Group (盛屯集团).
Chengxin's 2026 H1 report (p.32): sales of lithium products to CALB (HKEX: 3931), RMB 1,625,974,400 (含税) in H1-2026 -- the single largest related-party sales line, 19.55% of same-type related-party transactions. Related party ONLY because CALB signed a conditional share-subscription agreement (2025-10-31) to take >5% of Chengxin; that agreement was TERMINATED 2026-07-13, so future periods may not carry this related-party classification even if the trading relationship continues -- re-check status at the next filing.
Chengxin's 2026 H1 report (p.32): sales of lithium products to Huayou Holding Group and subsidiaries/affiliates, RMB 1,388,004,800 (含税) in H1-2026, 16.69% of same-type related-party transactions. Huayou Holding Group is the controlling shareholder of Zhejiang Huayou Cobalt Co., Ltd. (SSE 603799, tracked separately in this corpus as `huayou-cobalt`) -- it is the PARENT holding vehicle, a distinct legal entity from the listed company, so no `dossier_slug` link is set here. Related party ONLY because of the same now-terminated (2026-07-13) share-subscription agreement noted for CALB above -- re-check status at the next filing.
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.
0 of 1 of your scored CRMA-strategic material 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 |
|---|---|---|---|---|---|---|---|---|---|
| Lithium | 🇨🇳 CN 65% refining | 32 | 61 | Low | within 65% | High | some | 40 | ▲ 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 |
|---|---|---|---|---|---|---|
| Lithium | 4 | 3 | 5 | 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.
+ 25 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: 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 — Lithium — is a material Chengxin Lithium 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 2026-10-05) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 6 restrictive actions on Lithium since 2021 — cadence accelerating (mean gap 339d → 306d), severity flat (3.3 → 2.7).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 1 of these 13 materials (Lithium) — your binding Lithium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 20.8 months apart across 4 distinct restriction dates since 2021 (n=3 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime | 32 | 34 | +2 |
| Concentration | Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly) | 32 | 39 | +7 |
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 Chengxin Lithium 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.
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.
Every scored material here is one Chengxin Lithium 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 2026-08-06; 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
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