Geopolitical Supply-Risk Report·EU CRMA Art. 20–25 assessment·MacroLens · CiconiaLabs

China Minmetals Corporation

7 critical materials scored · binding chokepoint: Cobalt (🇨🇳 CN 78% of refining) · 124 restrictive government measures on record

Subject

china-minmetals-corporation · 🇨🇳 CN

Sector

commodity-trading

Materials scored

As of

2026-09-30

Ownership re-checked · exposure claims not re-checked since fill

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.

Risk Office verdict

Moderate · 53/100Exposure claims not re-checked since fillCompany supply-risk index · consumer-side read

Role check · this company is a producer, not a buyer

China Minmetals Corporation produces 7 of the 7 scored materials above (Cobalt, Copper, Zinc, Tungsten, Antimony, Tin, Aluminium). 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 2026-10-05) — 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 Cobalt — 🇨🇳 CN controls 78% of global refining. On this company's production footprint that scores 62/100 (neutral exposure; global 62). The register holds 124 restrictive government measures touching this company's materials — each traced to its primary source below.

Peer rank · Cobalt China Minmetals Corporation is the 529th-most-exposed of the 609 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.

Competitor cohort · commodity trading

China Minmetals Corporation ranks 20th of 22 verified commodity trading companies.

88🇩🇪 Deutsche Rohstoff AGTungsten
81🇨🇭 Mercuria Energy GroupTungsten
81🇯🇵 Sumitomo CorporationDysprosium
79🇱🇺 Traxys S.A.Dysprosium
73🇩🇪 Klöckner & Co SEManganese
71🇯🇵 Marubeni CorporationCobalt
69🇯🇵 Mitsui & Co., Ltd.Manganese
63🇸🇬 Trafigura GroupCobalt
62🇨🇾 Gunvor GroupCopper
61🇨🇦 Franco-Nevada CorporationRhodium-iridium
61🇯🇵 Itochu CorporationCopper
60🇯🇵 Mitsubishi CorporationPlatinum-palladium
60🇨🇭 Transamine Trading S.A.Lithium
59🇨🇭 Open Mineral AGLithium
53🇨🇳 China Minmetals CorporationCobalt

Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 6 further commodity trading 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 7 scored materials. Buyer-relative (first-order): weighted by where the company produces (CN 90% · PE 5% · BW 2% · AU 2% · CD 1%, 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

CN · Shizhuyuan Mine (Yizhang County, Chenzhou, Hunan) — tungsten + bismuth/molybdenum/tin/beryllium/fluorite polymetallic miningtungstenbismuthmolybdenumtinberyllium
PE · Las Bambas (via MMG) — copper mining, concentratecopper
BW · Khoemacau (via MMG) — copper mining, concentratecopper
AU · Dugald River and Rosebery (via MMG) — zinc mining, concentratezinc
CD · Kinsevere (via MMG) — copper cathode, cobalt byproductcoppercobalt

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.

China Minmetals Corporation

What they do

China Minmetals Corporation is a Beijing-headquartered, SASAC-owned state enterprise formed by the 2016 merger of the former China Minmetals Corporation and China Metallurgical Group Corporation (MCC). It is one of the world's largest metals and mining conglomerates, operating across three lines: base-metal mining and processing (via Hong Kong-listed MMG Limited and wholly-owned Hunan Nonferrous Metals Holding Group), metallurgical engineering and construction (MCC), and bulk-commodity trading and logistics (Shanghai-listed Minmetals Development). Unlike a pure trading house, Minmetals holds direct upstream production assets, giving it mine-level (not just trading-level) exposure to several scored critical minerals.

Critical-material exposure

Copper (bulk input) — MMG's Las Bambas mine (Apurímac, Peru) and Kinsevere mine (Katanga, DRC) are flagship group assets and place Minmetals among the world's larger copper miners. Risk sits mainly at the mine-jurisdiction level (Peru community/permitting blockades; DRC political and infrastructure risk).
Antimony (bulk input / structural) — Hunan Nonferrous subsidiary Hunan Gold operates the Xikuangshan mine, historically the world's largest and most concentrated antimony deposit ("Antimony Capital of the World"). China produces roughly 60% of global antimony supply, and antimony has been subject to Beijing's 2024-25 export-licensing regime — Minmetals sits on both the production and policy-conduit side of that exposure.
Tungsten (structural) — Hunan Nonferrous mines, smelts and processes tungsten alongside its antimony/tin lines; the group also holds a dedicated tungsten-materials arm, China Tungsten High-Tech.
Tin (structural) — Produced in the same Hunan Nonferrous mining/smelting chain as antimony and tungsten.
Zinc (structural) — MMG's Dugald River and Rosebery mines (Australia) plus Hunan-based Zhuzhou Smelter Group, one of China's largest zinc smelters, give Minmetals exposure across both mining and smelting stages.
Cobalt (trace / byproduct) — Recovered as a secondary product stream from MMG's Kinsevere copper mine in the DRC; a minor byproduct credit, not a dedicated cobalt operation.
Aluminium (structural) — Corrected 2026-09-17: the prior camaltd.com citation is now dead (403). Re-sourced to North China Aluminium's own site under the Minmetals corporate domain (ncanmt.minmetals.com.cn), which states the company is controlled by China Minmetals Group and produces aluminium sheet, coil/strip and battery/heavy-light-gauge foil.

Production footprint (added 2026-09-08, partial coverage): CN (Hunan Nonferrous, Zhuzhou Smelter Group, North China Aluminium and MCC's domestic engineering/construction base), PE (MMG's Las Bambas copper mine), CD (MMG's Kinsevere copper-cobalt mine), AU (MMG's Dugald River and Rosebery zinc mines), BW (MMG's Khoemacau copper-silver mine). GLEIF also lists group LEI entities in Bermuda, Hong Kong, Cayman Islands and the British Virgin Islands; these read as offshore financing/listing-holding vehicles (e.g. the Hong Kong shell for MMG's HKEX listing), not production sites, and are deliberately excluded — see ownership_note. No segment-level revenue/output split was sourced within this pass's budget, so countries are listed bare rather than with an invented weight (production_footprint_coverage: partial).

Note on rare earths: the sector-default stub for this dossier listed neodymium and dysprosium, reflecting Minmetals' historical ownership of Minmetals Rare Earth Group (one of China's former "Big Six" rare-earth SOEs). That stake and its operating control were transferred without compensation to the newly formed China Rare Earth Group Co. in January 2022 as part of Beijing's rare-earth consolidation. China Minmetals Corporation no longer controls rare-earth production, so rare earths are not carried as a current exposure.

Sources

China Minmetals — Wikipedia (re-checked 2026-09-08: confirms SASAC supervision, 2015/16 CMGC merger, MMG/MCC/Minmetals Development subsidiary structure)
Hunan Nonferrous Metals — Wikipedia (re-checked 2026-09-08: confirms wholly-owned subsidiary status, Xikuangshan antimony mine, and tungsten/tin/lead/zinc/gold operations)
Minmetals confirms China rare earths merger, creating new giant — MINING.COM
MMG Limited — Operations (checked 2026-09-08: Las Bambas, Kinsevere, Dugald River, Rosebery, Khoemacau mine list — this dossier's copper/zinc/production-footprint source)
MINING.COM — MMG bemoans Congo cobalt curbs that threaten investment (checked 2026-09-08: DRC cobalt export-quota impact on Kinsevere)
North China Aluminium New Materials Technology Co. (checked 2026-09-17: replaces dead camaltd.com [403] link; company's own site under the Minmetals domain, confirms Minmetals Group control and aluminium sheet/coil/strip/foil product line)
GLEIF — China Minmetals Corporation (LEI 3003002ULBI4T3DT7Z09) (ownership check, 2026-09-08)

Named counterparties — who actually buys and sells

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.

The full counterparty breakdownShow

Named suppliers (1)

Direction NOT READABLE — 1 counterparty is disclosed across two filings, but none carries figures that can honestly be compared. This is a gap in what the filer published, not a finding that nothing moved.

Read from the filer's own disclosed shares across vintages — what the company did, not pressure applied to it. Separate from every score on this page. “Unchanged” means every comparable move is under 2.0 points — a stated, arbitrary band, not a fitted one.

MMG Limitedlife of mine from 2014; FY2025 volume stated — → 2025-2027 — → 2026-2027 —not comparable · no share figure filedlife of mine from 2014; FY2025 volume stated ↗2025-2027 ↗2026-2027 ↗related party company-disclosure primary-source
life of mine from 2014; FY2025 volume stated · MMG Annual Report 2025, continuing connected transactions: Las Bambas CMN Copper Sale Framework Agreement (27 June 2014) for sale of Las Bambas copper concentrate 'to the CMN Group' (China Minmetals Non-ferrous Metals Co., Ltd., CMC subsidiary); offtake 'is for the term of the life of the Las Bambas mine'. 2025 cap 277,000 t Cu contained; 'approximately 240,000 tonnes of copper contained in copper concentrate were sold by MMG SA to members of the CMN Group' in 2025. Receiving smelter not named.source ↗
2025-2027 · MMG Dugald River Pty Ltd (Seller) signed the Dugald River Zinc Concentrate Sales Agreement (17 Feb 2025) with Minmetals North-Europe, 'a wholly-owned subsidiary of CMC, the ultimate controlling shareholder of' MMG -- disclosed by MMG as a continuing connected transaction. Quantity 'approximately 100,000-120,000 dry metric tonnes of Product (+/-10% at Seller's option) per annum' for 2025-2027, priced on LME zinc plus LBMA silver less an annually negotiated treatment charge; annual cap US$200.0m. Filing: 'China is an important market for zinc concentrate and the CMC Group has investments in several major Chinese zinc smelters which are in a position to process Dugald River zinc concentrates.'source ↗
2026-2027 · MMG connected-transaction announcement, 13 January 2026: Minmetals Album Company Limited (Macau, indirect wholly-owned subsidiary of CMC) buys 'approximately 36,000-48,000 dry metric tonnes' per contract year of Khoemacau (Botswana) copper concentrate from Khoemacau Copper Mining; annual cap US$220.0m for each of 2026 and 2027. 'China is an important market for copper concentrate and the CMC Group has investments in copper smelters which are in a position to process Khoemacau copper concentrates.'source ↗

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.

The exposure register

Ranked by buyer-relative risk, highest first.

2 of 4 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%	Low	some	37	▲ rising
Copper	🇨🇳 CN 48% refining	59	59	Elevated	within 48%	High	limited	52	▲ rising
Zinc	🇨🇳 CN 32% mining	44	37	Moderate	—	Med	ready	7	▲ rising
Tungsten	🇨🇳 CN 90% refining	38	76	Low	EXCEEDS 90%	Med	some	16	▲ rising
Antimony	🇨🇳 CN 78% refining	30	60	Low	—	High	limited	9	▲ rising
Tin	🇨🇳 CN 55% refining	30	56	Low	—	Med	ready	18	▲ rising
Aluminium	🇨🇳 CN 61% refining	21	40	Low	within 61%	Med	some	43	▲ 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 ↗

Supply-risk factor analysis

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.

The factor-by-factor analysisShow

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
Zinc	4	2	3	3	2	company input
Tungsten	4	4	5	3	3	company input
Antimony	4	3	1	3	4	company input
Tin	4	2	5	2	3	company input
Aluminium	4	3	1	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.

Material factors (scored 4–5) — evidence

Cobalt
- 4Geopolitical: 37 restrictive actions, peak severity 5, 24 in last 24mo, less 4 liberalising actions
Copper
- 4Geopolitical: 52 restrictive actions, peak severity 5, 33 in last 24mo, less 3 liberalising actions
- 5Price / market: price up, as of 2026-09-01
- 4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 70/100 (long-horizon, all major uses). Prior analyst short-run rating 0.50: USGS: aluminium substitutes in some electrical/heat-exchange uses
Zinc
- 4Geopolitical: 7 restrictive actions, peak severity 4, 3 in last 24mo
Tungsten
- 4Geopolitical: 16 restrictive actions, peak severity 5, 10 in last 24mo, less 2 liberalising actions
- 4Concentration: refining HHI 8126 (extreme); top CN 90%
- 5Price / market: price up, as of 2026-09-01
Antimony
- 4Geopolitical: 9 restrictive actions, peak severity 4, 6 in last 24mo, less 3 liberalising actions
- 4Import reliance: Eurostat Comext 2025: 74% extra-EU imports, top partner TJ 50% (partner HHI 2847)
Tin
- 4Geopolitical: 18 restrictive actions, peak severity 4, 13 in last 24mo
- 5Price / market: price up, as of 2026-09-01
Aluminium
- 4Geopolitical: 43 restrictive actions, peak severity 5, 26 in last 24mo, less 1 liberalising action

Named refiners in the supply base

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.

The named refinersShow

Tungsten

China = 54% of filer-disclosed refiner mentions · 291 named refiners

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

Tin

China = 28% of filer-disclosed refiner mentions · 879 named refiners

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.

Change log

last 30 days

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.

2026-09-30filedIndia Ministry of Mines launches first offshore mineral block auction (Andaman Sea)
2026-09-17filedUS Commerce Preliminary Affirmative Antidumping Determination: Tin Mill Products from China (September 2026)
2026-09-15filedUS Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)
2026-09-11amendedIndonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform— Kepmen ESDM No. 363.K/MB.01/MEM.B/2026 supersedes the Kepmen 144/2026 HPM formula for low-grade limonite: the nickel Correction Factor (CF) for 1.2%-Ni-or-lower ore is reset to 14% (falling 1pp per 0.1pp of grade below that), and the cobalt by-product coefficient is cut from 30% to 17%. Net effect on 1.2%-Ni ore: HPM falls ~45%, from USD 44.97/wmt to USD 24.89/wmt. The change targets the low-grade limonite/HPAL feedstock segment specifically — the 1.6%-grade CF set by 144/2026 is not disclosed as changed in available reporting.

The laws that threaten it

Restrictive government measures on this company's materials, newest first — each links to its primary government source.

The full list of lawsShow

🇮🇳 India Ministry of Mines launches first offshore mineral block auction (Andaman Sea)New since 2026-09-05
2026-09-30· industrial-policy· severity 2· cobalt, nickel, manganese, copper
🇺🇸 US Commerce Preliminary Affirmative Antidumping Determination: Tin Mill Products from China (September 2026)New since 2026-09-05
2026-09-17· tariff· severity 4· tin, steel
🇺🇸 US Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)New since 2026-09-05
2026-09-15· tariff· severity 4· tin, steel
🇨🇦 Canada expands counter-tariffs on US goods to CA$27.6bn, matching US Section 338/232 tariffs dollar-for-dollar
2026-08-26· tariff· severity 4· steel, aluminium
🇺🇸 BIS DPAS Directive Allocation Order — 100% domestic-sale mandate for black mass and tungsten waste/scrap
2026-08-06· export-control· severity 4· lithium, cobalt, nickel, manganese
🇵🇪 Peru DS 014-2026-EM — Mining exploration DIA fast-track platform threshold raised 40→60
2026-07-20· regulatory· severity 2· copper
🇨🇳 China MOFCOM Announcement No. 27 [2026] — 20 more Japanese entities incl. National Institute for Defense Studies added to Control List
2026-06-29· export-control· severity 4· rare-earths, gallium, germanium, antimony
🇨🇳 China MOFCOM Announcement No. 26 (2026) — Strategic Mineral Export Control Reporting and Whistleblower Mechanism
2026-06-24· regulatory· severity 2· rare-earth-elements, gallium, germanium, antimony
🇺🇸 US USTR Section 301 Determination — Proposed 25% Tariff on All Brazilian Goods
2026-06-04· tariff· severity 3· niobium, copper, iron-ore
🇿🇦 South Africa: Industrial Development Strategy 2026 — Permit-Conditioned Beneficiation Mandate for Critical Minerals
2026-06-03· industrial-policy· severity 3· chrome, platinum-group-metals, cobalt, lithium
🇺🇸 US USTR Section 301 Forced Labor Findings and Proposed Action — 60 Economies
2026-06-02· tariff· severity 3· cotton, polysilicon, cobalt, lithium
🇺🇸 US Proclamation 11032 — Further Adjusting Section 232 Tariff Regimes for Aluminum, Steel, and Copper
2026-06-01· tariff· severity 2· aluminum, steel, copper
🇨🇩 DRC Ministerial Suspension of All Mining in Mwenga and Shabunda (South Kivu)
2026-05-22· regulatory· severity 3· gold, coltan, cassiterite
🇨🇳 China State Council Order No. 839 — Regulations for the Implementation of the Mineral Resources Law
2026-05-20· regulatory· severity 3· rare-earths, gallium, germanium, antimony
🇪🇺 EU-US Trade: Political Agreement on Implementing Regulations for Joint Statement Tariff Commitments
2026-05-20· tariff· severity 3· steel, aluminium

+ 109 more in the register.

Art. 24(2)(c) · vulnerability to disruption

Stress test — two plausible scenarios

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:

Both stress-test scenariosShow

Policy shock — the controlling country escalates to a full export-licensing / ban regime.
Concentration shock — the supply structure collapses to a single source (second-source loss / full monopoly).

Which of your plants carries the binding exposure

Under the 🇨🇳 CN shock, your disclosed plant carries the binding Cobalt exposure:

🇨🇩 CD · Kinsevere (via MMG) — copper cathode, cobalt byproduct

Disclosed plant-level detail matched to the binding material — descriptive, from the company's own disclosures; a plant not listed here is undisclosed, not unexposed. Country weights still drive the score above.

Closest real precedent — an output-market event, not a supply vulnerability

Indonesia hilirisasi ladder — battery-mineral extension

value-chain ladder (material-set)

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 China Minmetals Corporation 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.

Trace the precedent to its primary source via the link above (/actions/2023-06-10-indonesia-bauxite-ore-export-ban). Producer/consumer side is taken from an explicit dossier 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 2 restrictive actions on Cobalt since 2016, severity flat (5.0 → 3.0).A descriptive trajectory of past official actions — not a forecast.

🇨🇳 CN's demonstrated restriction sequence — has restricted 22 materials since 2016, in this demonstrated order:

You hold exposure to 5 of these 22 materials (Cobalt, Copper, Aluminium, Antimony, Tungsten) — your binding Cobalt exposure is one of them.

Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 3.6 months apart across 10 distinct restriction dates since 2016 (n=9 intervals).

Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —

🇺🇸 US has historically countered a median of 3.9 months later (n=23 recorded episodes since 2024). Counter-move intensity: median severity 3/5 (3 of 23 via quantified basis).
🇮🇳 IN has historically countered a median of 9.9 months later (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5 (0 of 4 via quantified basis).

Descriptive history of recorded counter-actions in our causal register — not a forecast; the gap is what the controller's past moves drew in response.

Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —

when 🇨🇳 CN restricts your Cobalt, 🇺🇸 US has historically countered (median 3.9 months later) — and those counter-moves have also restricted Copper, which you also depend on (n=9 recorded episodes since 2025). Counter-move intensity: median severity 3/5, hardest 4/5 (1 of 9 via quantified basis).
when 🇨🇳 CN restricts your Cobalt, 🇺🇸 US has historically countered (median 3.9 months later) — and those counter-moves have also restricted Zinc, which you also depend on (n=3 recorded episodes since 2025). Counter-move intensity: median severity 3/5, hardest 4/5 (0 of 3 via quantified basis).
when 🇨🇳 CN restricts your Cobalt, 🇺🇸 US has historically countered (median 10.1 months later) — and those counter-moves have also restricted Antimony, which you also depend on (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5, hardest 4/5 (0 of 4 via quantified basis).

Descriptive history of recorded counter-actions in our causal register, intersected with your dependency basket — not a forecast; it shows where a controller's past retaliations have landed across your materials.

The ordered history of what this controller has restricted, each step traced to /actions/{id} — a descriptive sequence, not a forecast.

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	Zinc — 🇨🇳 CN escalates zinc controls to a full export-licensing / ban regime	44	55	+11
Concentration	Zinc — 🇨🇳 CN becomes the single source for zinc — the second source is lost (full 32%+ monopoly)	44	81	+37

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.

Art. 24(4) · mitigation trigger

Significant-vulnerability conclusion

No material crosses the significant-vulnerability threshold on the input side — every scored material here is one China Minmetals Corporation 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 7 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 — not yet law

Upcoming regulatory threats

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.

The upcoming threatsShow

🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)
passed-vote→high likelihood·flagged 55d ago · not yet law·matches Copper, Cobalt
If passed — On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
Caveat — ENACTED / already in force (signed 29 June 2026, five independent Congolese/international outlets corroborate the ministers, date and substance) but parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. cd unreachable per prior wakes — same constraint noted on the DRC Strategic Mineral Reclassification, ARECOMS forfeiture, and 5% Worker Equity entries elsewhere in this file). DISTINCT from: 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (ARECOMS sectoral cobalt-hydroxide quota system, cobalt-only), 2025-12-19-drc-artisanal-copper-cobalt-processing-suspension (artisanal-sector only), the queued ARECOMS H1-2026 quota-forfeiture entry above (operationalises the ARECOMS quota, not this arrêté), 2026-04-10-drc-strategic-reserve-minerals-arecoms, and 2026-05-29-drc-strategic-mineral-expansion-decree. This arrêté is the FIRST instrument in the register banning concentrate exports for BOTH copper and cobalt jointly and replacing the 2023 commercialisation/export/nomenclature framework wholesale — a materially broader legal basis than any of the above. Re-check mines. gouv. cd and jocc.
https://actualite.cd/2026/08/06/rdc-kinshasa-interdit-lexportation-des-concentres-de-cuivre-et-de-cobalt-pour-encourager
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇬🇳 Guinea — Ministry of Mines plan to reduce bauxite export volumes to support prices (differential quota/allocation tied to downstream-investment commitments)
announced→low likelihood·flagged 66d ago · not yet law·matches Aluminium
If passed — On 18 March 2026 Guinea's Minister of Mines Bouna Sylla told Reuters that Guinea — the world's top bauxite exporter (~40% of global seaborne supply, 2025 exports ~183 Mt, +25% y/y) — would reduce export volumes "in the coming weeks" to support prices and protect small producers, explicitly declining to call it a formal quota ("it is not really a quota, but we will reduce the volumes we export") and ruling out an outright ban. The plan requires major miners (SMB, Chalco/Winning-linked entities, CBG) to submit three-year production plans aligned with their downstream/alumina-investment commitments, with an unofficial target of cutting annual exports toward ~150 Mt. As of end-June 2026 no formal decree had been issued; market reporting through June/July 2026 still describes the mechanism as pending/rumoured. Distinct from all filed Guinea actions (bauxite reference-price arrêté 2022, GUITRAM freight mandate, GAC/EGA concession revocation+settlement, Chalco/SPIC alumina refinery deals, June 2026 raw-gold export ban) — none of which is a bauxite export-volume/quota control. Materiality: Guinea is the Step-0. 5 priority-tier chokepoint for bauxite (feeds the aluminium value chain); a formal quota would be the first-ever volume control on Guinea's dominant bauxite export stream.
Caveat — gov. gn/Journal Officiel instrument or a specific quota tonnage figure attributed to government.
https://www.agenceecofin.com/actualites-industries/1903-136782-bauxite-la-guinee-vise-d-ici-avril-un-plan-pour-limiter-l-export-et-soutenir-les-prix
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 66d ago · not yet law·matches Copper, Cobalt
If passed — Minister of Finance, acting under s. 89 of the Customs and Excise Act, cut the copper-concentrate export duty to ZERO for tariff headings 2603. 00. 21 / 2603. 00. 22 / 2603. 00. 23 / 2603. 00. 29, capped at 271,742 t, effective 1 June 2026 with automatic lapse 30 September 2026, with per-entity tonnage caps and (per one secondary) a requirement that exempt shipments channel through Industrial Resources Limited. This is a SUPPLY-RELIEF (liberalising) action — a net EASING of a copper/cobalt chokepoint for ~4 months, explicitly to clear stockpiled unprocessed concentrate while Zambia's major smelters are down for extended maintenance. It is the "(No. 2)" successor instrument to the already-filed 2026-03-05-zambia-si-15-2026-copper-concentrates-export-duty-suspension (a distinct SI with its own number, tonnage cap and validity window). Severity ~2 expected.
Caveat — ENACTED / already in force per multiple independent secondary sources (all agree on SI number, exact citation title, s. org URL pattern that resolves for the parent SI 15/2026 (`/akn/zm/act/si/2026/43/eng@<date>`) across several plausible dates, all 404; zambialii's SI-list index page for 2026 also 404s directly. Parked here per the standing verify-or-don't-file convention (cf. DRC ARECOMS, Pakistan chloroform, China sulfuric-acid entries below) rather than filed on secondaries alone. Re-check zambialii.
https://www.zambiamonitor.com/govt-suspends-export-duty-on-copper-concentrates/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 66d ago · not yet law·matches Cobalt, Copper, Aluminium
If passed — On 10 July 2026 the African Development Bank Group, with the African Union Commission, the AfCFTA Secretariat and UNECA, convened African ministers of mining/energy/industry in Abidjan for the "Ministerial Forum on Critical Minerals Value Chain and Beneficiation: Pathways for African Transformation". The stated ambition is continental: move the bloc off raw-ore exports toward regional value chains and in-country processing, with reporting of a push to HARMONISE African mining legislation by end-2026 around a ban on unprocessed ore exports, alongside a headline mobilisation figure of ~USD 63bn for critical-minerals value-chain investment. Why this matters as axis-2 early warning rather than noise: the register already holds a dense cluster of INDIVIDUAL national instruments moving in exactly this direction — Zimbabwe's 2026-02-25 indefinite raw-mineral/lithium-concentrate export suspension, Guinea's 2026-06-19 raw-gold export ban + domestic-refining mandate, Gabon's announced 2029 crude-manganese export ban, Nigeria's RMRDC 30% value-addition bill, Indonesia-style downstreaming copied across the continent, and CEMAC's regional Common Mining Code (all already filed or queued). A binding AU/AfCFTA-level harmonisation instrument would convert that scattered set into a coordinated continental supply shock across cobalt, copper, bauxite, manganese and lithium simultaneously — which is a materially different exposure event from any single-country ban, because it removes the substitute-jurisdiction escape route that currently absorbs each national ban.
Caveat — DELIBERATELY likelihood=low, not moderate. com) is low-quality and was NOT relied on. AU-level harmonisation instruments historically take years and frequently stall at the model-law stage (cf. the known ecb-spf 400 pattern) to establish whether a formal Abidjan Declaration text exists and what it actually commits signatories to.
https://www.afdb.org/en/documents/high-level-ministerial-forum-critical-minerals-value-chain-and-beneficiation-pathways-african-transformation
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
- Aluminium🇨🇳 today 21→23+2
🇨🇩 DRC — ARECOMS forfeiture & reallocation of unused H1-2026 cobalt export quotas to the state strategic reserve (in force ~29 June 2026)
passed-vote→high likelihood·flagged 77d ago · not yet law·matches Cobalt
If passed — On ~29 June 2026 the Autorité de Régulation et de Contrôle des Marchés des Substances Minérales Stratégiques (ARECOMS) ordered that all first-half-2026 cobalt export quotas left unused by 30 June 2026 be forfeited and recovered, with a 5 July 2026 cutoff, and reallocated into ARECOMS's discretionary "strategic quota" pool (already ~10% of the 96,600 t/yr authorised volume) earmarked for national-interest local-processing projects. This is an escalation/operationalisation of the filed 2025-02-22 ARECOMS cobalt quota system: it concentrates additional volume under state discretionary control, tightens the effective free-market allocation for producers (Glencore/KCC, CMOC, ERG) on the world's dominant cobalt chokepoint (~76% of mine supply), and — via the linked customs-notification malfunction that blocked quota-linked export declarations after 1 July 2026 — created a real short-run supply interruption. IPTM action would be an AMENDMENT to 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system.
Caveat — ENACTED / already in force (not speculative) — parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. com, lentrevuemagazine, HCN Times). DISTINCT from filed 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (the quota framework this amends), 2026-04-10-drc-strategic-reserve-minerals-arecoms (the reserve's legal creation — this is the first operational feeding of that reserve via forfeited quotas), and 2026-05-29-drc-strategic-mineral-expansion-decree. Severity 3 expected.
https://news.metal.com/newscontent/103980228-smm-analysis-drc-announces-forfeiture-and-reallocation-of-unused-quotas-in-h1-2026-to-strategic-quotas
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Cobalt🇨🇳 today 62→67+5
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 72d ago · not yet law·matches Copper
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
https://www.spglobal.com/energy/en/news-research/latest-news/metals/041526-chinas-sulfuric-acid-restrictions-set-to-squeeze-miners
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
🇬🇳 Guinea — Nimba Mining Company (NMC, 100% state-owned) / Glencore bauxite pre-financing and marketing agreement
announced→low likelihood·flagged 13d ago · not yet law·matches Aluminium
If passed — On 7 September 2026 Guinea's state-owned Nimba Mining Company and Glencore signed a five-year pre-financing agreement, announced by the government and Glencore on 10 September 2026, worth over USD 300 million and covering marketing of 10-12 Mt/yr of bauxite (50-60 Mt over the contract term) — a trader advance repaid via physical bauxite delivery rather than conventional debt. Minister of Mines and Geology Bouna Sylla is quoted on-record calling the signing a milestone for Guinean state participation in the mining value chain, and Guinea is separately reported discussing alumina-refining and energy investment with Glencore. This sits alongside the register's other Guinea bauxite-sector state-control instruments (2022 reference-price arrêté, GUITRAM freight mandate, GAC/EGA concession revocation, the parked export-volume-reduction plan below) and is part of the government's "Simandou 2040" push to expand national participation in extractives. Theme candidate: em-resource-upstream-capture. Polarity: none declared (a financing/offtake deal, not a restrictive or liberalising regulatory measure — but materially entrenches state-company control of a bauxite export stream at Guinea's dominant chokepoint, ~40% of global seaborne bauxite supply).
Caveat — gov. gn directly (reachable, HTTP 200) and searched its site for "Nimba Glencore" (no results); a mining. com direct fetch also 403'd. Parked here per verify-or-don't-file rather than filed on secondaries alone. Distinct from the already-parked "Guinea — Ministry of Mines plan to reduce bauxite export volumes" entry below (a volume-quota policy proposal, not this specific NMC-Glencore commercial financing/offtake contract).
https://www.mining.com/web/guinea-discussing-alumina-energy-investments-with-glencore-after-bauxite-deal-minister-says
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Cobalt
If passed — Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
Caveat — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
https://www.madini.go.tz/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Cobalt🇨🇳 today 62→67+5
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 98d ago · not yet law·matches Copper
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
https://senate.parlam.kz/en-US/news/details/14628
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 99d ago · not yet law·matches Copper, Cobalt
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in advanced negotiations to acquire a 15-20% equity stake (deal value ~USD 1. 5-2bn) in First Quantum Minerals' Zambian copper and nickel operations — i. e. the Kansanshi and Sentinel/Trident copper complex (Zambia's largest copper mines, ~0. 4-0. 5 Mt/yr combined) plus nickel. This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) directly into a binding African copper chokepoint, paralleling Manara's filed Vale Base Metals 10% stake (2024-03-01-sa-manara-minerals-vale-metals-10pct-stake) and its in-negotiation Reko Diq stake (queued below), and mirroring UAE IRH's Mopani (Zambia) acquisition. Gives Saudi Arabia an equity claim on a major non-China copper supply source and injects fresh capital into FQM as it recovers from the Cobre Panamá shutdown — a Gulf-capital re-pricing of Zambian copper supply risk that the exposure engine should track.
Caveat — As of 2026-06-28 this is in advanced negotiation, no signed SPA — hence announced/upcoming not enacted. DISTINCT from the Reko Diq (Pakistan) Manara stake queued below (different asset, different host country) and from the filed Vale Base Metals 10% stake. If completed, severity 2-3.
https://www.miningsee.eu/saudi-arabias-manara-minerals-eyes-stake-in-first-quantums-zambian-copper-and-nickel-assets/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Copper, Cobalt
If passed — First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2447259
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Cobalt
If passed — Second wave of CRMA Art. 14 strategic projects (drawn from 160+ applications: 95 EU-domestic + 66 third-country including 40 from strategic-partnership countries) gains fast-track permitting (27-month EU cap, 15-month Member State cap), EIB/EBRD financing-hub priority, and off-taker certainty; 75 battery-value-chain projects + 21 REE-for-permanent-magnets in pool; widens the EU's 2030 extraction/processing benchmarks pipeline beyond the first 60 projects
Caveat — Second call for applications closed January 15, 2026 (September 2025 launch). Commission stated ~4-month assessment period → designation expected May–June 2026. As of 2026-06-15, no Commission press release or OJ publication confirmed. EUR-Lex CELEX 32026D0923 verified via web search to be an unrelated EU animal-disease implementing decision. Moved from filing. md 2026-06-15. Distinct from: 2025-03-25-eu-crma-strategic-projects-first-designation (60 projects, first round) and 2024-05-23-eu-crma-entry-into-force (base regulation). Severity 3 expected (same as first-round designation).
https://single-market-economy.ec.europa.eu/news/strategic-projects-critical-raw-materials-gain-momentum-second-selection-round-potential-funding-and-2026-01-19_en
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Cobalt🇨🇳 today 62→67+5
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 113d ago · not yet law·matches Tungsten
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
https://www.mining.com/web/congo-adds-lithium-to-strategic-minerals-in-higher-tax-bracket
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Tungsten🇨🇳 today 38→40+2
🇬🇳 Guinea Bauxite Export Volume Controls 2026
announced→low likelihood·flagged 114d ago · not yet law·matches Aluminium
If passed — GN ≈ 60% global seaborne bauxite; a ~150 Mt/yr cap (vs 183 Mt 2025) tightens the alumina→aluminium chain — direct hit to EU aluminium-vertical names
Caveat — ministerial-announcement stage since 2026-06-01; repeatedly skipped by filing for lack of a gazetted decree — relocated here 2026-06-13. Sev 3 if decree issued, sev 2 if still announcement-stage.
https://www.bloomberg.com/news/articles/2026-05-25/top-bauxite-producer-guinea-to-unveil-export-controls-in-june
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 114d ago · not yet law·matches Tin, Tungsten
If passed — Mandates 15% free-carried interest for Uganda National Mining Company (UNMC) in all new mining licences; introduces mandatory mineral buying centres; tightens local-content and value-addition obligations — changes joint-venture economics for all new Ugandan mining operations, raising effective cost-of-entry for foreign miners
Caveat — Amends the already-filed Uganda Mining and Minerals Act 2022 (UG action 1); expected to be enacted before end of 2025/26 parliamentary session per legal commentary; Bank of Uganda gold purchase programme and new mineral buying centres already being piloted — regulatory infrastructure being built ahead of formal enactment. Distinct from filed Uganda Gold Export Regulations 2024 (SI No. 30 of 2024).
https://globallawexperts.com/uganda-mining-law-changes-2026/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Tin🇨🇳 today 30→31+1
- Tungsten🇨🇳 today 38→40+2
🇮🇩 Indonesia Tin Export Ban — Downstreaming Initiative
announced→low likelihood·flagged 113d ago · not yet law·matches Tin
If passed — Indonesia = ~20% of global refined tin exports (Bangka Belitung); a ban on refined-tin exports would force downstream solder/semiconductor-packaging manufacturing domestically; disrupts global electronics and EV supply chains dependent on Indonesian tin solder and specialty alloys
Caveat — Minister of Energy and Mineral Resources Bahlil Lahadalia announced government "studying" tin export ban on February 13, 2026 at the Indonesia Economic Outlook, Jakarta; framed as replication of 2020 nickel ore ban which claimed 10x value-add uplift; key complication — Indonesia already exports refined tin (not raw ore), so a ban would require immediate creation of advanced downstream industries (solder, electronic-grade tin, semiconductor components) that don't yet exist at scale; Mining Weekly (Feb 13 2026) and BERNAMA (Feb 2026) confirm announcement; no Perpres, PP, or Kepmen issued as of June 14, 2026; government described as "studying" — not yet in formal regulatory drafting. Distinct from filed Indonesia nickel ore export bans (2019, 2023), filed bauxite export ban, and filed Permendag export-licensing amendments.
https://indonesiabusinesspost.com/6137/policy/indonesia-s-potential-tin-export-ban
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Tin🇨🇳 today 30→31+1
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches Tin, Zinc
If passed — Prohibits raw mineral exports unless 30% value-addition achieved domestically; affects Chinese mining companies (dominant in Nigerian critical minerals sector), Western offtake agreements, and all foreign-invested mining JVs; builds on existing eMC+ digital cadastre and mandatory value-addition plans introduced Nov 2024; could force processing-plant investment or suspension of raw mineral shipments from Africa's most populous economy; RMRDC = Raw Materials Research and Development Council (the sponsoring agency)
Caveat — Bill passed third reading in House of Representatives; multiple Nov 2025 sources confirm both chambers approved; as of 2026-06-14 presidential signature not yet confirmed. Distinct from filed Nigeria Tax Reform Acts 2025 (Loi n°1/19 tax restructuring) and Mining Cadastral licence revocations (2025-06-19). Applies to ALL raw materials, not minerals only — IPTM relevance is the mineral export provisions.
https://www.nationalaccordnewspaper.com/turning-point-for-nigeria-as-rmrdcs-30-value-addition-bill-nears-presidential-assent/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Tin🇨🇳 today 30→31+1
- Zinc🇨🇳 today 44→55+11
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 113d ago · not yet law·matches Copper, Zinc
If passed — Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mining concessions for first time in Peruvian law history, making concessions revocable by administrative authority; introduces higher annual fees and stronger production/investment requirements; threatens legal certainty for Peru's undeveloped copper and silver project pipeline — Peru = #2 copper, #4 silver, #1 lead, #2 zinc globally
Caveat — Approved by Energy and Mining Commission March 17, 2026 by 11 votes to 1 with 3 abstentions — driven by left-aligned Juntos por el Perú (JPP) and Podemos Peru majority. Bill also introduces "comuneros como accionistas" (community shareholders) in mining concessions — first legislative insertion of indigenous community equity rights. MINEM, SNMPE, ComexPerú, and Ingemmet publicly opposed; MINEM warns reform would incentivise illegal mining expansion. Full plenary debate pending as of June 2026. Distinct from all filed PE actions (all executive/regulatory decrees — no prior legislative amendment to Ley General de Minería in register). Also distinct from filed PE actions on REINFO extension (2025-12-26), illegal-mining criminalization (2026-01-20), and Tía María revocation (2026-03-19).
https://elcomercio.pe/economia/peru/comision-de-energia-aprueba-cambios-en-la-ley-de-mineria-y-reaviva-alertas-por-impacto-en-inversion-y-estabilidad-juridica-noticia/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 59→63+4
- Zinc🇨🇳 today 44→55+11
🇸🇱 Sierra Leone No Raw Minerals Export Commitment (VP Jalloh, Mining Week May 2026)
announced→low likelihood·flagged 113d ago · not yet law·matches Aluminium
If passed — VP declared no new large-scale mining agreement will be concluded without a binding value-addition commitment; Mines Minister referenced Zimbabwe, Tanzania, Ghana, and Malawi precedents for raw-mineral export bans; if codified as a Statutory Instrument or Finance Act amendment, would impose export duties or licensing requirements on unprocessed rutile (Sierra Rutile / Iluka/Anglo American), ilmenite, zircon, bauxite, and diamond rough from new concessions; SL = world's top-5 rutile producer — a value-addition mandate on rutile concentrates would affect the entire global TiO2/titanium feedstock supply chain
Caveat — Declared May 2026 at Mining Week (coinciding with 2026-2031 National Critical Minerals Strategy launch, already filed). VP wording "new large-scale mining agreement" suggests concession-by-concession contract conditionality rather than a blanket statutory export ban; no bill, statutory instrument, or gazette reference found as of 2026-06-14. Distinct from SL CI national strategy (2026-05-20, filed) and SI 11/2024 SLMMDMC asset allocation (2026-06-02, filed as amendment to SLMMDMC Act).
https://www.switsalone.com/sierra-leone-hosts-2026-mining-week-launches-critical-minerals-strategy/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Cobalt, Tungsten
If passed — Establishes the first legally binding "safe level" benchmark for EU strategic stocks of each of the 17 strategic raw materials listed in the CRMA Annex I; benchmarks used as reference by Member States, financial institutions, and industrial consumers to assess strategic supply risk; mandated every 2 years, so this is the first edition setting the baseline; informs CRMA Art. 23 monitoring obligations and is the evidential basis for Art. 24 corporate-reporting thresholds
Caveat — The May 24, 2026 deadline set by Parliament and Council in Reg. (EU) 2024/1252 has now passed. No OJ publication confirmed as of June 15, 2026 — Commission may have adopted quietly or is overdue. This is the first CRMA Art. 22 benchmark cycle and is legally distinct from: (1) the CRMA base regulation (filed 2024-05-23); (2) the Strategic Projects first designation (filed 2025-03-25); (3) the RESourceEU Amendment — CRMA revision (filed 2026-03-04). If confirmed adopted, severity=2 (establishes the measurement baseline for EU strategic material supply risk assessment and directly feeds corporate Art. 24 reporting obligations). Distinct from all filed EU-CRMA actions. Not in filing. md or upcoming. md.
https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Cobalt🇨🇳 today 62→67+5
- Tungsten🇨🇳 today 38→40+2
🇪🇺 EU CBAM Scope Expansion to ~180 Downstream Steel/Aluminum Products (COM(2025) 989 final)
draft-published→moderate likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Extends the Carbon Border Adjustment Mechanism from the existing Regulation (EU) 2023/956 sectors (steel, aluminium, cement, fertilisers, hydrogen, electricity) to approximately 180 downstream products with high steel and/or aluminium content — including car parts, domestic appliances (refrigerators, washing machines), power transformers, cables, farming machinery, construction products, and a wide range of industrial equipment; ~2. 5% additional EU imports brought into CBAM scope; entry-into-force proposed from 1 January 2028; also introduces new anti-circumvention provisions (concept of "abusive practices" in proposed Art. 3(35)) targeting operators who split shipments or route via third countries to avoid CBAM liability; affects manufacturers in third countries (China, India, Vietnam, Turkey, ASEAN) that export steel- and aluminium-intensive goods to the EU; raises cost of embedded carbon in European supply chains for all downstream industrial inputs; structurally adjacent to CBAM definitive-phase commencement (January 1, 2026, already filed) — this is a legislative extension, not an implementing regulation
Caveat — Public consultation on downstream scope extension ran July 1 – August 26, 2025 (taxation-customs. ec. europa. eu); Commission adopted proposal December 17, 2025 alongside CBAM implementing acts package; Parliament lead committee is ENVI; Council working group active as of early 2026; no trilogue date announced. Distinct from: filed 2023-05-10-eu-carbon-border-adjustment-mechanism-2023-956 (base regulation, original scope) and 2023-05-10-eu-cbam-definitive-phase-entry-into-force (January 1, 2026 definitive-phase transition). Likelihood is elevated (not high): political consensus on CBAM base regulation was strong, but downstream expansion faces pushback from importing industries and some Member States worried about competitiveness. Secondary: https://taxation-customs. ec. europa. eu/news/cbam-public-consultation-extension-cbam-downstream-products-2025-07-02_en
OSINT passage signals·signals lean strongly toward passage·EU · updated 2026-07-19
- ▲ Extends an already-in-force regime (not a new law) (strong) — This amends the existing CBAM Regulation (definitive period live since 2026) rather than creating a new instrument — extensions of in-force EU regulations carry high passage odds vs. novel files. source ↗
- ▲ Council general approach adopted (strong) — The Council reached a general approach on the downstream extension on Jun 12, 2026 — the Council leg of the ordinary legislative procedure is aligned, leaving EP plenary + trilogue. source ↗
- ▲ EP rapporteur appointed and progressing (moderate) — MEP Mohammed Chahim named rapporteur Feb 23, 2026; the Parliament file is moving through committee, not stalled. source ↗
- ▲ Metals industry broadly supportive (asks for more) (weak) — EU metals producers publicly called for the downstream scope to go even further — the affected domestic industry is not the opposition here, reducing blocking risk. source ↗
- ▼ Large new compliance burden (~7,500 importers) (weak) — Extending to ~180 downstream codes pulls in ~7,500 new importers; downstream-importer pushback could slow (not block) the file in trilogue. source ↗
Sourced OSINT observations, not a forecast — a qualitative second read beside the stage-derived band. We do not publish a passage probability of our own until the accrual record proves it is calibrated (never a fabricated %).
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52025PC0989
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
🇬🇳 Guinea Bauxite Export Volume Controls — Mines Minister Sylla Quota Regime (2026)
in-consultation→moderate likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Guinea = world's #2 bauxite producer (183 Mt exported in 2025, ~45% of China's bauxite imports); Mines Minister Bouna Sylla confirmed in March 2026 that export volume curbs will be applied by early April 2026 to halt a ~50% price collapse from 2025 overproduction; target cap ~150 Mt/yr (≈18% reduction from 2025 actual); enforced via licence compliance — operators exceeding feasibility-study production ceilings face volume restrictions, not an outright export ban; formal policy instrument expected June 2026 per Bloomberg/Mining. com; mechanism: production-cap enforcement rather than new legislation, but a ministerial arrêté is the likely vehicle
Caveat — Distinct from all 7 filed GN actions: distinct from 2025-07-14-guinea-guitram-freight-mandate (state shipping — different instrument), 2025-08-05-guinea-presidential-decrees-gac-ega (concession revocations — different target), 2026-05-21-guinea-chalco-alumina-refinery-boffa (investment agreement — not export control). This action is the first GN volume-cap mechanism targeting all bauxite exporters. Severity estimate: 3 (affects ~45% of China's bauxite import supply; price-floor mechanism with direct feedthrough to aluminium production costs for smelters globally). Filed in upcoming queue 2026-06-16 per chokepoint-tier gap (Guinea = key bauxite chokepoint). No formal arrêté confirmed as of 2026-06-16.
https://www.guineamininginsights.com/news-insights/guinea-implement-bauxite-export-curbs-early-april-push-stabilise-prices
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
🇬🇳 Guinea Alumina Refinery Ultimatum — SMB and CBG 10-Day Deadline to Submit Construction Timeline (June 2026)
announced→low likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Guinea's CNRD junta gives Societe Minière de Boke (SMB, China-linked, ~50% of Guinea's bauxite output) and Compagnie des Bauxites de Guinée (CBG, joint venture: Halco Mining/Alcoa/Rio Tinto/Dadco) 10 days to present binding alumina refinery construction timelines; May deadline was missed; government stated "the companies had already committed to developing local refineries"; failure to comply risks concession revocation or conditions — the August 2025 GAC/EGA revocation provides the enforcement precedent; Guinea government has publicly stated intent to move up the bauxite value chain toward alumina and aluminum
Caveat — Distinct from 2025-08-05-guinea-presidential-decrees-gac-ega (that action revoked GAC/EGA specifically; this action targets SMB and CBG, which are Guinea's two largest bauxite operators — combined ~70% of Guinea's total bauxite exports). Distinct from 2026-05-21-guinea-chalco-alumina-refinery-boffa (Chalco/Chinalco positive investment agreement — contrast: that was a new investor welcomed in; this is a threat to incumbents). If a revocation or binding condition follows, severity = 4 (SMB + CBG together = dominant share of global seaborne bauxite supply). Filed upcoming 2026-06-16.
https://www.mining.com/web/guinea-extends-deadline-for-bauxite-miners-to-present-refinery-plans/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇮🇩 Indonesia PP 19/2025 Mining Royalty Rate Hike — Implementation Postponed Indefinitely (May 2026)
announced→low likelihood·flagged 111d ago · not yet law·matches Copper, Tin
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
https://en.antaranews.com/news/415656/indonesia-delays-mining-royalty-and-export-levy-plan
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
- Tin🇨🇳 today 30→31+1
🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining Policy
passed-committee→elevated likelihood·flagged 110d ago · not yet law·matches Aluminium
If passed — Cabinet-cleared bill to replace the 2006 Minerals and Mining Act, Act 703: raises mining royalties from current 3–5% range to 9–12% (price-linked sliding scale), introduces a new medium-scale mining licence category bridging artisanal and large-scale operations, mandates district-level community and traditional-authority consultation before applications reach national regulators, scraps unlimited concession renewals (currently indefinitely renewable), and strengthens Ghanaian ownership provisions; National Mining Policy approved by Cabinet simultaneously; affects Newmont (Ahafo/Akyem), AngloGold Ashanti, Kinross (Chirano), Gold Fields (Tarkwa, post-Damang reversion), and Atlantic Lithium (Ewoyaa lithium project); royalty more than doubles at current gold prices — material cost increase for large-scale operators
Caveat — Distinct from all 6 filed GH actions: distinct from 2025-12-19-ghana-minerals-mining-royalty-regulations-2025 (those set sliding royalty under existing Act 703 — this bill replaces Act 703 entirely and raises the ceiling well beyond current regulations); distinct from 2026-03-13-ghana-growth-sustainability-levy-amendment (profit-based tax, not royalty); distinct from 2026-03-19-ghana-atlantic-lithium-ewoyaa-mining-lease and 2026-04-07-ghana-damang-engineers-planners-lease (specific lease grants, not legislation). The Green Minerals Policy (cabinet-approved July 2023, banning raw mineral exports) has not been separately enacted as of June 2026 — if the new Mining Act incorporates its provisions, that becomes the first statutory export restriction for Ghana's lithium and critical minerals. Filed upcoming 2026-06-17.
https://gna.org.gh/2026/06/govt-hints-scrapping-unlimited-years-of-mining-concession-renewals/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Aluminium🇨🇳 today 21→23+2
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 110d ago · not yet law·matches Tin, Zinc, Copper
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
https://www.mineria.gob.bo/index.php/nota_prensa/bolivia-activa-reforma-minera-integral-y-sale-a-captar-inversiones-con-respaldo-del-banco-mundial/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Tin🇨🇳 today 30→31+1
- Zinc🇨🇳 today 44→55+11
- Copper🇨🇳 today 59→63+4
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Cobalt, Copper
If passed — Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
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 ↗
https://ustr.gov/about/policy-offices/press-office/press-releases/2026/february/ustr-seeks-public-comment-design-plurilateral-agreement-trade-critical-minerals-and-policy-actions
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 109d ago · not yet law·matches Copper, Cobalt
If passed — Full replacement of the Mining Act 1992 with sweeping new statute: state acquires up to 30% equity in any new mining project (Kumul Minerals free-carry); special mining leases (SML) issued for initial 30-month periods with FID requirement to renew; mandatory landowner and community consultation before licence grant; Mining Development Authority (MDA) replaces current Mineral Resources Authority (MRA) as the sector regulator; CGT on extractive asset transfers now in force since the 2025 Income Tax Act (separate filed action); bill as drafted would reshape FDI terms for all existing and future mining permits including Wafi-Golpu (Newmont/Harmony 26 Moz Au, 4. 8 Mt Cu — SML long-delayed), Frieda River copper-gold (PanAust), and Ok Tedi expansion; PNG's 2023 Mining (New Porgera) Amendment Act handled Porgera separately
Caveat — The public-consultation-draft stage is already filed in the register as 2025-02-25-papua-new-guinea-mining-bill-2025 (filed action records the consultation launch). This upcoming entry tracks the NEXT stage: parliamentary enactment. Consultations closed April 4, 2025; minister aimed for September 2025 tabling but no confirmed passage found as of June 2026. Likelihood moderate — bill has broad government backing and a 15-year development history, but PNG legislative timelines are frequently extended; the May 2025 Marape cabinet reshuffle may have shifted ministerial priorities. Distinct from: 2023-10-13-papua-new-guinea-mining-new-porgera-amendment-act (single-mine statute); 2025-03-12-papua-new-guinea-national-petroleum-authority-act (petroleum, not mining); 2025-03-20-papua-new-guinea-income-tax-act-2025 (CGT on extractive transfers — already enacted separately).
https://www.businessadvantagepng.com/papua-new-guineas-draft-mining-bill-sweeping-reforms-to-overhaul-the-sector/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇬🇳 Guinea Ministry of Mines — Bauxite Export Volume Cap (~150 Mt/yr, 2026)
in-consultation→moderate likelihood·flagged 108d ago · not yet law·matches Aluminium
If passed — ~25% reduction in Guinea's annual bauxite shipments to China (150 Mt target vs. 183 Mt in 2025 and projected ~200 Mt unconstrained); directly re-prices alumina feedstock costs for Chinese refineries (Guinea supplies ~70% of China's imported bauxite); raises spot bauxite prices; affects CBG/Rio Tinto, SMB-Winning Consortium, Emirates Global Aluminium, UC RUSAL affiliates
Caveat — As of June 19, 2026 no formal decree text confirmed; mechanism described as "licence enforcement" (operators aligned to three-year production plans) not new legislation — formal finalisation expected June 2026. Once decree confirmed, migrate to filing. md as new action (action_type=export-control; sub: export-volume-cap / quota-allocation / bauxite; severity=3). Dedup gate: DISTINCT from 2025-07-14-guinea-guitram-bauxite-shipping-mandate (maritime routing mandate, not volume cap); DISTINCT from 2025-05-26-guinea-ministerial-order-129-mining-permits-revoked (permit revocations); DISTINCT from 2026-05-21-guinea-chalco-alumina-refinery-boffa (downstream investment, not export restriction). Filed upcoming 2026-06-19.
https://www.guineamininginsights.com/news-insights/guinea-implement-bauxite-export-curbs-early-april-push-stabilise-prices
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
CEMAC Common Mining Code — 6-member regional harmonisation (April 2026)
draft-published→moderate likelihood·flagged 107d ago · not yet law·matches Cobalt
If passed — If adopted, creates a unified mining regulatory framework across Cameroon, CAR, Congo-Brazzaville, Gabon, Equatorial Guinea, and Chad — harmonising licensing regimes, fiscal terms, transparency obligations (EITI, KP, ICGLR), and environmental standards; would affect Eramet/Comilog manganese operations (Gabon), Sundance Resources iron ore (CAR), Chinese mining JVs (Congo-Brazzaville, CAR), and uranium projects across the region; if enacted, creates a regional investment-guarantee architecture that could facilitate cross-border mining finance and reduce individual-country treaty risk; structural precedent for pooled resource sovereignty in a region where individual states are renegotiating contracts (Gabon post-coup Décret 0276/2024 sovereign-equity mandate, CAR post-KP-readmission, Congo-Brazzaville mining-code review)
Caveat — Consultation meetings held April 2024 (Brazzaville), July 2024 (Riaba/Malabo), February 2025 (regional review workshop), April 2026 (Douala finalization session) — code still in draft form as of April-May 2026; CEMAC has a historically slow ratification track record (Tariff Union took ~15 years to operationalise); likelihood low until formal adoption at heads-of-state summit; DISTINCT from individually filed national mining code reforms: Gabon Décret 0276/2024 (sovereign substances regime), CAR Law 24-008 (new mining code). Filed upcoming 2026-06-20.
https://www.financialafrik.com/en/2026/04/24/cemac-a-common-mining-code-as-a-lever-for-regional-investment/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Cobalt🇨🇳 today 62→67+5
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 101d ago · not yet law·matches Cobalt, Copper
If passed — TZ Finance Bill establishes the Mineral Research Fund capitalised at 10% of gross mineral revenue (~TZS 141 billion/yr at 2025 collection levels); amends the Income Tax Act to formally recognise tax exemptions granted under individual mining Framework Agreements and introduces standard operating procedures — reduces discretionary government risk for large mining investors (Panda Hill niobium, graphite juniors, Buzwagi gold); parallel VAT amendments give equivalent statutory certainty for VAT exemptions; taken together, the bill moves Tanzania from discretionary tax administration toward a rule-of-law-based investor regime for all critical-mineral projects; budget targets Tanzania for top-4 niobium producer status (Panda Hill DA already signed March 24, 2026) and 50% geophysical survey coverage by 2030
Caveat — Tanzania fiscal year starts July 1; the Finance Act signature typically occurs last week of June. Budget speech delivered June 11, 2026 by Finance Minister Khamis Mussa Omar; Parliament approved June 23. Mining provisions in §§ amending Income Tax Act (Cap. 332) and VAT Act (Cap. 148) and establishing the Mineral Research Fund. Distinct from: filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year), filed 2026-03-24-tanzania-panda-hill-niobium-ferroniobium-development-agreement (the specific project DA), and filed 2026-04-15-tanzania-ministry-of-minerals-revokes-40-idle-mineral-exploration-licences. Severity 2: institutional reform that de-risks the investor regime rather than a direct trade restriction.
https://www.tanzaniainvest.com/economy/budget-2026-2027-parliament-approved
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 104d ago · not yet law·matches Cobalt, Copper
If passed — All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension; effectively forces equity restructuring across the entire DRC copper-cobalt belt; miners seeking moratorium as of June 18, 2026 — enforcement outcome by August 2026 will set the precedent
Caveat — Ministerial enforcement letter issued January 30, 2026 by Mines Minister Louis Watum Kabamba — activates dormant Art. 71 bis (5% employee equity in mining company capital) and Art. 144 bis (mechanics) of DRC Mining Code (Loi n° 18/001). Filed here (not filing. md) because DRC government websites (mines. gouv. cd, primature. gouv. cd) remain inaccessible per prior wakes — same constraint as the DRC Strategic Mineral Reclassification entry. Action IS already in effect and enforcement is underway (July 31, 2026 deadline); this is NOT speculative. DRC Chamber of Mines convened June 11, 2026 industry response meeting; companies arguing retroactive application is legally contested. Severity 3 expected if enforced. Distinct from: 2018-01-27-drc-mining-code-revision (underlying law), 2026-04-10-drc-strategic-reserve (ARECOMS mechanism), 2026-04-24-drc-tshisekedi-mining-export-revenue-audit.
https://www.kitco.com/news/off-the-wire/2026-06-18/congo-miners-seek-delay-5-worker-equity-rule-july-deadline
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
🇬🇭 Ghana Minerals and Mining Act 703 Amendment — Cabinet-Approved Proposal (Royalty 9-12%, Lease Cuts, DA Abolition)
draft-published→moderate likelihood·flagged 104d ago · not yet law·matches Aluminium
If passed — Gold mining royalties rise from 3-5% to 9-12% sliding-scale (price-indexed); mining lease maximum cut 30→15 years with renewals limited to 2×10-year additional terms; Development Agreements and Investment Agreements abolished; stability period capped 30→5 years with labour/environment/H&S issues removed from stability protection scope; affects Newmont (Ahafo/Akyem), Gold Fields (Damang/Tarkwa), AngloGold Ashanti (Obuasi) and all major operators in Ghana's ~120 t/yr gold sector
Caveat — Cabinet approved proposed amendments and targeted parliamentary tabling by March 2026; as of June 2026 still pending Parliament (not yet enacted). The amendment is a primary statute overhaul of the Minerals and Mining Act 2006 (Act 703). DISTINCT from: 2025-12-19-ghana-minerals-mining-royalty-regulations (that LI set royalty rates under existing Act 703 — the amendment SUPERSEDES this LI's royalty structure AND adds structural changes); 2026-03-13-ghana-growth-sustainability-levy-amendment (mining levy reduction, separate statute); 2026-03-19-ghana-parliament-atlantic-lithium (individual mining lease ratification); 2026-04-07-ghana-ministry-lands-damang-mining-lease (lease award). Also distinct from the Minerals Commission localisation enforcement already filed (2026-02-18). Q2 2026 was the target passage window per King & Spalding — the bill may be delayed into H2 2026. Severity 3 expected (structural fiscal change affecting all DM gold producers with Ghana operations).
https://mincom.gov.gh/wp-content/uploads/2025/05/PROPOSED-AMENDMENTS-ACT-703.pdf
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 104d ago · not yet law·matches Cobalt, Copper
If passed — Revises 30 CFR Part 580 to streamline 10 provisions governing prospecting, leasing, and operations for hard minerals (manganese nodules, cobalt-rich crusts, seafloor massive sulfides) on the US Outer Continental Shelf; eliminates environmental notification to adjacent state governors (§580. 31) and BOEM's own environmental review requirement (§580. 29); accelerates OCS hard mineral leasing pipeline in line with EOs 14285 and 14154 ("unleashing" OCS resources); comment period closed April 27, 2026; awaiting final rule
Caveat — First substantive revision of US OCS hard minerals regulatory framework in ~35 years; distinct from all filed US actions (no prior OCS hard minerals action in register). Severity 2: regulatory infrastructure that enables future OCS leasing rather than a direct production/export instrument; secondary-boem: https://www. boem. gov/newsroom/press-releases/boem-proposes-rule-changes-support-critical-mineral-exploration-and
Reference-class base rate
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 ↗
https://www.federalregister.gov/documents/2026/02/24/2026-03690/administrative-revisions-to-regulations-related-to-outer-continental-shelf-minerals-other-than-oil
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
🇬🇳 Guinea Bauxite Exchange (GBX) — Mines Minister Bouna Sylla announced July 2025 national bauxite price index targeting FOB pricing transparency and closing gap between declared export values and market prices; planned launch end-2025; Prospect Intel confirmed Guinea-Conakry launched GBX to reclaim pricing control; no enacted arrêté/décret confirmed in primary gazette sources
announced→low likelihood·flagged 102d ago · not yet law·matches Aluminium
If passed — Supersedes 2022 bauxite reference price arrêté; establishes real-time FOB benchmark for all Guinea bauxite exports (~182 Mt/yr, world's largest supplier); estimated >$1bn/yr additional government revenue if fully enforced; directly constrains Chinese alumina refinery price negotiating leverage (60%+ of Guinea bauxite goes to China)
Caveat — Announcement-only at this stage; no decree number or OJ publication found. The 2022 bauxite reference price arrêté (queued separately in filing. md) is the last enacted instrument; GBX is positioned as its successor and upgrade. Distinct from filed 2025-07-14-guinea-guitram-bauxite-shipping-mandate (freight mandate, separate instrument). Severity 3 expected if enacted: Guinea accounts for ~55% of global bauxite trade; mandatory FOB index would restructure all supply contracts for European and Chinese aluminium producers.
https://www.mysteel.net/news/5091124-guinea-to-launch-its-bauxite-price-index-mines-minister-says
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇪🇺 STAGE UPDATE — EU CBAM COM(2025)989 Downstream Extension: Council adopts general approach June 12, 2026
passed-committee→elevated likelihood·flagged 101d ago · not yet law·matches Aluminium
If passed — Council's general approach expands the Commission's proposed downstream scope further (more products than Commission proposed); mandates annual Commission review for future scope additions; adds anti-circumvention provisions targeting operators who split shipments or route via third countries; Council position now feeds into EP committee and trilogues; entry into force still targeted at 2028 under the proposal
Caveat — Stage advance from "draft-published" to "passed-committee" for the COM(2025)989 proposal flagged 2026-06-16. Council refined the downstream product list beyond Commission's original proposal. EP lead committee ENVI has yet to report; no trilogue date announced as of June 26, 2026. Likelihood remains elevated: Council political consensus secured June 12 — strongest signal since Commission proposal December 2025. Distinct from filed actions: 2023-05-10-eu-cbam-regulation-2023-956 (base regulation) and 2023-05-10-eu-cbam-definitive-phase-entry-into-force. Secondary: https://www. esgtoday. com/eu-member-states-agree-to-expand-cbam-carbon-import-tax-to-downstream-products/
https://www.consilium.europa.eu/en/press/press-releases/2026/06/12/council-moves-to-strengthen-the-eu-s-carbon-border-adjustment-mechanism/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Aluminium🇨🇳 today 21→23+2
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 101d ago · not yet law·matches Aluminium, Copper, Cobalt
If passed — Ministry of Mines issued operational guidelines for the Mining Sector Reforms component under Scheme for Special Assistance to States for Capital Investment (SASCI) FY2026-27, with total ₹5,000 crore (~USD 600M) incentive envelope to states; key components: (i) ₹250 crore one-time incentive to any state where ≥10% of pre-March-2026 auctioned major mineral blocks begin production+dispatch by end-2026; (ii) ₹100 crore baseline for systemic reforms (Unified Mining Portal integration, Pre-Auction Committees); (iii) ₹20 crore per block auctioned with pre-embedded forest and environmental clearances; scheme targets removing the "auction gap" — India has auctioned hundreds of mineral blocks since 2015 MMDR amendments but operationalisation lag remains a structural bottleneck; critical minerals relevance: India is running parallel programme of critical+strategic mineral auctions (7 tranches, 56 blocks auctioned by June 24, 2026) and this scheme incentivises states to bring those blocks into production faster; directly accelerates lithium (Rajasthan), REE (Andhra Pradesh, Tamil Nadu), graphite (Odisha), and nickel (Odisha, Jharkhand) pipelines
Caveat — Source is secondary (PolicyEdge news aggregator). To migrate to filing. md, filer must verify the primary notification on mines. gov. in or pib. gov. in (search "SASCI Mining 2026-27" on PIB search). India BHAVYA industrial parks scheme (₹33,660 crore, March 18, 2026) is separately filed — SASCI is a distinct scheme targeting state-level mining-sector governance reform. Distinct from filed India Union Budget 2026-27 Customs notifications and Semiconductor Mission 2. 0. Severity 2 (supply-side demand-unlock rather than export control or FDI gate).
https://www.policyedge.in/p/centre-launches-5000-crore-incentive-scheme-to-speed-up-mine-auctions-and-production
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 100d ago · not yet law·matches Copper, Cobalt, Tungsten
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
https://mono.mn/n/government_approves_draft
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
- Tungsten🇨🇳 today 38→40+2
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 100d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one of the world's largest undeveloped Cu-Au deposits (phase-1 ~200,000 t/yr copper concentrate + 250,000 oz/yr gold, first production targeted end-2028, ~USD 5. 5bn phase-1 capex). The stake would be purchased from the Pakistani state's half of the project (Pakistan federal SOEs + Balochistan hold 50%; Barrick Gold holds 50% and operates). This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) into a strategic copper chokepoint, paralleling Manara's Vale Base Metals 10% stake and IRH's Mopani (Zambia) acquisition; gives Saudi Arabia an equity claim on a major future non-China copper supply source.
Caveat — As of 2026-06-27 the deal is in negotiation — Pakistan's Petroleum Minister Musadik Malik said publicly he expected a deal "within the next six months," hence announced/upcoming not enacted. Distinct from filed 2025-09-08-pakistan-us-ussm-fwo-critical-minerals-mou (US EXIM/USSM financing angle on Reko Diq), filed 2025-03-14-pakistan-balochistan-mines-and-minerals-act (the provincial mining law), and filed 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake (Manara's Vale Base Metals deal). Severity 2-3 if completed.
https://www.mining-technology.com/news/manara-minerals-acquire-20-stake-reko-diq-project/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 99d ago · not yet law·matches Copper
If passed — Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring the interest from the Government of Pakistan (Pakistan + Balochistan together own 50%; Barrick Gold holds the other 50% as operator). Reko Diq is one of the world's largest undeveloped copper-gold deposits (~$74bn projected free cash flow over a ~37-yr life). IPTM relevance: a GCC sovereign-capital upstream-mining-FDI entry (theme gcc-mining-upstream-fdi) into COPPER — a binding chokepoint material — extending the Saudi diversification-of-supply strategy beyond the filed 2024-03-01 Manara→Vale Base Metals 10% stake; would also be a Pakistan host-state instrument (federal divestment of part of its Reko Diq equity to a Gulf SWF, complementing the 2025-09-08 Pakistan–US USSM critical-minerals MoU already filed). Distinct GCC third-party capital base separate from Chinese-SOE capture and Western MSP/CRMA-aligned investment.
Caveat — As of mid-2025 the deal was reported by Pakistan's Petroleum Minister as expected "within six months" but NO binding SPA or primary gov instrument has surfaced as of 2026-06-28 — hence announced/moderate, not enacted. Dedup: only the 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake Manara action is filed; no Reko Diq/Manara slug in action-index; the filed Reko Diq item (2025-09-08 Pakistan–US USSM–FWO MoU) is a DIFFERENT instrument (US bilateral MoU, not a Saudi equity purchase). Severity 2-3.
https://www.dawn.com/news/1886746
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
🇧🇷 Brazil BNDES "Mais Inovação" loan to Wave Aluminium Brasil SA (New Wave) — BRL 221m demonstration plant financing for bauxite-residue processing (Barcarena, Pará)
announced→low likelihood·flagged 87d ago · not yet law·matches Aluminium
If passed — On 16 November 2025 Brazil's national development bank BNDES signed a BRL 221 million (~USD 41. 4m) loan under its "Mais Inovação" program with Wave Aluminium Brasil SA (trading arm of New Wave, founded 2019 by Gustavo Emina) to help finance a semi-industrial demonstration plant that recovers metallic "green iron" from bauxite residue (red mud) using a proprietary microwave-based extraction process. The plant is being built on land inside Hydro Alunorte's Barcarena (Pará) alumina refinery site — which itself generates ~5m tonnes/year of bauxite residue — with total project cost ~BRL 250m and >70% physical progress as of the announcement; commissioning targeted H2 2026. GTA logged this as two linked interventions (a state loan + a local-content incentive) off the same state-act. Relevant to bauxite/alumina residue-valorisation industrial policy — an emerging sub-theme distinct from primary bauxite mining/export actions already in the register (Guinea, Indonesia).
Caveat — Charter §6 verify-or-don't-file: exhausted GTA state-act/intervention pages (sign-in-gated, no primary link exposed even via fetch), searched agenciadenoticias. bndes. gov. br directly (no matching press release — BNDES appears not to have issued a news release for this smaller/startup-scale operation, unlike its R$700m+-class loans which do get releases, e. g. the filed CBA/Eldorado/Suzano BNDES actions), and could not construct a direct link into BNDES's JS-rendered "Consulta a operações" transparency panel. This is NOT speculative: BRL amount, program name pattern (Mais Inovação — confirmed as a real BNDES product at bndes. gov. br/wps/portal/site/home/financiamento/produto/programa-bndes-mais-inovacao), signing date, beneficiary, plant location and physical-progress detail are corroborated by two independent Pará/mining trade outlets and match GTA's independently-logged state-act — so it does not fit the "reject, not credible" bucket. Parked here per the same precedent as the Sudan PM-directive / Egypt 548/2025 / Morocco lines above (real, already-implemented action; primary gov URL not independently locatable this wake). If a working primary URL is found, promote directly to filing. md — likely as TWO linked actions (state loan + local-content incentive) mirroring the two GTA intervention IDs, or one action with both instruments described if a single BNDES source covers both; action_type subsidy; issuer_agency BNDES; severity 1-2 (single mid-size demonstration-plant loan), severity_basis quant off the BRL 221m figure. The second filing. md queue item (local content incentive, intervention 150840) covers the same underlying signing — when promoting/rejecting, resolve both filing. md lines together rather than re-researching from scratch.
https://www.infopebas.com/destaque/new-wave-investe-r-250-milhoes-para-transformar-residuo-de-bauxita-em-ferro-verde/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇬🇳 Guinea bauxite export curbs / production-cap regime — Ministry of Mines & Geology sector-wide export-control measure (announced, no decree yet)
announced→low likelihood·flagged 83d ago · not yet law·matches Aluminium
If passed — Guinea — the world's largest bauxite exporter (~single-largest feed to China's alumina/aluminium chain) — is preparing a sector-wide measure to CAP/reduce bauxite exports to stabilise falling prices (benchmark cargoes down 20-35% from 2025 highs, ~$60-70/t). Mines & Geology Minister Bouna Sylla publicly stated (March 2026, reiterated May-June 2026 to Bloomberg) that the government would align each company's 2026 production/export volumes with the levels committed in their feasibility-study reports / mining conventions, using a compliance-based enforcement mechanism (rewarding operators who honoured downstream railway/port/refinery investment pledges, penalising pure-volume extractors) rather than a uniform hard quota. All producers were ordered to submit three-year production plans now under government review; the top-two producers SMB (Société Minière de Boké) and CBG (Compagnie des Bauxites de Guinée) face a parallel refinery ultimatum (government wants 5 new alumina refineries, ~7. 2 Mt/yr combined capacity). If enacted this re-prices a binding aluminium-supply-chain chokepoint and would join the register's existing GN bauxite actions as a NEW export-control instrument.
Caveat — As of end-June 2026 NO formal decree has been issued — total quota, per-company allocations and any retroactive clauses remain pending official confirmation, so this is announced/early-warning, NOT enacted (hence upcoming. md, not filing. md). Distinct from filed GN actions: 2022-09-01 bauxite reference-price arrêté (price mechanism, not volume cap), 2025-07-14 GUITRAM 50% freight mandate (shipping, not export volume), 2025-05-26 Order revoking 129 expired permits, 2026-06-19 raw-gold export ban (different material). The refinery-ultimatum strand overlaps the register's alumina-refinery actions (2025-03-26 SPIC Boffa, 2026-05-21 Chalco Boffa) but the export-cap instrument itself is new.
https://www.alcircle.com/news/guinea-weighs-bauxite-export-controls-to-stabilise-prices-amid-global-market-volatility-117673
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Cobalt, Tungsten, Copper
If passed — RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Cobalt🇨🇳 today 62→67+5
- Tungsten🇨🇳 today 38→40+2
- Copper🇨🇳 today 59→63+4
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Aluminium, Copper
If passed — President Peter Mutharika signed an executive order (dated 23 Oct 2025, effective 21 Oct 2025, announced at Sanjika Palace during a cabinet swearing-in) prohibiting the export of raw/unprocessed minerals extracted in Malawi — uranium, rare earth elements, niobium, graphite, tantalum, bauxite, coal, limestone, gemstones, heavy mineral sands, vermiculite, phosphate, rutile, gold, diamonds, copper and others — with an exemption for minerals processed/refined/value-added domestically per Malawian mining law. Announced alongside a suspension of new mining-licence issuance and a review of mining laws (2026/27 State of the Nation Address), plus a planned sovereign wealth fund. Stated rationale: local beneficiation, targeting up to USD 500m/yr once the Kasiya rutile/graphite deposit (Lilongwe) and Kangankunde rare-earth project (Balaka, Mkango Resources — Africa's prospective first new REE mine since 2017, targeting late-2026 production) are fully developed. Violators face fines/penalties under Malawian law. MW is currently the THINNEST country in the register (1 prior action) despite this breadth of minerals covered. Export-ban/beneficiation-mandate, same instrument class as Zimbabwe's SI 213/2022 raw-mineral bans and Guinea's 2026 gold-export ban already in the register.
Caveat — ENACTED (signed order, in force since 21 Oct 2025) but parked here rather than filing. gov. mw directly (TLS cert mismatch: cert is issued for agriculture. gov. mw, not statehouse. gov. mw) and the malawiace. com implementation-analysis piece cites no gov URL either. Same park-lot convention as the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines above (real, already-enacted action; primary URL not independently locatable this wake). Dedup: action-index has only 1 Malawi action total, none overlapping (no prior MW export-ban or beneficiation-mandate action exists). Severity 3-4 expected given the breadth of minerals covered and MW's fast-growing REE/graphite production profile.
https://www.theeastafrican.co.ke/tea/business-tech/malawi-president-mutharika-bans-exports-of-raw-minerals-5247332
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Aluminium🇨🇳 today 21→23+2
- Copper🇨🇳 today 59→63+4
🇲🇬 Madagascar — Council of Ministers lifts 16-year moratorium on new mining-permit issuance (except gold), effective ~29 Jan 2026
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Cobalt, Aluminium
If passed — Madagascar's Council of Ministers approved resumption of mining-permit issuance on ~28-29 Jan 2026, ending a moratorium in place since 2010 (imposed during a political transition amid mining-title speculation). Roughly 1,650-3,000 pending permit applications accumulated during the freeze can now be processed — Mining Cadastre Bureau (BCMM) confirmed first-come-first-served processing with a maximum 3-month target for first issuances. Covers nickel, cobalt, graphite, rare earths, mineral sands/ilmenite, bauxite, sapphire, quartz and mica; GOLD remains explicitly excluded pending further review. Legal basis: implementation of the 2023 mining code (Loi n°2023-007, promulgated 27 Jul 2024) following mining-cadastre cleanup. SUPPLY-RELIEF — opens Madagascar's graphite (6 large projects, ~3% of global production / 8% of global reserves), nickel-cobalt (Ambatovy) and rare-earth potential to new entrants after a 16-year freeze; MG is currently one of the thinnest countries in the register (2 prior actions) despite this graphite/nickel relevance.
Caveat — ENACTED (Cabinet approved, permits already being processed per BCMM statements) but parked here rather than filing. primature. gov. mg returned a self-signed-certificate error on direct fetch, and app. primature. gov. mg's Conseil des Ministres listing did not surface a January 2026 session in the portion fetched. Same park-lot convention as the Malawi entry above and the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines earlier in this file. Dedup: action-index has only 2 Madagascar actions total, neither about the permit moratorium. Severity 3 expected — moratorium lift affects licensing for nickel/cobalt/graphite/REE projects nationwide.
https://fr.allafrica.com/stories/202602040158.html
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Cobalt🇨🇳 today 62→67+5
- Aluminium🇨🇳 today 21→23+2
🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)
in-consultation→moderate likelihood·flagged 26d ago · not yet law·matches Aluminium
If passed — Minister of Mines, Petroleum and Energy Mamadou Sangafowa-Coulibaly formally launched the revision of Côte d'Ivoire's 2014 Mining Code on 13 June 2026, standing up an expert team drawn from his ministry, other state institutions and international bodies to rewrite Loi n° 2014-138 du 24 mars 2014. Stated goals: raise state revenue share, fix "disparate and sometimes poorly negotiated" mining conventions, and modernise the mining cadastre. No draft bill text published yet — this is a mandate/committee-formation stage, distinct from and earlier than the already-filed 2026-02-04 Assafou/Doropo gold-permit decrees and the 2025-12-03 PIRME minerals-energy policy (2025-2040), both of which operate under the CURRENT 2014 code rather than proposing to replace it. Chokepoint-relevant: register's only prior CI code-minier-lineage entries are the 2014 code itself and a 2022 local-content oil/gas law — no entry tracks this active rewrite.
Caveat — Dedup: checked action-index and both queues for "code minier"/"mining code" + CI — only hits are the already-filed 2014 code, the 2022 local-content petroleum law, and the 2024-12 gold-royalty finance law, none of which is this revision effort. Distinct from Senegal's and Morocco's already-queued mining-code amendments (different issuer/instrument).
https://www.energie.gouv.ci/actualite/sangafowa-coulibaly-veut-booster-lattractivite-du-code-minier
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
🇬🇳 Guinea — Nimba Mining Company (NMC SA) Signs First Base Mining Convention (Tinguilinta Bauxite Concession, Boké)
passed-vote→high likelihood·flagged 25d ago · not yet law·matches Aluminium
If passed — On 6 August 2026, at a ceremony at the Petit Palais of the Presidency chaired by Djiba Diakité (Minister Chief of Staff, chair of the Simandou 2040 Strategic Committee), Guinea's wholly state-owned Nimba Mining Company (NMC SA) signed its first mining convention, covering bauxite extraction at Tinguilinta and export via the Port of Kamsar — a 690. 20 km² concession in Boké Prefecture, 25-year term, refinery requirement, no tax exemptions. This operationalises NMC, which was created by the 5 August 2025 presidential decree revoking GAC/EGA's bauxite concession (already filed: 2025-08-05-guinea-presidential-decree-gac-nimba-mining-sa) — since start-up NMC has extracted ~5 Mt bauxite, exported ~4 Mt in 2026, and the Mines Ministry projects 8-10 Mt for 2026, 12 Mt 2027, 14 Mt 2028. Executive-signed and in force operationally, but multiple outlets state the convention text still requires National Transition Council ratification before Journal Officiel publication — parked on axis 2 rather than filed as enacted pending that primary text. Guinea = priority-tier chokepoint (bauxite, ~world's top exporter).
Caveat — Dedup: checked action-index and both queues for "Nimba"/"NMC"/"Tinguilinta" — the only existing GN hits are the Aug-2025 NMC-creation decree and the May-2026 GAC/EGA settlement, neither of which covers this specific convention signing. No primary Guinean government URL (mines. gov.
https://guineenews.org/2026/08/06/mines-la-guinee-lance-officiellement-la-convention-de-base-de-nimba-mining-company/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Aluminium🇨🇳 today 21→23+2
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 1d ago · not yet law·matches Copper
If passed — State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar's ambassador that it will resume the Jebel Ohier copper-gold project (Red Sea State) with an $800M commitment. Third GCC sovereign upstream-mining entry after Manara Minerals/Vale Base Metals 10% stake (2024-03-01, filed) and QIA/Ivanhoe Mines strategic placement (2025-09-17, filed) — extends the GCC-as-third-capital-base pattern (theme gcc-mining-upstream-fdi) to African copper, not just battery metals.
Caveat — gov. sd not independently reachable; QMSD's own project page does not yet mention the resumption) — parked here per the same convention used for the Malawi executive-order entry above (real/firm commitment, primary URL not yet locatable). Dedup: checked "qatar mining", "jebel ohier", "qmsd" across filing. md, upcoming. md, and action-index — zero hits. Likelihood=high reflects a confirmed government-to-government commitment, not a prediction of eventual gazettal.
https://sudantribune.com/article/313934
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4

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.

What to watch next

Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.

The watch listShow

Cobalt is the line to war-game: 🇨🇳 CN already controls 78% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Copper carries 52 restrictive measures on record (🇨🇳 CN 48% of refining) — a secondary escalation candidate.
Zinc carries 7 restrictive measures on record (🇨🇳 CN 32% of mining) — a secondary escalation candidate.

Art. 24(4) · diversification & substitution

Priority mitigations

Every scored material here is one China Minmetals Corporation 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.

The mitigation optionsShow

Track demand-side substitution against your own book. The buyer levers listed for consumers of Cobalt, Copper, Zinc, Tungsten, Antimony, Tin, Aluminium — qualifying alternative suppliers, designing the material out — are the demand risk to China Minmetals Corporation's revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by CN on a material China Minmetals Corporation produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The materials above are concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.

Annex A · regulatory basis

CRMA Art. 24 compliance crosswalk

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)).

The full crosswalkShow

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.

Why this dependence is structural, not transitional. The EU's own external auditor — the European Court of Auditors, Special Report “Critical raw materials for the energy transition — Not a rock-solid policy” (Feb 2026) — judges the bloc's 2030 extraction, processing and recycling targets to be out of reach (recycling runs 1–5% for 7 of 26 materials, and diversification shows no measurable effect). A separate industry-analyst assessment (Adamas Intelligence & Tradium, EU CRMA report, Apr 2024 — an interested-party commercial view, not an independent verdict) reaches a compatible conclusion that the 2030 rare-earth targets will be missed without an expedited push. The chokepoint this report maps is therefore a durable constraint the Act has not yet closed, not a gap that resolves on its own.

Annex B · Art. 24(1) · Art. 2(29)

Scope & applicability

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.

Scope detailsShow

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 7 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology	commodity-trading (confirm against Annex)
Formally identified by a Member State authority	company input

Evidence & sources

Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.

All sourcesShow

Methodology

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 2026-10-05

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).

Refresh SLA

New government measures — polled hourly; a filed action can appear on this report within the hour it's picked up.
Dossier verification (this company's exposure list, sourced against its own disclosures) — the auto-onboarded backlog drains on a 30-minute cycle; a specific company's upgrade timing depends on queue position, not a fixed date.
Live-quoted materials (currently: neodymium, praseodymium, dysprosium, terbium, indium, tellurium — see the price row on each material's page) — refreshed daily.
Other material prices — hand-maintained; flagged STALE on the minerals index past 45 days without a fresh source, rather than left silently out of date.

This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.

← All companies

Geopolitical Supply-Risk Report·EU CRMA Art. 20–25 assessment·MacroLens · CiconiaLabs

China Minmetals Corporation

7 critical materials scored · binding chokepoint: Cobalt (🇨🇳 CN 78% of refining) · 124 restrictive government measures on record

Subject

china-minmetals-corporation · 🇨🇳 CN

Sector

commodity-trading

Materials scored

As of

2026-09-30

Ownership re-checked · exposure claims not re-checked since fill

Risk Office verdict

Moderate · 53/100Exposure claims not re-checked since fillCompany supply-risk index · consumer-side read

Role check · this company is a producer, not a buyer

Competitor cohort · commodity trading

China Minmetals Corporation ranks 20th of 22 verified commodity trading companies.

88🇩🇪 Deutsche Rohstoff AGTungsten
81🇨🇭 Mercuria Energy GroupTungsten
81🇯🇵 Sumitomo CorporationDysprosium
79🇱🇺 Traxys S.A.Dysprosium
73🇩🇪 Klöckner & Co SEManganese
71🇯🇵 Marubeni CorporationCobalt
69🇯🇵 Mitsui & Co., Ltd.Manganese
63🇸🇬 Trafigura GroupCobalt
62🇨🇾 Gunvor GroupCopper
61🇨🇦 Franco-Nevada CorporationRhodium-iridium
61🇯🇵 Itochu CorporationCopper
60🇯🇵 Mitsubishi CorporationPlatinum-palladium
60🇨🇭 Transamine Trading S.A.Lithium
59🇨🇭 Open Mineral AGLithium
53🇨🇳 China Minmetals CorporationCobalt

Disclosed production sites

CN · Shizhuyuan Mine (Yizhang County, Chenzhou, Hunan) — tungsten + bismuth/molybdenum/tin/beryllium/fluorite polymetallic miningtungstenbismuthmolybdenumtinberyllium
PE · Las Bambas (via MMG) — copper mining, concentratecopper
BW · Khoemacau (via MMG) — copper mining, concentratecopper
AU · Dugald River and Rosebery (via MMG) — zinc mining, concentratezinc
CD · Kinsevere (via MMG) — copper cathode, cobalt byproductcoppercobalt

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.

China Minmetals Corporation

What they do

Critical-material exposure

Copper (bulk input) — MMG's Las Bambas mine (Apurímac, Peru) and Kinsevere mine (Katanga, DRC) are flagship group assets and place Minmetals among the world's larger copper miners. Risk sits mainly at the mine-jurisdiction level (Peru community/permitting blockades; DRC political and infrastructure risk).
Antimony (bulk input / structural) — Hunan Nonferrous subsidiary Hunan Gold operates the Xikuangshan mine, historically the world's largest and most concentrated antimony deposit ("Antimony Capital of the World"). China produces roughly 60% of global antimony supply, and antimony has been subject to Beijing's 2024-25 export-licensing regime — Minmetals sits on both the production and policy-conduit side of that exposure.
Tungsten (structural) — Hunan Nonferrous mines, smelts and processes tungsten alongside its antimony/tin lines; the group also holds a dedicated tungsten-materials arm, China Tungsten High-Tech.
Tin (structural) — Produced in the same Hunan Nonferrous mining/smelting chain as antimony and tungsten.
Zinc (structural) — MMG's Dugald River and Rosebery mines (Australia) plus Hunan-based Zhuzhou Smelter Group, one of China's largest zinc smelters, give Minmetals exposure across both mining and smelting stages.
Cobalt (trace / byproduct) — Recovered as a secondary product stream from MMG's Kinsevere copper mine in the DRC; a minor byproduct credit, not a dedicated cobalt operation.
Aluminium (structural) — Corrected 2026-09-17: the prior camaltd.com citation is now dead (403). Re-sourced to North China Aluminium's own site under the Minmetals corporate domain (ncanmt.minmetals.com.cn), which states the company is controlled by China Minmetals Group and produces aluminium sheet, coil/strip and battery/heavy-light-gauge foil.

Sources

China Minmetals — Wikipedia (re-checked 2026-09-08: confirms SASAC supervision, 2015/16 CMGC merger, MMG/MCC/Minmetals Development subsidiary structure)
Hunan Nonferrous Metals — Wikipedia (re-checked 2026-09-08: confirms wholly-owned subsidiary status, Xikuangshan antimony mine, and tungsten/tin/lead/zinc/gold operations)
Minmetals confirms China rare earths merger, creating new giant — MINING.COM
MMG Limited — Operations (checked 2026-09-08: Las Bambas, Kinsevere, Dugald River, Rosebery, Khoemacau mine list — this dossier's copper/zinc/production-footprint source)
MINING.COM — MMG bemoans Congo cobalt curbs that threaten investment (checked 2026-09-08: DRC cobalt export-quota impact on Kinsevere)
North China Aluminium New Materials Technology Co. (checked 2026-09-17: replaces dead camaltd.com [403] link; company's own site under the Minmetals domain, confirms Minmetals Group control and aluminium sheet/coil/strip/foil product line)
GLEIF — China Minmetals Corporation (LEI 3003002ULBI4T3DT7Z09) (ownership check, 2026-09-08)

Named counterparties — who actually buys and sells

The full counterparty breakdownShow

Named suppliers (1)

MMG Limitedlife of mine from 2014; FY2025 volume stated — → 2025-2027 — → 2026-2027 —not comparable · no share figure filedlife of mine from 2014; FY2025 volume stated ↗2025-2027 ↗2026-2027 ↗related party company-disclosure primary-source
life of mine from 2014; FY2025 volume stated · MMG Annual Report 2025, continuing connected transactions: Las Bambas CMN Copper Sale Framework Agreement (27 June 2014) for sale of Las Bambas copper concentrate 'to the CMN Group' (China Minmetals Non-ferrous Metals Co., Ltd., CMC subsidiary); offtake 'is for the term of the life of the Las Bambas mine'. 2025 cap 277,000 t Cu contained; 'approximately 240,000 tonnes of copper contained in copper concentrate were sold by MMG SA to members of the CMN Group' in 2025. Receiving smelter not named.source ↗
2025-2027 · MMG Dugald River Pty Ltd (Seller) signed the Dugald River Zinc Concentrate Sales Agreement (17 Feb 2025) with Minmetals North-Europe, 'a wholly-owned subsidiary of CMC, the ultimate controlling shareholder of' MMG -- disclosed by MMG as a continuing connected transaction. Quantity 'approximately 100,000-120,000 dry metric tonnes of Product (+/-10% at Seller's option) per annum' for 2025-2027, priced on LME zinc plus LBMA silver less an annually negotiated treatment charge; annual cap US$200.0m. Filing: 'China is an important market for zinc concentrate and the CMC Group has investments in several major Chinese zinc smelters which are in a position to process Dugald River zinc concentrates.'source ↗
2026-2027 · MMG connected-transaction announcement, 13 January 2026: Minmetals Album Company Limited (Macau, indirect wholly-owned subsidiary of CMC) buys 'approximately 36,000-48,000 dry metric tonnes' per contract year of Khoemacau (Botswana) copper concentrate from Khoemacau Copper Mining; annual cap US$220.0m for each of 2026 and 2027. 'China is an important market for copper concentrate and the CMC Group has investments in copper smelters which are in a position to process Khoemacau copper concentrates.'source ↗

The exposure register

Ranked by buyer-relative risk, highest first.

2 of 4 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%	Low	some	37	▲ rising
Copper	🇨🇳 CN 48% refining	59	59	Elevated	within 48%	High	limited	52	▲ rising
Zinc	🇨🇳 CN 32% mining	44	37	Moderate	—	Med	ready	7	▲ rising
Tungsten	🇨🇳 CN 90% refining	38	76	Low	EXCEEDS 90%	Med	some	16	▲ rising
Antimony	🇨🇳 CN 78% refining	30	60	Low	—	High	limited	9	▲ rising
Tin	🇨🇳 CN 55% refining	30	56	Low	—	Med	ready	18	▲ rising
Aluminium	🇨🇳 CN 61% refining	21	40	Low	within 61%	Med	some	43	▲ rising

Supply-risk factor analysis

The factor-by-factor analysisShow

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
Zinc	4	2	3	3	2	company input
Tungsten	4	4	5	3	3	company input
Antimony	4	3	1	3	4	company input
Tin	4	2	5	2	3	company input
Aluminium	4	3	1	3	–	company input

Material factors (scored 4–5) — evidence

Cobalt
- 4Geopolitical: 37 restrictive actions, peak severity 5, 24 in last 24mo, less 4 liberalising actions
Copper
- 4Geopolitical: 52 restrictive actions, peak severity 5, 33 in last 24mo, less 3 liberalising actions
- 5Price / market: price up, as of 2026-09-01
- 4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 70/100 (long-horizon, all major uses). Prior analyst short-run rating 0.50: USGS: aluminium substitutes in some electrical/heat-exchange uses
Zinc
- 4Geopolitical: 7 restrictive actions, peak severity 4, 3 in last 24mo
Tungsten
- 4Geopolitical: 16 restrictive actions, peak severity 5, 10 in last 24mo, less 2 liberalising actions
- 4Concentration: refining HHI 8126 (extreme); top CN 90%
- 5Price / market: price up, as of 2026-09-01
Antimony
- 4Geopolitical: 9 restrictive actions, peak severity 4, 6 in last 24mo, less 3 liberalising actions
- 4Import reliance: Eurostat Comext 2025: 74% extra-EU imports, top partner TJ 50% (partner HHI 2847)
Tin
- 4Geopolitical: 18 restrictive actions, peak severity 4, 13 in last 24mo
- 5Price / market: price up, as of 2026-09-01
Aluminium
- 4Geopolitical: 43 restrictive actions, peak severity 5, 26 in last 24mo, less 1 liberalising action

Named refiners in the supply base

The named refinersShow

Tungsten

China = 54% of filer-disclosed refiner mentions · 291 named refiners

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

Tin

China = 28% of filer-disclosed refiner mentions · 879 named refiners

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

Change log

last 30 days

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.

2026-09-30filedIndia Ministry of Mines launches first offshore mineral block auction (Andaman Sea)
2026-09-17filedUS Commerce Preliminary Affirmative Antidumping Determination: Tin Mill Products from China (September 2026)
2026-09-15filedUS Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)
2026-09-11amendedIndonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform— Kepmen ESDM No. 363.K/MB.01/MEM.B/2026 supersedes the Kepmen 144/2026 HPM formula for low-grade limonite: the nickel Correction Factor (CF) for 1.2%-Ni-or-lower ore is reset to 14% (falling 1pp per 0.1pp of grade below that), and the cobalt by-product coefficient is cut from 30% to 17%. Net effect on 1.2%-Ni ore: HPM falls ~45%, from USD 44.97/wmt to USD 24.89/wmt. The change targets the low-grade limonite/HPAL feedstock segment specifically — the 1.6%-grade CF set by 144/2026 is not disclosed as changed in available reporting.

The laws that threaten it

Restrictive government measures on this company's materials, newest first — each links to its primary government source.

The full list of lawsShow

🇮🇳 India Ministry of Mines launches first offshore mineral block auction (Andaman Sea)New since 2026-09-05
2026-09-30· industrial-policy· severity 2· cobalt, nickel, manganese, copper
🇺🇸 US Commerce Preliminary Affirmative Antidumping Determination: Tin Mill Products from China (September 2026)New since 2026-09-05
2026-09-17· tariff· severity 4· tin, steel
🇺🇸 US Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)New since 2026-09-05
2026-09-15· tariff· severity 4· tin, steel
🇨🇦 Canada expands counter-tariffs on US goods to CA$27.6bn, matching US Section 338/232 tariffs dollar-for-dollar
2026-08-26· tariff· severity 4· steel, aluminium
🇺🇸 BIS DPAS Directive Allocation Order — 100% domestic-sale mandate for black mass and tungsten waste/scrap
2026-08-06· export-control· severity 4· lithium, cobalt, nickel, manganese
🇵🇪 Peru DS 014-2026-EM — Mining exploration DIA fast-track platform threshold raised 40→60
2026-07-20· regulatory· severity 2· copper
🇨🇳 China MOFCOM Announcement No. 27 [2026] — 20 more Japanese entities incl. National Institute for Defense Studies added to Control List
2026-06-29· export-control· severity 4· rare-earths, gallium, germanium, antimony
🇨🇳 China MOFCOM Announcement No. 26 (2026) — Strategic Mineral Export Control Reporting and Whistleblower Mechanism
2026-06-24· regulatory· severity 2· rare-earth-elements, gallium, germanium, antimony
🇺🇸 US USTR Section 301 Determination — Proposed 25% Tariff on All Brazilian Goods
2026-06-04· tariff· severity 3· niobium, copper, iron-ore
🇿🇦 South Africa: Industrial Development Strategy 2026 — Permit-Conditioned Beneficiation Mandate for Critical Minerals
2026-06-03· industrial-policy· severity 3· chrome, platinum-group-metals, cobalt, lithium
🇺🇸 US USTR Section 301 Forced Labor Findings and Proposed Action — 60 Economies
2026-06-02· tariff· severity 3· cotton, polysilicon, cobalt, lithium
🇺🇸 US Proclamation 11032 — Further Adjusting Section 232 Tariff Regimes for Aluminum, Steel, and Copper
2026-06-01· tariff· severity 2· aluminum, steel, copper
🇨🇩 DRC Ministerial Suspension of All Mining in Mwenga and Shabunda (South Kivu)
2026-05-22· regulatory· severity 3· gold, coltan, cassiterite
🇨🇳 China State Council Order No. 839 — Regulations for the Implementation of the Mineral Resources Law
2026-05-20· regulatory· severity 3· rare-earths, gallium, germanium, antimony
🇪🇺 EU-US Trade: Political Agreement on Implementing Regulations for Joint Statement Tariff Commitments
2026-05-20· tariff· severity 3· steel, aluminium

+ 109 more in the register.

Art. 24(2)(c) · vulnerability to disruption

Stress test — two plausible scenarios

Both stress-test scenariosShow

Policy shock — the controlling country escalates to a full export-licensing / ban regime.
Concentration shock — the supply structure collapses to a single source (second-source loss / full monopoly).

Which of your plants carries the binding exposure

Under the 🇨🇳 CN shock, your disclosed plant carries the binding Cobalt exposure:

🇨🇩 CD · Kinsevere (via MMG) — copper cathode, cobalt byproduct

Closest real precedent — an output-market event, not a supply vulnerability

Indonesia hilirisasi ladder — battery-mineral extension

value-chain ladder (material-set)

🇨🇳 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.

🇨🇳 CN's demonstrated restriction sequence — has restricted 22 materials since 2016, in this demonstrated order:

You hold exposure to 5 of these 22 materials (Cobalt, Copper, Aluminium, Antimony, Tungsten) — your binding Cobalt exposure is one of them.

Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 3.6 months apart across 10 distinct restriction dates since 2016 (n=9 intervals).

Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —

🇺🇸 US has historically countered a median of 3.9 months later (n=23 recorded episodes since 2024). Counter-move intensity: median severity 3/5 (3 of 23 via quantified basis).
🇮🇳 IN has historically countered a median of 9.9 months later (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5 (0 of 4 via quantified basis).

Descriptive history of recorded counter-actions in our causal register — not a forecast; the gap is what the controller's past moves drew in response.

Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —

when 🇨🇳 CN restricts your Cobalt, 🇺🇸 US has historically countered (median 3.9 months later) — and those counter-moves have also restricted Copper, which you also depend on (n=9 recorded episodes since 2025). Counter-move intensity: median severity 3/5, hardest 4/5 (1 of 9 via quantified basis).
when 🇨🇳 CN restricts your Cobalt, 🇺🇸 US has historically countered (median 3.9 months later) — and those counter-moves have also restricted Zinc, which you also depend on (n=3 recorded episodes since 2025). Counter-move intensity: median severity 3/5, hardest 4/5 (0 of 3 via quantified basis).
when 🇨🇳 CN restricts your Cobalt, 🇺🇸 US has historically countered (median 10.1 months later) — and those counter-moves have also restricted Antimony, which you also depend on (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5, hardest 4/5 (0 of 4 via quantified basis).

The ordered history of what this controller has restricted, each step traced to /actions/{id} — a descriptive sequence, not a forecast.

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	Zinc — 🇨🇳 CN escalates zinc controls to a full export-licensing / ban regime	44	55	+11
Concentration	Zinc — 🇨🇳 CN becomes the single source for zinc — the second source is lost (full 32%+ monopoly)	44	81	+37

Art. 24(4) · mitigation trigger

Significant-vulnerability conclusion

Proposed — not yet law

Upcoming regulatory threats

The upcoming threatsShow

🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)
passed-vote→high likelihood·flagged 55d ago · not yet law·matches Copper, Cobalt
If passed — On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
Caveat — ENACTED / already in force (signed 29 June 2026, five independent Congolese/international outlets corroborate the ministers, date and substance) but parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. cd unreachable per prior wakes — same constraint noted on the DRC Strategic Mineral Reclassification, ARECOMS forfeiture, and 5% Worker Equity entries elsewhere in this file). DISTINCT from: 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (ARECOMS sectoral cobalt-hydroxide quota system, cobalt-only), 2025-12-19-drc-artisanal-copper-cobalt-processing-suspension (artisanal-sector only), the queued ARECOMS H1-2026 quota-forfeiture entry above (operationalises the ARECOMS quota, not this arrêté), 2026-04-10-drc-strategic-reserve-minerals-arecoms, and 2026-05-29-drc-strategic-mineral-expansion-decree. This arrêté is the FIRST instrument in the register banning concentrate exports for BOTH copper and cobalt jointly and replacing the 2023 commercialisation/export/nomenclature framework wholesale — a materially broader legal basis than any of the above. Re-check mines. gouv. cd and jocc.
https://actualite.cd/2026/08/06/rdc-kinshasa-interdit-lexportation-des-concentres-de-cuivre-et-de-cobalt-pour-encourager
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇬🇳 Guinea — Ministry of Mines plan to reduce bauxite export volumes to support prices (differential quota/allocation tied to downstream-investment commitments)
announced→low likelihood·flagged 66d ago · not yet law·matches Aluminium
If passed — On 18 March 2026 Guinea's Minister of Mines Bouna Sylla told Reuters that Guinea — the world's top bauxite exporter (~40% of global seaborne supply, 2025 exports ~183 Mt, +25% y/y) — would reduce export volumes "in the coming weeks" to support prices and protect small producers, explicitly declining to call it a formal quota ("it is not really a quota, but we will reduce the volumes we export") and ruling out an outright ban. The plan requires major miners (SMB, Chalco/Winning-linked entities, CBG) to submit three-year production plans aligned with their downstream/alumina-investment commitments, with an unofficial target of cutting annual exports toward ~150 Mt. As of end-June 2026 no formal decree had been issued; market reporting through June/July 2026 still describes the mechanism as pending/rumoured. Distinct from all filed Guinea actions (bauxite reference-price arrêté 2022, GUITRAM freight mandate, GAC/EGA concession revocation+settlement, Chalco/SPIC alumina refinery deals, June 2026 raw-gold export ban) — none of which is a bauxite export-volume/quota control. Materiality: Guinea is the Step-0. 5 priority-tier chokepoint for bauxite (feeds the aluminium value chain); a formal quota would be the first-ever volume control on Guinea's dominant bauxite export stream.
Caveat — gov. gn/Journal Officiel instrument or a specific quota tonnage figure attributed to government.
https://www.agenceecofin.com/actualites-industries/1903-136782-bauxite-la-guinee-vise-d-ici-avril-un-plan-pour-limiter-l-export-et-soutenir-les-prix
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 66d ago · not yet law·matches Copper, Cobalt
If passed — Minister of Finance, acting under s. 89 of the Customs and Excise Act, cut the copper-concentrate export duty to ZERO for tariff headings 2603. 00. 21 / 2603. 00. 22 / 2603. 00. 23 / 2603. 00. 29, capped at 271,742 t, effective 1 June 2026 with automatic lapse 30 September 2026, with per-entity tonnage caps and (per one secondary) a requirement that exempt shipments channel through Industrial Resources Limited. This is a SUPPLY-RELIEF (liberalising) action — a net EASING of a copper/cobalt chokepoint for ~4 months, explicitly to clear stockpiled unprocessed concentrate while Zambia's major smelters are down for extended maintenance. It is the "(No. 2)" successor instrument to the already-filed 2026-03-05-zambia-si-15-2026-copper-concentrates-export-duty-suspension (a distinct SI with its own number, tonnage cap and validity window). Severity ~2 expected.
Caveat — ENACTED / already in force per multiple independent secondary sources (all agree on SI number, exact citation title, s. org URL pattern that resolves for the parent SI 15/2026 (`/akn/zm/act/si/2026/43/eng@<date>`) across several plausible dates, all 404; zambialii's SI-list index page for 2026 also 404s directly. Parked here per the standing verify-or-don't-file convention (cf. DRC ARECOMS, Pakistan chloroform, China sulfuric-acid entries below) rather than filed on secondaries alone. Re-check zambialii.
https://www.zambiamonitor.com/govt-suspends-export-duty-on-copper-concentrates/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 66d ago · not yet law·matches Cobalt, Copper, Aluminium
If passed — On 10 July 2026 the African Development Bank Group, with the African Union Commission, the AfCFTA Secretariat and UNECA, convened African ministers of mining/energy/industry in Abidjan for the "Ministerial Forum on Critical Minerals Value Chain and Beneficiation: Pathways for African Transformation". The stated ambition is continental: move the bloc off raw-ore exports toward regional value chains and in-country processing, with reporting of a push to HARMONISE African mining legislation by end-2026 around a ban on unprocessed ore exports, alongside a headline mobilisation figure of ~USD 63bn for critical-minerals value-chain investment. Why this matters as axis-2 early warning rather than noise: the register already holds a dense cluster of INDIVIDUAL national instruments moving in exactly this direction — Zimbabwe's 2026-02-25 indefinite raw-mineral/lithium-concentrate export suspension, Guinea's 2026-06-19 raw-gold export ban + domestic-refining mandate, Gabon's announced 2029 crude-manganese export ban, Nigeria's RMRDC 30% value-addition bill, Indonesia-style downstreaming copied across the continent, and CEMAC's regional Common Mining Code (all already filed or queued). A binding AU/AfCFTA-level harmonisation instrument would convert that scattered set into a coordinated continental supply shock across cobalt, copper, bauxite, manganese and lithium simultaneously — which is a materially different exposure event from any single-country ban, because it removes the substitute-jurisdiction escape route that currently absorbs each national ban.
Caveat — DELIBERATELY likelihood=low, not moderate. com) is low-quality and was NOT relied on. AU-level harmonisation instruments historically take years and frequently stall at the model-law stage (cf. the known ecb-spf 400 pattern) to establish whether a formal Abidjan Declaration text exists and what it actually commits signatories to.
https://www.afdb.org/en/documents/high-level-ministerial-forum-critical-minerals-value-chain-and-beneficiation-pathways-african-transformation
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
- Aluminium🇨🇳 today 21→23+2
🇨🇩 DRC — ARECOMS forfeiture & reallocation of unused H1-2026 cobalt export quotas to the state strategic reserve (in force ~29 June 2026)
passed-vote→high likelihood·flagged 77d ago · not yet law·matches Cobalt
If passed — On ~29 June 2026 the Autorité de Régulation et de Contrôle des Marchés des Substances Minérales Stratégiques (ARECOMS) ordered that all first-half-2026 cobalt export quotas left unused by 30 June 2026 be forfeited and recovered, with a 5 July 2026 cutoff, and reallocated into ARECOMS's discretionary "strategic quota" pool (already ~10% of the 96,600 t/yr authorised volume) earmarked for national-interest local-processing projects. This is an escalation/operationalisation of the filed 2025-02-22 ARECOMS cobalt quota system: it concentrates additional volume under state discretionary control, tightens the effective free-market allocation for producers (Glencore/KCC, CMOC, ERG) on the world's dominant cobalt chokepoint (~76% of mine supply), and — via the linked customs-notification malfunction that blocked quota-linked export declarations after 1 July 2026 — created a real short-run supply interruption. IPTM action would be an AMENDMENT to 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system.
Caveat — ENACTED / already in force (not speculative) — parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. com, lentrevuemagazine, HCN Times). DISTINCT from filed 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (the quota framework this amends), 2026-04-10-drc-strategic-reserve-minerals-arecoms (the reserve's legal creation — this is the first operational feeding of that reserve via forfeited quotas), and 2026-05-29-drc-strategic-mineral-expansion-decree. Severity 3 expected.
https://news.metal.com/newscontent/103980228-smm-analysis-drc-announces-forfeiture-and-reallocation-of-unused-quotas-in-h1-2026-to-strategic-quotas
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Cobalt🇨🇳 today 62→67+5
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 72d ago · not yet law·matches Copper
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
https://www.spglobal.com/energy/en/news-research/latest-news/metals/041526-chinas-sulfuric-acid-restrictions-set-to-squeeze-miners
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
🇬🇳 Guinea — Nimba Mining Company (NMC, 100% state-owned) / Glencore bauxite pre-financing and marketing agreement
announced→low likelihood·flagged 13d ago · not yet law·matches Aluminium
If passed — On 7 September 2026 Guinea's state-owned Nimba Mining Company and Glencore signed a five-year pre-financing agreement, announced by the government and Glencore on 10 September 2026, worth over USD 300 million and covering marketing of 10-12 Mt/yr of bauxite (50-60 Mt over the contract term) — a trader advance repaid via physical bauxite delivery rather than conventional debt. Minister of Mines and Geology Bouna Sylla is quoted on-record calling the signing a milestone for Guinean state participation in the mining value chain, and Guinea is separately reported discussing alumina-refining and energy investment with Glencore. This sits alongside the register's other Guinea bauxite-sector state-control instruments (2022 reference-price arrêté, GUITRAM freight mandate, GAC/EGA concession revocation, the parked export-volume-reduction plan below) and is part of the government's "Simandou 2040" push to expand national participation in extractives. Theme candidate: em-resource-upstream-capture. Polarity: none declared (a financing/offtake deal, not a restrictive or liberalising regulatory measure — but materially entrenches state-company control of a bauxite export stream at Guinea's dominant chokepoint, ~40% of global seaborne bauxite supply).
Caveat — gov. gn directly (reachable, HTTP 200) and searched its site for "Nimba Glencore" (no results); a mining. com direct fetch also 403'd. Parked here per verify-or-don't-file rather than filed on secondaries alone. Distinct from the already-parked "Guinea — Ministry of Mines plan to reduce bauxite export volumes" entry below (a volume-quota policy proposal, not this specific NMC-Glencore commercial financing/offtake contract).
https://www.mining.com/web/guinea-discussing-alumina-energy-investments-with-glencore-after-bauxite-deal-minister-says
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Cobalt
If passed — Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
Caveat — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
https://www.madini.go.tz/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Cobalt🇨🇳 today 62→67+5
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 98d ago · not yet law·matches Copper
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
https://senate.parlam.kz/en-US/news/details/14628
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 99d ago · not yet law·matches Copper, Cobalt
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in advanced negotiations to acquire a 15-20% equity stake (deal value ~USD 1. 5-2bn) in First Quantum Minerals' Zambian copper and nickel operations — i. e. the Kansanshi and Sentinel/Trident copper complex (Zambia's largest copper mines, ~0. 4-0. 5 Mt/yr combined) plus nickel. This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) directly into a binding African copper chokepoint, paralleling Manara's filed Vale Base Metals 10% stake (2024-03-01-sa-manara-minerals-vale-metals-10pct-stake) and its in-negotiation Reko Diq stake (queued below), and mirroring UAE IRH's Mopani (Zambia) acquisition. Gives Saudi Arabia an equity claim on a major non-China copper supply source and injects fresh capital into FQM as it recovers from the Cobre Panamá shutdown — a Gulf-capital re-pricing of Zambian copper supply risk that the exposure engine should track.
Caveat — As of 2026-06-28 this is in advanced negotiation, no signed SPA — hence announced/upcoming not enacted. DISTINCT from the Reko Diq (Pakistan) Manara stake queued below (different asset, different host country) and from the filed Vale Base Metals 10% stake. If completed, severity 2-3.
https://www.miningsee.eu/saudi-arabias-manara-minerals-eyes-stake-in-first-quantums-zambian-copper-and-nickel-assets/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Copper, Cobalt
If passed — First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2447259
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Cobalt
If passed — Second wave of CRMA Art. 14 strategic projects (drawn from 160+ applications: 95 EU-domestic + 66 third-country including 40 from strategic-partnership countries) gains fast-track permitting (27-month EU cap, 15-month Member State cap), EIB/EBRD financing-hub priority, and off-taker certainty; 75 battery-value-chain projects + 21 REE-for-permanent-magnets in pool; widens the EU's 2030 extraction/processing benchmarks pipeline beyond the first 60 projects
Caveat — Second call for applications closed January 15, 2026 (September 2025 launch). Commission stated ~4-month assessment period → designation expected May–June 2026. As of 2026-06-15, no Commission press release or OJ publication confirmed. EUR-Lex CELEX 32026D0923 verified via web search to be an unrelated EU animal-disease implementing decision. Moved from filing. md 2026-06-15. Distinct from: 2025-03-25-eu-crma-strategic-projects-first-designation (60 projects, first round) and 2024-05-23-eu-crma-entry-into-force (base regulation). Severity 3 expected (same as first-round designation).
https://single-market-economy.ec.europa.eu/news/strategic-projects-critical-raw-materials-gain-momentum-second-selection-round-potential-funding-and-2026-01-19_en
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Cobalt🇨🇳 today 62→67+5
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 113d ago · not yet law·matches Tungsten
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
https://www.mining.com/web/congo-adds-lithium-to-strategic-minerals-in-higher-tax-bracket
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Tungsten🇨🇳 today 38→40+2
🇬🇳 Guinea Bauxite Export Volume Controls 2026
announced→low likelihood·flagged 114d ago · not yet law·matches Aluminium
If passed — GN ≈ 60% global seaborne bauxite; a ~150 Mt/yr cap (vs 183 Mt 2025) tightens the alumina→aluminium chain — direct hit to EU aluminium-vertical names
Caveat — ministerial-announcement stage since 2026-06-01; repeatedly skipped by filing for lack of a gazetted decree — relocated here 2026-06-13. Sev 3 if decree issued, sev 2 if still announcement-stage.
https://www.bloomberg.com/news/articles/2026-05-25/top-bauxite-producer-guinea-to-unveil-export-controls-in-june
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 114d ago · not yet law·matches Tin, Tungsten
If passed — Mandates 15% free-carried interest for Uganda National Mining Company (UNMC) in all new mining licences; introduces mandatory mineral buying centres; tightens local-content and value-addition obligations — changes joint-venture economics for all new Ugandan mining operations, raising effective cost-of-entry for foreign miners
Caveat — Amends the already-filed Uganda Mining and Minerals Act 2022 (UG action 1); expected to be enacted before end of 2025/26 parliamentary session per legal commentary; Bank of Uganda gold purchase programme and new mineral buying centres already being piloted — regulatory infrastructure being built ahead of formal enactment. Distinct from filed Uganda Gold Export Regulations 2024 (SI No. 30 of 2024).
https://globallawexperts.com/uganda-mining-law-changes-2026/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Tin🇨🇳 today 30→31+1
- Tungsten🇨🇳 today 38→40+2
🇮🇩 Indonesia Tin Export Ban — Downstreaming Initiative
announced→low likelihood·flagged 113d ago · not yet law·matches Tin
If passed — Indonesia = ~20% of global refined tin exports (Bangka Belitung); a ban on refined-tin exports would force downstream solder/semiconductor-packaging manufacturing domestically; disrupts global electronics and EV supply chains dependent on Indonesian tin solder and specialty alloys
Caveat — Minister of Energy and Mineral Resources Bahlil Lahadalia announced government "studying" tin export ban on February 13, 2026 at the Indonesia Economic Outlook, Jakarta; framed as replication of 2020 nickel ore ban which claimed 10x value-add uplift; key complication — Indonesia already exports refined tin (not raw ore), so a ban would require immediate creation of advanced downstream industries (solder, electronic-grade tin, semiconductor components) that don't yet exist at scale; Mining Weekly (Feb 13 2026) and BERNAMA (Feb 2026) confirm announcement; no Perpres, PP, or Kepmen issued as of June 14, 2026; government described as "studying" — not yet in formal regulatory drafting. Distinct from filed Indonesia nickel ore export bans (2019, 2023), filed bauxite export ban, and filed Permendag export-licensing amendments.
https://indonesiabusinesspost.com/6137/policy/indonesia-s-potential-tin-export-ban
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Tin🇨🇳 today 30→31+1
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches Tin, Zinc
If passed — Prohibits raw mineral exports unless 30% value-addition achieved domestically; affects Chinese mining companies (dominant in Nigerian critical minerals sector), Western offtake agreements, and all foreign-invested mining JVs; builds on existing eMC+ digital cadastre and mandatory value-addition plans introduced Nov 2024; could force processing-plant investment or suspension of raw mineral shipments from Africa's most populous economy; RMRDC = Raw Materials Research and Development Council (the sponsoring agency)
Caveat — Bill passed third reading in House of Representatives; multiple Nov 2025 sources confirm both chambers approved; as of 2026-06-14 presidential signature not yet confirmed. Distinct from filed Nigeria Tax Reform Acts 2025 (Loi n°1/19 tax restructuring) and Mining Cadastral licence revocations (2025-06-19). Applies to ALL raw materials, not minerals only — IPTM relevance is the mineral export provisions.
https://www.nationalaccordnewspaper.com/turning-point-for-nigeria-as-rmrdcs-30-value-addition-bill-nears-presidential-assent/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Tin🇨🇳 today 30→31+1
- Zinc🇨🇳 today 44→55+11
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 113d ago · not yet law·matches Copper, Zinc
If passed — Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mining concessions for first time in Peruvian law history, making concessions revocable by administrative authority; introduces higher annual fees and stronger production/investment requirements; threatens legal certainty for Peru's undeveloped copper and silver project pipeline — Peru = #2 copper, #4 silver, #1 lead, #2 zinc globally
Caveat — Approved by Energy and Mining Commission March 17, 2026 by 11 votes to 1 with 3 abstentions — driven by left-aligned Juntos por el Perú (JPP) and Podemos Peru majority. Bill also introduces "comuneros como accionistas" (community shareholders) in mining concessions — first legislative insertion of indigenous community equity rights. MINEM, SNMPE, ComexPerú, and Ingemmet publicly opposed; MINEM warns reform would incentivise illegal mining expansion. Full plenary debate pending as of June 2026. Distinct from all filed PE actions (all executive/regulatory decrees — no prior legislative amendment to Ley General de Minería in register). Also distinct from filed PE actions on REINFO extension (2025-12-26), illegal-mining criminalization (2026-01-20), and Tía María revocation (2026-03-19).
https://elcomercio.pe/economia/peru/comision-de-energia-aprueba-cambios-en-la-ley-de-mineria-y-reaviva-alertas-por-impacto-en-inversion-y-estabilidad-juridica-noticia/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 59→63+4
- Zinc🇨🇳 today 44→55+11
🇸🇱 Sierra Leone No Raw Minerals Export Commitment (VP Jalloh, Mining Week May 2026)
announced→low likelihood·flagged 113d ago · not yet law·matches Aluminium
If passed — VP declared no new large-scale mining agreement will be concluded without a binding value-addition commitment; Mines Minister referenced Zimbabwe, Tanzania, Ghana, and Malawi precedents for raw-mineral export bans; if codified as a Statutory Instrument or Finance Act amendment, would impose export duties or licensing requirements on unprocessed rutile (Sierra Rutile / Iluka/Anglo American), ilmenite, zircon, bauxite, and diamond rough from new concessions; SL = world's top-5 rutile producer — a value-addition mandate on rutile concentrates would affect the entire global TiO2/titanium feedstock supply chain
Caveat — Declared May 2026 at Mining Week (coinciding with 2026-2031 National Critical Minerals Strategy launch, already filed). VP wording "new large-scale mining agreement" suggests concession-by-concession contract conditionality rather than a blanket statutory export ban; no bill, statutory instrument, or gazette reference found as of 2026-06-14. Distinct from SL CI national strategy (2026-05-20, filed) and SI 11/2024 SLMMDMC asset allocation (2026-06-02, filed as amendment to SLMMDMC Act).
https://www.switsalone.com/sierra-leone-hosts-2026-mining-week-launches-critical-minerals-strategy/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Cobalt, Tungsten
If passed — Establishes the first legally binding "safe level" benchmark for EU strategic stocks of each of the 17 strategic raw materials listed in the CRMA Annex I; benchmarks used as reference by Member States, financial institutions, and industrial consumers to assess strategic supply risk; mandated every 2 years, so this is the first edition setting the baseline; informs CRMA Art. 23 monitoring obligations and is the evidential basis for Art. 24 corporate-reporting thresholds
Caveat — The May 24, 2026 deadline set by Parliament and Council in Reg. (EU) 2024/1252 has now passed. No OJ publication confirmed as of June 15, 2026 — Commission may have adopted quietly or is overdue. This is the first CRMA Art. 22 benchmark cycle and is legally distinct from: (1) the CRMA base regulation (filed 2024-05-23); (2) the Strategic Projects first designation (filed 2025-03-25); (3) the RESourceEU Amendment — CRMA revision (filed 2026-03-04). If confirmed adopted, severity=2 (establishes the measurement baseline for EU strategic material supply risk assessment and directly feeds corporate Art. 24 reporting obligations). Distinct from all filed EU-CRMA actions. Not in filing. md or upcoming. md.
https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Cobalt🇨🇳 today 62→67+5
- Tungsten🇨🇳 today 38→40+2
🇪🇺 EU CBAM Scope Expansion to ~180 Downstream Steel/Aluminum Products (COM(2025) 989 final)
draft-published→moderate likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Extends the Carbon Border Adjustment Mechanism from the existing Regulation (EU) 2023/956 sectors (steel, aluminium, cement, fertilisers, hydrogen, electricity) to approximately 180 downstream products with high steel and/or aluminium content — including car parts, domestic appliances (refrigerators, washing machines), power transformers, cables, farming machinery, construction products, and a wide range of industrial equipment; ~2. 5% additional EU imports brought into CBAM scope; entry-into-force proposed from 1 January 2028; also introduces new anti-circumvention provisions (concept of "abusive practices" in proposed Art. 3(35)) targeting operators who split shipments or route via third countries to avoid CBAM liability; affects manufacturers in third countries (China, India, Vietnam, Turkey, ASEAN) that export steel- and aluminium-intensive goods to the EU; raises cost of embedded carbon in European supply chains for all downstream industrial inputs; structurally adjacent to CBAM definitive-phase commencement (January 1, 2026, already filed) — this is a legislative extension, not an implementing regulation
Caveat — Public consultation on downstream scope extension ran July 1 – August 26, 2025 (taxation-customs. ec. europa. eu); Commission adopted proposal December 17, 2025 alongside CBAM implementing acts package; Parliament lead committee is ENVI; Council working group active as of early 2026; no trilogue date announced. Distinct from: filed 2023-05-10-eu-carbon-border-adjustment-mechanism-2023-956 (base regulation, original scope) and 2023-05-10-eu-cbam-definitive-phase-entry-into-force (January 1, 2026 definitive-phase transition). Likelihood is elevated (not high): political consensus on CBAM base regulation was strong, but downstream expansion faces pushback from importing industries and some Member States worried about competitiveness. Secondary: https://taxation-customs. ec. europa. eu/news/cbam-public-consultation-extension-cbam-downstream-products-2025-07-02_en
OSINT passage signals·signals lean strongly toward passage·EU · updated 2026-07-19
- ▲ Extends an already-in-force regime (not a new law) (strong) — This amends the existing CBAM Regulation (definitive period live since 2026) rather than creating a new instrument — extensions of in-force EU regulations carry high passage odds vs. novel files. source ↗
- ▲ Council general approach adopted (strong) — The Council reached a general approach on the downstream extension on Jun 12, 2026 — the Council leg of the ordinary legislative procedure is aligned, leaving EP plenary + trilogue. source ↗
- ▲ EP rapporteur appointed and progressing (moderate) — MEP Mohammed Chahim named rapporteur Feb 23, 2026; the Parliament file is moving through committee, not stalled. source ↗
- ▲ Metals industry broadly supportive (asks for more) (weak) — EU metals producers publicly called for the downstream scope to go even further — the affected domestic industry is not the opposition here, reducing blocking risk. source ↗
- ▼ Large new compliance burden (~7,500 importers) (weak) — Extending to ~180 downstream codes pulls in ~7,500 new importers; downstream-importer pushback could slow (not block) the file in trilogue. source ↗
Sourced OSINT observations, not a forecast — a qualitative second read beside the stage-derived band. We do not publish a passage probability of our own until the accrual record proves it is calibrated (never a fabricated %).
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52025PC0989
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
🇬🇳 Guinea Bauxite Export Volume Controls — Mines Minister Sylla Quota Regime (2026)
in-consultation→moderate likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Guinea = world's #2 bauxite producer (183 Mt exported in 2025, ~45% of China's bauxite imports); Mines Minister Bouna Sylla confirmed in March 2026 that export volume curbs will be applied by early April 2026 to halt a ~50% price collapse from 2025 overproduction; target cap ~150 Mt/yr (≈18% reduction from 2025 actual); enforced via licence compliance — operators exceeding feasibility-study production ceilings face volume restrictions, not an outright export ban; formal policy instrument expected June 2026 per Bloomberg/Mining. com; mechanism: production-cap enforcement rather than new legislation, but a ministerial arrêté is the likely vehicle
Caveat — Distinct from all 7 filed GN actions: distinct from 2025-07-14-guinea-guitram-freight-mandate (state shipping — different instrument), 2025-08-05-guinea-presidential-decrees-gac-ega (concession revocations — different target), 2026-05-21-guinea-chalco-alumina-refinery-boffa (investment agreement — not export control). This action is the first GN volume-cap mechanism targeting all bauxite exporters. Severity estimate: 3 (affects ~45% of China's bauxite import supply; price-floor mechanism with direct feedthrough to aluminium production costs for smelters globally). Filed in upcoming queue 2026-06-16 per chokepoint-tier gap (Guinea = key bauxite chokepoint). No formal arrêté confirmed as of 2026-06-16.
https://www.guineamininginsights.com/news-insights/guinea-implement-bauxite-export-curbs-early-april-push-stabilise-prices
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
🇬🇳 Guinea Alumina Refinery Ultimatum — SMB and CBG 10-Day Deadline to Submit Construction Timeline (June 2026)
announced→low likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Guinea's CNRD junta gives Societe Minière de Boke (SMB, China-linked, ~50% of Guinea's bauxite output) and Compagnie des Bauxites de Guinée (CBG, joint venture: Halco Mining/Alcoa/Rio Tinto/Dadco) 10 days to present binding alumina refinery construction timelines; May deadline was missed; government stated "the companies had already committed to developing local refineries"; failure to comply risks concession revocation or conditions — the August 2025 GAC/EGA revocation provides the enforcement precedent; Guinea government has publicly stated intent to move up the bauxite value chain toward alumina and aluminum
Caveat — Distinct from 2025-08-05-guinea-presidential-decrees-gac-ega (that action revoked GAC/EGA specifically; this action targets SMB and CBG, which are Guinea's two largest bauxite operators — combined ~70% of Guinea's total bauxite exports). Distinct from 2026-05-21-guinea-chalco-alumina-refinery-boffa (Chalco/Chinalco positive investment agreement — contrast: that was a new investor welcomed in; this is a threat to incumbents). If a revocation or binding condition follows, severity = 4 (SMB + CBG together = dominant share of global seaborne bauxite supply). Filed upcoming 2026-06-16.
https://www.mining.com/web/guinea-extends-deadline-for-bauxite-miners-to-present-refinery-plans/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇮🇩 Indonesia PP 19/2025 Mining Royalty Rate Hike — Implementation Postponed Indefinitely (May 2026)
announced→low likelihood·flagged 111d ago · not yet law·matches Copper, Tin
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
https://en.antaranews.com/news/415656/indonesia-delays-mining-royalty-and-export-levy-plan
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
- Tin🇨🇳 today 30→31+1
🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining Policy
passed-committee→elevated likelihood·flagged 110d ago · not yet law·matches Aluminium
If passed — Cabinet-cleared bill to replace the 2006 Minerals and Mining Act, Act 703: raises mining royalties from current 3–5% range to 9–12% (price-linked sliding scale), introduces a new medium-scale mining licence category bridging artisanal and large-scale operations, mandates district-level community and traditional-authority consultation before applications reach national regulators, scraps unlimited concession renewals (currently indefinitely renewable), and strengthens Ghanaian ownership provisions; National Mining Policy approved by Cabinet simultaneously; affects Newmont (Ahafo/Akyem), AngloGold Ashanti, Kinross (Chirano), Gold Fields (Tarkwa, post-Damang reversion), and Atlantic Lithium (Ewoyaa lithium project); royalty more than doubles at current gold prices — material cost increase for large-scale operators
Caveat — Distinct from all 6 filed GH actions: distinct from 2025-12-19-ghana-minerals-mining-royalty-regulations-2025 (those set sliding royalty under existing Act 703 — this bill replaces Act 703 entirely and raises the ceiling well beyond current regulations); distinct from 2026-03-13-ghana-growth-sustainability-levy-amendment (profit-based tax, not royalty); distinct from 2026-03-19-ghana-atlantic-lithium-ewoyaa-mining-lease and 2026-04-07-ghana-damang-engineers-planners-lease (specific lease grants, not legislation). The Green Minerals Policy (cabinet-approved July 2023, banning raw mineral exports) has not been separately enacted as of June 2026 — if the new Mining Act incorporates its provisions, that becomes the first statutory export restriction for Ghana's lithium and critical minerals. Filed upcoming 2026-06-17.
https://gna.org.gh/2026/06/govt-hints-scrapping-unlimited-years-of-mining-concession-renewals/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Aluminium🇨🇳 today 21→23+2
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 110d ago · not yet law·matches Tin, Zinc, Copper
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
https://www.mineria.gob.bo/index.php/nota_prensa/bolivia-activa-reforma-minera-integral-y-sale-a-captar-inversiones-con-respaldo-del-banco-mundial/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Tin🇨🇳 today 30→31+1
- Zinc🇨🇳 today 44→55+11
- Copper🇨🇳 today 59→63+4
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Cobalt, Copper
If passed — Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
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 ↗
https://ustr.gov/about/policy-offices/press-office/press-releases/2026/february/ustr-seeks-public-comment-design-plurilateral-agreement-trade-critical-minerals-and-policy-actions
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 109d ago · not yet law·matches Copper, Cobalt
If passed — Full replacement of the Mining Act 1992 with sweeping new statute: state acquires up to 30% equity in any new mining project (Kumul Minerals free-carry); special mining leases (SML) issued for initial 30-month periods with FID requirement to renew; mandatory landowner and community consultation before licence grant; Mining Development Authority (MDA) replaces current Mineral Resources Authority (MRA) as the sector regulator; CGT on extractive asset transfers now in force since the 2025 Income Tax Act (separate filed action); bill as drafted would reshape FDI terms for all existing and future mining permits including Wafi-Golpu (Newmont/Harmony 26 Moz Au, 4. 8 Mt Cu — SML long-delayed), Frieda River copper-gold (PanAust), and Ok Tedi expansion; PNG's 2023 Mining (New Porgera) Amendment Act handled Porgera separately
Caveat — The public-consultation-draft stage is already filed in the register as 2025-02-25-papua-new-guinea-mining-bill-2025 (filed action records the consultation launch). This upcoming entry tracks the NEXT stage: parliamentary enactment. Consultations closed April 4, 2025; minister aimed for September 2025 tabling but no confirmed passage found as of June 2026. Likelihood moderate — bill has broad government backing and a 15-year development history, but PNG legislative timelines are frequently extended; the May 2025 Marape cabinet reshuffle may have shifted ministerial priorities. Distinct from: 2023-10-13-papua-new-guinea-mining-new-porgera-amendment-act (single-mine statute); 2025-03-12-papua-new-guinea-national-petroleum-authority-act (petroleum, not mining); 2025-03-20-papua-new-guinea-income-tax-act-2025 (CGT on extractive transfers — already enacted separately).
https://www.businessadvantagepng.com/papua-new-guineas-draft-mining-bill-sweeping-reforms-to-overhaul-the-sector/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇬🇳 Guinea Ministry of Mines — Bauxite Export Volume Cap (~150 Mt/yr, 2026)
in-consultation→moderate likelihood·flagged 108d ago · not yet law·matches Aluminium
If passed — ~25% reduction in Guinea's annual bauxite shipments to China (150 Mt target vs. 183 Mt in 2025 and projected ~200 Mt unconstrained); directly re-prices alumina feedstock costs for Chinese refineries (Guinea supplies ~70% of China's imported bauxite); raises spot bauxite prices; affects CBG/Rio Tinto, SMB-Winning Consortium, Emirates Global Aluminium, UC RUSAL affiliates
Caveat — As of June 19, 2026 no formal decree text confirmed; mechanism described as "licence enforcement" (operators aligned to three-year production plans) not new legislation — formal finalisation expected June 2026. Once decree confirmed, migrate to filing. md as new action (action_type=export-control; sub: export-volume-cap / quota-allocation / bauxite; severity=3). Dedup gate: DISTINCT from 2025-07-14-guinea-guitram-bauxite-shipping-mandate (maritime routing mandate, not volume cap); DISTINCT from 2025-05-26-guinea-ministerial-order-129-mining-permits-revoked (permit revocations); DISTINCT from 2026-05-21-guinea-chalco-alumina-refinery-boffa (downstream investment, not export restriction). Filed upcoming 2026-06-19.
https://www.guineamininginsights.com/news-insights/guinea-implement-bauxite-export-curbs-early-april-push-stabilise-prices
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
CEMAC Common Mining Code — 6-member regional harmonisation (April 2026)
draft-published→moderate likelihood·flagged 107d ago · not yet law·matches Cobalt
If passed — If adopted, creates a unified mining regulatory framework across Cameroon, CAR, Congo-Brazzaville, Gabon, Equatorial Guinea, and Chad — harmonising licensing regimes, fiscal terms, transparency obligations (EITI, KP, ICGLR), and environmental standards; would affect Eramet/Comilog manganese operations (Gabon), Sundance Resources iron ore (CAR), Chinese mining JVs (Congo-Brazzaville, CAR), and uranium projects across the region; if enacted, creates a regional investment-guarantee architecture that could facilitate cross-border mining finance and reduce individual-country treaty risk; structural precedent for pooled resource sovereignty in a region where individual states are renegotiating contracts (Gabon post-coup Décret 0276/2024 sovereign-equity mandate, CAR post-KP-readmission, Congo-Brazzaville mining-code review)
Caveat — Consultation meetings held April 2024 (Brazzaville), July 2024 (Riaba/Malabo), February 2025 (regional review workshop), April 2026 (Douala finalization session) — code still in draft form as of April-May 2026; CEMAC has a historically slow ratification track record (Tariff Union took ~15 years to operationalise); likelihood low until formal adoption at heads-of-state summit; DISTINCT from individually filed national mining code reforms: Gabon Décret 0276/2024 (sovereign substances regime), CAR Law 24-008 (new mining code). Filed upcoming 2026-06-20.
https://www.financialafrik.com/en/2026/04/24/cemac-a-common-mining-code-as-a-lever-for-regional-investment/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Cobalt🇨🇳 today 62→67+5
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 101d ago · not yet law·matches Cobalt, Copper
If passed — TZ Finance Bill establishes the Mineral Research Fund capitalised at 10% of gross mineral revenue (~TZS 141 billion/yr at 2025 collection levels); amends the Income Tax Act to formally recognise tax exemptions granted under individual mining Framework Agreements and introduces standard operating procedures — reduces discretionary government risk for large mining investors (Panda Hill niobium, graphite juniors, Buzwagi gold); parallel VAT amendments give equivalent statutory certainty for VAT exemptions; taken together, the bill moves Tanzania from discretionary tax administration toward a rule-of-law-based investor regime for all critical-mineral projects; budget targets Tanzania for top-4 niobium producer status (Panda Hill DA already signed March 24, 2026) and 50% geophysical survey coverage by 2030
Caveat — Tanzania fiscal year starts July 1; the Finance Act signature typically occurs last week of June. Budget speech delivered June 11, 2026 by Finance Minister Khamis Mussa Omar; Parliament approved June 23. Mining provisions in §§ amending Income Tax Act (Cap. 332) and VAT Act (Cap. 148) and establishing the Mineral Research Fund. Distinct from: filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year), filed 2026-03-24-tanzania-panda-hill-niobium-ferroniobium-development-agreement (the specific project DA), and filed 2026-04-15-tanzania-ministry-of-minerals-revokes-40-idle-mineral-exploration-licences. Severity 2: institutional reform that de-risks the investor regime rather than a direct trade restriction.
https://www.tanzaniainvest.com/economy/budget-2026-2027-parliament-approved
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 104d ago · not yet law·matches Cobalt, Copper
If passed — All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension; effectively forces equity restructuring across the entire DRC copper-cobalt belt; miners seeking moratorium as of June 18, 2026 — enforcement outcome by August 2026 will set the precedent
Caveat — Ministerial enforcement letter issued January 30, 2026 by Mines Minister Louis Watum Kabamba — activates dormant Art. 71 bis (5% employee equity in mining company capital) and Art. 144 bis (mechanics) of DRC Mining Code (Loi n° 18/001). Filed here (not filing. md) because DRC government websites (mines. gouv. cd, primature. gouv. cd) remain inaccessible per prior wakes — same constraint as the DRC Strategic Mineral Reclassification entry. Action IS already in effect and enforcement is underway (July 31, 2026 deadline); this is NOT speculative. DRC Chamber of Mines convened June 11, 2026 industry response meeting; companies arguing retroactive application is legally contested. Severity 3 expected if enforced. Distinct from: 2018-01-27-drc-mining-code-revision (underlying law), 2026-04-10-drc-strategic-reserve (ARECOMS mechanism), 2026-04-24-drc-tshisekedi-mining-export-revenue-audit.
https://www.kitco.com/news/off-the-wire/2026-06-18/congo-miners-seek-delay-5-worker-equity-rule-july-deadline
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
🇬🇭 Ghana Minerals and Mining Act 703 Amendment — Cabinet-Approved Proposal (Royalty 9-12%, Lease Cuts, DA Abolition)
draft-published→moderate likelihood·flagged 104d ago · not yet law·matches Aluminium
If passed — Gold mining royalties rise from 3-5% to 9-12% sliding-scale (price-indexed); mining lease maximum cut 30→15 years with renewals limited to 2×10-year additional terms; Development Agreements and Investment Agreements abolished; stability period capped 30→5 years with labour/environment/H&S issues removed from stability protection scope; affects Newmont (Ahafo/Akyem), Gold Fields (Damang/Tarkwa), AngloGold Ashanti (Obuasi) and all major operators in Ghana's ~120 t/yr gold sector
Caveat — Cabinet approved proposed amendments and targeted parliamentary tabling by March 2026; as of June 2026 still pending Parliament (not yet enacted). The amendment is a primary statute overhaul of the Minerals and Mining Act 2006 (Act 703). DISTINCT from: 2025-12-19-ghana-minerals-mining-royalty-regulations (that LI set royalty rates under existing Act 703 — the amendment SUPERSEDES this LI's royalty structure AND adds structural changes); 2026-03-13-ghana-growth-sustainability-levy-amendment (mining levy reduction, separate statute); 2026-03-19-ghana-parliament-atlantic-lithium (individual mining lease ratification); 2026-04-07-ghana-ministry-lands-damang-mining-lease (lease award). Also distinct from the Minerals Commission localisation enforcement already filed (2026-02-18). Q2 2026 was the target passage window per King & Spalding — the bill may be delayed into H2 2026. Severity 3 expected (structural fiscal change affecting all DM gold producers with Ghana operations).
https://mincom.gov.gh/wp-content/uploads/2025/05/PROPOSED-AMENDMENTS-ACT-703.pdf
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 104d ago · not yet law·matches Cobalt, Copper
If passed — Revises 30 CFR Part 580 to streamline 10 provisions governing prospecting, leasing, and operations for hard minerals (manganese nodules, cobalt-rich crusts, seafloor massive sulfides) on the US Outer Continental Shelf; eliminates environmental notification to adjacent state governors (§580. 31) and BOEM's own environmental review requirement (§580. 29); accelerates OCS hard mineral leasing pipeline in line with EOs 14285 and 14154 ("unleashing" OCS resources); comment period closed April 27, 2026; awaiting final rule
Caveat — First substantive revision of US OCS hard minerals regulatory framework in ~35 years; distinct from all filed US actions (no prior OCS hard minerals action in register). Severity 2: regulatory infrastructure that enables future OCS leasing rather than a direct production/export instrument; secondary-boem: https://www. boem. gov/newsroom/press-releases/boem-proposes-rule-changes-support-critical-mineral-exploration-and
Reference-class base rate
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 ↗
https://www.federalregister.gov/documents/2026/02/24/2026-03690/administrative-revisions-to-regulations-related-to-outer-continental-shelf-minerals-other-than-oil
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Cobalt🇨🇳 today 62→67+5
- Copper🇨🇳 today 59→63+4
🇬🇳 Guinea Bauxite Exchange (GBX) — Mines Minister Bouna Sylla announced July 2025 national bauxite price index targeting FOB pricing transparency and closing gap between declared export values and market prices; planned launch end-2025; Prospect Intel confirmed Guinea-Conakry launched GBX to reclaim pricing control; no enacted arrêté/décret confirmed in primary gazette sources
announced→low likelihood·flagged 102d ago · not yet law·matches Aluminium
If passed — Supersedes 2022 bauxite reference price arrêté; establishes real-time FOB benchmark for all Guinea bauxite exports (~182 Mt/yr, world's largest supplier); estimated >$1bn/yr additional government revenue if fully enforced; directly constrains Chinese alumina refinery price negotiating leverage (60%+ of Guinea bauxite goes to China)
Caveat — Announcement-only at this stage; no decree number or OJ publication found. The 2022 bauxite reference price arrêté (queued separately in filing. md) is the last enacted instrument; GBX is positioned as its successor and upgrade. Distinct from filed 2025-07-14-guinea-guitram-bauxite-shipping-mandate (freight mandate, separate instrument). Severity 3 expected if enacted: Guinea accounts for ~55% of global bauxite trade; mandatory FOB index would restructure all supply contracts for European and Chinese aluminium producers.
https://www.mysteel.net/news/5091124-guinea-to-launch-its-bauxite-price-index-mines-minister-says
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇪🇺 STAGE UPDATE — EU CBAM COM(2025)989 Downstream Extension: Council adopts general approach June 12, 2026
passed-committee→elevated likelihood·flagged 101d ago · not yet law·matches Aluminium
If passed — Council's general approach expands the Commission's proposed downstream scope further (more products than Commission proposed); mandates annual Commission review for future scope additions; adds anti-circumvention provisions targeting operators who split shipments or route via third countries; Council position now feeds into EP committee and trilogues; entry into force still targeted at 2028 under the proposal
Caveat — Stage advance from "draft-published" to "passed-committee" for the COM(2025)989 proposal flagged 2026-06-16. Council refined the downstream product list beyond Commission's original proposal. EP lead committee ENVI has yet to report; no trilogue date announced as of June 26, 2026. Likelihood remains elevated: Council political consensus secured June 12 — strongest signal since Commission proposal December 2025. Distinct from filed actions: 2023-05-10-eu-cbam-regulation-2023-956 (base regulation) and 2023-05-10-eu-cbam-definitive-phase-entry-into-force. Secondary: https://www. esgtoday. com/eu-member-states-agree-to-expand-cbam-carbon-import-tax-to-downstream-products/
https://www.consilium.europa.eu/en/press/press-releases/2026/06/12/council-moves-to-strengthen-the-eu-s-carbon-border-adjustment-mechanism/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Aluminium🇨🇳 today 21→23+2
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 101d ago · not yet law·matches Aluminium, Copper, Cobalt
If passed — Ministry of Mines issued operational guidelines for the Mining Sector Reforms component under Scheme for Special Assistance to States for Capital Investment (SASCI) FY2026-27, with total ₹5,000 crore (~USD 600M) incentive envelope to states; key components: (i) ₹250 crore one-time incentive to any state where ≥10% of pre-March-2026 auctioned major mineral blocks begin production+dispatch by end-2026; (ii) ₹100 crore baseline for systemic reforms (Unified Mining Portal integration, Pre-Auction Committees); (iii) ₹20 crore per block auctioned with pre-embedded forest and environmental clearances; scheme targets removing the "auction gap" — India has auctioned hundreds of mineral blocks since 2015 MMDR amendments but operationalisation lag remains a structural bottleneck; critical minerals relevance: India is running parallel programme of critical+strategic mineral auctions (7 tranches, 56 blocks auctioned by June 24, 2026) and this scheme incentivises states to bring those blocks into production faster; directly accelerates lithium (Rajasthan), REE (Andhra Pradesh, Tamil Nadu), graphite (Odisha), and nickel (Odisha, Jharkhand) pipelines
Caveat — Source is secondary (PolicyEdge news aggregator). To migrate to filing. md, filer must verify the primary notification on mines. gov. in or pib. gov. in (search "SASCI Mining 2026-27" on PIB search). India BHAVYA industrial parks scheme (₹33,660 crore, March 18, 2026) is separately filed — SASCI is a distinct scheme targeting state-level mining-sector governance reform. Distinct from filed India Union Budget 2026-27 Customs notifications and Semiconductor Mission 2. 0. Severity 2 (supply-side demand-unlock rather than export control or FDI gate).
https://www.policyedge.in/p/centre-launches-5000-crore-incentive-scheme-to-speed-up-mine-auctions-and-production
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 100d ago · not yet law·matches Copper, Cobalt, Tungsten
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
https://mono.mn/n/government_approves_draft
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 59→63+4
- Cobalt🇨🇳 today 62→67+5
- Tungsten🇨🇳 today 38→40+2
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 100d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one of the world's largest undeveloped Cu-Au deposits (phase-1 ~200,000 t/yr copper concentrate + 250,000 oz/yr gold, first production targeted end-2028, ~USD 5. 5bn phase-1 capex). The stake would be purchased from the Pakistani state's half of the project (Pakistan federal SOEs + Balochistan hold 50%; Barrick Gold holds 50% and operates). This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) into a strategic copper chokepoint, paralleling Manara's Vale Base Metals 10% stake and IRH's Mopani (Zambia) acquisition; gives Saudi Arabia an equity claim on a major future non-China copper supply source.
Caveat — As of 2026-06-27 the deal is in negotiation — Pakistan's Petroleum Minister Musadik Malik said publicly he expected a deal "within the next six months," hence announced/upcoming not enacted. Distinct from filed 2025-09-08-pakistan-us-ussm-fwo-critical-minerals-mou (US EXIM/USSM financing angle on Reko Diq), filed 2025-03-14-pakistan-balochistan-mines-and-minerals-act (the provincial mining law), and filed 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake (Manara's Vale Base Metals deal). Severity 2-3 if completed.
https://www.mining-technology.com/news/manara-minerals-acquire-20-stake-reko-diq-project/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 99d ago · not yet law·matches Copper
If passed — Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring the interest from the Government of Pakistan (Pakistan + Balochistan together own 50%; Barrick Gold holds the other 50% as operator). Reko Diq is one of the world's largest undeveloped copper-gold deposits (~$74bn projected free cash flow over a ~37-yr life). IPTM relevance: a GCC sovereign-capital upstream-mining-FDI entry (theme gcc-mining-upstream-fdi) into COPPER — a binding chokepoint material — extending the Saudi diversification-of-supply strategy beyond the filed 2024-03-01 Manara→Vale Base Metals 10% stake; would also be a Pakistan host-state instrument (federal divestment of part of its Reko Diq equity to a Gulf SWF, complementing the 2025-09-08 Pakistan–US USSM critical-minerals MoU already filed). Distinct GCC third-party capital base separate from Chinese-SOE capture and Western MSP/CRMA-aligned investment.
Caveat — As of mid-2025 the deal was reported by Pakistan's Petroleum Minister as expected "within six months" but NO binding SPA or primary gov instrument has surfaced as of 2026-06-28 — hence announced/moderate, not enacted. Dedup: only the 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake Manara action is filed; no Reko Diq/Manara slug in action-index; the filed Reko Diq item (2025-09-08 Pakistan–US USSM–FWO MoU) is a DIFFERENT instrument (US bilateral MoU, not a Saudi equity purchase). Severity 2-3.
https://www.dawn.com/news/1886746
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4
🇧🇷 Brazil BNDES "Mais Inovação" loan to Wave Aluminium Brasil SA (New Wave) — BRL 221m demonstration plant financing for bauxite-residue processing (Barcarena, Pará)
announced→low likelihood·flagged 87d ago · not yet law·matches Aluminium
If passed — On 16 November 2025 Brazil's national development bank BNDES signed a BRL 221 million (~USD 41. 4m) loan under its "Mais Inovação" program with Wave Aluminium Brasil SA (trading arm of New Wave, founded 2019 by Gustavo Emina) to help finance a semi-industrial demonstration plant that recovers metallic "green iron" from bauxite residue (red mud) using a proprietary microwave-based extraction process. The plant is being built on land inside Hydro Alunorte's Barcarena (Pará) alumina refinery site — which itself generates ~5m tonnes/year of bauxite residue — with total project cost ~BRL 250m and >70% physical progress as of the announcement; commissioning targeted H2 2026. GTA logged this as two linked interventions (a state loan + a local-content incentive) off the same state-act. Relevant to bauxite/alumina residue-valorisation industrial policy — an emerging sub-theme distinct from primary bauxite mining/export actions already in the register (Guinea, Indonesia).
Caveat — Charter §6 verify-or-don't-file: exhausted GTA state-act/intervention pages (sign-in-gated, no primary link exposed even via fetch), searched agenciadenoticias. bndes. gov. br directly (no matching press release — BNDES appears not to have issued a news release for this smaller/startup-scale operation, unlike its R$700m+-class loans which do get releases, e. g. the filed CBA/Eldorado/Suzano BNDES actions), and could not construct a direct link into BNDES's JS-rendered "Consulta a operações" transparency panel. This is NOT speculative: BRL amount, program name pattern (Mais Inovação — confirmed as a real BNDES product at bndes. gov. br/wps/portal/site/home/financiamento/produto/programa-bndes-mais-inovacao), signing date, beneficiary, plant location and physical-progress detail are corroborated by two independent Pará/mining trade outlets and match GTA's independently-logged state-act — so it does not fit the "reject, not credible" bucket. Parked here per the same precedent as the Sudan PM-directive / Egypt 548/2025 / Morocco lines above (real, already-implemented action; primary gov URL not independently locatable this wake). If a working primary URL is found, promote directly to filing. md — likely as TWO linked actions (state loan + local-content incentive) mirroring the two GTA intervention IDs, or one action with both instruments described if a single BNDES source covers both; action_type subsidy; issuer_agency BNDES; severity 1-2 (single mid-size demonstration-plant loan), severity_basis quant off the BRL 221m figure. The second filing. md queue item (local content incentive, intervention 150840) covers the same underlying signing — when promoting/rejecting, resolve both filing. md lines together rather than re-researching from scratch.
https://www.infopebas.com/destaque/new-wave-investe-r-250-milhoes-para-transformar-residuo-de-bauxita-em-ferro-verde/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇬🇳 Guinea bauxite export curbs / production-cap regime — Ministry of Mines & Geology sector-wide export-control measure (announced, no decree yet)
announced→low likelihood·flagged 83d ago · not yet law·matches Aluminium
If passed — Guinea — the world's largest bauxite exporter (~single-largest feed to China's alumina/aluminium chain) — is preparing a sector-wide measure to CAP/reduce bauxite exports to stabilise falling prices (benchmark cargoes down 20-35% from 2025 highs, ~$60-70/t). Mines & Geology Minister Bouna Sylla publicly stated (March 2026, reiterated May-June 2026 to Bloomberg) that the government would align each company's 2026 production/export volumes with the levels committed in their feasibility-study reports / mining conventions, using a compliance-based enforcement mechanism (rewarding operators who honoured downstream railway/port/refinery investment pledges, penalising pure-volume extractors) rather than a uniform hard quota. All producers were ordered to submit three-year production plans now under government review; the top-two producers SMB (Société Minière de Boké) and CBG (Compagnie des Bauxites de Guinée) face a parallel refinery ultimatum (government wants 5 new alumina refineries, ~7. 2 Mt/yr combined capacity). If enacted this re-prices a binding aluminium-supply-chain chokepoint and would join the register's existing GN bauxite actions as a NEW export-control instrument.
Caveat — As of end-June 2026 NO formal decree has been issued — total quota, per-company allocations and any retroactive clauses remain pending official confirmation, so this is announced/early-warning, NOT enacted (hence upcoming. md, not filing. md). Distinct from filed GN actions: 2022-09-01 bauxite reference-price arrêté (price mechanism, not volume cap), 2025-07-14 GUITRAM 50% freight mandate (shipping, not export volume), 2025-05-26 Order revoking 129 expired permits, 2026-06-19 raw-gold export ban (different material). The refinery-ultimatum strand overlaps the register's alumina-refinery actions (2025-03-26 SPIC Boffa, 2026-05-21 Chalco Boffa) but the export-cap instrument itself is new.
https://www.alcircle.com/news/guinea-weighs-bauxite-export-controls-to-stabilise-prices-amid-global-market-volatility-117673
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Aluminium🇨🇳 today 21→23+2
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Cobalt, Tungsten, Copper
If passed — RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Cobalt🇨🇳 today 62→67+5
- Tungsten🇨🇳 today 38→40+2
- Copper🇨🇳 today 59→63+4
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Aluminium, Copper
If passed — President Peter Mutharika signed an executive order (dated 23 Oct 2025, effective 21 Oct 2025, announced at Sanjika Palace during a cabinet swearing-in) prohibiting the export of raw/unprocessed minerals extracted in Malawi — uranium, rare earth elements, niobium, graphite, tantalum, bauxite, coal, limestone, gemstones, heavy mineral sands, vermiculite, phosphate, rutile, gold, diamonds, copper and others — with an exemption for minerals processed/refined/value-added domestically per Malawian mining law. Announced alongside a suspension of new mining-licence issuance and a review of mining laws (2026/27 State of the Nation Address), plus a planned sovereign wealth fund. Stated rationale: local beneficiation, targeting up to USD 500m/yr once the Kasiya rutile/graphite deposit (Lilongwe) and Kangankunde rare-earth project (Balaka, Mkango Resources — Africa's prospective first new REE mine since 2017, targeting late-2026 production) are fully developed. Violators face fines/penalties under Malawian law. MW is currently the THINNEST country in the register (1 prior action) despite this breadth of minerals covered. Export-ban/beneficiation-mandate, same instrument class as Zimbabwe's SI 213/2022 raw-mineral bans and Guinea's 2026 gold-export ban already in the register.
Caveat — ENACTED (signed order, in force since 21 Oct 2025) but parked here rather than filing. gov. mw directly (TLS cert mismatch: cert is issued for agriculture. gov. mw, not statehouse. gov. mw) and the malawiace. com implementation-analysis piece cites no gov URL either. Same park-lot convention as the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines above (real, already-enacted action; primary URL not independently locatable this wake). Dedup: action-index has only 1 Malawi action total, none overlapping (no prior MW export-ban or beneficiation-mandate action exists). Severity 3-4 expected given the breadth of minerals covered and MW's fast-growing REE/graphite production profile.
https://www.theeastafrican.co.ke/tea/business-tech/malawi-president-mutharika-bans-exports-of-raw-minerals-5247332
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Aluminium🇨🇳 today 21→23+2
- Copper🇨🇳 today 59→63+4
🇲🇬 Madagascar — Council of Ministers lifts 16-year moratorium on new mining-permit issuance (except gold), effective ~29 Jan 2026
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Cobalt, Aluminium
If passed — Madagascar's Council of Ministers approved resumption of mining-permit issuance on ~28-29 Jan 2026, ending a moratorium in place since 2010 (imposed during a political transition amid mining-title speculation). Roughly 1,650-3,000 pending permit applications accumulated during the freeze can now be processed — Mining Cadastre Bureau (BCMM) confirmed first-come-first-served processing with a maximum 3-month target for first issuances. Covers nickel, cobalt, graphite, rare earths, mineral sands/ilmenite, bauxite, sapphire, quartz and mica; GOLD remains explicitly excluded pending further review. Legal basis: implementation of the 2023 mining code (Loi n°2023-007, promulgated 27 Jul 2024) following mining-cadastre cleanup. SUPPLY-RELIEF — opens Madagascar's graphite (6 large projects, ~3% of global production / 8% of global reserves), nickel-cobalt (Ambatovy) and rare-earth potential to new entrants after a 16-year freeze; MG is currently one of the thinnest countries in the register (2 prior actions) despite this graphite/nickel relevance.
Caveat — ENACTED (Cabinet approved, permits already being processed per BCMM statements) but parked here rather than filing. primature. gov. mg returned a self-signed-certificate error on direct fetch, and app. primature. gov. mg's Conseil des Ministres listing did not surface a January 2026 session in the portion fetched. Same park-lot convention as the Malawi entry above and the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines earlier in this file. Dedup: action-index has only 2 Madagascar actions total, neither about the permit moratorium. Severity 3 expected — moratorium lift affects licensing for nickel/cobalt/graphite/REE projects nationwide.
https://fr.allafrica.com/stories/202602040158.html
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Cobalt🇨🇳 today 62→67+5
- Aluminium🇨🇳 today 21→23+2
🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)
in-consultation→moderate likelihood·flagged 26d ago · not yet law·matches Aluminium
If passed — Minister of Mines, Petroleum and Energy Mamadou Sangafowa-Coulibaly formally launched the revision of Côte d'Ivoire's 2014 Mining Code on 13 June 2026, standing up an expert team drawn from his ministry, other state institutions and international bodies to rewrite Loi n° 2014-138 du 24 mars 2014. Stated goals: raise state revenue share, fix "disparate and sometimes poorly negotiated" mining conventions, and modernise the mining cadastre. No draft bill text published yet — this is a mandate/committee-formation stage, distinct from and earlier than the already-filed 2026-02-04 Assafou/Doropo gold-permit decrees and the 2025-12-03 PIRME minerals-energy policy (2025-2040), both of which operate under the CURRENT 2014 code rather than proposing to replace it. Chokepoint-relevant: register's only prior CI code-minier-lineage entries are the 2014 code itself and a 2022 local-content oil/gas law — no entry tracks this active rewrite.
Caveat — Dedup: checked action-index and both queues for "code minier"/"mining code" + CI — only hits are the already-filed 2014 code, the 2022 local-content petroleum law, and the 2024-12 gold-royalty finance law, none of which is this revision effort. Distinct from Senegal's and Morocco's already-queued mining-code amendments (different issuer/instrument).
https://www.energie.gouv.ci/actualite/sangafowa-coulibaly-veut-booster-lattractivite-du-code-minier
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Aluminium🇨🇳 today 21→23+2
🇬🇳 Guinea — Nimba Mining Company (NMC SA) Signs First Base Mining Convention (Tinguilinta Bauxite Concession, Boké)
passed-vote→high likelihood·flagged 25d ago · not yet law·matches Aluminium
If passed — On 6 August 2026, at a ceremony at the Petit Palais of the Presidency chaired by Djiba Diakité (Minister Chief of Staff, chair of the Simandou 2040 Strategic Committee), Guinea's wholly state-owned Nimba Mining Company (NMC SA) signed its first mining convention, covering bauxite extraction at Tinguilinta and export via the Port of Kamsar — a 690. 20 km² concession in Boké Prefecture, 25-year term, refinery requirement, no tax exemptions. This operationalises NMC, which was created by the 5 August 2025 presidential decree revoking GAC/EGA's bauxite concession (already filed: 2025-08-05-guinea-presidential-decree-gac-nimba-mining-sa) — since start-up NMC has extracted ~5 Mt bauxite, exported ~4 Mt in 2026, and the Mines Ministry projects 8-10 Mt for 2026, 12 Mt 2027, 14 Mt 2028. Executive-signed and in force operationally, but multiple outlets state the convention text still requires National Transition Council ratification before Journal Officiel publication — parked on axis 2 rather than filed as enacted pending that primary text. Guinea = priority-tier chokepoint (bauxite, ~world's top exporter).
Caveat — Dedup: checked action-index and both queues for "Nimba"/"NMC"/"Tinguilinta" — the only existing GN hits are the Aug-2025 NMC-creation decree and the May-2026 GAC/EGA settlement, neither of which covers this specific convention signing. No primary Guinean government URL (mines. gov.
https://guineenews.org/2026/08/06/mines-la-guinee-lance-officiellement-la-convention-de-base-de-nimba-mining-company/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Aluminium🇨🇳 today 21→23+2
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 1d ago · not yet law·matches Copper
If passed — State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar's ambassador that it will resume the Jebel Ohier copper-gold project (Red Sea State) with an $800M commitment. Third GCC sovereign upstream-mining entry after Manara Minerals/Vale Base Metals 10% stake (2024-03-01, filed) and QIA/Ivanhoe Mines strategic placement (2025-09-17, filed) — extends the GCC-as-third-capital-base pattern (theme gcc-mining-upstream-fdi) to African copper, not just battery metals.
Caveat — gov. sd not independently reachable; QMSD's own project page does not yet mention the resumption) — parked here per the same convention used for the Malawi executive-order entry above (real/firm commitment, primary URL not yet locatable). Dedup: checked "qatar mining", "jebel ohier", "qmsd" across filing. md, upcoming. md, and action-index — zero hits. Likelihood=high reflects a confirmed government-to-government commitment, not a prediction of eventual gazettal.
https://sudantribune.com/article/313934
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 59→63+4

What to watch next

Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.

The watch listShow

Cobalt is the line to war-game: 🇨🇳 CN already controls 78% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Copper carries 52 restrictive measures on record (🇨🇳 CN 48% of refining) — a secondary escalation candidate.
Zinc carries 7 restrictive measures on record (🇨🇳 CN 32% of mining) — a secondary escalation candidate.

Art. 24(4) · diversification & substitution

Priority mitigations

The mitigation optionsShow

Track demand-side substitution against your own book. The buyer levers listed for consumers of Cobalt, Copper, Zinc, Tungsten, Antimony, Tin, Aluminium — qualifying alternative suppliers, designing the material out — are the demand risk to China Minmetals Corporation's revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by CN on a material China Minmetals Corporation produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The materials above are concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.

Annex A · regulatory basis

CRMA Art. 24 compliance crosswalk

The full crosswalkShow

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

Annex B · Art. 24(1) · Art. 2(29)

Scope & applicability

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.

Scope detailsShow

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 7 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology	commodity-trading (confirm against Annex)
Formally identified by a Member State authority	company input

Evidence & sources

Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.

All sourcesShow

Methodology

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).

Refresh SLA

New government measures — polled hourly; a filed action can appear on this report within the hour it's picked up.
Dossier verification (this company's exposure list, sourced against its own disclosures) — the auto-onboarded backlog drains on a 30-minute cycle; a specific company's upgrade timing depends on queue position, not a fixed date.
Live-quoted materials (currently: neodymium, praseodymium, dysprosium, terbium, indium, tellurium — see the price row on each material's page) — refreshed daily.
Other material prices — hand-maintained; flagged STALE on the minerals index past 45 days without a fresh source, rather than left silently out of date.

This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.