Loading…
Loading…
3 critical materials scored · binding chokepoint: Tungsten (🇨🇳 CN 90% of refining) · 81 restrictive government measures on record
China Molybdenum Co., Ltd. (CMOC) produces 3 of the 3 scored materials above (Tungsten, Cobalt, Copper). 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 Elevated · 62/100 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 Tungsten — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 63/100 (footprint-hedged; global 76). The register holds 81 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Tungsten China Molybdenum Co., Ltd. (CMOC) is the 438th-most-exposed of the 465 named companies we track on 🇨🇳 CN's Tungsten chokepoint; the most-exposed is Elbit Systems (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
China Molybdenum Co., Ltd. (CMOC) ranks 213th of 448 verified mining metals companies, tied with 6 others at 62.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 127 further mining metals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 62/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 3 scored materials. Buyer-relative (first-order): weighted by where the company produces (CD 45% · CN 35% · BR 20%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
The exposure report this dossier powers is at /intelligence/dossiers/china-molybdenum/report.
CMOC (Luoyang Molybdenum, HKEX/SSE-listed) is a diversified miner with four geographically distinct production bases: molybdenum and tungsten mining in Henan, China; copper-cobalt mining in the DRC (Tenke Fungurume and Kisanfu); niobium and phosphate fertiliser production in Brazil (CMOC Brasil, formerly Anglo American's Nb/P business); and a wholly owned Geneva-based physical trading arm, IXM, that trades base metals globally. In 2024 it became a top-10 global copper producer and the world's largest refined-cobalt producer.
produced roughly 114,000 mt of refined cobalt in 2024, making it the world's largest cobalt producer. The DRC supplies ~70% of global mined cobalt, and most DRC cobalt is refined in China — a double concentration (single-country mine supply, single-country midstream) that is the core chokepoint risk for any cobalt-dependent buyer, independent of CMOC's own scale.
mt in 2025) is CMOC's largest revenue line by volume. Copper's supply risk is lower than cobalt's (more geographically diverse mine base globally), but CMOC's own copper is geographically concentrated in the DRC, adding single-jurisdiction political and infrastructure risk on top of global market conditions.
producer (after CBMM, also Brazilian); Brazil accounts for roughly 88% of global niobium supply. Niobium is a small-volume but structural input to high-strength steel and superalloys, so the two-company Brazilian duopoly is the binding chokepoint rather than CMOC's individual share.
fertiliser producer. Phosphate rock supply is globally dominated by Morocco/Western Sahara, China, and the US; CMOC's Brazilian output is a minor share of that total but is a genuine bulk fertiliser business line, not a byproduct.
SCORED_MATERIALS slug exists on this platform)*. CMOC's Henan operations (Sandaozhuang) are among the world's largest molybdenum mines — the company's own English name. China is the largest single producer of molybdenum globally; this is a real production-concentration exposure, though it currently sits outside MacroLens's scored critical-mineral set (no production-concentration index yet) so it is not reflected in the numeric risk score below. Removed from material_exposures 2026-08-20 for the same reason as the other 14 dossiers carrying this tag — a bare unresolved tag silently no-ops rather than scoring — but this dossier is the single strongest case in the corpus (alongside plansee.md) for the platform to build a real molybdenum SCORED_MATERIALS entry: it is a named, quantifiable, currently-untracked exposure for one of the world's largest producers of the metal.
operations sit inside the world's most concentrated tungsten supply base: China accounts for the large majority of global mined tungsten and has used export licensing on tungsten as a policy lever (most recently February 2025). This is a genuine, material exposure for CMOC as both producer and, via China's broader export-control posture, potential policy target.
Source for this entire section: China Molybdenum Co., Ltd. (洛阳栾川钼业集团股份有限公司) FY2025 annual report, updated version, filed with the Shanghai Stock Exchange via cninfo 2026-04-02 — static.cninfo.com.cn/finalpage/2026-04-02/1225072765.PDF (financial-statement notes (十一) 关联方及关联交易, pp.111-114; note (四)4(4), p.56). Reporting period: FY2025 (year ended 2025-12-31), with FY2024 comparatives from the same filing. Confidence: primary-source (audited annual report, Deloitte Huayong opinion).
Unlike every other producer worked in this lane so far (Yunnan Tin, Xiamen Tungsten, Huayou Cobalt, JL MAG, Tianqi, Northern Rare Earth — all standard PRC MD&A boilerplate with "前五名客户/前五名供应商合计销售/采购金额占年度 销售/采购总额的比例"), CMOC's annual report — filed under a dual A+H disclosure format — does not carry that table at all. A full-text search of all 227 pages for "前五名客户", "前五名供应商", and the sales/purchase-total phrasing that normally anchors them returned nothing. This is a genuine structural finding about CMOC's disclosure format, not a search failure: the sales-based concentration lane is closed for this filer specifically.
What the filing discloses instead, in the financial-statement notes, is (a) a related-party transactions table with named counterparties and absolute RMB values (not percentages of a total), and (b) an accounts-receivable top-5-debtor table (credit-risk concentration, not sales concentration) that happens to name one debtor in its FY2024 comparative column.
| Named counterparty | Relationship | Flow | FY2025 (RMB) | FY2024 (RMB) | Δ |
|---|---|---|---|---|---|
| CATL (宁德时代) and subsidiaries | Company shareholder & subsidiaries | CMOC sells to CATL | 2,553,515,666.76 | 5,615,991,396.91 | -54.5% |
| CATL (宁德时代) and subsidiaries | Company shareholder & subsidiaries | CMOC buys from CATL | 820,375,604.19 | 288,198,127.33 | +184.7% |
| Huayue Nickel Cobalt (华越镍钴, PT Huayue Nickel Cobalt, Indonesia) | CMOC associate (联营企业) | CMOC buys from Huayue | 1,978,366,890.03 | 2,004,273,322.36 | -1.3% |
| Fuchuan (富川) | Subsidiary of a CMOC JV | CMOC buys from Fuchuan | 529,170,193.79 | 1,138,452,705.59 | -53.5% |
CATL is disclosed in note (十一)4 as a shareholder of CMOC itself (not only a minority partner in the Kisanfu DRC project, as the production-footprint note above already captured) — the related-party table's "其他关联方情况" section lists "宁德时代新能源科技股份有限公司及其子公司" under 与本公司关系: "公司 股东及其子公司". The two flows move in opposite directions year-on-year: CMOC's sales to CATL nearly halved while its purchases from CATL nearly tripled — consistent with a shifting commercial relationship between the world's largest refined-cobalt producer and the world's largest battery maker, but the filing gives no product-level breakdown of either flow, so the material composition (cobalt/copper sold vs. whatever CATL supplies back) is not stated and this dossier does not infer one.
Huayue Nickel Cobalt is a large, stable purchase line (~RMB 2bn both years) — CMOC buying nickel-cobalt intermediate from an Indonesian HPAL associate it holds an equity stake in, i.e. captive intra-group supply rather than arm's-length procurement. Fuchuan is a smaller, sharply declining purchase line from a Luanchuan-area (Henan) joint-venture subsidiary — same district as CMOC's own Sandaozhuang mine, so plausibly ore/concentrate feed, though the filing does not state the product.
None of these four lines come with a "% of total sales/procurement" — CMOC's notes give absolute RMB values only, so no arm's-length-residual arithmetic (the Yunnan Tin-style correction) can be computed here; the numbers stand as disclosed transaction values, not shares of a denominator.
The FY2025 filing's accounts-receivable top-5-debtor table (note (五)4(4)) is coded, not named, in the FY2025 (2025-12-31) column — five anonymous labels (BV 45.38%, BU 3.94%, BY 2.90%, BZ 2.82%, BP 2.80% of total AR). But its own FY2024 (2024-12-31) comparative column, printed on the same page, names one debtor outright: 香港邦普资源循环科技有限公司 / Hong Kong Brunp Resource Recycling Technology Co., Ltd., RMB 92,423,435.81 = 13.27% of total accounts receivable at 2024-12-31 (rank 2 of that year's top five, behind an anonymous 17.55% debtor). Brunp is not on CMOC's own related-party list — this is a genuinely independent, arm's-length customer relationship, not an intra-group one.
Brunp Recycling (广东邦普循环科技) is publicly known as a subsidiary of CATL (majority stake acquired 2015), one of the largest EV-battery recyclers in the world — see CATL's own recycling page and Brunp's own site. CMOC selling on credit to Brunp's Hong Kong entity is consistent with Brunp buying cobalt/copper as recycling/remanufacturing feedstock — i.e. CATL shows up as a named counterparty to CMOC on both the ownership side (shareholder, related-party table) and, via its separately-incorporated recycling subsidiary, the independent-customer side (receivables table) — two distinct relationships that should not be merged into one line.
This is a receivables-balance share, not a sales-revenue share — a different denominator from the standard "% of annual sales" figure used elsewhere in this corpus, stated explicitly here so it is not misread as one. The 2025-12-31 column no longer names this debtor (all five 2025 slots are coded) — that is a right-censored observation (Brunp fell below whatever balance threshold made the FY2024 top five, or the coded 2025 labels include it un-named), not evidence the commercial relationship ended.
Source: China Molybdenum Co., Ltd. 2026 semi-annual report, filed with the Shanghai Stock Exchange via cninfo 2026-08-20 (period ended 2026-06-30, H1-2025 comparatives from the same filing) — static.cninfo.com.cn/finalpage/2026-08-20/1225482748.PDF. This filer is on the CSRC/SSE semi-annual grid tracked under R145 (H1-2026 due 2026-08-31) and filed 11 days early. Confidence: primary-source (interim report is explicitly stated unaudited by the filing itself, §1.4 — flagged here since the FY2025/FY2024 rows above are audited and these are not).
The interim confirms and updates all three previously-tracked related parties, and adds a fourth:
| Named counterparty | Flow | H1-2026 (RMB) | H1-2025 (RMB) | Δ |
|---|---|---|---|---|
| CATL (宁德时代) and subsidiaries | CMOC sells to CATL | 4,086,311,491.48 | 2,433,549,923.34 | +67.9% |
| CATL (宁德时代) and subsidiaries | CMOC buys from CATL | 3,246,514,347.53 | 453,330,790.98 | +616% |
| Huayue Nickel Cobalt (华越镍钴) | CMOC buys from Huayue | 1,851,789,010.11 | 1,363,653,100.27 | +35.8% |
| Fuchuan (富川) | CMOC buys from Fuchuan | 300,212,520.35 | 241,621,753.26 | +24.3% |
| Yulu Mining (豫鹭矿业, new) | CMOC buys from Yulu | 265,697,375.03 | 96,296,245.10 | +176% |
The CATL relationship is the standout finding: H1-2026 sales to CATL (RMB 4.09bn) already exceed the entire FY2025 annual sales-to-CATL total (RMB 2.55bn), reversing the -54.5% FY2025 y/y decline flagged in the section above — and H1-2026 purchases from CATL (RMB 3.25bn) are already more than 3x the entire FY2025 annual purchases-from-CATL total (RMB 820m). Both flows are accelerating sharply in the same direction in 2026, not just recovering. CATL also remains a large balance-sheet creditor: other non-current liabilities owed to CATL were RMB 10.54bn at 2026-06-30 (RMB 10.75bn at 2025-12-31, roughly flat) plus RMB 1.05bn of contract liabilities — this looks like the financing/prepayment arrangement tied to CATL's Kisanfu (KFM) project stake noted in the production-footprint block above, not a goods-flow balance, and this dossier does not attempt to link it to the sales/purchase figures.
Yulu Mining (豫鹭矿业) is new to this dossier — not present in the FY2025 annual-report related-party table read for the section above. It is disclosed here as a CMOC associate (联营企业). "Yulu Mining" is an unverified transliteration of the Chinese name, not a confirmed official English rendering — treat 豫鹭矿业 as the authoritative identifier until an English name is confirmed from an independent source.
GLEIF has an LEI record for CMOC (2549008KG3638J59U652, legal name "CMOC Group Limited", jurisdiction CN, status ISSUED) but no parent relationship filed — parent_reported: false. CMOC is large/well-known enough that a controlling shareholder would be public knowledge, so this recheck did not stop at "no parent reported."
Actual controller, per CMOC's own audited FY2025 annual report (SSE 603993 via cninfo, filed 2026-04-02, note (十一)1 "本公司的母公司情况" + the top-10-shareholder table, p.81-82): 鸿商产业控股集团有限公司 / Cathay Fortune Industrial Holding Group Co., Ltd. ("鸿商控股"), Shanghai, investment management, registered capital RMB 181.8182m. The note states a 24.69% registered-contribution/voting ratio, and separately that 鸿商控股 "actually holds 5,333,220,000 shares, approximately 24.93% of total share capital" as of 2025-12-31. The filing names it explicitly: "鸿商控股为本 公司实际控制人" (鸿商控股 is the Company's actual controller). The top-10-shareholder table's row 1 (533,322.00 万股 = 5,333,220,000 shares, 24.93%) matches this figure to the share.
Row 2 of the same shareholder table (532,978.04 万股 = 5,329,780,400 shares, 24.91%) is CATL (宁德时代), held indirectly through CATL's wholly-owned subsidiary 四川时代新能源科技有限公司 (Sichuan Times New Energy), which in 2022 acquired 洛阳矿业集团有限公司 (Luoyang Mining Group, CMOC's other pre-existing top holder) — corroborated by contemporaneous press (界面新闻 and 观察者网, 2022-11-01: "宁德时代通过全资子公司四川时代 ...成为洛阳钼业间接第二大股东", holding 24.68% at the time of the deal; a 2026-01-09 东方财富网 piece still describes CATL as CMOC's second-largest shareholder at "近25%"). The PDF's own Chinese shareholder-name glyphs in this table are unrenderable (the filer embeds a custom/substituted font in this specific table — a scraping-resistance artifact, not a redaction; the numeric columns extract cleanly) — the identification of row 2 as CATL/四川 时代 therefore rests on the share-count match plus the independent press corroboration, not on reading the garbled name directly, and is flagged as such rather than presented as a direct filing read.
This is not a parent-subsidiary relationship — CMOC's own filing names 鸿商控股 as sole actual controller, and CATL's ~24.9% is a large but non-controlling stake (already captured as related_party: true in the named-counterparty rows above). The corpus has a separate catl dossier, but parent_slug is deliberately NOT set here: CMOC is independently controlled, not a CATL subsidiary.
Ultimate beneficial owner of 鸿商控股, per public reporting (not CMOC's own filing): Yu Yong (于泳), founder/chairman, via Cathay Fortune Corporation — see Forbes profile and SCMP coverage citing a Cathay Fortune stake in CMOC (SCMP's figure, ~35.5%, is an aggregate group-level number from a different reporting point and is not reconciled here against the filing's 24.93% for 鸿商控股 alone — noted as a discrepancy, not resolved by guessing which is current).
ownership_country/operating_hq are not set: 鸿商控股 (Shanghai) and CMOC (Luoyang, Henan) are both PRC-domiciled, so hq_country: CN already covers the controlling jurisdiction.
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.
FY2024 · FY2024 comparative from the same FY2025 filing: RMB 288,198,127.33 in purchases of goods from CATL.
H1-2025 · H1-2025 comparative column of the same H1-2026 interim report: RMB 453,330,790.98 in purchases of goods from CATL; RMB 313,939,215.79 in interest expense to CATL.source ↗
FY2025 · Purchases of goods from CATL: RMB 820,375,604.19 in FY2025 (up from RMB 288,198,127.33 in FY2024, +184.7%). CMOC also carries CATL as a counterparty on RMB 10.75bn of other non-current liabilities and RMB 845m of contract liabilities at 2025-12-31 (financing/prepayment items, not goods flow).
H1-2026 · H1-2026 interim report: purchases of goods from CATL RMB 3,246,514,347.53, up from RMB 453,330,790.98 in the H1-2025 comparative (+616%) — already more than 3x the entire FY2025 annual purchases-from-CATL total (RMB 820,375,604.19). Also pays CATL interest expense (RMB 253,692,391.06 in H1-2026 vs RMB 313,939,215.79 in H1-2025) on a large financing-related balance: other non-current liabilities owed to CATL stood at RMB 10,540,270,406.12 at 2026-06-30 (RMB 10,754,059,227.94 at 2025-12-31, roughly flat) plus contract liabilities of RMB 1,047,043,971.43 (RMB 845,420,216.09 at 2025-12-31). These balance figures are period-end snapshots, not H1 flows — stated separately from the purchase amount above.source ↗
FY2024 · FY2024 comparative from the same FY2025 filing: RMB 2,004,273,322.36 in purchases of product from Huayue Nickel Cobalt.
H1-2025 · H1-2025 comparative column of the same H1-2026 interim report: RMB 1,363,653,100.27 in purchases of product from Huayue Nickel Cobalt.source ↗
FY2025 · Indonesia-based nickel-cobalt intermediate producer carried as a CMOC associate (联营企业, filing note (五)11 — equity stake not quantified in the pages read). Purchases of product from it: RMB 1,978,366,890.03 in FY2025 (RMB 2,004,273,322.36 in FY2024, roughly flat, -1.3%). No % of total procurement disclosed.
H1-2026 · H1-2026 interim report: purchases of product from Huayue Nickel Cobalt RMB 1,851,789,010.11, up from RMB 1,363,653,100.27 in the H1-2025 comparative (+35.8%).source ↗
FY2024 · FY2024 comparative from the same FY2025 filing: RMB 1,138,452,705.59 in purchases of product from Fuchuan.
H1-2025 · H1-2025 comparative column of the same H1-2026 interim report: RMB 241,621,753.26 in purchases of product from Fuchuan.source ↗
FY2025 · Subsidiary of a CMOC joint venture (合营企业的子公司), Luanchuan/Henan area — same district as CMOC's own Sandaozhuang Mo/W mine. Purchases of product: RMB 529,170,193.79 in FY2025 (RMB 1,138,452,705.59 in FY2024, -53.5%). Smaller reciprocal sales flow to Fuchuan: RMB 11.16m (FY2025) / RMB 13.40m (FY2024).
H1-2026 · H1-2026 interim report: purchases of product from Fuchuan RMB 300,212,520.35, up from RMB 241,621,753.26 in the H1-2025 comparative (+24.3%); services received RMB 2,369,178.25 (RMB 3,494,640.79 in H1-2025). Small reciprocal sales flow to Fuchuan: RMB 6,638,871.75 in H1-2026 (RMB 5,924,330.66 in H1-2025).source ↗
H1-2025 · H1-2025 comparative column of the same H1-2026 interim report: RMB 96,296,245.10 in purchases of product from Yulu Mining.source ↗
H1-2026 · New to this dossier (not in the FY2025 annual-report related-party table read previously). Disclosed as an associate (联营企业) in the H1-2026 interim report's related-party note. Purchases of product from Yulu Mining RMB 265,697,375.03 in H1-2026, up from RMB 96,296,245.10 in the H1-2025 comparative (+176%). Company received a RMB 32,000,000.00 dividend from Yulu Mining recorded at 2025-12-31 period-start (gone by 2026-06-30). English rendering \"Yulu Mining\" is a transliteration of 豫鹭矿业, not a confirmed official English name — treat the Chinese name as authoritative.source ↗
FY2024 · FY2024 comparative from the same FY2025 filing: RMB 5,615,991,396.91 in sales of goods to CATL.
H1-2025 · H1-2025 comparative column of the same H1-2026 interim report: RMB 2,433,549,923.34 in sales of goods to CATL.source ↗
FY2025 · Disclosed as a shareholder of the Company and its subsidiaries. Sales of goods to CATL: RMB 2,553,515,666.76 in FY2025 (down from RMB 5,615,991,396.91 in FY2024, -54.5%). No % of total sales disclosed — this filing states related-party value only, not the sales denominator.
H1-2026 · H1-2026 interim report (filed 2026-08-20, period ended 2026-06-30): sales of goods to CATL RMB 4,086,311,491.48, up from RMB 2,433,549,923.34 in the H1-2025 comparative (+67.9%). Confirms the FY2025 annual-report finding of a shifting relationship: the FY2025 annual figure had CMOC's full-year sales to CATL nearly halving y/y, but H1-2026 sales already exceed the entire FY2025 sales-to-CATL total (RMB 2,553,515,666.76), so the decline did not continue into 2026. No % of total sales disclosed.source ↗
Named in the FY2025 annual report's FY2024 comparative column of the top-5 accounts-receivable-debtor table (RMB 92,423,435.81 of RMB ~697m implied total AR). Not on CMOC's own related-party list — appears to be an independent (arm's-length) customer. Publicly known as a CATL subsidiary specialising in battery recycling (Guangdong Brunp Recycling Technology), consistent with buying cobalt/copper as recycling feedstock. In the FY2025 (2025-12-31) column this debtor no longer appears among the named-eligible top-5 (all five 2025 slots are coded, not named) — right-censored, not evidence the relationship ended.
Gécamines (20% shareholder of CMOC's Tenke Fungurume Mining JV, CMOC 80%) exercised its right to purchase 100,000t of TFM's 2026 copper cathode production -- its first direct purchase of TFM volumes reserved under the JV -- earmarked for the US market per the Dec-2025 DRC-US minerals agreement, with Mercuria providing export support.
CMOC FY2025 annual report (cninfo, 2026-04-02), Section 5 sales model, p.22: '铌产品同样建立了\"生产厂-IXM－客户\"的经销模式，整合IXM全球销售网络和中国国内销售团队的铌铁客户销售网络，不断增厚铌铁销售利润' — CMOC Brasil's niobium (ferroniobium) is sold through a plant-to-IXM-to-customer distribution model combining IXM's global sales network with a China domestic sales team's ferroniobium customer network. IXM is CMOC's 100%-owned trading subsidiary (intra-group flow). No volume, value or end-customer name disclosed; China is named as a sales territory but end-buyers are not.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
2 of 3 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 |
|---|---|---|---|---|---|---|---|---|---|
| Tungsten | 🇨🇳 CN 90% refining | 63 | 76 | Elevated | EXCEEDS 90% | High | some | 16 | ▲ rising |
| Cobalt | 🇨🇳 CN 78% refining | 62 | 62 | Elevated | EXCEEDS 78% | High | some | 37 | ▲ rising |
| Copper | 🇨🇳 CN 48% refining | 59 | 59 | Elevated | within 48% | High | limited | 52 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Tungsten | 4 | 4 | 5 | 3 | 3 | company input |
| Cobalt | 4 | 3 | 3 | 3 | 3 | company input |
| Copper | 4 | 2 | 5 | 4 | 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.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
Two independent lenses: USGS official puts China at 90% of global refining output (by tonnage); US filers' own disclosures independently name China for 54% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| Jiangwu H.C. Starck Tungsten Products Co., Ltd.CID2551 | China | 15 | SEC |
| Chongyi Zhangyuan Tungsten Co., Ltd.CID258 | China | 14 | SEC |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd.CID2315 | China | 14 | SEC |
| Ganzhou Seadragon W & Mo Co., Ltd.CID2494 | China | 14 | SEC |
| Jiangxi Gan Bei Tungsten Co., Ltd.CID2321 | China | 14 | SEC |
Source: US SEC Form SD / Conflict Minerals Report exhibits (EDGAR full-text search), aggregated from RMI smelter tables. “US filers naming it” = distinct US-listed companies whose most-recent CMR names that refiner — disclosure-derived presence, not verified throughput. Link opens the SEC exhibit.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 66 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Tungsten — 🇨🇳 CN escalates tungsten controls to a full export-licensing / ban regime | 63 | 66 | +3 |
| Concentration | Tungsten — 🇨🇳 CN becomes the single source for tungsten — the second source is lost (full 90%+ monopoly) | 63 | 68 | +5 |
| 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 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one China Molybdenum Co., Ltd. (CMOC) 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 3 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one China Molybdenum Co., Ltd. (CMOC) produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 3 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | mining-metals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-30; 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).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.