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4 critical materials scored · binding chokepoint: Dysprosium (🇨🇳 CN 99% of refining) · 51 restrictive government measures on record
China Northern Rare Earth (Group) High-Tech Co., Ltd. produces 4 of the 4 scored materials above (Dysprosium, Terbium, Neodymium, Praseodymium). 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 · 45/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-07) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Dysprosium — 🇨🇳 CN controls 99% of global refining. On this company's production footprint that scores 48/100 (inside the chokepoint; global 88). The register holds 51 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Dysprosium China Northern Rare Earth (Group) High-Tech Co., Ltd. is the 246th-most-exposed of the 261 named companies we track on 🇨🇳 CN's Dysprosium chokepoint; the most-exposed is TdVib (95/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
China Northern Rare Earth (Group) High-Tech Co., Ltd. ranks 385th of 460 verified mining metals companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 133 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 45/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 4 scored materials. Buyer-relative (first-order): weighted by where the company produces (CN 100%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
China Northern Rare Earth (Group) High-Tech Co., Ltd. (SSE: 600111), based in Baotou, Inner Mongolia, is the world's largest rare-earth producer by volume and holds the separation/refining licences covering output from the Bayan Obo deposit — controlled by its parent, Baotou Steel (Group). It processes rare earth concentrate into rare earth salts, oxides and metals, then further into functional materials (magnetic, polishing, hydrogen-storage, catalytic) and downstream terminal products including NdFeB permanent-magnet high-efficiency motors.
deposit, and the company is the world's dominant source of separated NdPr oxide, the primary feedstock for NdFeB permanent magnets. This is core, volume-scale business, not a trace input.
as "NdPr oxide"; same Bayan Obo light-rare-earth mineralogy, same volume-scale exposure.
additive in the company's own NdFeB magnet materials, but Bayan Obo's light-rare-earth ore carries only trace dysprosium; heavy-rare-earth supply for this purpose is concentrated in ionic-clay deposits in southern China (Jiangxi), outside this company's own mine base. No-substitute risk applies to the additive itself, not to a large volume this company controls.
heavy-rare-earth sourcing caveat as dysprosium: a gram-scale additive, not a bulk input, and largely sourced outside the company's own Bayan Obo supply.
the heavy rare earths (Dy, Tb) and this single company alone accounts for a large share of world NdPr supply, so policy actions targeting Chinese rare-earth export licensing (e.g. quota or license changes) hit this company's core product line directly, not just a peripheral input.
All figures below come from the company's own audited annual reports filed with the Shanghai Stock Exchange via cninfo (the CSRC-designated disclosure portal). Every name is reproduced as the filing gives it, with the Chinese legal name retained. Confidence: `primary-source` unless marked otherwise.
Reporting periods covered: FY2024 (filed 2025-04-19), FY2025 (filed 2026-04-18), and H1-2026 (filed 2026-08-20). These are the filer's own disclosures for those periods — not a current snapshot. Do not present any of them as "today."
| Purchase | FY2024 | FY2025 |
|---|---|---|
| Rare-earth concentrate (稀土精矿) from Baotou Steel Union | RMB 8,548,424,689.57 | RMB 9,417,453,148.62 |
| Share of same-type transactions | 100.00% | 100.00% |
| Disclosed unit price | RMB 18,021.80 / tonne | not stated (price column blank) |
Amounts are tax-inclusive (含税), as labelled in the filings. Pricing basis is 协议价 (agreement price), i.e. negotiated intra-group, not a market reference.
The world's largest rare-earth producer buys 100% of its rare-earth concentrate from a single related party — 内蒙古包钢钢联股份有限公司 (Inner Mongolia BaoTou Steel Union Co., Ltd., SSE: 600010), a subsidiary of the company's controlling shareholder 包头钢铁（集团）有限责任公司 (Baotou Iron & Steel (Group) Co., Ltd.). The company states its own operating model this way: it "relies on the Bayan Obo rare-earth resource advantage controlled by its controlling shareholder Baotou Steel (Group), and purchases the rare-earth concentrate produced by its controlled subsidiary Baotou Steel Union."
This is the Bayan Obo chokepoint expressed as an audited procurement line. It is also disclosed as a standing major purchase contract: subject 稀土精矿, counterparty 包钢股份, total contract value RMB 12.0 billion (tax-inclusive), of which RMB 9.417bn was performed in FY2025 and RMB 8.548bn in FY2024, both recorded as performing normally.
| FY2024 | FY2025 | |
|---|---|---|
| Top-5 customers, value | RMB 8,552,679,000 | RMB 13,959,131,000 |
| Top-5 customers, % of annual sales | 25.94% | 32.80% |
| — of which related-party | 0 (0%) | 0 (0%) |
| Top-5 suppliers, value | RMB 10,455,711,600 | RMB 15,440,729,600 |
| Top-5 suppliers, % of annual purchases | 38.78% | 44.71% |
| — of which related-party | RMB 7,564,977,600 (28.06%) | RMB 8,590,332,200 (24.88%) |
Both sides concentrated further year over year. Related-party purchases fell as a share of total procurement (28.06% → 24.88%) while rising ~13.6% in absolute RMB — dilution by growth, not disengagement. The company answered "not applicable" to the prompts asking whether any single customer exceeded 50% of sales, whether there were new entrants in the top five, or whether it is severely dependent on a few customers or suppliers.
From the FY2025 daily related-party transaction summary and the financial- statement related-party notes. Note the two disclosures use different tax bases: the governance-section table is tax-inclusive, the financial-statement notes are ex-VAT. They reconcile at 1.13× (e.g. Antai Beifang RE-metal sales: RMB 408,882,050.87 ex-VAT × 1.13 = RMB 462.0m, matching the tax-inclusive figure) — not a discrepancy.
Suppliers to the company (FY2025 unless noted):
concentrate, RMB 9,417,453,148.62, 100.00% of that transaction type. Separately materials, tailings, security services/equipment, energy & power, oxygen, testing: RMB 288,378,030.62.
shareholder. Leasing, energy & power, security services/equipment, metering, inspection, consulting: RMB 185,317,029.90 (FY2024: RMB 36,880,833.60 — a ~5× increase).
equipment spares, labour-protection materials, installation, leasing, design, feasibility/maintenance/network/chemical-testing services: RMB 158,605,269.64.
training, integrated services: RMB 13,838,175.20.
RMB 100,615.00.
and magnets: RMB 12,067,684.96 (FY2024: RMB 29,082,158.78). See the bidirectional note below.
and installation/commissioning: RMB 1,040,707.96.
supplier. Deposits RMB 3,302,917,720.77 (72.95% of same-type, up from 60.93% in FY2024), interest income RMB 39,160,526.49 (62.15%), loans RMB 45,043,312.49 (0.55%), interest expense RMB 1,614,718.17 (0.76%). Nearly three-quarters of the company's deposits sit inside the parent group's own finance company.
Customers (FY2025):
service fees, RMB 408,882,050.87 ex-VAT / RMB 462,024,372.48 tax-inclusive (FY2024: RMB 419,976,774.05 ex-VAT / RMB 474,559,083.08 tax-inclusive, at a disclosed RMB 429,737.35/tonne, then 3.37% of same-type transactions). Caveat that matters: this is not an arm's-length external buyer. The FY2025 filing lists Antai Beifang as an associate (联营企业) in which China Northern Rare Earth holds 41.50% directly plus 5.02% indirectly (46.52%), equity-method, based in Baotou, business nature "processing." Treat it as an affiliated processing outlet, not as evidence of external demand. The relationship is bidirectional — RE metal out, NdFeB scrap and magnets back in.
alloys, slag and waste, chemicals, motors RMB 412,972,875.85; testing/labour/ environmental-monitoring/technical services/waste-disposal and freight RMB 673,028,845.81; engineering services RMB 10,461,935.56.
services, transport, engineering: RMB 402,354,400.73 (tax-inclusive).
包钢矿业 / Baotou Steel Mining — RMB 930,593.37; 铁捷物流 / Tiejie Logistics — RMB 1,645,195.57; 铁花文化 / Tiehua Culture — RMB 733,434.32; 国瑞科创稀土功能材料有限公司 / Guorui Kechuang RE Functional Materials — utilities and property, RMB 95,584.96.
Note that almost everything sold to the parent group is services, scrap and by-products — not rare-earth product. The only named rare-earth product customer anywhere in the filing is the 46.5%-owned associate Antai Beifang.
Name-collision hazard — two different "Antai" entities appear in the same filing. The definitions page distinguishes 安泰北方 = 安泰北方科技有限公司 (Antai Beifang Technology, the 46.52% associate above) from 北方中鑫安泰新材料 （内蒙古）有限公司 (Beifang Zhongxin Antai New Materials (Inner Mongolia), the 40%-held entity acquired in FY2024 and consolidated). Do not merge them.
The negative below still stands for CNRE's own filings — but one external customer has since been identified from the *counterparty's* filing.
JL MAG Rare-Earth (SZSE 300748 / HKEX 06680) names 中国北方稀土（集团）高科技 股份有限公司 as its #1 supplier in its own audited FY2025 annual report: RMB 4,548,596,045.78, 69.13% of JL MAG's total procurement (FY2024: RMB 2,793,283,045.09, 52.72%). See [jl-mag-rare-earth](jl-mag-rare-earth.md). Confidence: primary-source for the figure and the naming.
JL MAG is necessarily one of CNRE's FY2025 top-5 customers. CNRE's disclosed top-5 of RMB 13,959,131,000 = 32.80% implies FY2025 revenue of ~RMB 42.56bn, so JL MAG's purchases are ~10.7% of CNRE revenue as stated (~9.5% if JL MAG's figure is tax-inclusive and CNRE's revenue ex-VAT). If JL MAG were not in the top five, all five would each have to exceed that, totalling ≥47% — more than the disclosed 32.80%. The placement is therefore forced arithmetically, not assumed. Confidence: secondary (cross-filing deduction, arithmetic shown).
Two limits, stated deliberately: this does not establish that JL MAG is 客户 1 — being largest is consistent with the numbers but not forced by them — and it does not identify the other four. The tax-basis and consolidation-scope differences between the two filers' figures are not reconciled here.
The method point is the transferable part. CNRE's own disclosure withholds every external customer name, and 98.5% of its sales never cross a border so customs is blind too — yet the buyer's filing names the seller. Where both ends of a link are listed filers, the disclosure asymmetry runs in one direction and can be read from whichever end discloses. Worth running against other CNRE counterparties before concluding its customer list is closed.
CNRE's H1-2026 semi-annual report (filed 2026-08-20, nine days ahead of the CSRC Art. 20 due date of 2026-08-31) does not repeat the mandatory top-5 sales/purchase concentration table above — that disclosure is required only in annual reports, not semi-annual ones, under the CSRC's differing Content & Format Standards for the two filing types. It does, however, carry two other mandatory top-5 disclosures that name real counterparties: the top-5 accounts-receivable and contract-asset debtors (customers who owe CNRE money at period-end) and the top-5 prepayment recipients (suppliers CNRE paid in advance). Both are new metrics for this dossier — a receivables/ prepayment balance, not a sales/purchase-volume share — so they are recorded as their own rows rather than joined to the FY2024/FY2025 series above.
Customers (top-5 accounts-receivable and contract-asset debtors, H1-2026, total RMB 2,256,122,812.31 = 39.06% of the period-end balance):
| Debtor | RMB | % |
|---|---|---|
| 江西金力永磁科技股份有限公司 / Jiangxi JL MAG Technology (JL MAG Rare-Earth, SZSE 300748) | 748,545,679.43 | 12.96 |
| 内蒙古包钢钢联股份有限公司及其子公司 / Baotou Steel Union and subsidiaries (SSE 600010, related party) | 627,382,299.08 | 10.86 |
| 某单位 / an unnamed unit (anonymised in the filing) | 368,533,000.00 | 6.38 |
| 宁波招宝磁业股份有限公司 / Ningbo Zhaobao Magnetic Industry Co., Ltd. | 284,862,394.89 | 4.93 |
| 宁波华辉磁业有限公司 / Ningbo Huahui Magnetic Co., Ltd. | 226,799,438.91 | 3.93 |
This is the first time JL MAG is named in CNRE's OWN filing, not just inferred from JL MAG's side (the secondary-confidence row above). It is a different metric — a receivables balance, not a sales percentage — so it confirms the relationship at primary-source confidence without confirming or contradicting the ~10.7% sales-share estimate derived earlier. Ningbo Zhaobao Magnetic and Ningbo Huahui Magnetic are new names in this corpus: both are NdFeB magnet makers (consistent with CNRE's downstream customer base being magnet producers), neither previously identified from either side.
Suppliers (top-5 prepayment recipients, H1-2026, total RMB 313,659,337.92 = 59.05% of the period-end prepayment balance):
| Recipient | RMB | % |
|---|---|---|
| 中稀天马新材料科技股份有限公司 / Zhongxi Tianma New Material Technology Co., Ltd. | 99,777,630.00 | 18.79 |
| 某单位 / an unnamed unit (anonymised in the filing) | 73,413,087.77 | 13.82 |
| 宁波晋周磁材有限公司 / Ningbo Jinzhou Magnetic Materials Co., Ltd. | 49,152,000.00 | 9.25 |
| 万安乐达新材料有限公司 / Wan'an Leda New Material Co., Ltd. | 47,900,000.00 | 9.02 |
| 龙南市建控资源综合利用有限公司 / Longnan Jiankong Resource Comprehensive Utilization Co., Ltd. | 43,416,620.15 | 8.17 |
Both "某单位" rows are the filing's own anonymisation — a euphemistic label, not a stable coded slot like the 客户1–5 tables elsewhere in this dossier — so per this corpus's standing rule they are recorded here as a finding (the concentration structure) but not written into named_counterparties, which requires an identity (name or a stable code).
Zero arm's-length customers are identified in either filing. The top-5 customer disclosure is explicit that related-party sales within it are RMB 0 (0%) — so the 32.80% of FY2025 revenue those five buyers represent is entirely external, and entirely anonymous. Where the filing does break out a top-five customer table (for the trading segment, 贸易业务, whose revenue exceeds 10% of the total), the buyers are listed only as 客户 1 … 客户 5:
| Sales (RMB) | % of annual sales | |
|---|---|---|
| 客户 1 | 1,172,740,455.79 | 2.76 |
| 客户 2 | 902,973,134.93 | 2.12 |
| 客户 3 | 761,407,079.63 | 1.79 |
| 客户 4 | 452,918,398.86 | 1.06 |
| 客户 5 | 423,734,513.28 | 1.00 |
| Total | 3,713,773,582.49 | 8.73 |
The matching trading-segment supplier table is likewise anonymised (供应商 1–5, RMB 3,338,435,015.30 total, 9.67% of annual purchases).
Per this corpus's standing rule, anonymised counterparties are a finding, not a failure: the concentration structure is disclosed even where the names are withheld. Do not attempt to infer the identities of 客户 1–5.
Why customs data cannot close this gap either. The FY2025 geographic split of main-business revenue is domestic RMB 41,737,048,515.17 versus overseas RMB 613,967,088.62 — overseas is just 1.45% of main-business revenue (though it grew 99.35% year over year off that small base, against 28.44% domestic growth). Roughly 98.5% of the world's largest rare-earth producer's sales never cross a border, so they generate no bill of lading anywhere on earth. For this company, the A-share filing lane and the customs lane are both blind to the external buyer list — the filing because names are withheld, customs because the goods stay domestic. That boundary is worth stating plainly rather than re-attempting.
The FY2025 report discloses that the CSRC's Inner Mongolia bureau issued the company a warning letter (警示函, decision [2025] No. 21), announced 2025-10-14. Recorded here because it bears on filing reliability; the underlying subject matter was not examined in this pass. Confidence: `primary-source` for the existence of the letter, unverified as to its subject.
SSE via cninfo) — operating model p13, geographic revenue split and major purchase contract p24, top-5 customer/supplier concentration p26, anonymised trading-segment tables p27, CSRC warning letter p80, daily related-party transaction summary pp80–81, associate shareholdings p221, related-party purchase/sale notes pp240–241: http://static.cninfo.com.cn/finalpage/2026-04-18/1225118607.PDF
SSE via cninfo) — operating model p18, production/sales volumes and major purchase contract p25, top-5 concentration, daily related-party transaction table with disclosed unit prices p106. Retrieved via scripts/py/cninfo_filings.py 600111 --index 3.
aggregator: 包钢股份 → code 600010, orgId gssh0600010, A股.
names CNRE as its #1 supplier, pp.23-24, the buyer-side identification above: http://static.cninfo.com.cn/finalpage/2026-03-26/1225030339.PDF
2026-08-20, SSE via cninfo, nine days ahead of the CSRC due date) — top-5 accounts-receivable/contract-asset debtors p101, top-5 prepayment recipients p104: http://static.cninfo.com.cn/finalpage/2026-08-20/1225483017.PDF
From the company’s own mandatory filings — the CSRC top-5 customer/supplier concentration disclosure and the related-party tables. This is a disclosure, not a netting: a named supplier concentration is shown beside the exposure score and never adjusts it. Figures are the fiscal years labelled, not a current snapshot.
The customer side is fully arm's-length AND fully anonymous — zero external buyers are named anywhere, and 98.5 percent of sales never cross a border, so customs is blind too. The supplier side is the opposite: over half the top-5 is intra-group.
The Bayan Obo chokepoint as an audited procurement line — RMB 9,417,453,148.62 under a standing RMB 12.0bn contract, at negotiated intra-group agreement price. FY2024: RMB 8,548,424,689.57, also 100.00 percent.
Controlling shareholder. Leasing, energy and power, security, metering, inspection, consulting — RMB 185,317,029.90, roughly 5x the FY2024 figure of RMB 36,880,833.60.
The ONLY named rare-earth PRODUCT customer in the filing — RMB 408,882,050.87 ex-VAT — and a 46.52 percent-held associate, so it is an affiliated processing outlet, not evidence of external demand. Bidirectional: RE metal out, NdFeB scrap and magnets back in (RMB 12,067,684.96).
Captive treasury, not a goods supplier. RMB 3,302,917,720.77 of deposits sit inside the parent group's own finance company, up from 60.93 percent in FY2024.
#1 prepayment recipient, RMB 99,777,630.00 — CNRE paid this company in advance of delivery, the disclosure's own signal of a supply relationship. New name.
#3 prepayment recipient, RMB 49,152,000.00. New name.
#4 prepayment recipient, RMB 47,900,000.00. New name.
#5 prepayment recipient, RMB 43,416,620.15. Longnan sits in Jiangxi's ionic-clay heavy-rare-earth belt — worth a follow-up read on this company's own supply position, not researched this tick.
The ONLY named rare-earth PRODUCT customer in the filing — RMB 408,882,050.87 ex-VAT — and a 46.52 percent-held associate, so it is an affiliated processing outlet, not evidence of external demand. Bidirectional: RE metal out, NdFeB scrap and magnets back in (RMB 12,067,684.96).
Scrap steel, alloys, slag, chemicals, motors RMB 412,972,875.85 plus services and freight RMB 673,028,845.81 — by-products and services, not rare-earth product.
Identified from the BUYER's filing, not this one — JL MAG names CNRE as its number-1 supplier at RMB 4,548,596,045.78. Forced arithmetically into CNRE's top-5 (that is ~10.7 percent of CNRE revenue against a 32.80 percent top-5), but which rank is NOT established. Cross-filing deduction, hence secondary.
First direct naming of JL MAG in CNRE's OWN filing —
#2 accounts-receivable debtor, RMB 627,382,299.08. Same related party already carried above on the FY2025 sales-concentration rows; this is the receivables-balance cut, a different share_of basis, so it is a separate row rather than a joined vintage.
#4 accounts-receivable debtor, RMB 284,862,394.89. New name, not previously in this dossier.
#5 accounts-receivable debtor, RMB 226,799,438.91. New name, not previously in this dossier.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: A-share issuers anonymise counterparties they are not required to name. · section source filing ↗
Ranked by buyer-relative risk, highest first.
4 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 |
|---|---|---|---|---|---|---|---|---|---|
| Dysprosium | 🇨🇳 CN 99% refining | 48 | 88 | Moderate | EXCEEDS 99% | Low | none | 51 | ▲ rising |
| Terbium | 🇨🇳 CN 99% refining | 42 | 84 | Moderate | EXCEEDS 99% | Low | limited | 51 | ▲ rising |
| Neodymium | 🇨🇳 CN 85% refining | 36 | 72 | Low | EXCEEDS 85% | High | some | 50 | ▲ rising |
| Praseodymium | 🇨🇳 CN 85% refining | 36 | 72 | Low | EXCEEDS 85% | High | some | 48 | ▲ 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 |
|---|---|---|---|---|---|---|
| Dysprosium | 4 | 5 | 5 | 5 | 3 | company input |
| Terbium | 4 | 5 | 5 | 4 | 3 | company input |
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Praseodymium | 4 | 4 | 5 | 3 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 36 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
The binding exposure this precedent lands on — Dysprosium — is a material China Northern Rare Earth (Group) High-Tech Co., Ltd. produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-07) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 4 restrictive actions on Dysprosium since 2024 — cadence accelerating (mean gap 483d → 152d), severity flat (3.5 → 3.5).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 4 of these 26 materials (Neodymium, Dysprosium, Praseodymium, Terbium) — your binding Dysprosium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 4.7 months apart across 5 distinct restriction dates since 2024 (n=4 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Dysprosium — 🇨🇳 CN escalates dysprosium controls to a full export-licensing / ban regime | 48 | 49 | +1 |
| Concentration | Dysprosium — 🇨🇳 CN becomes the single source for dysprosium — the second source is lost (full 99%+ monopoly) | 48 | 48 | 0 |
| Policy | Terbium — 🇨🇳 CN escalates terbium controls to a full export-licensing / ban regime | 42 | 43 | +1 |
| Concentration | Terbium — 🇨🇳 CN becomes the single source for terbium — the second source is lost (full 99%+ monopoly) | 42 | 42 | 0 |
| Policy | Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime | 36 | 37 | +1 |
| Concentration | Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly) | 36 | 39 | +3 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one China Northern Rare Earth (Group) High-Tech Co., Ltd. produces, and Art. 24 addresses the use of a strategic raw material as an input. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the 0 materials this company buys (the 4 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one China Northern Rare Earth (Group) High-Tech Co., Ltd. produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 4 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 2026-10-07
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