4 critical materials scored · binding chokepoint: Gallium (🇨🇳 CN 98% of refining) · 30 restrictive government measures on record
Subject
COHR · 🇺🇸 US
Sector
semiconductor-equipment
Materials scored
4
As of
2026-09-22
Risk Office verdict
High · 84/100Company supply-risk index
The binding exposure is Gallium — 🇨🇳 CN controls 98% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 74). The register holds 30 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · GalliumCoherent Corp. is the 25th-most-exposed of the 118 named companies we track on 🇨🇳 CN's Gallium chokepoint; the most-exposed is Appia Rare Earths & Uranium Corp. (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · semiconductor equipment
Coherent Corp. ranks 6th of 61 verified semiconductor equipment companies, tied with 2 others at 84.
86🇱🇹 Ekspla UABNeodymium
86🇹🇼 GlobalWafers Co., Ltd.Gallium
86🇰🇷 SK SiltronGraphite
85🇩🇪 Physik Instrumente (PI) SE & Co. KGDysprosium
84🇩🇪 Carl Zeiss SMT GmbHNeodymium
84🇺🇸 Coherent Corp.Gallium
84🇬🇧 Oxford Instruments plcTungsten
83🇩🇪 Aixtron SEGallium
83🇺🇸 Entegris, Inc.Graphite
82
Company supply-risk index 84/100 — 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 (US 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.
Coherent Corp. (NYSE: COHR), headquartered in Saxonburg, Pennsylvania, is a photonics, laser, and optical-communications company formed by the 2022 merger of II-VI Incorporated and legacy Coherent Inc. It reports through three segments — Materials, Networking, and Lasers — spanning industrial and aerospace lasers, optical-communications components (transceivers and InP optoelectronics for datacom, AI interconnects, and 6G), compound-semiconductor devices (VCSELs, semiconductor lasers for sensing), and engineered materials and optics (crystals, infrared optics, and compound-semiconductor substrates).
Critical-material exposure
Gallium (as gallium arsenide, GaAs) — bulk substrate feedstock for
Coherent's 150mm GaAs wafer platform, which underpins its compound- semiconductor lasers, VCSELs, and RF devices. Coherent itself named gallium as a material it sources when it publicly assessed China's 2023 gallium/germanium export controls.
Germanium — bulk raw substrate material and functional optical
component. Named alongside gallium in Coherent's 2023 export-control assessment; independently confirmed by Coherent's own product line of germanium substrates (up to 150mm) used in infrared optics — lenses, beamsplitters, and thermal-imaging/aerospace-defense domes.
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.
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.
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 scenariosShowHide
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).
Counterfactual: the 50%-ownership automatic extension of Entity List designations runs to its full perimeter (one-year suspension at 2025-11-10 lifted on schedule). Direct-hit lines are basket issuers in semiconductor / chip-equipment / AI-compute sectors — the perimeter where the rule's 50% controller-affiliate test compounds with existing Entity List names.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 88 → 90(+2) — a relative official policy-pressure magnitude, not a price drawdown.
Trace the precedent to its primary source via the link above ().
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
No material crosses the significant-vulnerability threshold. 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 materials this company buys. 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. Market-implied percentages are live external prediction-market prices (alternative/OSINT signal) — an independent read, not our model output and not merged into the official register or the stage-derived band; the gap between the market price and our stage assessment is itself the signal.
The upcoming threatsShowHide
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 113d ago · not yet law·matches Silicon
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
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 listShowHide
Gallium is the line to war-game: 🇨🇳 CN already controls 98% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Silicon carries 19 restrictive measures on record (🇨🇳 CN 80% of refining) — a secondary escalation candidate.
Germanium carries 11 restrictive measures on record (🇨🇳 CN 60% of refining) — a secondary escalation candidate.
Art. 24(4) · diversification & substitution
Priority mitigations
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Gallium).
The mitigation optionsShowHide
Map your real exposure to Gallium. Trace it from the component back to the smelter/refiner and country of origin — most buyers discover the dependence is one tier deeper than their direct supplier.
Qualify a non-CN source. Identify and validate at least one supplier outside CN for the binding input before it is needed, even at a cost premium — optionality is the hedge.
Lead-time to re-source is ~18 months (12-24mo). The largest tracked non-CN producer of Gallium is 🇷🇺 RU (~1% of refining); scaling it into a replacement is roughly a 12-24mo ramp. A share-of-stage substitution heuristic derived from current production share, not a firm supplier quote.
Design for substitution where feasible. Gallium has at least partial substitutes; specify them into next-generation products to cut the dependence structurally.
Hold strategic inventory / contract forward. For materials with no substitute and active export controls, a buffer stock or long-dated offtake converts a shock into a managed cost.
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 crosswalkShowHide
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)
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 detailsShowHide
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
Yes — 4 scored SRMs on the input side (binding: Gallium)
Manufactures a listed strategic technology
semiconductor-equipment (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.
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 2026-09-22; the register is continuously maintained and should be re-pulled against each new policy action.
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.
🇯🇵 Advantest Corporation
Tungsten
82🇱🇹 EKSMA OpticsGallium
82🇺🇸 Keysight Technologies, Inc.Tungsten
82🇩🇪 Kontron AGTungsten
82🇯🇵 Lasertec CorporationNeodymium
82🇩🇪 RENA Technologies GmbHGallium
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 2 further semiconductor equipment 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.
describes itself as running a "leading indium phosphide platform" and is investing in new 6-inch InP wafer fabs for AI-transceiver and 6G-wireless lasers, plus InP optoelectronic devices for coherent optical communications and datacom transceivers.
Silicon (as silicon carbide, SiC) — bulk substrate feedstock. SiC is one
of the core compound-semiconductor platforms in Coherent's Materials segment (alongside GaAs, InP, ZnSe, ZnS, GaSb), used for 200mm power- electronics and RF-device substrates.
None of these are trace additives for Coherent — each is a bulk feedstock or structural substrate material for a named product line, which is why gallium and germanium export-control exposure is significant enough for the company to have issued a standalone public assessment of it (concluding minimal near-term impact given inventory buffers, non-China sourcing, and in-house recycling as of 2023).
Two commonly-assumed exposures were checked and dropped for lack of current verification: neodymium (legacy Coherent Inc. was known for Nd:YAG lasers, but no current 10-K or company material confirms Nd:YAG as a present product line post-merger) and helium (no disclosure ties it to Coherent's purchased inputs). Tungsten, tin, tantalum, and copper — carried over from the sector-derived stub — are also dropped; no company disclosure supports them as material exposures.
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 ↗
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
Gallium
5Geopolitical: 9 restrictive actions, peak severity 5, 7 in last 24mo, less 1 liberalising action
5Concentration: refining HHI 9684 (extreme); top CN 98%
Silicon
4Geopolitical: 19 restrictive actions, peak severity 4, 14 in last 24mo
4Concentration: refining HHI 6498 (extreme); top CN 80%
4Substitutability: limited substitutes in electronics/electrical steel
4Import reliance: Eurostat Comext 2025: 63% extra-EU imports, top partner NO 47% (partner HHI 2698)
Indium
4Geopolitical: 2 restrictive actions, peak severity 4, 2 in last 24mo
🇨🇳 CN has issued 7 restrictive actions on Gallium since 2023 — cadence accelerating (mean gap 248d → 116d), severity flat (4.3 → 3.0).A descriptive trajectory of past official actions — not a forecast.
🇨🇳 CN's demonstrated restriction sequence — has restricted 15 materials since 2021, in this demonstrated order:
You hold exposure to 4 of these 15 materials (Silicon, Gallium, Indium, Germanium) — your binding Gallium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 7.7 months apart across 7 distinct restriction dates since 2021 (n=6 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 Silicon, 🇺🇸 US has historically countered (median 6.8 months later) — and those counter-moves have also restricted Gallium, which you also depend on (n=5 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 of 5 via quantified basis).
when 🇨🇳 CN restricts your Gallium, 🇺🇸 US has historically countered (median 11.4 months later) — and those counter-moves have also restricted Germanium, which you also depend on (n=4 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 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
Gallium — 🇨🇳 CN escalates gallium controls to a full export-licensing / ban regime
88
90
+2
Concentration
Gallium — 🇨🇳 CN becomes the single source for gallium — the second source is lost (full 98%+ monopoly)
88
89
+1
Policy
Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime
77
82
+5
Concentration
Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly)
77
89
+12
Policy
Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime
76
86
+10
Concentration
Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly)
76
91
+15
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.
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).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Silicon🇨🇳 today 77→82+5
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches Silicon, Gallium, Indium, Germanium
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.
If passed — Requires US allies — primarily the Netherlands (ASML) and Japan (Tokyo Electron, Shin-Etsu) — to align their national export controls on advanced semiconductor manufacturing equipment with US BIS restrictions targeting China; strips DoC discretionary licensing authority for chipmaking tools; DUV immersion lithography machines (ASML TWINSCAN NXT series) would face mandatory licensing denial for China-bound sales/servicing; includes anti-circumvention provisions to block third-country re-export through Malaysia, Singapore, or UAE; if enacted, would overturn the bilateral US-Netherlands arrangement on DUV servicing and pressure Japan to expand its April 2023 / January 2024 semiconductor-equipment controls beyond current scope; diplomatic friction: NL Trade Minister Sjoerdsma was in Washington the same week opposing this bill while simultaneously signing Pax Silica
Caveat — Senate bill introduced April 8, 2026 (bipartisan: Risch R-ID, Ricketts R-NE, Kim D-NJ, Schumer D-NY); House companion H. R. 8170 introduced April 2, 2026 (Baumgartner R-WA); House Foreign Affairs Committee passed April 22, 2026 in what HFAC members described as "the largest significant export-control markup in the history of Congress" (20 bills advanced in single markup). Full House and Senate chamber votes still pending as of June 24, 2026. Key contested provision removed pre-committee: country-wide ban on cryogenic etching tool exports — DUV restrictions remain. Administration position unclear — DoC has been resistant to losing licensing discretion; USTR and State potentially prefer diplomatic alignment (Pax Silica model) over binding legislation. If enacted, directly targets ASML NL: estimated ~USD 3–5bn annual China DUV machine revenue at risk. Distinct from: filed 2025-01-15-netherlands-export-control-metrology-inspection-semiconductor (Dutch national expansion, not US law); filed 2024-09-07-netherlands-export-control-expansion-asml-duv-1970i-1980i (Dutch unilateral DUV controls — MATCH Act would mandate further alignment); filed 2025-12-12-us-pax-silica-initiative (non-binding multilateral cooperation — MATCH Act is the binding-legislation complement). If passed, would become the first US law explicitly requiring allied-country export-control harmonisation on semiconductor equipment. Severity 4 expected if enacted.
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 ↗
▲Bipartisan lead sponsors incl. Senate leadership (strong) — S.4281 introduced by Risch (R-ID, SFRC Chair), Ricketts (R-NE), Kim (D-NJ) and Schumer (D-NY, Minority Leader) — cross-party and leadership-level backing raises floor-time odds.source ↗
▲Bicameral — House companion exists (H.R.8170) (moderate) — Rep. Baumgartner (R-WA) introduced the House companion Apr 2, 2026; a live measure in both chambers is further along than a single-chamber bill.source ↗
🇹🇿 Tanzania Finance Bill 2026/27 — NEW raw-mineral EXPORT LEVY on quartz (HS 25.06) and feldspar (HS 2529.10.00) under the Export Tax Act, Cap. 196
awaiting-signature→high likelihood·flagged 100d ago · not yet law·matches Silicon
If passed — The same Finance Bill 2026/27 already tabled (Parliament-passed 23 June 2026, effective 1 July 2026) inserts a NEW export levy of "10% of the FOB value of the cargo OR TZS 200 per kilogram, whichever is higher" on exports of quartz minerals (HS 25. 06) and feldspar (HS 2529. 10. 00) via amendment to the Export Tax Act, Cap. 196 — a distinct beneficiation-forcing EXPORT-TAX instrument that pushes raw quartz/feldspar exporters toward in-country value-addition. 196), and neither existing entry mentions it; (2) material-relevant — quartz HS 25. 06 covers high-purity/silica quartz feeding the silicon→semiconductor/solar value chain, so a Tanzanian export tax re-prices a raw-silica supply node; the same "rocks to riches" beneficiation logic Tanzania applies elsewhere; (3) part of the wider African raw-mineral-export-tax wave (cf. Zimbabwe 10% lithium-concentrate levy, Namibia unprocessed-mineral ban, Guinea bauxite reference price).
Caveat — On enactment, fold into that one TZ Finance Act 2026 action with action_type capturing both the fiscal-incentive and the export-levy (export-control/tariff) provisions; do NOT double-file. Distinct from filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year — no quartz/feldspar export levy). Severity 2 (sectoral raw-mineral export tax, niche HS lines).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Silicon🇨🇳 today 77→82+5
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 68d ago · not yet law·matches Gallium, Germanium
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").
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Gallium🇨🇳 today 88→90+2
Germanium🇨🇳 today 66→70+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.
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.
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.
▲Organized industry coalition support (weak) — AI Policy Network led a coalition letter backing the MATCH Act — organized outside support, though narrow.source ↗
▼Senate side still in committee (Banking) (moderate) — S.4281 was read twice and referred to Senate Banking, Housing & Urban Affairs; no Senate committee markup or floor calendaring reported as of Jul 2026.source ↗
▼Executive-branch resistance (Commerce) (moderate) — The bill strips DoC discretionary licensing authority; Commerce has been resistant to losing that discretion, and State/USTR may prefer diplomatic alignment (Pax Silica) over binding legislation.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 %).