1 critical material scored · binding chokepoint: Uranium (🇷🇺 RU 45% of refining) · 25 restrictive government measures on record
Subject
PRIVATE · 🇺🇸 US
Sector
mining-metals
Materials scored
1
As of
2026-08-21
Risk Office verdict
Elevated · 67/100Company supply-risk index · consumer-side read
Role check · this company is a producer, not a buyer
ConverDyn produces 1 of the 1 scored material above (Uranium). 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 · 67/100 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 Uranium — 🇷🇺 RU controls 45% of global refining. On this company's production footprint that scores 67/100 (adversarial chokepoint; global 57). The register holds 25 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · UraniumConverDyn is the 13th-most-exposed of the 55 named companies we track on 🇷🇺 RU's Uranium chokepoint; the most-exposed is Appia Rare Earths & Uranium Corp. (67/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · mining metals
ConverDyn ranks 146th of 445 verified mining metals companies, tied with 16 others at 67.
95🇺🇸 TdVibDysprosium
95🇦🇺 Northern Minerals LimitedDysprosium
93🇺🇸 Alta Resource TechnologiesDysprosium
93🇬🇧 Mkango Resources LimitedDysprosium
93🇨🇦 Defense Metals Corp.Dysprosium
93🇨🇦 Ucore Rare MetalsDysprosium
92🇺🇸 Phoenix TailingsDysprosium
91🇨🇦 Appia Rare Earths & Uranium Corp.Dysprosium
91🇦🇺 Arafura Rare Earths LimitedDysprosium
91🇦🇺 Hastings Technology Metals LimitedDysprosium
91🇦🇺 VHM LimitedDysprosium
91🇦🇺 Vital Metals LtdDysprosium
90🇨🇦 NioCorp DevelopmentsDysprosium
90🇺🇸 Energy Fuels Inc.Dysprosium
67🇺🇸 ConverDynUranium
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 67/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 1 scored material. Buyer-relative (first-order): weighted by where the company produces (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.
Disclosed production sites
US · Metropolis Works, IL (operated by Solstice Advanced Materials) — uranium conversion U3O8 -> UF6 (>10 kt UF6 projected 2026)uranium
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.
ConverDyn
What they do
ConverDyn is a 50/50 general partnership of Solstice Advanced Materials (the October 2025 Honeywell spin-off) and General Atomics, headquartered in Greenwood Village, Colorado. It is the exclusive marketing agent for all uranium hexafluoride (UF6) produced at Metropolis Works, Illinois, which is the only UF6 conversion facility in the United States. Utilities deliver uranium concentrate (U3O8), which is weighed and sampled at Metropolis and converted to UF6 for enrichment. It serves utilities in North America, Europe and Asia. Solstice projects Metropolis output of over 10 kt UF6 in 2026, about 20 % above planned 2024 output, and reports a backlog above $2 billion.
Critical-material exposure
Uranium (producer of the converted form; bulk input): ConverDyn sells
conversion, the step between mined U3O8 and enrichment. Its feed is natural uranium: BoLs from February 2026 record Kazatomprom material shipped from Kazakhstan to the US and consigned to ConverDyn. Conversion is one of the most concentrated steps in the fuel cycle, and Metropolis is the only US plant. That makes ConverDyn a chokepoint for US-origin UF6. It is also directly exposed to measures on Russian-origin nuclear fuel and to policy on Central Asian uranium routes.
**Fluorine / hydrogen fluoride (process reagent, not listed as an
exposure):** the dry fluoride volatility process includes hydrofluorination and fluorination stages. However, no ConverDyn or Solstice disclosure names the fluorspar source or quantity, and the reagent is consumed by the plant operator (Solstice), not by ConverDyn. Fluorspar is therefore not listed as a ConverDyn exposure.
Sources
https://converdyn.com/about-us/ — 50/50 Solstice–General Atomics partnership; UF6 conversion for utilities in North America, Europe and Asia
https://converdyn.com/our-services/ — U3O8 → UF6 conversion at Metropolis; U3O8 weighing/sampling; dry fluoride volatility process
https://www.solstice.com/us/en/resources/press-releases/2026/02/solstice-advanced-materials-announces-expansion-of-uranium-conversion-production-to-support-strong-nuclear-industry-customer-demand — Metropolis is the only US UF6 conversion facility; ConverDyn is exclusive marketing agent; >10 kt UF6 in 2026
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Supply-risk factor analysis
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
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
Uranium
4Geopolitical: 25 restrictive actions, peak severity 5, 14 in last 24mo, less 2 liberalising actions
5Price / market: price up (+31.8% YoY), as of 2026-04-24
4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 63/100 (long-horizon, all major uses). Prior analyst short-run rating 0.95: no substitute as nuclear fuel (per reactor design)
Change log
last 30 days
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
No filings or amendments in this window — the register has been quiet on this company's materials.
The laws that threaten it
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
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).
Which of your plants carries the binding exposure
Under the 🇷🇺 RU shock, your disclosed plant carries the binding Uranium exposure:
🇺🇸 US · Metropolis Works, IL (operated by Solstice Advanced Materials) — uranium conversion U3O8 -> UF6 (>10 kt UF6 projected 2026)
Disclosed plant-level detail matched to the binding material — descriptive, from the company's own disclosures; a plant not listed here is undisclosed, not unexposed. Country weights still drive the score above.
Type
Scenario
Today
Stressed
Δ
Policy
Uranium — 🇷🇺 RU escalates uranium controls to a full export-licensing / ban regime
67
74
+7
Concentration
Uranium — 🇷🇺 RU becomes the single source for uranium — the second source is lost (full 45%+ monopoly)
67
92
+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.
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one ConverDyn produces, and Art. 24 addresses the use of a strategic raw material as an input. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the 0 materials this company buys (the 1 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed — not yet law
Upcoming regulatory threats
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
The upcoming threatsShowHide
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 98d ago · not yet law·matches Uranium
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Uranium🇷🇺 today 67→74+7
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 113d ago · not yet law·matches Uranium
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
If passed & escalated to a full control regime — modelled impact (high likelihood)
Uranium🇷🇺 today 67→74+7
🇳🇦 Namibia new Minerals Bill (Minerals Prospecting and Mining Act overhaul)
in-consultation→moderate likelihood·flagged 113d ago · not yet law·matches Uranium
If passed — 10% free-carried state equity in ALL new mining and energy projects (no-cost government stake via Epangelo Mining); consultations on 51% Namibian ownership in new mining ventures; maximum royalty rate rise from 5% to potentially 10% for strategic minerals; introduction of profit-based windfall-tax mechanism; tighter local-content and environmental obligations; affects Uranium One/NamCor (uranium), Osino Resources, B2Gold, and lithium juniors in Namibia
Caveat — Reforms the 1992 Minerals (Prospecting and Mining) Act — the foundational mining law since independence. MME announced that Government is also consulting on mechanisms to promote 51% Namibian ownership in new ventures (more aggressive than the 10% headline). The Extractor Magazine (July 17, 2025) and Veridicor (Sep 16, 2025) also confirm reform scope. Distinct from already-filed NA actions: 2023-06-06 Cabinet export ban on unprocessed critical minerals; 2024-12-04 National Upstream Petroleum Local Content Policy; 2025-09-23 Nuclear Industry Strategy. The 2025 Nuclear Strategy covers uranium value-chain capture but not the broader Minerals Act reform. Namibia is the 3rd-largest uranium producer globally (Rössing, Husab) and an emerging lithium jurisdiction.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Uranium🇷🇺 today 67→74+7
CEMAC Common Mining Code — 6-member regional harmonisation (April 2026)
draft-published→moderate likelihood·flagged 107d ago · not yet law·matches Uranium
If passed — If adopted, creates a unified mining regulatory framework across Cameroon, CAR, Congo-Brazzaville, Gabon, Equatorial Guinea, and Chad — harmonising licensing regimes, fiscal terms, transparency obligations (EITI, KP, ICGLR), and environmental standards; would affect Eramet/Comilog manganese operations (Gabon), Sundance Resources iron ore (CAR), Chinese mining JVs (Congo-Brazzaville, CAR), and uranium projects across the region; if enacted, creates a regional investment-guarantee architecture that could facilitate cross-border mining finance and reduce individual-country treaty risk; structural precedent for pooled resource sovereignty in a region where individual states are renegotiating contracts (Gabon post-coup Décret 0276/2024 sovereign-equity mandate, CAR post-KP-readmission, Congo-Brazzaville mining-code review)
Caveat — Consultation meetings held April 2024 (Brazzaville), July 2024 (Riaba/Malabo), February 2025 (regional review workshop), April 2026 (Douala finalization session) — code still in draft form as of April-May 2026; CEMAC has a historically slow ratification track record (Tariff Union took ~15 years to operationalise); likelihood low until formal adoption at heads-of-state summit; DISTINCT from individually filed national mining code reforms: Gabon Décret 0276/2024 (sovereign substances regime), CAR Law 24-008 (new mining code). Filed upcoming 2026-06-20.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Uranium🇷🇺 today 67→74+7
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
What to watch next
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The watch listShowHide
Uranium is the line to war-game: 🇷🇺 RU already controls 45% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Art. 24(4) · diversification & substitution
Priority mitigations
Every scored material here is one ConverDyn produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
The mitigation optionsShowHide
Track demand-side substitution against your own book. The buyer levers listed for consumers of Uranium — qualifying alternative suppliers, designing the material out — are the demand risk to ConverDyn's revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by RU on a material ConverDyn produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The material above is concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.
Annex A · regulatory basis
CRMA Art. 24 compliance crosswalk
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
The full 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)
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.
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
company input — all 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology
mining-metals (confirm against Annex)
Formally identified by a Member State authority
company input
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 2026-08-21; 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.