5 critical materials scored · binding chokepoint: Tungsten (🇨🇳 CN 90% of refining) · 57 restrictive government measures on record
Subject
000990.KS · 🇰🇷 KR
Sector
semiconductor
Materials scored
5
As of
2026-09-22
Risk Office verdict
High · 83/100Company supply-risk index
The binding exposure is Tungsten — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 76). The register holds 57 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · TungstenDB HiTek Co., Ltd. is the 46th-most-exposed of the 465 named companies we track on 🇨🇳 CN's Tungsten chokepoint; the most-exposed is Elbit Systems (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · semiconductor
DB HiTek Co., Ltd. ranks 9th of 72 verified semiconductor companies, tied with 2 others at 83.
88🇬🇧 Filtronic plcGallium
86🇺🇸 MicroLink Devices, Inc.Gallium
86🇬🇧 CML Microsystems plcGallium
86🇸🇪 Norstel ABGraphite
86🇺🇸 Skyworks Solutions, Inc.Gallium
85🇦🇺 BluGlass LimitedGallium
84🇱🇹 Brolis SemiconductorsGallium
83🇦🇹 ams-OSRAM AGTerbium
83🇰🇷 DB HiTek Co., Ltd.Tungsten
83
Company supply-risk index 83/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 5 scored materials. Buyer-relative (first-order): weighted by where the company produces (KR 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.
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.
DB HiTek (KRX: 000990) is a pure-play specialty semiconductor foundry headquartered in Bucheon, South Korea, running two 200mm (8-inch) wafer fabs — its original Bucheon campus and the Sangwoo campus in Eumseong-gun — with combined capacity of roughly 154,000 wafers/month. Unlike memory makers such as Samsung or SK Hynix, DB HiTek does not fabricate its own chip designs at volume for itself; it foundries analog and mixed-signal processes (BCDMOS, analog CMOS, power MOSFET/IGBT, CMOS image sensors) for around 400 customers, mainly serving display-driver ICs and power-management ICs for TVs, smartphones, PCs, industrial gear and automotive electronics. As Samsung and TSMC wind down legacy 8-inch capacity, trade press (TrendForce, Nov 2025) reports DB HiTek gaining share in mature-node analog foundry work.
Critical-material exposure
Silicon — bulk input. The 200mm wafer substrate underlying every die DB HiTek produces; foundational but not itself a supply-concentration chokepoint at the wafer-fab tier.
Tungsten — structural component. Named directly in DB HiTek's own conflict-minerals policy as one of the four regulated 3TG minerals its suppliers must source from RMAP-certified smelters; used industry-wide as CVD tungsten via/contact plugs in analog and BCD back-end-of-line processing. China accounts for the large majority of global tungsten mining.
Tantalum — structural component. Also named in DB HiTek's 3TG conflict-minerals policy; used as sputtering-target material and in tantalum capacitors common to analog/power-management chip packages. Roughly half of global tantalum supply traces to the DRC and Rwanda, a concentration and conflict-sourcing risk.
Does the company disclose this dependency?
A separate read from its own public reporting — not part of the exposure score above. We check whether the company's latest annual / CSRD-ESRS filing names, quantifies, and gives a mitigation plan for the critical-minerals dependency our register ranks it on. The mismatch — ranked exposed here, silent in its own filing — is the engagement / short-thesis signal. Every answer is traced to a primary filing or left “not found”; nothing is inferred.
The disclosure checkShowHide
Names the dependency
✓ yes
Quantifies it
✗ no
States a mitigation plan
✓ yes
Disclosed. The company acknowledges the dependency in its own reporting but does not quantify it and states a mitigation plan.
Basis: DB HiTek supply-chain / conflict-minerals management page (3TG: W, Ta, Sn, Au)
Source: primary filing ↗ · checked 2026-07-29 · Alternative track — a disclosure read, never merged into the exposure score.
The exposure register
Ranked by buyer-relative risk, highest first.
3 of 3 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
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.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
The named refinersShowHide
Tungsten
China = 54% of filer-disclosed refiner mentions · 291 named refiners
Two independent lenses: USGS official puts China at 90% of global refining output (by tonnage); US filers' own disclosures independently name China for 54% of their refiners (by facility count). Different metrics — both rank China first.
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).
Which of your plants carries the binding exposure
Under the 🇨🇳 CN shock, these disclosed plants carry the binding Tungsten exposure:
🇰🇷 KR · Bucheon — 200mm analog/mixed-signal wafer fab
🇰🇷 KR · Sangwoo (Eumseong-gun) — 200mm analog/mixed-signal wafer fab
Disclosed plant-level detail matched to the binding material — descriptive, from the company's own disclosures; a plant not listed here is undisclosed, not unexposed. Country weights still drive the score above.
Closest real precedent — this isn’t hypothetical
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 factors we could score (1 of 25 inputs unrated across the materials bought). Absence of data is not evidence of low risk — an unrated factor enters the score as zero, not as an estimate, so this conclusion could change once those inputs are rated. 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 112d 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
Tungsten is the line to war-game: 🇨🇳 CN already controls 90% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Gallium carries 9 restrictive measures on record (🇨🇳 CN 98% of refining) — a secondary escalation candidate.
Silicon carries 19 restrictive measures on record (🇨🇳 CN 80% 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 (Tungsten).
The mitigation optionsShowHide
Map your real exposure to Tungsten. 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 ~9 months (6-12mo). The largest tracked non-CN producer of Tungsten is 🇦🇹 AT (~4% of refining); scaling it into a replacement is roughly a 6-12mo ramp. A share-of-stage substitution heuristic derived from current production share, not a firm supplier quote.
Design for substitution where feasible. Tungsten 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 — 5 scored SRMs on the input side (binding: Tungsten)
Manufactures a listed strategic technology
semiconductor (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.
🇹🇼 Himax Technologies, Inc.
Tungsten
82🇮🇹 LFoundry S.r.l.Tungsten
82🇺🇸 Qorvo, Inc.Gallium
82🇹🇼 Vanguard International Semiconductor Corporation (VIS)Gallium
81🇳🇴 Nordic Semiconductor ASATungsten
81🇬🇧 Pragmatic Semiconductor LtdGallium
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 11 further semiconductor 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.
Tin — structural component. The third of DB HiTek's named 3TG minerals; used in solder bumping and wire-bonding at the packaging tier. Mining is concentrated in China and Indonesia.
Gallium — trace additive today, rising. DB HiTek is developing a 650V E-mode GaN (gallium nitride) power-semiconductor line, running multi-project-wafer trials since December 2025 with mass production targeted for 2027; this is a new, low-volume line layered on top of the legacy silicon BCD business, not yet a bulk input. China refines the large majority of the world's gallium and has used export licensing on the metal as a trade-policy lever.
Sources
DB HiTek supply-chain / conflict-minerals policy (Ta, W, Sn, Au 3TG scope): https://www.dbhitek.com/en/sustainability/social/supply-chain-management
DB HiTek GaN HEMT development, Semiconductor Today: https://www.semiconductor-today.com/news_items/2025/sep/dbhitek-110925.shtml
DB HiTek 8-inch capacity / market position, TrendForce: https://www.trendforce.com/news/2025/11/12/news-tsmc-samsung-reportedly-cut-8-inch-wafer-output-boosting-koreas-db-hitek/
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
Tungsten
4Geopolitical: 16 restrictive actions, peak severity 5, 10 in last 24mo, less 2 liberalising actions
4Concentration: refining HHI 8126 (extreme); top CN 90%
5Price / market: price up, as of 2026-09-01
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)
Tin
4Geopolitical: 18 restrictive actions, peak severity 4, 13 in last 24mo
5Price / market: price up, as of 2026-09-01
Tantalum
4Geopolitical: 12 restrictive actions, peak severity 4, 8 in last 24mo, less 2 liberalising actions
China = 28% of filer-disclosed refiner mentions · 879 named refiners
Two independent lenses: USGS official puts China at 55% of global refining output (by tonnage); US filers' own disclosures independently name China for 28% of their refiners (by facility count). Different metrics — both rank China first.
China = 43% of filer-disclosed refiner mentions · 243 named refiners
Two independent lenses: USGS official puts China at 50% of global refining output (by tonnage); US filers' own disclosures independently name China for 43% of their refiners (by facility count). Different metrics — both rank China first.
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 → 91(+3) — a relative official policy-pressure magnitude, not a price drawdown.
Trace the precedent to its primary source via the link above (/actions/2025-09-30-us-bis-affiliates-rule-entity-list-50-percent).
🇨🇳 CN has issued 4 restrictive actions on Tungsten since 2025 — cadence accelerating (mean gap 264d → 103d), severity flat (4.0 → 4.0).A descriptive trajectory of past official actions — not a forecast.
🇨🇳 CN's demonstrated restriction sequence — has restricted 18 materials since 2021, in this demonstrated order:
You hold exposure to 3 of these 18 materials (Silicon, Gallium, Tungsten) — your binding Tungsten exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 3.9 months apart across 9 distinct restriction dates since 2021 (n=8 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 Tungsten, 🇺🇸 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 2.6 months later) — and those counter-moves have also restricted Tungsten, 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
Tungsten — 🇨🇳 CN escalates tungsten controls to a full export-licensing / ban regime
88
91
+3
Concentration
Tungsten — 🇨🇳 CN becomes the single source for tungsten — the second source is lost (full 90%+ monopoly)
88
92
+4
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
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
🇨🇩 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 Tantalum, Tungsten
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
If passed & escalated to a full control regime — modelled impact (high likelihood)
Tantalum🇨🇳 today 53→60+7
Tungsten🇨🇳 today 88→91+3
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 114d ago · not yet law·matches Tin, Tungsten, Tantalum
If passed — Mandates 15% free-carried interest for Uganda National Mining Company (UNMC) in all new mining licences; introduces mandatory mineral buying centres; tightens local-content and value-addition obligations — changes joint-venture economics for all new Ugandan mining operations, raising effective cost-of-entry for foreign miners
Caveat — Amends the already-filed Uganda Mining and Minerals Act 2022 (UG action 1); expected to be enacted before end of 2025/26 parliamentary session per legal commentary; Bank of Uganda gold purchase programme and new mineral buying centres already being piloted — regulatory infrastructure being built ahead of formal enactment. Distinct from filed Uganda Gold Export Regulations 2024 (SI No. 30 of 2024).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Tin🇨🇳 today 66→71+5
Tungsten🇨🇳 today 88→91+3
Tantalum🇨🇳 today 53→60+7
🇮🇩 Indonesia Tin Export Ban — Downstreaming Initiative
announced→low likelihood·flagged 113d ago · not yet law·matches Tin
If passed — Indonesia = ~20% of global refined tin exports (Bangka Belitung); a ban on refined-tin exports would force downstream solder/semiconductor-packaging manufacturing domestically; disrupts global electronics and EV supply chains dependent on Indonesian tin solder and specialty alloys
Caveat — Minister of Energy and Mineral Resources Bahlil Lahadalia announced government "studying" tin export ban on February 13, 2026 at the Indonesia Economic Outlook, Jakarta; framed as replication of 2020 nickel ore ban which claimed 10x value-add uplift; key complication — Indonesia already exports refined tin (not raw ore), so a ban would require immediate creation of advanced downstream industries (solder, electronic-grade tin, semiconductor components) that don't yet exist at scale; Mining Weekly (Feb 13 2026) and BERNAMA (Feb 2026) confirm announcement; no Perpres, PP, or Kepmen issued as of June 14, 2026; government described as "studying" — not yet in formal regulatory drafting. Distinct from filed Indonesia nickel ore export bans (2019, 2023), filed bauxite export ban, and filed Permendag export-licensing amendments.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Tin🇨🇳 today 66→71+5
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches Tin
If passed — Prohibits raw mineral exports unless 30% value-addition achieved domestically; affects Chinese mining companies (dominant in Nigerian critical minerals sector), Western offtake agreements, and all foreign-invested mining JVs; builds on existing eMC+ digital cadastre and mandatory value-addition plans introduced Nov 2024; could force processing-plant investment or suspension of raw mineral shipments from Africa's most populous economy; RMRDC = Raw Materials Research and Development Council (the sponsoring agency)
Caveat — Bill passed third reading in House of Representatives; multiple Nov 2025 sources confirm both chambers approved; as of 2026-06-14 presidential signature not yet confirmed. Distinct from filed Nigeria Tax Reform Acts 2025 (Loi n°1/19 tax restructuring) and Mining Cadastral licence revocations (2025-06-19). Applies to ALL raw materials, not minerals only — IPTM relevance is the mineral export provisions.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Tin🇨🇳 today 66→71+5
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Silicon, Tungsten, Gallium
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 & escalated to a full control regime — modelled impact (high likelihood)
Silicon🇨🇳 today 77→82+5
Tungsten🇨🇳 today 88→91+3
Gallium🇨🇳 today 88→90+2
🇹🇼 Taiwan proposed comprehensive AI chip export controls on China — MOEA/ITA considering extending SHTC licensing requirements beyond blacklisted entities (Huawei, SMIC) to cover ALL Chinese customers for advanced AI chips and AI servers; would give Taiwanese regulators broader authority to block diversion of AI hardware (NVIDIA-powered servers, advanced AI chips) from Taiwan to China via third-country routing; MOEA stated June 9, 2026 "will continue strengthening oversight of strategic high-tech exports in line with global export-control trends"; discussions between Taiwan and US officials ongoing on controls for advanced chips
announced→low likelihood·flagged 112d ago · not yet law
If passed — If enacted, first Taiwan restriction covering all Chinese customers (not just blacklisted entities); would require Taiwanese OEMs (Foxconn, Pegatron, ASUS, Quanta, Wiwynn), server makers, and component suppliers to seek export licences before any AI hardware shipment to China — affects ~$15-20bn/yr of Taiwan-to-China AI server/component flows; raises costs for Taiwanese firms with significant China revenue
Caveat — Distinct from filed 2025-06-15-taiwan-moea-shtc-entity-list-expansion (Huawei/SMIC-specific, +599 entities) and 2025-11-18-taiwan-moea-ita-shtc-controlled-goods-list-expansion (quantum computers/3D printers). This is a proposed expansion to entity-neutral coverage. Low-to-elevated likelihood: confirmed that US lawmakers pressed Taiwan (2026 defence legislation); Taiwan-US synchronisation pattern well-established (aligned with US BIS controls on China); but MOEA has not publicly announced a formal rulemaking process.
announced→low likelihood·flagged 111d ago · not yet law·matches Tin
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Tin🇨🇳 today 66→71+5
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 110d ago · not yet law·matches Tin
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Tin🇨🇳 today 66→71+5
🇹🇼 Taiwan ITA — Dual-Use Export Control List Revision: AI Chips and Advanced Semiconductors Targeting China (June 2026)
in-consultation→moderate likelihood·flagged 107d ago · not yet law
If passed — Taiwan ITA (International Trade Administration, MOEA) launched a 60-day public consultation on planned revisions to the SHTC (Sensitive High-Tech Commodity) controlled-goods export list to add AI chips and advanced semiconductor categories specifically targeting exports to China; if enacted, would extend Taiwan's existing sub-14nm chip / advanced packaging export controls (SHTC list 2025-11-18) to include AI-application chips sold for China use — the measure is designed to align Taiwan's export controls with US BIS advanced-chip restrictions and close the gap on AI server / Nvidia chip diversion from Taiwan to China; Bloomberg June 9, 2026 cites Taiwan authorities "considering much stricter export controls on AI chip sales to China to further align with US measures"; ITA confirmed a 60-day review period for planned revisions; if enacted, would add legal tools to address diversion of AI servers and Nvidia chips through Taiwan to China; affects global AI hardware supply chains and Taiwan-domiciled chip distributors, system integrators, and ODM/OEM assemblers
Caveat — Distinct from 2025-11-18-taiwan-moea-shtc-controlled-goods-expansion (that amendment added quantum computers and advanced semiconductor equipment to the SHTC list — this proposed revision targets AI application chips and AI server hardware for China specifically, different commodity scope and different policy driver); distinct from 2025-06-10-taiwan-moea-shtc-entity-list-huawei-smic (entity list addition, not commodity list revision). Timeline: 60-day review likely closes August 2026; if enacted, new SHTC amendment would take effect Q3/Q4 2026. Likelihood elevated: the ITA has formally initiated the review process and the stated policy driver (US BIS alignment) is official; Taiwan government has consistently tightened SHTC controls in line with US export control strategy since 2022. Filed upcoming 2026-06-20.
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 ↗
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 100d ago · not yet law·matches Tungsten
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Tungsten🇨🇳 today 88→91+3
🇹🇿 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 99d 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
🇨🇳 China unpublished 50% domestic-equipment local-content mandate for new/expanded semiconductor fabs
announced→low likelihood·flagged 93d ago · not yet law
If passed — Reuters (exclusive, multiple sources) reported 31 Dec 2025 that Chinese authorities have been requiring domestic chipmakers to source at least 50% of equipment spend from Chinese toolmakers when applying for approval to build or expand fab capacity — enforced administratively (approval rejected if the threshold isn't met) rather than via any published law or ministry order; strictest on mature-node lines, with temporary carve-outs for advanced-node lithography where local tools don't yet exist; officials reportedly want the floor higher over time, with a stated long-run goal of 100% domestic tooling. Directly squeezes foreign equipment suppliers (Lam Research, Applied Materials, Tokyo Electron, ASML) out of incremental Chinese fab capacity and is already lifting order books at domestic tool makers Naura Technology and AMEC (Naura H1 2025 revenue +30% YoY to RMB16bn; AMEC +44% YoY to RMB5bn). GTA logged this as a state act (state-act/95890) but provides no primary source; no MIIT/NDRC/MOFCOM document, gazette notice, or on-the-record government confirmation has surfaced in any outlet reviewed.
Caveat — Charter §6 verify-or-don't-file: GTA state-act/95890 provides zero primary source (page states only "reportedly mandated," no gov link, no gazette reference) and exhaustive web search (Reuters exclusive + 7 corroborating outlets: Modern Diplomacy, IBS Electronics, ExportComplianceDaily, Seeking Alpha, Stocktwits, Hawaii Tribune-Herald) confirms this is deliberately UNPUBLISHED administrative practice (enforced via approval-rejection, not a public instrument) rather than a not-yet-enacted proposal — it is arguably already in force but structurally opaque, so it does not fit filing. md's primary-source bar. Flagging as upcoming/announced rather than rejecting: multiple independent, well-sourced outlets corroborate a specific, falsifiable mechanism (50% threshold, mature-node-strict/advanced-node-exempt split, approval-rejection enforcement) with observable market effects (Naura/AMEC revenue growth) — this is credible policy, not speculation; likelihood HIGH reflects that the practice already appears to be in effect, with the open question being whether/when a public document ever surfaces to cross the register's verification bar. If no primary source ever emerges, this may need a standing "policy tracked, never promotable" annotation rather than eventual promotion — flag for a future strategy wake. Distinct from all filed CN semiconductor entries (export-control/entity-list actions on the inbound side); this is an outbound-directed, tooling-localisation industrial-policy instrument. Severity 3-4 expected if a primary document surfaces (broad fab-capex-shaping local-content rule); severity_basis would be quant (explicit 50% floor).
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Gallium, Tungsten
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
Tungsten🇨🇳 today 88→91+3
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Tantalum
If passed — President Peter Mutharika signed an executive order (dated 23 Oct 2025, effective 21 Oct 2025, announced at Sanjika Palace during a cabinet swearing-in) prohibiting the export of raw/unprocessed minerals extracted in Malawi — uranium, rare earth elements, niobium, graphite, tantalum, bauxite, coal, limestone, gemstones, heavy mineral sands, vermiculite, phosphate, rutile, gold, diamonds, copper and others — with an exemption for minerals processed/refined/value-added domestically per Malawian mining law. Announced alongside a suspension of new mining-licence issuance and a review of mining laws (2026/27 State of the Nation Address), plus a planned sovereign wealth fund. Stated rationale: local beneficiation, targeting up to USD 500m/yr once the Kasiya rutile/graphite deposit (Lilongwe) and Kangankunde rare-earth project (Balaka, Mkango Resources — Africa's prospective first new REE mine since 2017, targeting late-2026 production) are fully developed. Violators face fines/penalties under Malawian law. MW is currently the THINNEST country in the register (1 prior action) despite this breadth of minerals covered. Export-ban/beneficiation-mandate, same instrument class as Zimbabwe's SI 213/2022 raw-mineral bans and Guinea's 2026 gold-export ban already in the register.
Caveat — ENACTED (signed order, in force since 21 Oct 2025) but parked here rather than filing. gov. mw directly (TLS cert mismatch: cert is issued for agriculture. gov. mw, not statehouse. gov. mw) and the malawiace. com implementation-analysis piece cites no gov URL either. Same park-lot convention as the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines above (real, already-enacted action; primary URL not independently locatable this wake). Dedup: action-index has only 1 Malawi action total, none overlapping (no prior MW export-ban or beneficiation-mandate action exists). Severity 3-4 expected given the breadth of minerals covered and MW's fast-growing REE/graphite production profile.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Tantalum🇨🇳 today 53→60+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.
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 %).