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1 critical material scored · binding chokepoint: Uranium (🇷🇺 RU 45% of refining) · 25 restrictive government measures on record
A verification pass re-checked this dossier's ownership/corporate-structure fields against their cited sources. It did not re-read the material_exposures claim the score, band and stress figures below are built on — treat those as not yet independently re-checked.
Denison Mines Corp. 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 · Uranium Denison Mines Corp. is the 14th-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.
Denison Mines Corp. ranks 147th of 445 verified mining metals companies, tied with 16 others at 67.
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 (CA 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
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
> The exposure report this dossier powers is at > /intelligence/dossiers/denison-mines/report.
Denison Mines Corp. (TSX: DML; NYSE American: DNN) is a Canadian uranium company — in its own words "a leading uranium mining, development, and exploration company" — with essentially all of its interests in the Athabasca Basin of northern Saskatchewan, the region that hosts the world's highest-grade uranium deposits.
The flagship is Wheeler River, in which Denison holds an effective 95% interest and which it calls the largest undeveloped uranium project in the infrastructure-rich eastern Athabasca Basin. Its Phoenix deposit is being built as an in-situ recovery (ISR) operation: a feasibility study was completed in mid-2023, final investment decision came in February 2026, construction began in March 2026, and first production is targeted for mid-2028. A second Wheeler River deposit, Gryphon, sits at pre-feasibility stage as a conventional underground mine.
Denison's only current output comes from minority JV interests: a 22.5% stake in the McClean Lake Joint Venture (operator Orano Canada), which brought the McClean North deposit into production in 2025 using the SABRE mining method and also owns the McClean Lake mill — a mill currently using part of its licensed capacity to toll-mill ore from the Cigar Lake mine. Denison additionally holds 25.17% of the Midwest JV and 70.55% of the Tthe Heldeth Túé and Huskie deposits at Waterbury Lake, all undeveloped, plus a large exploration portfolio and a 50% stake in JCU (Canada) Exploration Company, Limited.
This is an upstream producer — but read the scale carefully, because Denison is far more developer than producer today.
Denison's business: every project in its portfolio index is a uranium property bar one. Current attributable output is small and new: its share of McClean North's first production year was 145,926 lb U3O8 in 2025 (of 648,558 lb on a 100% basis), at roughly $36/lb average operating cash cost of finished goods. The strategically relevant fact is what is being built rather than what is currently mined — Phoenix would add a low-cost ISR uranium source in Canada, one of very few new Western primary uranium units in construction, in a market where enrichment and conversion capacity outside Russia has been the binding constraint. The magnitude band is high because uranium is the entirety of the business, not because current tonnage is large; a first-production year of ~146 klb is not a steady-state position.
Lithium is deliberately not listed, despite being a scored material. Denison's project index does name the Kindersley Lithium Project, held under an earn-in agreement with Grounded Lithium under which Denison "can earn up to a 75% interest". That is an option on an exploration-stage project, not a lithium supply position: no lithium is produced, no interest is yet earned, and listing it would assert a producer role that does not exist. Re-check if Denison exercises the earn-in and the project advances.
Nothing is listed for the McClean Lake mill's toll-milling of Cigar Lake ore. That is a service revenue stream on someone else's uranium, not Denison output, and it is already counted inside the JV interest above.
Not disclosed: sales geography. The 2025 results release gives production but no destination or customer breakdown for uranium sales, so sales_geography is left absent rather than inferred from the Canadian production base. This is a gap in the record, not a finding that sales are domestic.
Ranked by buyer-relative risk, highest first.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Uranium | 🇷🇺 RU 45% refining | 67 | 57 | Elevated | — | High | limited | 25 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Uranium | 4 | 2 | 5 | 4 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
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.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 10 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇷🇺 RU shock, your disclosed plant carries the binding Uranium exposure:
| 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.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Denison Mines Corp. 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, 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.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one Denison Mines Corp. produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 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 |
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.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-05
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