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1 critical material scored · binding chokepoint: Tungsten (🇨🇳 CN 90% of refining) · 16 restrictive government measures on record
Deutsche Rohstoff AG produces 1 of the 1 scored material above (Tungsten). 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 Critical · 88/100 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 2026-10-06) — 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 Tungsten — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 76). The register holds 16 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Tungsten Deutsche Rohstoff AG is the 10th-most-exposed of the 453 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.
Deutsche Rohstoff AG ranks 1st of 22 verified commodity trading companies.
Company supply-risk index 88/100 — 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.
> The exposure report this dossier powers is at > /intelligence/dossiers/deutsche-rohstoff/report.
Deutsche Rohstoff AG (Frankfurt/Xetra: DR0), based in Mannheim/Heidelberg, Germany, is a resource-investment holding company, not an operator of mines or factories itself. Its core business — close to 100% of group revenue — is crude oil and natural gas production in the US, run through four operating US subsidiaries (over 100 wells drilled; ~13,500 boe/d as of 2025). Alongside that, DR runs a small metals-investment side-book, currently a single minority equity stake in Almonty Industries (tungsten) that DR has been actively selling down through 2026, not a permanent business line. A second side-bet, an interest in lithium developer Prime Lithium AG, was fully divested (100% of DR's stake sold to Prime Lithium's CEO, Dr. Axel C. Heitmann, effective 31 December 2024) — DR carries no lithium exposure today.
a shrinking, actively-divested position. Almonty's Sangdong mine in South Korea reached Phase-1 mechanical completion in March 2026, began saleable-concentrate production in June 2026, and had moved to full quarterly production by September 2026; at full (Phase-2, 2027) capacity management projects Sangdong could supply roughly 40% of tungsten demand outside China, alongside Almonty's existing Panasqueira (Portugal) operation. DR has been selling down its Almonty stake through 2026 as Sangdong ramped up, not holding a stable position: it disclosed selling 9 million shares on 1 April 2026 (Schedule 13G/A, cutting its stake to 4.9%, ~281.9M shares outstanding basis), a further 5 million shares around 25 July 2026 for a ~€65m profit (leaving 5.5 million shares), and trimmed again in a sale reported 2 September 2026 booking a €128m profit — exact remaining stake not disclosed in that report. (Corrected 2026-09-08 — the dossier previously presented the April snapshot as DR's current, settled position; it was superseded within the same fiscal year by two further disposals.) This is investment/equity-value exposure**, not an operational input dependency — DR does not consume tungsten in a product. Tungsten itself is a genuine chokepoint material: China dominates global mine supply, and its extreme hardness/melting point give it no practical substitute in cutting tools, defense and aerospace hardware.
Ranked by buyer-relative risk, highest first.
1 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Tungsten | 🇨🇳 CN 90% refining | 88 | 76 | Critical | EXCEEDS 90% |
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 |
|---|---|---|---|---|---|---|
| Tungsten | 4 | 4 | 5 | 3 |
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.
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.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| Jiangwu H.C. Starck Tungsten Products Co., Ltd.CID2551 | China | 15 | SEC |
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.
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:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Tungsten — 🇨🇳 CN escalates tungsten controls to a full export-licensing / ban regime | 88 | 91 | +3 |
| Concentration |
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Deutsche Rohstoff AG 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.
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 Deutsche Rohstoff AG 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) |
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 | commodity-trading (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 2026-08-06; 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 2026-10-06
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).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 6 further commodity trading 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.
AG (an early-stage direct-lithium-extraction developer) no longer exists: DR sold its entire stake to Prime Lithium's CEO, Dr. Axel C. Heitmann, effective 31 December 2024, making him sole shareholder. This predates even this dossier's last company-fill (2026-07-14), which carried the exposure forward incorrectly — a stale claim, not a newly-drifted one.
through minority equity ownership rather than a bill of materials, the risk is portfolio/investment-value risk (would a Chinese tungsten-price shock or export curb move Almonty's share price, and hence DR's NAV) rather than the operational disruption risk a manufacturer would face from losing access to the metal — and even that position is being wound down through 2026.
| Low |
| some |
| 16 |
| ▲ 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 ↗
| 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.
| Chongyi Zhangyuan Tungsten Co., Ltd.CID258 | China | 14 | SEC |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd.CID2315 | China | 14 | SEC |
| Ganzhou Seadragon W & Mo Co., Ltd.CID2494 | China | 14 | SEC |
| Jiangxi Gan Bei Tungsten Co., Ltd.CID2321 | China | 14 | SEC |
Source: US SEC Form SD / Conflict Minerals Report exhibits (EDGAR full-text search), aggregated from RMI smelter tables. “US filers naming it” = distinct US-listed companies whose most-recent CMR names that refiner — disclosure-derived presence, not verified throughput. Link opens the SEC exhibit.
+ 1 more in the register.
| Tungsten — 🇨🇳 CN becomes the single source for tungsten — the second source is lost (full 90%+ monopoly) |
| 88 |
| 92 |
| +4 |
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.
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. | 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.