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1 critical material scored · binding chokepoint: Rhodium-iridium (🇿🇦 ZA 83% of mining) · 10 restrictive government measures on record
The binding exposure is Rhodium-iridium — 🇿🇦 ZA controls 83% of global mining. On this company's production footprint that scores 71/100 (neutral exposure; global 71). The register holds 10 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Rhodium-iridium Ercros, S.A. is the 12th-most-exposed of the 67 named companies we track on 🇿🇦 ZA's Rhodium-iridium chokepoint; the most-exposed is Isuzu Motors Limited (71/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Where the 101 verified chemicals companies we track sit.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 14 further chemicals 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 71/100 — 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 (ES 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.
Ercros is a Spanish industrial chemicals group (BME-listed, MAD:ECR) organised around three divisions. Chlorine derivatives — its largest by sales — produces chlorine, caustic soda, PVC (S-PVC, VCM), sodium chlorate/chlorite, hydrochloric acid, TCCA and hydrogen peroxide from plants at Vila-seca I (Tarragona) and Sabiñánigo (Huesca); both converted from mercury-cell to membrane-cell electrolysis by end-2017/2019 ahead of the EU mercury ban. Intermediate chemicals makes formaldehyde-based derivatives (paraformaldehyde, resins, moulding powders) — Ercros ranks first worldwide in paraformaldehyde. Pharmaceuticals manufactures generic APIs (antibiotics, fosfomycin, fusidic acid) via fermentation and chemical synthesis. None of the intermediate-chemicals or pharma inputs (methanol, brine/salt, fermentation feedstocks) touch a scored critical mineral.
anode coatings) — trace catalytic input. Membrane-cell chlor-alkali electrolysis, the technology Ercros confirms running at both plants, requires dimensionally-stable anodes: titanium substrates coated with a thin RuO2/IrO2 catalytic layer that has displaced graphite anodes industry-wide for corrosion resistance and current efficiency. The coating is a re-applied catalytic film, not a bulk consumable, and this is inherent to the chlor-alkali process generally rather than an Ercros-specific disclosure — Ercros does not publish anode-coating sourcing detail. Iridium supply is tightly concentrated (a platinum-mining by-product, dominated by South Africa), which is the chokepoint this flags, even though Ercros's own usage is small-scale and low-frequency (electrodes last years between recoats).
No other scored critical mineral is verifiable against Ercros's disclosed product lines. The sector-default list previously carried on this stub (phosphate, potash, lithium, cobalt, nickel, manganese, silicon, antimony, vanadium) does not match what Ercros actually makes and has been dropped; Ercros's own hydrogen peroxide process is stated to use "proprietary technology" with no disclosed catalyst, so a palladium/AO-process exposure could not be confirmed and is not included.
conversion, plant capacities): https://www.ercros.es/en/products/chlorine-derivatives-division
https://www.ercros.es/en/company/production-sites/sabinanigo
https://www.ercros.es/en/products/intermediate-chemicals-division , https://www.ercros.es/en/products/pharmaceuticals-division
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 |
|---|---|---|---|---|---|---|---|---|---|
| Rhodium-iridium | 🇿🇦 ZA 83% mining | 71 | 71 | High | EXCEEDS 83% | Low | none | 10 | ▲ 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 |
|---|---|---|---|---|---|---|
| Rhodium-iridium | 4 | 4 | 3 | 5 | 4 | 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.
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 | Rhodium-iridium — 🇿🇦 ZA escalates rhodium-iridium controls to a full export-licensing / ban regime | 71 | 77 | +6 |
| Concentration | Rhodium-iridium — 🇿🇦 ZA becomes the single source for rhodium-iridium — the second source is lost (full 83%+ monopoly) | 71 | 82 | +11 |
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.
This assessment identifies 1 significant vulnerability — Rhodium-iridium — each a High/Critical exposure that is hard to substitute and already under at least one in-force restrictive measure. This engages the duty under Art. 24(4) to take mitigating efforts, including assessing diversification of the supply chain or substitution of the material (see Priority mitigations below).
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.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
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 (Rhodium-iridium).
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 | Yes — 1 scored SRM on the input side (binding: Rhodium-iridium) |
| Manufactures a listed strategic technology | chemicals (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 2026-06-03; 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
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.