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2 critical materials scored · binding chokepoint: Gallium (🇨🇳 CN 98% of refining) · 10 restrictive government measures on record
The binding exposure is Gallium — 🇨🇳 CN controls 98% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 74). The register holds 10 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Gallium GHGSat Inc. is the 21st-most-exposed of the 113 named companies we track on 🇨🇳 CN's Gallium chokepoint; the most-exposed is Appia Rare Earths & Uranium Corp. (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
GHGSat Inc. ranks 6th of 48 verified space satellite companies, tied with 2 others at 86.
Company supply-risk index 86/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 2 scored materials. 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.
GHGSat Inc. is a Montreal-based company that designs, owns, and operates the world's largest commercial satellite constellation dedicated to greenhouse-gas emissions monitoring — detecting methane (and, on its newest satellite, CO2) from individual industrial facilities at ~25-50m resolution and selling the data as an analytics service to oil & gas, mining, waste-management, government, and financial customers. GHGSat does not build its own satellites: the satellite buses are designed and built under contract by third parties (Spire Global; SFL Missions from late 2025 onward). GHGSat's own verifiable hardware contribution is the payload it designs and holds IP for — a patented shortwave-infrared Fabry-Pérot imaging spectrometer — which is itself manufactured under contract by ABB in Quebec.
staff, peer-reviewed) documents a 640x512 InGaAs (indium gallium arsenide) focal-plane detector array as the light-sensing element of its shortwave- infrared spectrometer, the core differentiator of its methane-detection capability. A tiny, gram-scale quantity per detector chip, not a bulk input — but a component GHGSat itself specified and patented, unlike the rest of the satellite. Indium supply is concentrated and largely sourced as a byproduct of Chinese zinc refining.
the same InGaAs detector array described above. China controls the large majority of global refined gallium supply and has applied export-licensing restrictions on gallium since 2023, making it the more actively-restricted of the two elements in this component.
Sector-typical exposures for space-satellite manufacturers (rare-earth magnets in reaction wheels, structural aluminium, tantalum capacitors, copper wiring) are deliberately here: those sit in the satellite bus, which GHGSat neither designs nor builds — that is Spire Global's (or SFL Missions') bill of materials, not a verifiable GHGSat exposure.
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 |
|---|---|---|---|---|---|---|---|---|---|
| Gallium | 🇨🇳 CN 98% refining | 88 | 74 | Critical | EXCEEDS 98% |
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 |
|---|---|---|---|---|---|---|
| Gallium | 5 | 5 | 3 | 3 |
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:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Gallium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|
No material crosses the significant-vulnerability threshold. 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 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, 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.
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 (Gallium).
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 | Yes — 2 scored SRMs on the input side (binding: Gallium) |
| Manufactures a listed strategic technology | space-satellite (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 2026-06-29; 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 — 31 further space satellite 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.
spectrometer," Atmospheric Measurement Techniques 14, 2127-2140 (2021): https://amt.copernicus.org/articles/14/2127/2021/
https://www.ghgsat.com/en/technology/constellation/
https://spaceq.ca/sfl-missions-to-build-ghgsat-c18-and-c-19-satellite/
| Low |
| ready |
| 9 |
| ▲ rising |
| Indium | 🇨🇳 CN 69% refining | 76 | 64 | High | — | Low | limited | 2 | ▲ 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 |
| Indium | 4 | 3 | 5 | 3 | 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.
| 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 | Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime | 76 | 86 | +10 |
| Concentration | Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly) | 76 | 91 | +15 |
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.