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4 critical materials scored · binding chokepoint: Potash (🇨🇦 CA 31% of refining) · 18 restrictive government measures on record
Gomel Chemical Plant (Khimzavod) produces 1 of the 4 scored materials above (Fluorspar). 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. The remaining 3 (Potash, Phosphate, Sulfur) are genuine buyer dependencies and drive the mitigations below. The two sides are reported separately and never netted against each other.
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 Potash — 🇨🇦 CA controls 31% of global refining. On this company's production footprint that scores 58/100 (adversarial chokepoint; global 50). The register holds 18 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Potash Gomel Chemical Plant (Khimzavod) is the 4th-most-exposed of the 41 named companies we track on 🇨🇦 CA's Potash chokepoint; the most-exposed is Belaruskali (58/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Gomel Chemical Plant (Khimzavod) ranks 82nd of 101 verified chemicals companies.
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 53/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 4 scored materials. Buyer-relative (first-order): weighted by where the company produces (BY 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.
OJSC Gomel Chemical Plant is Belarus's only producer of phosphate fertilisers and its largest phosphate-chemicals complex, operating as part of the state-owned Belneftekhim concern. It converts imported phosphate rock and sulfur into sulfuric acid, phosphoric acid, and finished fertilisers (ammophos, ammonised superphosphate, NPK blends), and runs a downstream fluorine-chemicals line (aluminium fluoride, cryolite) plus technical products (aerosil/fumed silica, sodium sulfite, crop-protection agents). Roughly three-quarters of fertiliser output is exported, chiefly to Ukraine, Poland, Latvia and Lithuania (though Ukraine sanctioned the plant in January 2023 over the Russia-Belarus war alignment).
plant's core feedstock, converted via sulfuric-acid digestion into phosphoric acid and then ammophos/NPK fertiliser. Belarus has no domestic phosphate rock deposits; the plant depends on imported apatite concentrate, historically Russian-sourced — a single-corridor dependency with no substitute for phosphorus as a plant nutrient.
consumed at scale to digest phosphate rock into phosphoric acid; the plant also sells surplus sulfuric acid (technical, battery, and high-purity grades) as a standalone product line. Sulfuric acid has no substitute in the phosphate-fertiliser process, and sulfur supply is inelastic since it's a byproduct of oil/gas desulfurisation rather than a mined-to-order commodity.
fertiliser line blends in potash. Unlike phosphate rock, this leg is a domestic-supply-chain strength rather than a risk: Belarus (via Belaruskali) is one of the world's top-three potash producers, so this input is unlikely to be import-constrained.
purchased ore.* The aluminium-fluoride and cryolite lines run on fluorosilicic acid (FSA) recovered from phosphate-rock processing (the rock contains fluorine), not on purchased fluorspar (CaF₂) — a route USGS specifically flags as one of the few real substitutes that offsets acid-grade fluorspar demand. Practically, this makes the plant a marginal domestic FSA supplier* to the fluorine-chemicals chain rather than a fluorspar-import dependent, but it's tagged here because its output (AlF₃, cryolite) sits in the same scored market and a phosphate-rock supply shock would flow through to this product line too.
Ranked by buyer-relative risk, highest first.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Potash | 🇨🇦 CA 31% refining | 58 | 50 | Elevated | — | — | none | 8 | ▲ rising |
| Phosphate | 🇨🇳 CN 38% refining | 53 | 59 | Moderate | — | — | none | 10 | ▲ rising |
| Fluorspar | 🇨🇳 CN 60% mining | 41 | 45 | Moderate | — | — | hard | — | ▬ stable |
| Sulfur | 🇨🇳 CN 23% mining | 31 | 34 | Low | — | — | hard | 3 | ▲ 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 |
|---|---|---|---|---|---|---|
| Potash | 4 | 2 | 3 | 5 | 3 | company input |
| Phosphate | 4 | 2 | 3 | 5 | 4 | company input |
| Fluorspar | 1 | 3 | 3 | 4 | 5 | company input |
| Sulfur | 3 | 2 | – | 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.
+ 3 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:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Potash — 🇨🇦 CA escalates potash controls to a full export-licensing / ban regime | 58 | 66 | +8 |
| Concentration | Potash — 🇨🇦 CA becomes the single source for potash — the second source is lost (full 31%+ monopoly) | 58 | 90 | +32 |
| Policy | Phosphate — 🇨🇳 CN escalates phosphate controls to a full export-licensing / ban regime | 53 | 56 | +3 |
| Concentration | Phosphate — 🇨🇳 CN becomes the single source for phosphate — the second source is lost (full 38%+ monopoly) | 53 | 76 | +23 |
| Policy | Fluorspar — 🇨🇳 CN escalates fluorspar controls to a full export-licensing / ban regime | 41 | 62 | +21 |
| Concentration | Fluorspar — 🇨🇳 CN becomes the single source for fluorspar — the second source is lost (full 60%+ monopoly) | 41 | 58 | +17 |
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. The Art. 24(4) mitigation duty is not triggered on the factors we could score (1 of 15 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 3 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.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
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.
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 (Potash). The 1 material Gomel Chemical Plant (Khimzavod) produces (Fluorspar) is excluded from these buyer levers — see the role check in the verdict and the significant-vulnerability conclusion above.
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 — 3 scored SRMs on the input side (binding: Potash); 1 further scored SRM produced, not consumed |
| 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 2026-07-24; 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.