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3 critical materials scored · binding chokepoint: Tungsten (🇨🇳 CN 90% of refining) · 24 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.
The binding exposure is Tungsten — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 78/100 (neutral exposure; global 76). The register holds 24 restrictive government measures touching this company's materials — each traced to its primary source below.
Where the 34 verified tooling companies we track sit.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 3 further tooling 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 3 scored materials. Buyer-relative (first-order): weighted by where the company produces (DE 62% · CN 23% · CA 15%, 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.
H.C. Starck Tungsten GmbH (Goslar, Germany) is one of the world's leading mid-stream tungsten processors. The company converts raw tungsten inputs — ore concentrate or ammonium paratungstate (APT) — into tungsten metal powders, tungsten carbide (WC) powders, and performance-additive carbide powders (TaC, NbC) sold to cemented-carbide and hardmetal manufacturers. Key end-markets are cutting-tool inserts, wear parts, mining/construction drill tips, and oil & gas drill bits. The company claims leadership in tungsten recycling, stating that secondary (scrap-derived) material is a primary feedstock alongside virgin ore.
H.C. Starck Tungsten is not an independent company. Mitsubishi Materials Corporation (TSE: 5711) agreed on 14 May 2024 to acquire 100% of H.C. Starck Holding (Germany) GmbH from Masan High-Tech Materials (MHT, the Vietnamese group listed on UPCoM), and the purchase closed through Mitsubishi Materials Europe B.V. on 17 December 2024 (MHT dated its own completion announcement 18 December 2024) at an equity purchase price of ~US$134.5 million. MMC's stated rationale was its "Medium-term Management Strategy FY2031" goal of becoming "a leading company in tungsten products recognized by customers globally," gaining operational presence across Japan, Europe, North America and China and combining the two firms' tungsten recycling technology.
Two consequences matter for the exposure read:
1. The register must not count this as a German mid-cap. Control, capital allocation and offtake strategy sit in Tokyo. parent_slug: mitsubishi-materials and ownership_country: JP are set accordingly, so the group is scored once rather than twice. 2. A long-term Vietnamese feedstock line came with the deal. As part of the transaction MMC secured "a long-term, win-win APT and tungsten oxide offtake agreement" with the MHT Group. MHT's tungsten chemicals — APT, blue tungsten oxide, yellow tungsten oxide and sodium tungstate — are produced by Masan Tungsten from ore supplied by its sister subsidiary Nui Phao Mining Company in Thai Nguyen, Vietnam, which MHT describes as a "secured long term supply source." So H.C. Starck's virgin-feedstock dependency is not only the Ganzhou JV route: a contractual, non-Chinese Vietnamese stream now sits alongside it. That is a genuine partial de-risking of the China concentration described below, and it should be read as such.
tungsten-based. China produces ~80% of global tungsten mine output and dominates APT supply. The company's own Ganzhou JV with JXTC (Jiangxi Tungsten Company) structurally embeds Chinese supply-chain integration; this is the single largest concentration risk. Alternative non-Chinese primary sources (Almonty Sangdong/KR, Wolfram Camp/AU) cover a small share of global supply. The company's recycling programme partially mitigates virgin-tungsten dependence but does not eliminate it.
produces tantalum carbide (TaC) powder as a performance additive for hardmetal (cemented carbide) customers. Tantalum is an EU Critical Raw Material with supply concentrated in DRC (~60% mine share) and Rwanda. Tantalum is subject to OECD conflict-minerals due-diligence requirements; H.C. Starck holds iTSCi and RMI memberships indicating formalised chain-of-custody controls.
niobium carbide (NbC) powder alongside TaC as a hardmetal grain-growth inhibitor. Niobium supply is highly concentrated: Brazil (CBMM/Niobras) accounts for >85% of global output. Niobium is on the EU CRM list; supply disruption would affect carbide additive production.
Dropped from sector-default exposures: cobalt, molybdenum, chromium, vanadium. Cobalt is used by H.C. Starck's customers (hardmetal makers) as a binder when blending WC powder into WC-Co composites — it is not a confirmed H.C. Starck input. Molybdenum, chromium, and vanadium have no confirmed role in H.C. Starck's published product or process descriptions.
Raw Material Procurement Statement): https://www.hcstarck.com/en/company/sustainability
production): https://pubs.usgs.gov/periodicals/mcs2025/mcs2025-tungsten.pdf
world mined tantalum; Brazil ~93% of world niobium production): https://pubs.usgs.gov/periodicals/mcs2025/mcs2025.pdf
From the company’s own filings and dated disclosures — top-5 concentration and related-party tables where the filer’s regime compels them, named supply and offtake agreements where it does not. This is a disclosure, not a netting: a named supplier concentration is shown beside the exposure score and never adjusts it. Figures are the fiscal years labelled, not a current snapshot.
Long-term APT and tungsten-oxide offtake agreement signed as part of MMC's acquisition of H.C. Starck Holding; no volume or share percentage disclosed.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
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 | 78 | 76 | High | EXCEEDS 90% | High | some | 16 | ▲ rising |
| Niobium | 🇧🇷 BR 89% refining | 61 | 61 | Elevated | — | Med | some | 5 | ▲ rising |
| Tantalum | 🇨🇳 CN 50% refining | 45 | 44 | Moderate | — | Med | some | 12 | ▲ 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 |
|---|---|---|---|---|---|---|
| Tungsten | 4 | 4 | 5 | 3 | 3 | company input |
| Niobium | 3 | 4 | 3 | 3 | 3 | company input |
| Tantalum | 4 | 2 | – | 3 | 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.
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 |
| 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 |
Two independent lenses: USGS official puts China at 50% of global refining output (by tonnage); US filers' own disclosures independently name China for 43% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| F&X Electro-Materials Ltd.CID460 | China | 14 | SEC |
| Hengyang King Xing Lifeng New Materials Co., Ltd.CID2492 | China | 14 | SEC |
| JiuJiang JinXin Nonferrous Metals Co., Ltd.CID914 | China | 14 | SEC |
| Ningxia Orient Tantalum Industry Co., Ltd.CID1277 | China | 14 | SEC |
| Ulba Metallurgical Plant JSCCID1969 | Kazakhstan | 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.
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.
+ 9 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 | Tungsten — 🇨🇳 CN escalates tungsten controls to a full export-licensing / ban regime | 78 | 83 | +5 |
| Concentration | Tungsten — 🇨🇳 CN becomes the single source for tungsten — the second source is lost (full 90%+ monopoly) | 78 | 85 | +7 |
| Policy | Niobium — 🇧🇷 BR escalates niobium controls to a full export-licensing / ban regime | 61 | 71 | +10 |
| Concentration | Niobium — 🇧🇷 BR becomes the single source for niobium — the second source is lost (full 89%+ monopoly) | 61 | 68 | +7 |
| Policy | Tantalum — 🇨🇳 CN escalates tantalum controls to a full export-licensing / ban regime | 45 | 51 | +6 |
| Concentration | Tantalum — 🇨🇳 CN becomes the single source for tantalum — the second source is lost (full 50%+ monopoly) | 45 | 71 | +26 |
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 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.
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 (Tungsten).
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: Tungsten) |
| Manufactures a listed strategic technology | tooling (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.