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4 critical materials scored · binding chokepoint: Silicon (🇨🇳 CN 80% of refining) · 52 restrictive government measures on record
Heraeus produces 2 of the 4 scored materials above (Platinum-palladium, Silver). 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 2 (Silicon, Tin) 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 2026-10-06) — 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 Silicon — 🇨🇳 CN controls 80% of global refining. On this company's production footprint that scores 61/100 (partially hedged; global 64). The register holds 52 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Silicon Heraeus is the 744th-most-exposed of the 843 named companies we track on 🇨🇳 CN's Silicon chokepoint; the most-exposed is aerodyn Engineering GmbH (77/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Heraeus ranks 65th of 98 verified metals refining companies, tied with 6 others at 58.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 39 further metals refining 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 58/100 — 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 (DE 22% · CN 20% · US 15% · ZA 10% · IN 8% · CH 8% · IE 5% · RO 4% · SG 4% · MY 4%, 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.
> The exposure report this dossier powers is at > /intelligence/dossiers/heraeus/report.
Heraeus is a privately (family-)held German technology and materials group headquartered in Hanau, active in precious-metals refining/trading/recycling, high-purity quartz glass, electronic materials, medical technology and sensors. Its precious-metals arm (Heraeus Precious Metals) is one of the world's largest processors of gold, silver and platinum-group metals across mining, industrial-scrap and catalyst recycling — including Argor-Heraeus (Mendrisio, Switzerland), an LBMA-accredited gold/silver refinery Heraeus has fully owned since 2017. Its quartz-glass arm (Heraeus Covantics) makes ultra-high-purity fused quartz and fused silica components used to build semiconductor wafer-processing equipment. Its electronics arm (Heraeus Electronics) supplies bonding wire and solder materials for chip packaging and power electronics,. Its photovoltaics silver-paste unit (Heraeus Photovoltaics, Shanghai/Singapore) was sold to China's Haitian Group; the deal closed 2025-04-13 (pv-magazine, 2025-01-06).
recycles silver at scale; Heraeus Electronics sells silver bonding wire for semiconductor packaging. Heraeus exited PV silver paste in 2025 (sold to Haitian Group), so solar-cell paste is no longer a Heraeus exposure. No drop-in substitute exists at the conductivity/purity these applications require, so Heraeus's precious-metals and electronics lines remain directly exposed to silver supply concentration and price risk.
paste for chip packaging and power-electronics assembly; tin supply is geographically concentrated (Indonesia, DRC, China) and subject to conflict-minerals sourcing rules that flow through to Heraeus's own solder supply chain.
rods are structural/process materials for the equipment that fabricates silicon wafers (boats, susceptors, wafer carriers, etch chamber components). This is an upstream-tooling link to the silicon-wafer supply chain, not a claim that Heraeus itself produces silicon metal — but it means a disruption to high-purity quartz/fused-silica supply constrains semiconductor-fab capacity as surely as a silicon-metal shortage would.
re-checked 2026-09-07; the old heraeus.com/en/het/... URL now 301-redirects here (Heraeus Electronics has its own domain). Solder pastes and solder wires for chip packaging/power electronics still confirmed current.
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.
Northam summarised financial results for the year ended 30 June 2025 name 'Heraeus Deutschland GmbH & Co. KG' as 'one of our two precious metal refiners' (the other is Johnson Matthey, contracted for extra capacity), and note 31: 'Subsequent to year-end, Northam and Heraeus ... concluded an amicable engagement ... redetermination of historical refining outcomes ... Heraeus has made a once-off payment to Northam to the value of USD66.0 million'. The FY2025 document does not say which Heraeus refinery (Hanau DE vs Port Elizabeth ZA) treats the concentrate; the DE leg rests on Northam's metallurgical-operations page (https://www.northam.co.za/about-northam/metallurgical-operations). Prior: Heraeus press release, Oct 2015: 20-year agreement extending a partnership dating from 1988; Heraeus refines Northam's PGM concentrates at Port Elizabeth (ZA) and Hanau (DE) and purchases up to 40% of Northam's refined precious metals. Terms as announced in 2015; not re-confirmed as current.
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 2 of your scored CRMA-strategic materials 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 |
|---|---|---|---|---|---|---|---|---|---|
| Silicon | 🇨🇳 CN 80% refining | 61 | 64 | Elevated | EXCEEDS 80% | Low | limited | 19 | ▲ rising |
| Platinum-palladium | 🇿🇦 ZA 54% mining | 58 | 62 | Elevated | within 54% | High | limited | 12 | ▲ rising |
| Tin | 🇨🇳 CN 55% refining | 54 | 56 | Moderate | — | Med | ready | 18 | ▲ rising |
| Silver | 🇲🇽 MX 24% mining | 42 | 43 | Moderate | — | High | some | 5 | ▲ 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 |
|---|---|---|---|---|---|---|
| Silicon | 4 | 4 | 1 | 4 | 4 | company input |
| Platinum-palladium | 4 | 3 | 5 | 4 | 3 | company input |
| Tin | 4 | 2 | 5 | 2 | 3 | company input |
| Silver | 3 | 1 | 5 | 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 55% of global refining output (by tonnage); US filers' own disclosures independently name China for 28% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| China Tin Group Co., Ltd.CID1070 | China | 20 | SEC |
| PT Mitra Stania PrimaCID1453 | Indonesia | 18 | SEC |
| Gejiu Kai Meng Industry and Trade LLCCID942 | China | 18 | SEC |
| PT ATD Makmur Mandiri JayaCID2503 | Indonesia | 17 | SEC |
| PT Prima Timah UtamaCID1458 | Indonesia | 17 | 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.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 37 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:
Under the 🇨🇳 CN shock, these disclosed plants carry the binding Silicon exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime | 61 | 64 | +3 |
| Concentration | Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly) | 61 | 72 | +11 |
| Policy | Platinum-palladium — 🇿🇦 ZA escalates platinum-palladium controls to a full export-licensing / ban regime | 58 | 63 | +5 |
| Concentration | Platinum-palladium — 🇿🇦 ZA becomes the single source for platinum-palladium — the second source is lost (full 54%+ monopoly) | 58 | 78 | +20 |
| Policy | Tin — 🇨🇳 CN escalates tin controls to a full export-licensing / ban regime | 54 | 58 | +4 |
| Concentration | Tin — 🇨🇳 CN becomes the single source for tin — the second source is lost (full 55%+ monopoly) | 54 | 76 | +22 |
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 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 2 materials this company buys (the 2 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.
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 (Silicon). The 2 materials Heraeus produces (Platinum-palladium, Silver) are 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 — 2 scored SRMs on the input side (binding: Silicon); 2 further scored SRMs produced, not consumed |
| Manufactures a listed strategic technology | metals-refining (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 2026-09-22; 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.