1 critical material scored · binding chokepoint: Chromium (🇨🇳 CN 46% of refining) · 13 restrictive government measures on record
Subject
hernic-ferrochrome · 🇿🇦 ZA
Sector
metals-refining
Materials scored
1
As of
2026-06-03
Risk Office verdict
Moderate · 42/100Company supply-risk index · consumer-side read
Partial-data score
Computed with 2 of 5 risk factors absent on the binding material (Chromium). Absence of data is not evidence of low risk — each absent factor enters the composite as zero, not as an estimate. The factor matrix below marks which cells are unscored.
Role check · this company is a producer, not a buyer
Hernic Ferrochrome (Pty) Ltd produces 1 of the 1 scored material above (Chromium). 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. Every scored material here sits on its output side, so the Moderate · 42/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-08) — 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 Chromium — 🇨🇳 CN controls 46% of global refining. On this company's production footprint that scores 42/100 (neutral exposure; global 42). The register holds 13 restrictive government measures touching this company's materials — each traced to its primary source below.
Competitor cohort · metals refining
Where the 98 verified metals refining companies we track sit.
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 42/100 — 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 (ZA 100%, HQ proxy), applied across all materials — it does not yet trace each input to its specific sourcing step.
Hernic Ferrochrome (Pty) Ltd
What they do
Hernic Ferrochrome, based at Brits in South Africa's North West Province, is a chrome-ore miner and ferrochrome producer: two underground mines, four ore beneficiation plants, four closed submerged-arc furnaces, pelletising and sintering plants and two ferrochrome recovery plants, exporting mainly to Asia and Europe. Formerly a Mitsubishi Corporation subsidiary, it entered voluntary business rescue in September 2017; under the adopted plan the business was sold as a going concern to Samancor Chrome (process ran to June 2021). The assets are now operated within Samancor Chrome, hence parent_slug.
Critical-material exposure
Chromium — producer, bulk product. Chrome ore is mined and smelted into
ferrochrome, whose main end use is stainless steel. South Africa hosts the large majority of the world's chrome-ore reserves and output, and ferrochrome smelting is electricity-intensive, so Eskom supply and South African export policy on chrome ore bear directly on this asset.
The sector-default materials (silver, copper, nickel, tin, antimony) were
dropped: nothing in the sources links them to a ferrochrome operation.
No geographic revenue split is disclosed (the business is now inside a
private group), so sales_geography is left absent; "mainly Asia and Europe" is the only sourced statement.
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 ↗
Supply-risk factor analysis
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.
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.
Material factors (scored 4–5) — evidence
Chromium
4Geopolitical: 13 restrictive actions, peak severity 5, 9 in last 24mo, less 2 liberalising actions
4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 76/100 (long-horizon, all major uses). Prior analyst short-run rating 0.95: USGS: no substitute in stainless steel or superalloys
Change log
last 30 days
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.
2026-09-11amendedIndonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform— Kepmen ESDM No. 363.K/MB.01/MEM.B/2026 supersedes the Kepmen 144/2026 HPM formula for low-grade limonite: the nickel Correction Factor (CF) for 1.2%-Ni-or-lower ore is reset to 14% (falling 1pp per 0.1pp of grade below that), and the cobalt by-product coefficient is cut from 30% to 17%. Net effect on 1.2%-Ni ore: HPM falls ~45%, from USD 44.97/wmt to USD 24.89/wmt. The change targets the low-grade limonite/HPAL feedstock segment specifically — the 1.6%-grade CF set by 144/2026 is not disclosed as changed in available reporting.
The laws that threaten it
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:
Both stress-test scenariosShowHide
Policy shock — the controlling country escalates to a full export-licensing / ban regime.
Concentration shock — the supply structure collapses to a single source (second-source loss / full monopoly).
Type
Scenario
Today
Stressed
Δ
Policy
Chromium — 🇨🇳 CN escalates chromium controls to a full export-licensing / ban regime
42
47
+5
Concentration
Chromium — 🇨🇳 CN becomes the single source for chromium — the second source is lost (full 46%+ monopoly)
42
66
+24
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.
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Hernic Ferrochrome (Pty) Ltd produces, and Art. 24 addresses the use of a strategic raw material as an input. 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 0 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 — not yet law
Upcoming regulatory threats
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.
The upcoming threatsShowHide
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 101d ago · not yet law·matches Chromium
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Chromium🇨🇳 today 42→47+5
🇿🇦 South Africa DTIC Industrial Development Strategy 2026 — chrome export tax/quota + beneficiation licensing conditions
passed-committee→elevated likelihood·flagged 115d ago · not yet law·matches Chromium
If passed — If enacted, chrome ore export tax and/or quota would disrupt South Africa's ~2. 4 Mt/yr chrome ore export stream (≈45% of global seaborne supply); beneficiation licensing conditions attached to mineral rights allocations would require FTSE/JSE-listed chrome miners (Samancor/Merafe, Assore, Glencore) to build local ferrochrome and stainless-steel capacity before new rights are allocated; PGMs and other minerals may follow chrome as the test-case model, expanding scope to the full South African mining portfolio
Caveat — DMPR Director-General Jacob Mbele publicly described DTIC's beneficiation licensing proposal as outside DMPR's agreed jurisdiction ("a proposal, not agreed policy") — inter-departmental tension signals implementation risk; Minerals Council SA (90% of output by value) stated June 9, 2026 it will "engage" but expressed significant concern about policy uncertainty (TimesLive / Engineering News June 9, 2026). Cabinet approval makes this official government strategy direction; implementing instruments require separate legislative/regulatory action. Secondary: https://www. engineeringnews. co. za/article/minerals-council-to-engage-dtic-on-beneficiation-element-of-new-industrial-development-strategy-2026-06-09
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Chromium🇨🇳 today 42→47+5
🇯🇵 Japan METI/MOF Anti-Dumping Duty on Nickel-Added Cold-Rolled Stainless Steel Coil/Sheet/Strip from China and Taiwan
awaiting-signature→high likelihood·flagged 101d ago · not yet law·matches Chromium
If passed — Japan's METI + MOF made an affirmative PRELIMINARY determination in an anti-dumping investigation (initiated 22 Jul 2025 on an application from Nippon Steel, Nippon Yakin Kogyo, NAS Stainless Steel Strip and Nippon Kinzoku) into nickel-added cold-rolled stainless steel coil, sheet and strip originating in the People's Republic of China and the separate customs territory of Taiwan (Penghu, Kinmen, Matsu); Trade Minister Ryosei Akazawa indicated provisional duties of ~45% on Chinese product and ~21% on Taiwanese product, expected to take effect as soon as July 2026. On 19 Jun 2026 METI/MOF EXTENDED the investigation period by four months to 21 Nov 2026 (final determination pending). IPTM relevance: (1) a RARE Japan-issuer trade remedy — JP has ZERO trade-remedy actions on the register and seldom uses AD, so a Japanese AD wall is a notable issuer + instrument-bloc gap; (2) China/Taiwan-target on nickel-added stainless steel, a nickel+chromium chokepoint-adjacent material; re-prices a China/TW->Japan stainless flow into a major downstream manufacturing base; (3) parallels the active 2025-26 Asian steel-AD wave the register is now capturing (Thailand DFT aluminium-extrusions, Indonesia KADI HRC, Malaysia MITI galvanised steel).
Caveat — As of 2026-06-29 only an affirmative PRELIMINARY determination exists; the provisional-duty cabinet order is not yet promulgated and the final determination is deferred to 21 Nov 2026 (investigation extended 19 Jun 2026) — hence awaiting-signature/upcoming, not enacted. Likelihood HIGH: preliminary affirmative + minister-stated rates + provisional duties imminent; the open question is final rate/scope, not whether duties happen. COMPANION lead for a future wake: METI/MOF separately INITIATED (1 Jun 2026) an AD investigation into cold-rolled steel coil/sheet/strip (carbon) from Korea, China and Taiwan (https://www. meti. go. jp/english/press/2026/0601_002. html) — earlier stage (initiation only), track separately. action_type=trade-remedy (sub: anti-dumping / preliminary-determination / stainless-steel / China / Taiwan); target_countries=[CN, TW]; sectors=[steel, trade-remedies, manufacturing]; materials=[stainless-steel, nickel, chromium]. Severity 2 expected.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Chromium🇨🇳 today 42→47+5
🇿🇼 Zimbabwe — ban on new mining licences for single-mineral ("isolated") operations; VP Chiwenga, Zimbabwe-China Business Forum
announced→low likelihood·flagged 4d ago · not yet law·matches Chromium
If passed — VP Constantino Chiwenga announced at the Zimbabwe-China Business Forum (Hangzhou) that Zimbabwe will no longer issue new mining licences for operations that extract only one mineral from a deposit — future licensees must demonstrate capacity to identify, separate and process the full mineral suite present, or be barred from operating. Framed as beneficiation policy, layered on Zimbabwe's Feb-2026 raw-mineral/lithium-concentrate export ban (filed). Raises the entry bar specifically for Great Dyke chrome/PGM claims, which are frequently single-mineral operations — a licensing-stage chokepoint action, distinct instrument type from the export-ban actions already in the register.
Caveat — Likelihood kept LOW per the discovery brief's calibration caution (a forum announcement with no SI number is exactly the channel that has previously stalled — e. g. the chrome-concentrate extension signalled since Feb-2026, entry below, remains unenacted 8 months on). Dedup: checked "chiwenga", "single mineral", "single-mineral", "zimbabwe chrome licence" across filing. md, upcoming. md, and action-index — zero hits; distinct from filed Zimbabwe lithium/chrome export-ban actions (different instrument: licensing bar on NEW operations, not export control on existing ones).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Chromium🇨🇳 today 42→47+5
🇿🇼 Zimbabwe — signalled extension of the raw-mineral export ban to chrome CONCENTRATE (currently exempt)
announced→low likelihood·flagged 4d ago · not yet law·matches Chromium
If passed — Zimbabwean officials have signalled intent ("raw chrome exports obsolete") to expand the 25-Feb-2026 raw-mineral/lithium-concentrate export ban (filed) to cover chrome CONCENTRATE specifically — concentrate was exempt under the original order, which targeted raw ore only. This is the same ore/concentrate carve-out pattern that made Zimbabwe's 2022 SI 213 lithium ban a non-event (everyone exported the exempt concentrate instead). If the concentrate carve-out is closed, it would hit Zimbabwe's ~$1. 5-2bn/yr chrome sector feeding South African and Chinese ferrochrome smelters. No SI number, no date, no gazette found.
Caveat — Calibration caution per the discovery brief's instrument-vs-flow-fit lesson (this is Zimbabwe's own prior lithium-ban non-event, recurring): an ore ban that exempts concentrate is not a magnitude claim until the concentrate carve-out itself closes — kept likelihood LOW, not moderate. Dedup: checked "chrome concentrate", "zimbabwe concentrate" across filing. md, upcoming. md, and action-index — zero hits. Distinct from the licensing-ban entry above (new-operation licensing bar vs. scope-extension of an existing export ban) and from the filed Feb-2026 export ban itself (this flags a scope-extension TO that ban, not a restatement of it).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Chromium🇨🇳 today 42→47+5
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.
What to watch next
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The watch listShowHide
Chromium is the line to war-game: 🇨🇳 CN already controls 46% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Art. 24(4) · diversification & substitution
Priority mitigations
Every scored material here is one Hernic Ferrochrome (Pty) Ltd produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
The mitigation optionsShowHide
Track demand-side substitution against your own book. The buyer levers listed for consumers of Chromium — qualifying alternative suppliers, designing the material out — are the demand risk to Hernic Ferrochrome (Pty) Ltd's revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by CN on a material Hernic Ferrochrome (Pty) Ltd produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The material above is concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.
Annex A · regulatory basis
CRMA Art. 24 compliance crosswalk
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)).
The full crosswalkShowHide
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.
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.
Why this dependence is structural, not transitional. The EU's own external auditor — the European Court of Auditors, Special Report “Critical raw materials for the energy transition — Not a rock-solid policy” (Feb 2026) — judges the bloc's 2030 extraction, processing and recycling targets to be out of reach (recycling runs 1–5% for 7 of 26 materials, and diversification shows no measurable effect). A separate industry-analyst assessment (Adamas Intelligence & Tradium, EU CRMA report, Apr 2024 — an interested-party commercial view, not an independent verdict) reaches a compatible conclusion that the 2030 rare-earth targets will be missed without an expedited push. The chokepoint this report maps is therefore a durable constraint the Act has not yet closed, not a gap that resolves on its own.
Annex B · Art. 24(1) · Art. 2(29)
Scope & applicability
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.
Scope detailsShowHide
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
company input — all 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology
metals-refining (confirm against Annex)
Formally identified by a Member State authority
company input
Evidence & sources
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.
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).
Refresh SLA
New government measures — polled hourly; a filed action can appear on this report within the hour it's picked up.
Dossier verification (this company's exposure list, sourced against its own disclosures) — the auto-onboarded backlog drains on a 30-minute cycle; a specific company's upgrade timing depends on queue position, not a fixed date.
Live-quoted materials (currently: neodymium, praseodymium, dysprosium, terbium, indium, tellurium — see the price row on each material's page) — refreshed daily.
Other material prices — hand-maintained; flagged STALE on the minerals index past 45 days without a fresh source, rather than left silently out of date.
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.