4 critical materials scored · binding chokepoint: Magnesium (🇨🇳 CN 86% of refining) · 20 restrictive government measures on record
Subject
ICL · 🇮🇱 IL
Sector
mining-metals
Materials scored
4
As of
2026-07-24
Risk Office verdict
Elevated · 67/100Company supply-risk index · consumer-side read
Role check · mixed producer / buyer
ICL Group Ltd produces 3 of the 4 scored materials above (Magnesium, Phosphate, Potash). 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 1 (Sulfur) is 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 Magnesium — 🇨🇳 CN controls 86% of global refining. On this company's production footprint that scores 75/100 (adversarial chokepoint; global 63). The register holds 20 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · MagnesiumICL Group Ltd is the 32nd-most-exposed of the 63 named companies we track on 🇨🇳 CN's Magnesium chokepoint; the most-exposed is Leonardo S.p.A. (75/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · mining metals
ICL Group Ltd ranks 150th of 445 verified mining metals companies, tied with 16 others at 67.
95🇺🇸 TdVibDysprosium
95🇦🇺 Northern Minerals LimitedDysprosium
93🇺🇸 Alta Resource TechnologiesDysprosium
93🇬🇧 Mkango Resources LimitedDysprosium
93🇨🇦 Defense Metals Corp.Dysprosium
93🇨🇦 Ucore Rare MetalsDysprosium
92🇺🇸 Phoenix TailingsDysprosium
91🇨🇦 Appia Rare Earths & Uranium Corp.Dysprosium
91🇦🇺 Arafura Rare Earths LimitedDysprosium
91🇦🇺 Hastings Technology Metals LimitedDysprosium
91🇦🇺 VHM LimitedDysprosium
91🇦🇺 Vital Metals LtdDysprosium
90🇨🇦 NioCorp DevelopmentsDysprosium
90🇺🇸 Energy Fuels Inc.Dysprosium
67🇮🇱 ICL Group LtdMagnesium
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 127 further mining metals 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 67/100 — 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 (IL 100%, HQ proxy), applied across all materials — it does not yet trace each input to its specific sourcing step.
Also listed in the dossier but not platform-scored: Bromine — no supply-risk series is tracked for it here.
ICL Group Ltd
What they do
ICL Group Ltd (NYSE/TASE: ICL; Tel Aviv) is a specialty-minerals and fertilizer group built on Dead Sea and Negev resources. It reports four segments — Industrial Products (bromine and bromine compounds from the Sodom plant), Potash (Dead Sea Works in Israel, Iberpotash in Spain, and Dead Sea Magnesium), Phosphate Solutions (Rotem phosphate rock in the Negev plus the 50/50 YPH joint venture in Yunnan, China), and Growing Solutions (specialty fertilizers). FY2025 sales were $7,153m.
Critical-material exposure
Phosphate (producer, bulk output): Phosphate Solutions is ICL's largest segment ($2,333m FY2025 segment sales). Rock is mined at Rotem (IL) and at the Haikou mine held through YPH, which ICL owns equally with Yunnan Yuntianhua. That puts part of ICL's phosphate supply inside China. Phosphate is a scored material.
Potash (producer, bulk output): Dead Sea Works and Iberpotash (Súria, ES) feed a $1,714m segment. ICL is one of the few potash sources outside the Canada/Russia/Belarus concentration, which makes it a counter-party in any potash sanctions or diversion scenario. Potash is a scored material.
Magnesium (producer, structural metal output): the 20-F calls Dead Sea Magnesium "the largest magnesium producer outside of China and Russia". That matters because China dominates primary magnesium supply. Chlorine from the magnesium electrolysis also feeds bromine production. Magnesium is a scored material.
Bromine (producer, bulk output): bromine comes from Dead Sea brines and is oxidised at Sodom (Industrial Products, $1,254m segment sales). It is a single-basin, single-site concentration. Bromine is not in SCORED_MATERIALS (checked 2026-09-29), so it is carried for the record and not scored.
Sulfur (consumer, bulk process input): the 20-F names sulphur as "a key raw material in phosphate production" (for sulfuric acid). Sulphur price moves pass straight into phosphate costs.
Every production asset except YPH (CN) and Iberpotash (ES) sits in Israel. Israeli sites produced $3,172m of FY2025 gross sales before intercompany eliminations. Sales are spread widely: Brazil, the US and China together take 52%.
Sources
ICL Group Ltd, Form 20-F for FY2025 (filed 2026-03-11): https://www.sec.gov/Archives/edgar/data/941221/000117891326000817/zk2634483.htm
ICL Form 6-K 2026-06-23 (Indian Potash Limited supply contract): https://www.sec.gov/Archives/edgar/data/941221/000117891326003308/zk2635598.htm
Named counterparties — who actually buys and sells
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.
The full counterparty breakdownShowHide
Named customers (2)
Indian Potash Limited · FY2026arm's lengthcompany-disclosuresecondarysource ↗
6-K dated 2026-06-23 (SEC filing index live at https://www.sec.gov/Archives/edgar/data/941221/000117891326003308/; the underlying document itself returned HTTP 403 at verification): ICL to supply 375,000 metric tons of potash, option for +50,000t, at $383/ton CIFFO Indian ports, within the 2022-2027 five-year IPL supply framework. No pair-specific share-of-sales percentage disclosed.
Oakley Fertilizer Inc · 2024-2025, per US import bills of ladingarm's lengthcustomsprimary-sourcesource ↗
US import bills of lading (ImportGenius): shipper 'DEAD SEA WORKS LTD, POTASH HOUSE PO BOX 75 BEER SHEVA, IL', consignee Oakley Fertilizer Inc; GIMIADNOLANO0003 dated 2025-09-18, potash in bulk, 4,285,542 kg, foreign port Ashdod, country of origin Israel; earlier BoLs GIMI0225ADNO003 (2025-02-23, red granular muriate of potash, 2,812,274 kg), GIMIADNOREA003 (2024-10-23, 2,812,274 kg) and GIMI0824ADNO0002 (2024-09-19, 11,407,851 kg), all origin Israel. Dead Sea Works potash is produced at Sodom on the Dead Sea, Israel; Oakley is the US importer (US port of unlading not shown). Dead Sea Works supplier page also lists BoL BLWR26032002 (2026-09-19, 'TO THE ORDER OAKLEY FERTILIZER INC', red granular muriate of potash, 8,436,821 kg).
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.
The exposure register
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).
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
Magnesium
4Concentration: refining HHI 7507 (extreme); top CN 86%
5Substitutability: Graedel et al. 2013 PNAS Fig. 5: 94/100 (long-horizon, all major uses). Prior analyst short-run rating 0.58: aluminium substitutes in some structural/alloy uses
Phosphate
4Geopolitical: 10 restrictive actions, peak severity 4, 9 in last 24mo, less 1 liberalising action
5Substitutability: no substitute for phosphorus in agriculture
4Import reliance: Eurostat Comext 2025: 78% extra-EU imports, top partner MA 36% (partner HHI 2129)
Potash
4Geopolitical: 8 restrictive actions, peak severity 4, 4 in last 24mo
5Substitutability: no substitute for potassium as a plant nutrient
Sulfur
4Substitutability: byproduct of oil/gas desulfurization + smelting — cannot be produced on demand, so supply is price-inelastic; sulfuric acid has no substitute in phosphate fertilizer or copper SX-EW leaching (USGS: no substitute for the sulfur plant nutrient)
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.
No filings or amendments in this window — the register has been quiet on this company's materials.
The laws that threaten it
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
2023-12-14· export-control· severity 3· copper, nickel, aluminium, lead
+ 5 more in the register.
Art. 24(2)(c) · vulnerability to disruption
Stress test — two plausible scenarios
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
Magnesium — 🇨🇳 CN escalates magnesium controls to a full export-licensing / ban regime
75
90
+15
Concentration
Magnesium — 🇨🇳 CN becomes the single source for magnesium — the second source is lost (full 86%+ monopoly)
75
85
+10
Policy
Phosphate — 🇨🇳 CN escalates phosphate controls to a full export-licensing / ban regime
69
73
+4
Concentration
Phosphate — 🇨🇳 CN becomes the single source for phosphate — the second source is lost (full 38%+ monopoly)
69
94
+25
Policy
Potash — 🇨🇦 CA escalates potash controls to a full export-licensing / ban regime
40
45
+5
Concentration
Potash — 🇨🇦 CA becomes the single source for potash — the second source is lost (full 31%+ monopoly)
40
60
+20
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. The Art. 24(4) mitigation duty is not triggered on the factors we could score (1 of 5 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.
Reported separately (not an Art. 24(4) trigger): Magnesium clears the same numeric bar but is a material ICL Group Ltd produces. That is an output-market concentration — relevant to revenue and to counterparties who buy from this company — not an input dependency the company must mitigate under Art. 24(4).
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 1 material this company buys (the 3 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
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 72d ago · not yet law·matches Phosphate, Sulfur
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Phosphate🇨🇳 today 69→73+4
Sulfur🇨🇳 today 40→57+17
🇸🇳 Senegal New Code Minier
passed-committee→elevated likelihood·flagged 114d ago · not yet law·matches Phosphate
If passed — Replaces 2016 Code Minier; embeds 'sovereignty doctrine' with stronger state participation, local-transformation mandate, and WAEMU-conformity requirements; President Faye targeted adoption before end-2025; PM Sonko's May 2026 dismissal may have delayed/revised the bill
Caveat — Council of Ministers approved the bill Nov 12, 2025 for transmission to National Assembly. Distinct from already-filed Senegal Code des Investissements 2025 (Loi 2025-16) and March 2026 contract-renegotiation findings. Replaces Loi n° 2016-32 (2016 code) — that base law not separately filed in register. Moderate likelihood pending new-government confirmation under PM Amadou Makhtar Ba.
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Phosphate🇨🇳 today 69→73+4
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Phosphate
If passed — Establishes the first legally binding "safe level" benchmark for EU strategic stocks of each of the 17 strategic raw materials listed in the CRMA Annex I; benchmarks used as reference by Member States, financial institutions, and industrial consumers to assess strategic supply risk; mandated every 2 years, so this is the first edition setting the baseline; informs CRMA Art. 23 monitoring obligations and is the evidential basis for Art. 24 corporate-reporting thresholds
Caveat — The May 24, 2026 deadline set by Parliament and Council in Reg. (EU) 2024/1252 has now passed. No OJ publication confirmed as of June 15, 2026 — Commission may have adopted quietly or is overdue. This is the first CRMA Art. 22 benchmark cycle and is legally distinct from: (1) the CRMA base regulation (filed 2024-05-23); (2) the Strategic Projects first designation (filed 2025-03-25); (3) the RESourceEU Amendment — CRMA revision (filed 2026-03-04). If confirmed adopted, severity=2 (establishes the measurement baseline for EU strategic material supply risk assessment and directly feeds corporate Art. 24 reporting obligations). Distinct from all filed EU-CRMA actions. Not in filing. md or upcoming. md.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Phosphate🇨🇳 today 69→73+4
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Phosphate
If passed — RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Phosphate🇨🇳 today 69→73+4
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 31d ago · not yet law·matches Phosphate
If passed — Draft law amending Morocco's 2015 Mining Code (led by the Ministry of Energy Transition and Sustainable Development, Minister Leila Benali), with public consultations reported open since ~Feb 2025. Three structural changes: (1) a National Commission for Strategic and Critical Minerals empowered to designate an official list of "strategic and critical minerals" — Morocco's first formal legal mechanism to do so, which would sit upstream of and interact directly with the phosphate chokepoint (Morocco holds ~70% of world phosphate-rock reserves via OCP); (2) the digital mining cadastre (governance/transparency layer — this component has ALREADY gone live, launched 2026-04-07, and is queued separately to filing. md as an enacted action); (3) sharply increased penalties for illegal mining/prospecting (unauthorised prospecting: MAD 100k-1m; illegal extraction/transport/sale: up to MAD 2m). Morocco is chokepoint-tier and thinly covered (only 4 prior MA actions: 2022 Investment Charter, an AfDB agriculture loan, the 2026 Loi de Finances, and a Feb-2026 mining-tender notice — none creates a minerals-designation regime).
Caveat — distinct from the already-filed 2026-04-07 digital-cadastre launch (enacted, queued to filing. Dedup: no MA action in the index covers a strategic-minerals designation commission or mining-code amendment; the 3 other MA entries (Investment Charter 2022, Loi de Finances 2026, Feb-2026 mining tender) are distinct instruments.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Phosphate🇨🇳 today 69→73+4
🇺🇸 US Senate S.4418 / House HR 8583 — "Lowering Input Costs for American Farmers Act" (eliminate CVD order on Moroccan phosphate fertilizer)
announced→low likelihood·flagged 30d ago · not yet law·matches Phosphate
If passed — Introduced 28-Apr-2026 by Sen. Roger Marshall (R-KS) with Grassley, Hyde-Smith and Ernst as cosponsors (companion HR 8583 referred to House Ways and Means 29-Apr-2026); would revoke the 2021 Commerce countervailing-duty order on phosphate fertilizer imports from Morocco (OCP Group) within 4 business days of enactment and require refund of duties already collected. Commerce's own preliminary sunset-review finding (Federal Register, 24-Jul-2026) is that revocation would let subsidies recur at ~20% — i. e. the executive-branch trade posture is currently the opposite of what this bill does, so passage is a bigger lift than the stage alone suggests (hence likelihood: low despite four sponsors). SUPPLY-RELIEF if enacted — would materially cheapen US import access to Morocco's phosphate-rock-derived fertiliser (Morocco holds ~70% of world phosphate-rock reserves via OCP), netting against the register's chokepoint-restriction actions elsewhere.
Caveat — Bill itself is proposed/unlikely to pass on its own (no committee action found as of 2026-09-05); the REAL near-term mover is the CVD sunset review due ~Oct-2026, which is the vehicle to actually watch. Dedup: no existing MA or US action in filing. md/upcoming. md covers Moroccan phosphate CVD duties.
Reference-class base rate
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 ↗
If passed & escalated to a full control regime — modelled impact (low likelihood)
Phosphate🇨🇳 today 69→73+4
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
Magnesium is the line to war-game: 🇨🇳 CN already controls 86% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Phosphate carries 10 restrictive measures on record (🇨🇳 CN 38% of refining) — a secondary escalation candidate.
Potash carries 8 restrictive measures on record (🇨🇦 CA 31% of refining) — a secondary escalation candidate.
Art. 24(4) · diversification & substitution
Priority mitigations
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 (Sulfur). The 3 materials ICL Group Ltd produces (Magnesium, Phosphate, Potash) are excluded from these buyer levers — see the role check in the verdict and the significant-vulnerability conclusion above.
The mitigation optionsShowHide
Map your real exposure to Sulfur. Trace it from the component back to the smelter/refiner and country of origin — most buyers discover the dependence is one tier deeper than their direct supplier.
Qualify a non-CN source. Identify and validate at least one supplier outside CN for the binding input before it is needed, even at a cost premium — optionality is the hedge.
Lead-time to re-source is ~3 months (0-6mo). The largest tracked non-CN producer of Sulfur is 🇺🇸 US (~10% of mining); scaling it into a replacement is roughly a 0-6mo ramp. A share-of-stage substitution heuristic derived from current production share, not a firm supplier quote.
Hold strategic inventory / contract forward. For materials with no substitute and active export controls, a buffer stock or long-dated offtake converts a shock into a managed cost.
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.
Consider production localisation. Where the material is consumed inside the controlling country's perimeter, local sourcing/assembly can move you inside the chokepoint rather than across the export-control line.
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
Yes — 1 scored SRM on the input side (binding: Sulfur); 3 further scored SRMs produced, not consumed
Manufactures a listed strategic technology
mining-metals (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 2026-07-24; 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.