1 critical material scored · binding chokepoint: Tin (🇨🇳 CN 55% of refining) · 18 restrictive government measures on record
Subject
INDOMETAL · 🇬🇧 GB
Sector
mining-metals
Materials scored
1
As of
2026-09-17
Risk Office verdict
Elevated · 66/100Company supply-risk index · consumer-side read
Role check · this company is a producer, not a buyer
Indometal (London) Ltd produces 1 of the 1 scored material above (Tin). 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 Elevated · 66/100 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 2026-10-07) — 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 Tin — 🇨🇳 CN controls 55% of global refining. On this company's production footprint that scores 66/100 (adversarial chokepoint; global 56). The register holds 18 restrictive government measures touching this company's materials — each traced to its primary source below.
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Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 132 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 66/100 — 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 (GB 100%, HQ proxy), applied across all materials — it does not yet trace each input to its specific sourcing step.
Indometal (London) Ltd
What they do
Indometal (London) Limited is a London-registered trading company (Companies House deed of establishment no. 2224189, 20 February 1988) that is 100 % owned by PT TIMAH Tbk, Indonesia's state-owned tin miner and smelter. Timah describes it as its vehicle to be "closer to the London Metal Exchange (LME) market" and its tin sales agent in Europe and the United States. It does not mine or smelt; it markets Timah's refined tin ingots (smelted at Muntok, Bangka) to Western buyers, and appears as consignee on Timah tin bills of lading into the US (see the timah dossier, named_counterparties).
Critical-material exposure
Tin — sell-side, bulk commodity (the whole business). Indometal's revenue
is the marketing of Indonesian refined tin, so its exposure is the parent's: Indonesian export policy on tin (smelter licensing, RKAB mining quotas, export-via-exchange rules) directly gates the volume it can sell, and Indonesia is the world's largest tin exporter. Role recorded as producer because it is the producer group's selling arm, not an end user.
Third-party reports (MMTA member listing) say it has also been appointed
global trader for other Indonesian state miners (aluminium, ferro-nickel, coal); this is not on Timah's own page and is therefore not recorded as an exposure here.
Sales geography: not disclosed (no segment data found) — left blank.
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
Tin
4Geopolitical: 18 restrictive actions, peak severity 4, 13 in last 24mo
5Price / market: price up, as of 2026-09-01
Named refiners in the supply base
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.
The named refinersShowHide
Tin
China = 28% of filer-disclosed refiner mentions · 879 named refiners
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.
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.
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.
2023-12-14· export-control· severity 3· copper, nickel, aluminium, lead
+ 3 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
Tin — 🇨🇳 CN escalates tin controls to a full export-licensing / ban regime
66
71
+5
Concentration
Tin — 🇨🇳 CN becomes the single source for tin — the second source is lost (full 55%+ monopoly)
66
90
+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 Indometal (London) 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
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 116d ago · not yet law·matches Tin
If passed — Mandates 15% free-carried interest for Uganda National Mining Company (UNMC) in all new mining licences; introduces mandatory mineral buying centres; tightens local-content and value-addition obligations — changes joint-venture economics for all new Ugandan mining operations, raising effective cost-of-entry for foreign miners
Caveat — Amends the already-filed Uganda Mining and Minerals Act 2022 (UG action 1); expected to be enacted before end of 2025/26 parliamentary session per legal commentary; Bank of Uganda gold purchase programme and new mineral buying centres already being piloted — regulatory infrastructure being built ahead of formal enactment. Distinct from filed Uganda Gold Export Regulations 2024 (SI No. 30 of 2024).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Tin🇨🇳 today 66→71+5
🇮🇩 Indonesia Tin Export Ban — Downstreaming Initiative
announced→low likelihood·flagged 115d ago · not yet law·matches Tin
If passed — Indonesia = ~20% of global refined tin exports (Bangka Belitung); a ban on refined-tin exports would force downstream solder/semiconductor-packaging manufacturing domestically; disrupts global electronics and EV supply chains dependent on Indonesian tin solder and specialty alloys
Caveat — Minister of Energy and Mineral Resources Bahlil Lahadalia announced government "studying" tin export ban on February 13, 2026 at the Indonesia Economic Outlook, Jakarta; framed as replication of 2020 nickel ore ban which claimed 10x value-add uplift; key complication — Indonesia already exports refined tin (not raw ore), so a ban would require immediate creation of advanced downstream industries (solder, electronic-grade tin, semiconductor components) that don't yet exist at scale; Mining Weekly (Feb 13 2026) and BERNAMA (Feb 2026) confirm announcement; no Perpres, PP, or Kepmen issued as of June 14, 2026; government described as "studying" — not yet in formal regulatory drafting. Distinct from filed Indonesia nickel ore export bans (2019, 2023), filed bauxite export ban, and filed Permendag export-licensing amendments.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Tin🇨🇳 today 66→71+5
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 115d ago · not yet law·matches Tin
If passed — Prohibits raw mineral exports unless 30% value-addition achieved domestically; affects Chinese mining companies (dominant in Nigerian critical minerals sector), Western offtake agreements, and all foreign-invested mining JVs; builds on existing eMC+ digital cadastre and mandatory value-addition plans introduced Nov 2024; could force processing-plant investment or suspension of raw mineral shipments from Africa's most populous economy; RMRDC = Raw Materials Research and Development Council (the sponsoring agency)
Caveat — Bill passed third reading in House of Representatives; multiple Nov 2025 sources confirm both chambers approved; as of 2026-06-14 presidential signature not yet confirmed. Distinct from filed Nigeria Tax Reform Acts 2025 (Loi n°1/19 tax restructuring) and Mining Cadastral licence revocations (2025-06-19). Applies to ALL raw materials, not minerals only — IPTM relevance is the mineral export provisions.
announced→low likelihood·flagged 113d ago · not yet law·matches Tin
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Tin🇨🇳 today 66→71+5
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 112d ago · not yet law·matches Tin
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Tin🇨🇳 today 66→71+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
Tin is the line to war-game: 🇨🇳 CN already controls 55% 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 Indometal (London) 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 Tin — qualifying alternative suppliers, designing the material out — are the demand risk to Indometal (London) 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 Indometal (London) 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
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 2026-09-17; 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.