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2 critical materials scored · binding chokepoint: Rhodium-iridium (🇿🇦 ZA 83% of mining) · 12 restrictive government measures on record
A verification pass re-checked this dossier's ownership/corporate-structure fields against their cited sources. It did not re-read the material_exposures claim the score, band and stress figures below are built on — treat those as not yet independently re-checked.
The binding exposure is Rhodium-iridium — 🇿🇦 ZA controls 83% of global mining. On this company's production footprint that scores 71/100 (neutral exposure; global 71). The register holds 12 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Rhodium-iridium Johnson Matthey plc is the 22nd-most-exposed of the 67 named companies we track on 🇿🇦 ZA's Rhodium-iridium chokepoint; the most-exposed is Isuzu Motors Limited (71/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Johnson Matthey plc ranks 33rd of 100 verified chemicals companies, tied with 4 others at 69.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 13 further chemicals 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 69/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 2 scored materials. Buyer-relative (first-order): weighted by where the company produces (GB 35% · US 25% · IN 12% · CN 10% · DE 8% · SE 5% · MY 5%, 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.
Johnson Matthey (JMAT.L) is a UK-listed specialty chemicals company whose business is built on platinum group metals (PGMs). Its two core divisions are Clean Air — emission-control catalysts for internal combustion engines and hybrid powertrains, including SCR catalysts via the newly acquired CORMETECH (May 2026, $360M) — and PGM Services, which refines and recycles PGMs from spent autocatalysts and industrial catalysts, closing the circular-materials loop. A third segment, Hydrogen Technologies, manufactures catalyst-coated membranes and membrane electrode assemblies for PEM fuel cells and electrolysers. A fourth division, Catalyst Technologies (syngas, refinery, chemical-process catalysts), was sold to Honeywell International for £1,325 million (enterprise value, cash-and-debt-free), completed 17 July 2026 (confirmed 2026-09-06 — matthey.com/media/2026/ct-honeywell-completion; terms unchanged from the original announcement). Post-divestiture, JM is now a PGM-dominated Clean Air + hydrogen materials company; net proceeds of ~£1bn are being returned to shareholders via an £800m special dividend (with share consolidation) and a £200m buyback.
electrolyser membrane electrodes; supply is ~73% South African, putting the ZA mining-sector risk (labour, energy, water) at the centre of JM's cost structure. JM publishes the benchmark annual PGM Market Report, reflecting deep dependency on this supply chain.
of world supply) is the concentration chokepoint. Long-running deficit structure: JM's own 2025 market report forecast palladium returning to balance only after years of supply deficits.
market by volume, highest price volatility, and South-Africa-origin concentration comparable to platinum. No commercially viable substitute in ICE catalysts.
global supply is extremely thin (<9 t/yr, almost entirely South Africa). Growing as JM's Hydrogen Technologies segment scales. Nickel — dropped 2026-09-06. Nickel was carried as a transitional exposure via Catalyst Technologies' syngas/refinery catalyst formulations, pending the Honeywell sale. That sale completed 17 July 2026 (confirmed against matthey.com's own completion notice), and Catalyst Technologies is no longer part of JM — so the nickel basis this dossier relied on no longer exists and the entry is removed rather than left standing on a business line JM has divested. JM's other historical nickel line, the eLNO battery-cathode business, was separately and fully divested across 2022-2024 (Battery Materials to EV Metals Group in 2022, Battery Systems in Apr-2024, the remaining Poland site in Jul-2024) and was never a basis for this exposure.
Not carried, and why. JM's stationary SCR catalysts (SINOx) plausibly use vanadia-titania chemistry per general SCR industry literature, but that could not be confirmed against a current primary JM source, so vanadium is left unverified rather than asserted. Byproduct silver and gold recovery does occur inside PGM recycling, but it is incidental rather than a business line — JM sold its dedicated gold/silver refining unit to Asahi Holdings in 2015 — so silver is not carried either. Cobalt and lithium exited with the battery-materials divestitures above. Ruthenium and osmium are genuine JM PGM lines but have no slug in this register's scored-materials list, so they appear nowhere in the frontmatter. (All four determinations merged from johnson-matthey.md 2026-08-14.)
merged from johnson-matthey.md 2026-08-14: https://matthey.com/media/2026/transaction-update
2026 (verified 2026-09-06; sale is CLOSED, terms unchanged at £1,325m): https://matthey.com/media/2026/ct-honeywell-completion
palladium, rhodium, iridium, ruthenium, osmium) — merged from johnson-matthey.md 2026-08-14: https://matthey.com/products-and-markets/pgms-and-circularity/pgm-refining-and-recycling
2026-08-14; basis for the Royston and Brimsdown site entries and for excluding South Africa (Germiston plant closed Oct-2023). URL corrected 2026-09-06 — the old /about-us/locations path 404s; current path is /locations, Royston and Brimsdown confirmed still listed: https://matthey.com/locations
https://api.gleif.org/api/v1/lei-records/2138001AVBSD1HSC6Z10 ; BlackRock TR-1 major-holding RNS, notified 2025-08-04: https://th.tradingview.com/news/reuters.com%2C2025-08-05%3Anewsml_RSE1088Ua%3A0-reg-johnson-matthey-plc-holding-s-in-company
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.
JM's own press release: JM and Sibanye-Stillwater 'extended their current pgm supply and refining agreements to ensure long term sustainable supply for Johnson Matthey's products and customers'; no volume or share of JM's PGM feedstock disclosed.
JM's own press release: JM 'agreed an extension to our metal supply agreement with Anglo American Platinum Limited' (marketing agreement had run since 1992, amended/extended from 2004); a separate pgm market-research services contract also begins 31 Dec 2013. No volume or share disclosed.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
1 of 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 |
|---|---|---|---|---|---|---|---|---|---|
| Rhodium-iridium | 🇿🇦 ZA 83% mining | 71 | 71 | High | EXCEEDS 83% | High | none | 10 | ▲ rising |
| Platinum-palladium | 🇿🇦 ZA 54% mining | 62 | 62 | Elevated | within 54% | High | limited | 12 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Rhodium-iridium | 4 | 4 | 3 | 5 | 4 | company input |
| Platinum-palladium | 4 | 3 | 5 | 4 | 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.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
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 🇿🇦 ZA shock, these disclosed plants carry the binding Rhodium-iridium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Rhodium-iridium — 🇿🇦 ZA escalates rhodium-iridium controls to a full export-licensing / ban regime | 71 | 77 | +6 |
| Concentration | Rhodium-iridium — 🇿🇦 ZA becomes the single source for rhodium-iridium — the second source is lost (full 83%+ monopoly) | 71 | 82 | +11 |
| Policy | Platinum-palladium — 🇿🇦 ZA escalates platinum-palladium controls to a full export-licensing / ban regime | 62 | 67 | +5 |
| Concentration | Platinum-palladium — 🇿🇦 ZA becomes the single source for platinum-palladium — the second source is lost (full 54%+ monopoly) | 62 | 83 | +21 |
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.
This assessment identifies 1 significant vulnerability — Rhodium-iridium — each a High/Critical exposure that is hard to substitute and already under at least one in-force restrictive measure. This engages the duty under Art. 24(4) to take mitigating efforts, including assessing diversification of the supply chain or substitution of the material (see Priority mitigations below).
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the materials this company buys. The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Rhodium-iridium).
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: Rhodium-iridium) |
| Manufactures a listed strategic technology | chemicals (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 2026-06-03; 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.