2 critical materials scored · binding chokepoint: Indium (🇨🇳 CN 69% of refining) · 19 restrictive government measures on record
Subject
jsr-corporation · 🇯🇵 JP
Sector
semiconductor
Materials scored
2
As of
2026-09-17
Risk Office verdict
High · 74/100Company supply-risk index
The binding exposure is Indium — 🇨🇳 CN controls 69% of global refining. On this company's production footprint that scores 76/100 (adversarial chokepoint; global 64). The register holds 19 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · IndiumJSR Corporation is the 72nd-most-exposed of the 161 named companies we track on 🇨🇳 CN's Indium chokepoint; the most-exposed is ispace, Inc. (76/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · semiconductor
JSR Corporation ranks 55th of 72 verified semiconductor companies.
88🇬🇧 Filtronic plcGallium
86🇺🇸 MicroLink Devices, Inc.Gallium
86🇬🇧 CML Microsystems plcGallium
86🇸🇪 Norstel ABGraphite
86🇺🇸 Skyworks Solutions, Inc.Gallium
85🇦🇺 BluGlass LimitedGallium
84🇱🇹 Brolis SemiconductorsGallium
83🇦🇹 ams-OSRAM AGTerbium
83🇰🇷 DB HiTek Co., Ltd.Tungsten
83🇹🇼 Himax Technologies, Inc.
Company supply-risk index 74/100 — 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 (JP 55% · KR 20% · BE 15% · TW 10%, 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
JP · Yokkaichi — photoresists (main plant + Fine Electronic Materials Development Center)
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.
JSR Corporation
What they do
JSR Corporation is a Japan-based specialty-chemicals company and the world's largest photoresist manufacturer, holding an estimated ~27% share of the global semiconductor photoresist market. Founded in 1957 as Japan Synthetic Rubber, it has narrowed to a semiconductor-materials focus (photoresists, CMP slurries, cleaning chemistries) since its 2024 acquisition by Japan Investment Corporation (JIC), a government-backed fund that took it private and delisted it from the Tokyo Stock Exchange.
Critical-material exposure
Tin (Sn) — structural component of a flagship product line, not a
trace additive. JSR's Inpria subsidiary (acquired 2021) makes metal-oxide resist (MOR), a next-generation EUV photoresist built on tin-oxide chemistry rather than the organic photoacid-generator chemistry of conventional resists. MOR is in qualification/ramp with Samsung and SK hynix for next-gen DRAM, backed by a dedicated production plant at JSR Micro Korea (Cheongju) and a planned Taiwan plant near TSMC. Tin mine supply is relatively diversified (China, Indonesia, Myanmar, Peru, Bolivia), so the exposure here is less raw-material scarcity than EUV-photoresist qualification lock-in — fabs re-qualify a resist chemistry over years, so a supply disruption is hard to substitute around quickly.
Indium (In) — trace additive, R&D-stage only. JSR's own technical
publications describe indium, alongside titanium and zinc, as one of several alternative metal cores investigated for next-generation MOR variants beyond tin-oxide. No confirmed commercial product currently ships on an indium-based resist — flagged as a forward-looking exposure to watch, not a present bill-of-materials risk.
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 (1)
SK hynix Inc. · 2022-2026 (qualification/ramp, ongoing)arm's lengthcompany-disclosureprimary-sourcesource ↗
JSR's Inpria subsidiary is co-developing metal-oxide resist (MOR) with SK hynix for next-generation DRAM patterning; in qualification/ramp, not yet disclosed as full commercial-volume shipment. No share_pct 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.
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.
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.
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.
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).
Counterfactual: the 50%-ownership automatic extension of Entity List designations runs to its full perimeter (one-year suspension at 2025-11-10 lifted on schedule). Direct-hit lines are basket issuers in semiconductor / chip-equipment / AI-compute sectors — the perimeter where the rule's 50% controller-affiliate test compounds with existing Entity List names.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 76 → 86(+10) — a relative official policy-pressure magnitude, not a price drawdown.
Trace the precedent to its primary source via the link above ().
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 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 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 — 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. Market-implied percentages are live external prediction-market prices (alternative/OSINT signal) — an independent read, not our model output and not merged into the official register or the stage-derived band; the gap between the market price and our stage assessment is itself the signal.
The upcoming threatsShowHide
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 115d 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
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
Indium is the line to war-game: 🇨🇳 CN already controls 69% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Tin carries 18 restrictive measures on record (🇨🇳 CN 55% 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 (Indium).
The mitigation optionsShowHide
Map your real exposure to Indium. 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 Indium is 🇰🇷 KR (~16% of refining); 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.
Design for substitution where feasible. Indium has at least partial substitutes; specify them into next-generation products to cut the dependence structurally.
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.
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)
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 — 2 scored SRMs on the input side (binding: Indium)
Manufactures a listed strategic technology
semiconductor (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.
Tungsten
82🇮🇹 LFoundry S.r.l.Tungsten
82🇺🇸 Qorvo, Inc.Gallium
82🇹🇼 Vanguard International Semiconductor Corporation (VIS)Gallium
81🇬🇧 IQE plcGallium
74🇯🇵 JSR CorporationIndium
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 10 further semiconductor 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.
No other SCORED_MATERIALS critical minerals (e.g. tungsten, tantalum, antimony, rare earths) could be verified against JSR's actual product line; the sector-default guesses for those have been dropped.
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 ↗
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
Indium
4Geopolitical: 2 restrictive actions, peak severity 4, 2 in last 24mo
You hold exposure to 1 of these 5 materials (Indium) — your binding Indium exposure is one of them.
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
🇺🇸 US has historically countered a median of 3.9 months later (n=23 recorded episodes since 2024). Counter-move intensity: median severity 3/5 (3 of 23 via quantified basis).
🇮🇳 IN has historically countered a median of 9.9 months later (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5 (0 of 4 via quantified basis).
Descriptive history of recorded counter-actions in our causal register — not a forecast; the gap is what the controller's past moves drew in response.
The ordered history of what this controller has restricted, each step traced to /actions/{id} — a descriptive sequence, not a forecast.
Type
Scenario
Today
Stressed
Δ
Policy
Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime
76
86
+10
Concentration
Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly)
76
91
+15
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.
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 114d 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 114d 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.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Tin🇨🇳 today 66→71+5
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches Indium
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)
Indium🇨🇳 today 76→86+10
🇹🇼 Taiwan proposed comprehensive AI chip export controls on China — MOEA/ITA considering extending SHTC licensing requirements beyond blacklisted entities (Huawei, SMIC) to cover ALL Chinese customers for advanced AI chips and AI servers; would give Taiwanese regulators broader authority to block diversion of AI hardware (NVIDIA-powered servers, advanced AI chips) from Taiwan to China via third-country routing; MOEA stated June 9, 2026 "will continue strengthening oversight of strategic high-tech exports in line with global export-control trends"; discussions between Taiwan and US officials ongoing on controls for advanced chips
announced→low likelihood·flagged 113d ago · not yet law
If passed — If enacted, first Taiwan restriction covering all Chinese customers (not just blacklisted entities); would require Taiwanese OEMs (Foxconn, Pegatron, ASUS, Quanta, Wiwynn), server makers, and component suppliers to seek export licences before any AI hardware shipment to China — affects ~$15-20bn/yr of Taiwan-to-China AI server/component flows; raises costs for Taiwanese firms with significant China revenue
Caveat — Distinct from filed 2025-06-15-taiwan-moea-shtc-entity-list-expansion (Huawei/SMIC-specific, +599 entities) and 2025-11-18-taiwan-moea-ita-shtc-controlled-goods-list-expansion (quantum computers/3D printers). This is a proposed expansion to entity-neutral coverage. Low-to-elevated likelihood: confirmed that US lawmakers pressed Taiwan (2026 defence legislation); Taiwan-US synchronisation pattern well-established (aligned with US BIS controls on China); but MOEA has not publicly announced a formal rulemaking process.
announced→low likelihood·flagged 112d 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 111d 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
🇹🇼 Taiwan ITA — Dual-Use Export Control List Revision: AI Chips and Advanced Semiconductors Targeting China (June 2026)
in-consultation→moderate likelihood·flagged 108d ago · not yet law
If passed — Taiwan ITA (International Trade Administration, MOEA) launched a 60-day public consultation on planned revisions to the SHTC (Sensitive High-Tech Commodity) controlled-goods export list to add AI chips and advanced semiconductor categories specifically targeting exports to China; if enacted, would extend Taiwan's existing sub-14nm chip / advanced packaging export controls (SHTC list 2025-11-18) to include AI-application chips sold for China use — the measure is designed to align Taiwan's export controls with US BIS advanced-chip restrictions and close the gap on AI server / Nvidia chip diversion from Taiwan to China; Bloomberg June 9, 2026 cites Taiwan authorities "considering much stricter export controls on AI chip sales to China to further align with US measures"; ITA confirmed a 60-day review period for planned revisions; if enacted, would add legal tools to address diversion of AI servers and Nvidia chips through Taiwan to China; affects global AI hardware supply chains and Taiwan-domiciled chip distributors, system integrators, and ODM/OEM assemblers
Caveat — Distinct from 2025-11-18-taiwan-moea-shtc-controlled-goods-expansion (that amendment added quantum computers and advanced semiconductor equipment to the SHTC list — this proposed revision targets AI application chips and AI server hardware for China specifically, different commodity scope and different policy driver); distinct from 2025-06-10-taiwan-moea-shtc-entity-list-huawei-smic (entity list addition, not commodity list revision). Timeline: 60-day review likely closes August 2026; if enacted, new SHTC amendment would take effect Q3/Q4 2026. Likelihood elevated: the ITA has formally initiated the review process and the stated policy driver (US BIS alignment) is official; Taiwan government has consistently tightened SHTC controls in line with US export control strategy since 2022. Filed upcoming 2026-06-20.
If passed — Requires US allies — primarily the Netherlands (ASML) and Japan (Tokyo Electron, Shin-Etsu) — to align their national export controls on advanced semiconductor manufacturing equipment with US BIS restrictions targeting China; strips DoC discretionary licensing authority for chipmaking tools; DUV immersion lithography machines (ASML TWINSCAN NXT series) would face mandatory licensing denial for China-bound sales/servicing; includes anti-circumvention provisions to block third-country re-export through Malaysia, Singapore, or UAE; if enacted, would overturn the bilateral US-Netherlands arrangement on DUV servicing and pressure Japan to expand its April 2023 / January 2024 semiconductor-equipment controls beyond current scope; diplomatic friction: NL Trade Minister Sjoerdsma was in Washington the same week opposing this bill while simultaneously signing Pax Silica
Caveat — Senate bill introduced April 8, 2026 (bipartisan: Risch R-ID, Ricketts R-NE, Kim D-NJ, Schumer D-NY); House companion H. R. 8170 introduced April 2, 2026 (Baumgartner R-WA); House Foreign Affairs Committee passed April 22, 2026 in what HFAC members described as "the largest significant export-control markup in the history of Congress" (20 bills advanced in single markup). Full House and Senate chamber votes still pending as of June 24, 2026. Key contested provision removed pre-committee: country-wide ban on cryogenic etching tool exports — DUV restrictions remain. Administration position unclear — DoC has been resistant to losing licensing discretion; USTR and State potentially prefer diplomatic alignment (Pax Silica model) over binding legislation. If enacted, directly targets ASML NL: estimated ~USD 3–5bn annual China DUV machine revenue at risk. Distinct from: filed 2025-01-15-netherlands-export-control-metrology-inspection-semiconductor (Dutch national expansion, not US law); filed 2024-09-07-netherlands-export-control-expansion-asml-duv-1970i-1980i (Dutch unilateral DUV controls — MATCH Act would mandate further alignment); filed 2025-12-12-us-pax-silica-initiative (non-binding multilateral cooperation — MATCH Act is the binding-legislation complement). If passed, would become the first US law explicitly requiring allied-country export-control harmonisation on semiconductor equipment. Severity 4 expected if enacted.
Reference-class base rate
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — a base rate for comparable bills, not a forecast for this one. source ↗
▲Bipartisan lead sponsors incl. Senate leadership (strong) — S.4281 introduced by Risch (R-ID, SFRC Chair), Ricketts (R-NE), Kim (D-NJ) and Schumer (D-NY, Minority Leader) — cross-party and leadership-level backing raises floor-time odds.source ↗
▲Bicameral — House companion exists (H.R.8170) (moderate) — Rep. Baumgartner (R-WA) introduced the House companion Apr 2, 2026; a live measure in both chambers is further along than a single-chamber bill.source ↗
🇨🇳 China unpublished 50% domestic-equipment local-content mandate for new/expanded semiconductor fabs
announced→low likelihood·flagged 94d ago · not yet law
If passed — Reuters (exclusive, multiple sources) reported 31 Dec 2025 that Chinese authorities have been requiring domestic chipmakers to source at least 50% of equipment spend from Chinese toolmakers when applying for approval to build or expand fab capacity — enforced administratively (approval rejected if the threshold isn't met) rather than via any published law or ministry order; strictest on mature-node lines, with temporary carve-outs for advanced-node lithography where local tools don't yet exist; officials reportedly want the floor higher over time, with a stated long-run goal of 100% domestic tooling. Directly squeezes foreign equipment suppliers (Lam Research, Applied Materials, Tokyo Electron, ASML) out of incremental Chinese fab capacity and is already lifting order books at domestic tool makers Naura Technology and AMEC (Naura H1 2025 revenue +30% YoY to RMB16bn; AMEC +44% YoY to RMB5bn). GTA logged this as a state act (state-act/95890) but provides no primary source; no MIIT/NDRC/MOFCOM document, gazette notice, or on-the-record government confirmation has surfaced in any outlet reviewed.
Caveat — Charter §6 verify-or-don't-file: GTA state-act/95890 provides zero primary source (page states only "reportedly mandated," no gov link, no gazette reference) and exhaustive web search (Reuters exclusive + 7 corroborating outlets: Modern Diplomacy, IBS Electronics, ExportComplianceDaily, Seeking Alpha, Stocktwits, Hawaii Tribune-Herald) confirms this is deliberately UNPUBLISHED administrative practice (enforced via approval-rejection, not a public instrument) rather than a not-yet-enacted proposal — it is arguably already in force but structurally opaque, so it does not fit filing. md's primary-source bar. Flagging as upcoming/announced rather than rejecting: multiple independent, well-sourced outlets corroborate a specific, falsifiable mechanism (50% threshold, mature-node-strict/advanced-node-exempt split, approval-rejection enforcement) with observable market effects (Naura/AMEC revenue growth) — this is credible policy, not speculation; likelihood HIGH reflects that the practice already appears to be in effect, with the open question being whether/when a public document ever surfaces to cross the register's verification bar. If no primary source ever emerges, this may need a standing "policy tracked, never promotable" annotation rather than eventual promotion — flag for a future strategy wake. Distinct from all filed CN semiconductor entries (export-control/entity-list actions on the inbound side); this is an outbound-directed, tooling-localisation industrial-policy instrument. Severity 3-4 expected if a primary document surfaces (broad fab-capex-shaping local-content rule); severity_basis would be quant (explicit 50% floor).
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.
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.
▲Organized industry coalition support (weak) — AI Policy Network led a coalition letter backing the MATCH Act — organized outside support, though narrow.source ↗
▼Senate side still in committee (Banking) (moderate) — S.4281 was read twice and referred to Senate Banking, Housing & Urban Affairs; no Senate committee markup or floor calendaring reported as of Jul 2026.source ↗
▼Executive-branch resistance (Commerce) (moderate) — The bill strips DoC discretionary licensing authority; Commerce has been resistant to losing that discretion, and State/USTR may prefer diplomatic alignment (Pax Silica) over binding legislation.source ↗
Sourced OSINT observations, not a forecast — a qualitative second read beside the stage-derived band. We do not publish a passage probability of our own until the accrual record proves it is calibrated (never a fabricated %).