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1 critical material scored · binding chokepoint: Helium (🇺🇸 US 43% of mining) · 3 restrictive government measures on record
Linde plc produces 1 of the 1 scored material above (Helium). 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 Low · 37/100 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 2026-10-06) — 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 Helium — 🇺🇸 US controls 43% of global mining. On this company's production footprint that scores 37/100 (footprint-hedged; global 49). The register holds 3 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Helium Linde plc is the 50th-most-exposed of the 59 named companies we track on 🇺🇸 US's Helium chokepoint; the most-exposed is JSC Angstrem (56/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Company supply-risk index 37/100 — 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 (US 49% · DE 14% · CN 11% · BR 8% · AU 7% · GB 7% · IN 4%, estimated split — no cited source states these exact shares, covering 72% of stated output — shares are renormalised across that portion, so the remaining 28% is unmodelled), 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: Hydrogen, Neon, Krypton, Xenon, Argon, Nitrogen, Oxygen, Natural-gas, Co2, Nf3, Wf6 — no supply-risk series is tracked for these here.
Linde is the world's largest industrial-gas company by revenue (~USD 33bn FY24), formed by the 2018 merger of Linde AG (Munich) and Praxair (Danbury CT) into an Ireland-domiciled plc with primary Nasdaq listing. The business runs on three structural pillars: (1) on-site / pipeline gases — large take-or-pay contracts (typically 15-20 years) supplying oxygen, nitrogen, hydrogen, argon and CO₂ to steel mills, refineries, chemical Verbund sites, and increasingly semiconductor fabs through dedicated air-separation units (ASUs) or merchant pipelines; (2) merchant and packaged gases — bulk liquid and cylinder distribution to general industrial customers; (3) electronics and specialty gases — ultra-high-purity gases (N₂, O₂, Ar, He, NF₃, WF₆, neon, krypton, xenon) supplying every leading-edge logic and memory fab including TSMC Arizona, Samsung Taylor, Intel Ohio One, Micron Boise, and the Magdeburg / Dresden European fab complex. Linde's two largest pipeline networks are the ~1000-mile Gulf Coast hydrogen / syngas system (Texas-Louisiana refining and ammonia corridor) and the Tees Valley / Rotterdam / Antwerp European industrial-gas backbone. The contract book is more bond-like than equity-cyclical — visible cash flows under take-or-pay clauses — and that is exactly why every state-aid / clean-industrial / hydrogen / chip-fab industrial-policy stack since 2022 has had to negotiate with Linde, Air Liquide, or Air Products as the three-firm gateway to industrial-gas supply.
Industrial gases are the chokepoint input that every major industrial-policy regime since 2022 has discovered it has to legislate around. Specific dependencies in priority order:
pipeline network. Currently ~100% grey/blue from SMR; eligibility under §45V (clean-H₂ PTC) versus §45Q (CCS credit) is the structural question. Linked: /minerals/hydrogen.
gas portfolio: pre-2022, Russia's Gazprom-Linde Amur GPP project was intended to be ~30% of world supply by 2025; the 2022 Russia exit cancelled it. Remaining supply now sources principally from Qatar (RasGas), Algeria (Sonatrach), and the US (Cliffside facility, sold to Messer by BLM, closed 2024-06-27). Linked: /minerals/helium.
semiconductor-grade neon was recovered as by-product from Ukrainian ASUs at Mariupol (Ingas) and Odessa (Cryoin), themselves bolted onto Soviet-legacy Mariupol/Zaporizhzhia steel works. The Mar-May 2022 destruction of those facilities permanently restructured the rare-gas supply chain. Linked: /minerals/rare-gases.
ASU electricity load; ammonia / methanol Verbund customers.
every §45Q / EU ETS CCUS-eligible project on the project pipeline.
chamber-cleaning and deposition gases without which no leading-edge fab can run.
| Action | Issuer | Type | Sev | Why it touches Linde |
|---|---|---|---|---|
| 2022-08-16 US Inflation Reduction Act | US | industrial-policy | 5 | §45V (clean-H₂ PTC, up to $3/kg) and §45Q (CCS up to $85/t) are the dual eligibility lanes structurally re-shaping Linde's Gulf Coast pipeline economics; §48E ITC for ASUs paired with electrolysers; §45X for cryogenic compression equipment. |
| 2025-01-10 US Treasury/IRS §45V Clean Hydrogen Final Rule | US | regulatory | 5 | Three-pillar test (incrementality, hourly time-matching, deliverability) defines which Linde projects qualify for the $3/kg PTC. Final-rule expressly cites Air Products and Linde as natural-gas infrastructure operators whose SMR-based merchant H₂ book is structurally outside §45V eligibility. |
| 2023-05-10 EU CBAM Regulation 2023/956 | EU | regulatory | 5 | CBAM scope (cement, steel, aluminium, fertilisers, electricity, hydrogen) captures Linde-supplied SMR hydrogen sold to importers of ammonia/urea precursors; CBAM-import certificate pricing makes EU-domestic green H₂ structurally competitive against grey imports for the first time. |
| 2026-01-01 EU CBAM Definitive Phase | EU | regulatory | 4 | The CBAM-certificate purchase obligation activates 2026-01-01; the rate at which Linde-on-site green-H₂ pipeline contracts get repriced upward is set by the CBAM-default-value schedule rather than by ETS spot. |
| 2024-05-23 EU CRMA entry into force | EU | industrial-policy | 4 | CRMA classifies helium as Strategic not Critical raw material — meaning CRMA strategic-projects funding pipeline does not flow to helium recovery facilities and the diversification mandate is asymmetric vs. lithium / REE / cobalt. |
| 2024-06-22 EU Net-Zero Industry Act | EU | industrial-policy | 3 | NZIA Annex strategic-technologies list includes electrolysers, CCUS, and grid components — Linde's Leuna 24 MW PEM electrolyser, Niagara Falls electrolyser, and Tees Valley CCS project all qualify. |
| 2025-02-26 EU Clean Industrial Deal | EU | industrial-policy | 4 | Clean Industrial Deal's IPCEI Hydrogen pipeline + Innovation Fund + Hydrogen Bank stack is the EU funding triangle that Linde-anchored projects (Hyport Duqm Oman with EU offtake, Leuna green-H₂, Niagara) need to win. |
| 2025-05-20 EU Hydrogen Bank Second Auction Results | EU | industrial-policy | 4 | EU Hydrogen Bank second-auction allocation flows to electrolyser project sponsors; Linde participates as both offtaker (Leuna) and engineering provider for winning projects. |
| 2023-07-26 Germany NWS Fortschreibung 2023 | DE | industrial-policy | 3 | German National Hydrogen Strategy 2023 update — Leuna-Schkopau cluster (Linde 24 MW PEM + planned 100 MW Leuna IV) sits inside the cluster-prioritised funding envelope. |
| 2025-09-18 Germany SVIKG Sondervermögen Infrastruktur Klimaneutralität | DE | industrial-policy | 5 | EUR 500bn SVIKG infrastructure / climate fund — hydrogen pipeline core grid (H₂-Kernnetz) build-out is a primary line item, with Linde / Air Liquide / Open Grid Europe as principal contractors for pipeline conversion and new-build segments. |
| 2025-07-08 EU Chemicals Industry Action Plan COM(2025) 530 | EU | industrial-policy | 3 | Chemicals Action Plan envelope for cracker steam-feedstock electrification and ammonia decarbonisation — Linde supplies the O₂ / N₂ / H₂ Verbund inputs and competes for the project EPC work. |
| 2025-11-10 EU FSR Phase II Conditional Approval ADNOC/Covestro | EU | regulatory | 3 | FSR conditional approval explicitly names Linde alongside BASF / Solvay / Evonik / Arkema as the European chemicals/industrial-gas oligopoly receiving a structural competitive lift from the FSR ADNOC-divestment behavioural commitments. |
| 2024-05-01 Oman Green Hydrogen Strategy / Hydrom Round 2 | OM | industrial-policy | 3 | Hyport Duqm consortium (OQ + Linde + Hydrom-anchor) is one of two named anchor projects in the Hydrom Round 2 award; Linde is the EPC and offtake anchor. |
| 2025-10-09 Romania HG 855 National Hydrogen Strategy | RO | industrial-policy | 3 | Strategy explicitly names Linde (LIN) among the international industrial-gas operators expected to anchor Romanian cluster projects. |
| 2025-04-10 France Stratégie Nationale Hydrogène (SNH) 2025 | FR | industrial-policy | 3 | SNH 2025 prioritises FR-domiciled electrolyser supply chain — Air Liquide is the French anchor; Linde competes from outside the SNH cap-table preference. |
| 2024-12-16 EU 15th Russia Sanctions Package (Reg 2024/3192) | EU | sanctions | 4 | Continued tightening of dual-use / industrial-equipment exports to Russia closes residual Linde-equipment carry-over channels (cryogenic, ASU controls). |
| 2025-07-18 EU 18th Russia Sanctions Package (Reg 2025/1494) | EU | sanctions | 4 | 18th package extends the LNG and ASU-component constraints, confirming Linde's 2022 EUR ~1bn write-down on Russia-Yamal LNG / Amur GPP turbo-compressor contracts will not reverse. |
| 2025-01-09 China MOFCOM TIB EU FSR Final Determination | CN | regulatory | 4 | TIB countermeasure to EU FSR — touches Linde Engineering's China project sales (Shanghai office, Hangzhou JV) and the rare-gas export channel from Chinese cryogenic ASUs that became substitute supply post-Mariupol. |
| 2026-02-01 India Semiconductor Mission 2.0 | IN | industrial-policy | 4 | Mission 2.0 explicitly names specialty gases among the materials targeted for localised supply; Linde's Indian JV (Linde India Ltd, BSE: 523457) is the structural beneficiary of any on-site-gas EPC at upcoming fabs (Tata-Powerchip Dholera, Micron Sanand). |
| 2024-11-05 Tanzania Mining Act Critical Minerals | TZ | regulatory | 3 | Tanzania designates helium as a critical mineral — Rukwa helium project (Helium One Global) downstream offtake is the structurally cleanest non-Qatar / non-Algeria new helium supply for the global industrial-gas oligopoly. |
| 2013-06-06 Germany AWG parent statute | DE | regulatory | 5 | §55-62 inward-screening perimeter applies to acquisitions of Linde German operating subsidiaries but not to Linde plc parent (IE-domiciled). The dual-perimeter asymmetry is structural — see Surface 1 below. |
trade associations (EIGA) for CRMA list amendment moving helium from Strategic to Critical so that strategic-projects funding can flow to recovery capacity. Status: Commission has acknowledged the petition; no draft amendment scheduled within the 2026 CRMA review window.
rulemaking is open to reconsideration after the Final Rule's three-pillar test was published Jan 2025; the merchant-H₂ industry (Air Products, Linde) has lobbied for relaxation of the hourly-time-matching pillar.
projects (Leuna IV, Niagara, Hyport Duqm) are candidates.
signalled that the three-firm structure of the global industrial-gas market (Linde / Air Liquide / Air Products) is on the watch list for cluster-pricing review post-2026.
Within Linde's own portfolio, the dual-perimeter Ireland / US domicile gives the unusual ability to claim both EU and US industrial-policy eligibility simultaneously on different projects. Substitution from the customer side is structurally weak — switching costs on a take-or-pay ASU contract are 10-15 years of cash flow — so the competitive constraint is principally Air Liquide (FR-domiciled, NZIA-preferred for EU clusters) and Air Products (US-domiciled, deeper Saudi/NEOM hydrogen JV exposure). New entrants are essentially absent at the relevant scale; Messer (private, DE) is a distant fourth. The principal policy-vehicle stack Linde projects can combine: IRA §45V + §45Q + §48E (US); IPCEI Hydrogen + Hydrogen Bank + Innovation Fund + NZIA + CRMA (EU); SVIKG + KTF + NWS (Germany); PERTE VEC equivalents (Spain); Hydrom auctions (Oman); Mission 2.0 specialty-gas envelope (India).
Post-2023 (after Linde delisted from XETRA following the MSCI weight-cap conflict that prevented full-weight S&P 500 inclusion), the parent is an Ireland-domiciled plc with Nasdaq as its primary listing. Linde's German operating subsidiaries (Leuna, Schkopau, Pullach, Munich HQ office, ~5,000 DE employees) are owned through the IE holding, and the IE holding is owned by US- and rest-of-world-resident equity. This is more than a tax structure: it places Linde simultaneously inside the EU industrial-policy perimeter (the IE parent is EU-domiciled for NZIA "EU manufacturing-capacity" tests; the DE subsidiaries draw KTF / SVIKG / IPCEI / Hydrogen Bank funding as German legal entities) and inside the US industrial-policy perimeter (US LLC project SPVs claim IRA §45V / §45Q / §48E / §45X on a project-level test that ignores the IE parent). Air Liquide (FR-domiciled, Euronext Paris) cannot claim EU-OEM dispute-defence on US projects with comparable ease; Air Products (US-domiciled, NYSE) cannot anchor EU NZIA-preferred projects with comparable ease. This dual-perimeter optionality is also why the Germany AWG §55-62 inward-screening perimeter applies to a hypothetical acquirer of Linde's German operating subsidiaries but not to a hypothetical acquirer of Linde plc itself — the controlling entity is EU-domiciled. The same structure has no analogue among the comparables; sell-side equity research treats Linde / Air Liquide / Air Products as substitutable-multiples comps, missing the structural premium that the dual-perimeter arbitrage warrants.
Pre-invasion, ~50% of world semiconductor-grade neon was recovered as by-product from Ukrainian ASUs at Cryoin (Odessa) and Ingas (Mariupol), themselves bolted onto Soviet-legacy Mariupol/Zaporizhzhia steel-plant air-separation infrastructure. The Mar-May 2022 destruction of those facilities, plus the prolonged occupation of Mariupol and the Zaporizhzhia front line, eliminated that supply for the foreseeable physical horizon. The chip-fab supply chain rerouted first to Chinese cryogenic ASUs — then exposed to MOFCOM's tightening rare-gas / dual-use export control regime through 2024-25 (2024-10-19-china-dual-use-export-control-regulations covers noble-gas residuals among other classes) — and then to Linde-and-Air-Liquide's own newly invested rare-gas recovery capacity at La Porte TX, Leuna DE and Le Blanc Mesnil FR. From 2023 onward, leading-edge fab take-or-pay gas contracts have carried rare-gas-indexed pricing clauses pricing the structural supply tightness directly into the contract book. The margin lift accrues fully to Linde and Air Liquide. Sell-side models that treat industrial-gas pricing as utility-like (formula-pass-through) miss this; the rare-gas line is a permanent structural margin uplift embedded in 15-20 year contract bodies signed 2023-2025 with TSMC AZ, Samsung Taylor, Intel Ohio One, Magdeburg, and Dresden as named counterparties.
Linde operates the largest US merchant H₂ pipeline network (~1000 miles on the Texas-Louisiana Gulf Coast). The Jan 2025 §45V Final Rule (2025-01-10-us-treasury-irs-45v-clean-hydrogen-final-rule) — three pillars: incrementality, hourly time-matching, deliverability — effectively excludes existing SMR-derived merchant H₂ from the $3/kg clean-H₂ PTC, and the rule's text explicitly names Air Products and Linde as the natural-gas infrastructure operators structurally outside §45V at the merchant-pipeline scale. The equity-research consensus reads this as a structural bear for the incumbent industrial gases. But §45Q (the carbon-sequestration credit at $85/tonne for permanent geological storage) applies to the same SMR units with bolt-on CCS. Linde's USD ~1.8bn Beaumont TX clean-H₂ + CCUS facility announced 2023 monetises the existing SMR book as §45Q rather than §45V. The sequencing matters: §45Q is the certain near-term credit (existing units retrofitted); §45V is the uncertain medium-term credit (new electrolyser plants dependent on hourly-grid-mix evolution and possible Republican- administration relaxation of the three-pillar test). The book of sell-side models treating §45V and §45Q as substitutes — must pick one — misses the structural sequencing in which the merchant pipeline becomes a §45Q cash flow first while the green-H₂ project queue (Leuna IV, Niagara, Hyport Duqm) builds toward §45V eligibility. The cross-axis is also load-bearing for the European side: Linde-supplied SMR hydrogen sold to ammonia/urea importers is the upstream input that CBAM phase-2 prices into the import certificate — making Linde-on-site EU green H₂ supply contracts structurally competitive against US-sourced grey-H₂ imports for the first time post-2026.
Pre-2022, Linde was the largest contractor to Russia's Amur GPP project (Gazprom partnership), with the helium-recovery phase intended to be commissioned 2024-26 at ~60 mcm/yr — roughly 30% of projected world supply. The Russia exit + Yamal/Amur cancellation removed that pipeline. Concurrently, the BLM Cliffside stockpile (the US strategic helium reserve) was sold to Messer, closing 2024-06-27, ending US federal strategic stewardship of the asset (BLM's winning bid was accepted January 2024; the sale itself closed June, not October, correcting this dossier's prior date). Global Linde helium supply now sources principally from RasGas (Qatar) and Sonatrach (Algeria), with Cliffside as a tail. The CRMA classifies helium as Strategic not Critical, meaning the CRMA strategic-projects funding pipeline does not flow to helium recovery facilities and the diversification mandate does not bite. Tanzania's 2024-11-05 Mining Act designating helium as critical opens a Rukwa-deposit (Helium One Global) supply channel that would partially relieve the Qatar/Algeria concentration — but the project is years from commercial offtake and the offtake-anchor decision is itself within the Linde / Air Liquide / Air Products oligopoly's gift. A Hormuz-disruption scenario — which the parallel 2026-iran-hormuz case study covers from the energy-trade side — would simultaneously choke ~70% of global merchant helium supply, with no policy instrument calibrated to address it because the CRMA review window treats the supply problem as "Strategic but not Critical." The gating risk for global MRI capacity, leading-edge semiconductor purge-gas supply, and aerospace pressure-purge gas is sitting in the policy-classification gap.
Refresh triggers: any change in §45V / §45Q rulemaking; any EU CRMA list amendment touching helium; any new Hydrogen Bank or IPCEI Hydrogen allocation naming Linde-anchored projects; any Hormuz / Qatar / Algeria supply disruption; any major fab on-site-gas contract announcement involving Linde. Default refresh cadence: quarterly review of action-table relevance; annual structural re-read.
representations to DG GROW (2024-25 cycle).
XETRA delisting (2023-03), Beaumont TX project announcement (2023-Q3), Hyport Duqm consortium award (2024-Q2).
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.
Linde builds/owns/operates on-site air-separation and specialty-gas plants supplying TSMC's Phoenix, Arizona fab complex under a long-term take-or-pay agreement. Linde's own 2021/2026 press releases on this deal (linde.com) describe the customer only generically ('one of the world's largest semiconductor manufacturers'); TSMC is named by trade press (Arizona Technology Council, gasworld) rather than by Linde itself, so treated as secondary rather than company-disclosure.
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.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Helium | 🇺🇸 US 43% mining | 37 | 49 | Low | — | High | none | 3 | ▬ stable |
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 |
|---|---|---|---|---|---|---|
| Helium | 3 | 2 | 3 | 5 | 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:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Helium — 🇺🇸 US escalates helium controls to a full export-licensing / ban regime | 37 | 44 | +7 |
| Concentration | Helium — 🇺🇸 US becomes the single source for helium — the second source is lost (full 43%+ monopoly) | 37 | 52 | +15 |
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.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Linde plc 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, 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.
Every scored material here is one Linde plc 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.
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 | 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 | industrial-gases (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 2025-04-23; 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.