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2 critical materials scored · binding chokepoint: Neodymium (🇨🇳 CN 85% of refining) · 56 restrictive government measures on record
Luossavaara-Kiirunavaara AB (LKAB) produces 2 of the 2 scored materials above (Neodymium, Phosphate). 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 High · 83/100 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 Neodymium — 🇨🇳 CN controls 85% of global refining. On this company's production footprint that scores 86/100 (adversarial chokepoint; global 72). The register holds 56 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Neodymium Luossavaara-Kiirunavaara AB (LKAB) is the 116th-most-exposed of the 519 named companies we track on 🇨🇳 CN's Neodymium chokepoint; the most-exposed is Alta Resource Technologies (86/100). 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 83/100 — 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 (SE 100%, 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.
Also listed in the dossier but not platform-scored: Iron-ore — no supply-risk series is tracked for it here.
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.
Wholly state-owned Swedish iron-ore miner — three northern-Sweden underground complexes (Kiruna, Malmberget/Gällivare, Svappavaara), DR-grade fluxed magnetite pellet specialist (the EU steel-decarbonisation feedstock). Two structurally distinct forward-leg projects: Per Geijer (Europe's largest known REE deposit, 10-15 year timeline) and ReeMAP / Luleå Circular Industrial Park (REE + phosphorus + fluorine recovery from existing apatite by-product, demo facility operational autumn 2026 — CRMA Strategic Project).
Binding thesis. Material-direct exposure as upstream supplier of policy-blessed feedstock: DR-pellet thesis binds to EU steel-decarbonisation demand pull (CBAM + Clean Industrial Deal + Steel Action Plan + Safeguard); REE/P/F thesis binds to EU CRMA Article-7 fast-track permitting (already secured for ReeMAP via Strategic Project designation) and Sweden's Minerals Act SFS 2024:325 Natura 2000 decoupling (designed-for-LKAB carve-out per the action's own text).
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.
LKAB's own press release states LKAB and SSAB 'have significant business relationships and conduct strategic development projects together, including HYBRIT'; SSAB is also Sweden's dominant DR/BF-grade steelmaker and the obvious domestic destination for LKAB pellet output per the dossier body's customer list. Flagged related_party: LKAB is also SSAB's largest shareholder (16.0% of votes, 10.5% of capital, per the release dated 2021-06-07 -- this is the newest LKAB-side figure found, not a confirmed current holding) -- a governance-relevant overlap between customer and owner roles, not just a supply relationship. Re-checked 2026-09-23 (wake-minerals-buyers, step 0.5): source_url still live and both quoted claims (the HYBRIT business-relationship sentence and the 16.0%/10.5% holding) verbatim; earlier LKAB releases (2019-12-23: 5.1%; 2020-02-28: 10.5%) show the stake path but nothing later than 2021-06-07 surfaced, and SSAB's shareholder table is JS-rendered and could not be read -- so the related_party flag stands but the current percentage is unconfirmed.
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 1 of your scored CRMA-strategic material 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 |
|---|---|---|---|---|---|---|---|---|---|
| Neodymium | 🇨🇳 CN 85% refining | 86 | 72 | Critical | EXCEEDS 85% | — | some | 50 | ▲ rising |
| Phosphate | 🇨🇳 CN 38% refining | 69 | 59 | Elevated | — | — | none | 10 | ▲ 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 |
|---|---|---|---|---|---|---|
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Phosphate | 4 | 2 | 3 | 5 | 4 | 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.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 41 more in the register.
An analyst traced these register actions to a specific, named effect on this company — date and severity below are read live from the register, not hand-typed.
Action's own summary text explicitly names "LKAB Per Geijer" as the policy-trigger case. The Natura 2000 decoupling removes the largest sequencing bottleneck for Per Geijer's exploitation-concession application. Direct industrial-policy carve-out for one company's pipeline.
CORRECTED 2026-09-23 — this action designated THREE LKAB projects as EU CRMA Strategic Projects, not one: the Malmberget/Gällivare mine (REE + phosphorus extraction from existing iron-ore operations), the Luleå industrial park (ReeMAP refining hub), AND the Per Geijer deposit in Kiruna itself (LKAB press release, 25 March 2025: \"LKAB's future initiatives designated as Strategic Projects by the EU\"). This dossier previously stated Per Geijer designation was a separate, not-yet-submitted round-2 candidate — that was wrong; Per Geijer already holds Strategic Project status as of this action's date. Triggers Article 7 fast-track permitting (15-month statutory cap for processing projects), Article 16 priority financing access via the EIB/EBRD/CRMA-financing-subgroup track, and Swedish-state priority permitting. Strategic-project status was a precondition for the May 2026 Land and Environmental Court permit.
The Chinese export-licensing regime on HREE (Dy, Tb, Y, Sm) tightens the structural demand pull for non-China HREE supply. Per Geijer's HREE tail (the smaller, magnet-relevant fraction) gains direct strategic significance — but realised offtake economics depend on commercial-scale HREE separation, which is the REEtec partnership's technical bet, not LKAB's.
Structural China-REE export-control architecture (entered into force 1 Oct 2024). Sets the policy backdrop for EU CRMA-led project pipelines; LKAB Per Geijer is one of the named EU diversification options in EU/Commission rhetoric.
Customer-side demand support for EU fossil-free steel (SSAB / ArcelorMittal Hamburg DR / Voestalpine etc.). LKAB is the implicit upstream beneficiary as DR-pellet supplier. Action plan's "lead-market" and CBAM-architecture extensions raise downstream willingness-to-pay for green-DR feedstock.
Iron and steel are CBAM Annex I goods. LKAB's hydroelectric-powered Swedish pellet production carries a structurally low-carbon footprint vs. coal-routed competitors; CBAM tilts EU-bound steel customers toward Swedish pellet feed.
Protects EU-resident steel customers (SSAB, ArcelorMittal Europe, etc.) — LKAB's pellet offtake demand is downstream of this protection.
Same customer-side protection mechanism as above.
Lead Market demand-pull instruments (mandatory low-carbon content quotas for steel in public procurement, automotive, construction) directly raise the EU-side willingness-to-pay for HYBRIT/SSAB/LKAB green-steel feedstock.
LKAB is 100% Swedish-state-owned so direct foreign-acquisition is not the binding case; relevant for any future minority-investor or JV-partner introduction at Per Geijer or ReeMAP, particularly the REEtec separation partnership and any future offtake-financing structures.
Competitive-pricing input on the global iron-ore-pellet market — Brazilian PNM 2050 architecture sets a 25-year frame for Vale's pellet capex.
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 🇨🇳 CN shock, your disclosed plant carries the binding Neodymium exposure:
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
The binding exposure this precedent lands on — Neodymium — is a material Luossavaara-Kiirunavaara AB (LKAB) produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-07) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 13 restrictive actions on Neodymium since 2024 — cadence accelerating (mean gap 103d → 29d), severity flat (3.8 → 3.4).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 2 of these 30 materials (Neodymium, Phosphate) — your binding Neodymium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 3.7 months apart across 6 distinct restriction dates since 2024 (n=5 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime | 86 | 88 | +2 |
| Concentration | Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly) | 86 | 92 | +6 |
| Policy | Phosphate — 🇨🇳 CN escalates phosphate controls to a full export-licensing / ban regime | 69 | 73 | +4 |
| Concentration | Phosphate — 🇨🇳 CN becomes the single source for phosphate — the second source is lost (full 38%+ monopoly) | 69 | 94 | +25 |
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 Luossavaara-Kiirunavaara AB (LKAB) 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 2 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.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
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.
Named, datable events on the binding chokepoint and adjacent regimes — each linked to its primary government / multilateral source.
Every scored material here is one Luossavaara-Kiirunavaara AB (LKAB) 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 2 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | iron-ore-mining (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 2026-09-30; 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 2026-10-07
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.