Geopolitical Supply-Risk Report·EU CRMA Art. 20–25 assessment · DRAFT·MacroLens · CiconiaLabs

Minera Exar S.A. (Cauchari-Olaroz)

1 critical material scored · binding chokepoint: Lithium (🇨🇳 CN 65% of refining) · 40 restrictive government measures on record

Subject

minera-exar · 🇦🇷 AR

Sector

mining-metals

Materials scored

As of

2026-08-06

Draft — not yet independently re-checked

This dossier's claims have not yet been independently re-checked against their cited sources. Treat every score, band and stress figure below as provisionalpending that re-check.

Risk Office verdict

Elevated · 61/100Not yet independently re-checkedCompany supply-risk index · consumer-side read

Role check · this company is a producer, not a buyer

Minera Exar S.A. (Cauchari-Olaroz) produces 1 of the 1 scored material above (Lithium). For those, a supply restriction by the controlling country is a tailwind, not a headwind — the exposure is to disruption of a market this company supplies, not to a chokepoint it depends on. Every scored material here sits on its output side, so the Elevated · 61/100 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 2026-10-05) — 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 Lithium — 🇨🇳 CN controls 65% of global refining. On this company's production footprint that scores 61/100 (neutral exposure; global 61). The register holds 40 restrictive government measures touching this company's materials — each traced to its primary source below.

Peer rank · Lithium Minera Exar S.A. (Cauchari-Olaroz) is the 383rd-most-exposed of the 491 named companies we track on 🇨🇳 CN's Lithium chokepoint; the most-exposed is Momentum Technologies (72/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.

Competitor cohort · mining metals

Minera Exar S.A. (Cauchari-Olaroz) ranks 236th of 445 verified mining metals companies, tied with 28 others at 61.

95🇺🇸 TdVibDysprosium
95🇦🇺 Northern Minerals LimitedDysprosium
93🇺🇸 Alta Resource TechnologiesDysprosium
93🇬🇧 Mkango Resources LimitedDysprosium
93🇨🇦 Defense Metals Corp.Dysprosium
93🇨🇦 Ucore Rare MetalsDysprosium
92🇺🇸 Phoenix TailingsDysprosium
91🇨🇦 Appia Rare Earths & Uranium Corp.Dysprosium
91🇦🇺 Arafura Rare Earths LimitedDysprosium
91🇦🇺 Hastings Technology Metals LimitedDysprosium
91🇦🇺 VHM LimitedDysprosium
91🇦🇺 Vital Metals LtdDysprosium
90🇨🇦 NioCorp DevelopmentsDysprosium
90🇺🇸 Energy Fuels Inc.Dysprosium
61🇦🇷 Minera Exar S.A. (Cauchari-Olaroz)Lithium

Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 127 further mining metals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.

Company supply-risk index 61/100 — 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 (AR 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.

Disclosed production sites

AR · Cauchari-Olaroz (Salares de Cauchari and Olaroz, Jujuy Province) — technical- and battery-grade lithium carbonate from brine, via conventional evaporation pondslithium

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.

Minera Exar S.A. (Cauchari-Olaroz)

> The exposure report this dossier powers is at > /intelligence/dossiers/minera-exar/report.

What they do

Minera Exar S.A. is the Argentine operating company for Cauchari-Olaroz, a lithium brine operation on the Cauchari and Olaroz salares in Jujuy Province. It is a single-asset, single-product producer: brine is pumped from the salar, concentrated through conventional solar evaporation ponds, and processed into technical- and battery-grade lithium carbonate using a process optimised for the salar with Ganfeng. Phase 1 nameplate capacity is 40,000 t/y of lithium carbonate; first production was in mid-2023, output exceeded 25,000 t in 2024, and a Stage 2 expansion of a further 45,000 t/y LCE is being advanced.

Ownership is a three-way joint venture with no majority holder: as of 30 June 2026, Ganfeng Lithium held 46.7%, Lithium Argentina AG 44.8%, and JEMSE — the Jujuy provincial state mining company — 8.5%.

Critical-material exposure

Minera Exar is an upstream producer, so its position in the lithium supply chain is a supply position rather than a consumption dependency. The exposure below should be read that way: policy measures touching lithium act on what this company sells, not on what it must buy.

Lithium — the product itself, not an input. Lithium carbonate is

Minera Exar's only output, and Cauchari-Olaroz its only asset, so the company has no product diversification to absorb a lithium-specific measure. Its relevance to the register is concentration on the sell side: it is one of the larger single brine operations in the Argentine "lithium triangle", it sits in a jurisdiction whose provincial governments hold direct equity in the licence (JEMSE's 8.5%), and its largest single shareholder and process-technology partner is Chinese — so export-control, ownership-screening and offtake-restriction measures aimed at China-linked upstream lithium positions land on this entity directly.

Dropped from the sector default: cobalt, copper, chromium, manganese, nickel, aluminium, niobium and vanadium. These were the mining-metals sector bill-of-materials guesses; none is supported for this company. Cauchari-Olaroz is a brine operation, not a polymetallic hard-rock mine — it neither produces nor depends on any of them, and no primary source attributes any of them to Minera Exar.

Not asserted: Andean lithium brines are potassium-bearing and a potassium-chloride by-product is common in this operation class, but no Minera Exar or shareholder disclosure located this pass states that Cauchari-Olaroz actually produces or sells one, so potash is deliberately not listed. The processing reagents a brine plant consumes (soda ash, lime) are not scored materials in this register.

Sources

Lithium Argentina AG — Form 20-F, FY2024 (SEC) — Minera Exar as the Cauchari-Olaroz operating entity, brine processing to battery-quality lithium carbonate, Stage 2 expansion
Lithium Argentina AG — Form 6-K, period ended 30 June 2026 (SEC) — 44.8% / 46.7% / 8.5% Lithium Argentina / Ganfeng / JEMSE ownership split
Cauchari-Olaroz Lithium Project, Jujuy province, Argentina — NS Energy — Phase 1 40,000 t/y nameplate, mid-2023 first production

The exposure register

Ranked by buyer-relative risk, highest first.

0 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
Lithium	🇨🇳 CN 65% refining	61	61	Elevated	within 65%	High	some	40	▲ 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 ↗

Supply-risk factor analysis

Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.

The factor-by-factor analysisShow

Material	Geopolitical	Concentration	Price / market	Substitutability	Import reliance	Logistics · ESG · Supplier
Lithium	4	3	5	3	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.

Material factors (scored 4–5) — evidence

Lithium
- 4Geopolitical: 40 restrictive actions, peak severity 5, 21 in last 24mo, less 3 liberalising actions
- 5Price / market: price up, as of 2026-09-01

Change log

last 30 days

Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.

No filings or amendments in this window — the register has been quiet on this company's materials.

The laws that threaten it

Restrictive government measures on this company's materials, newest first — each links to its primary government source.

The full list of lawsShow

🇺🇸 BIS DPAS Directive Allocation Order — 100% domestic-sale mandate for black mass and tungsten waste/scrap
2026-08-06· export-control· severity 4· lithium, cobalt, nickel, manganese
🇿🇦 South Africa: Industrial Development Strategy 2026 — Permit-Conditioned Beneficiation Mandate for Critical Minerals
2026-06-03· industrial-policy· severity 3· chrome, platinum-group-metals, cobalt, lithium
🇺🇸 US USTR Section 301 Forced Labor Findings and Proposed Action — 60 Economies
2026-06-02· tariff· severity 3· cotton, polysilicon, cobalt, lithium
🇨🇳 China Customs Tariff Commission — Zero-Tariff Treatment for All 53 African Diplomatic Partners (May 2026–April 2028)
2026-04-28· tariff· severity 3· cobalt, copper, bauxite, lithium
🇿🇼 Zimbabwe Cabinet approves Minerals Value Chain Framework
2026-04-15· industrial-policy· severity 2· lithium, chromite, platinum-group-metals, vanadium
🇲🇽 Mexico SCJN rules lithium nationalisation constitutional (Acción de Inconstitucionalidad 78/2022)
2026-03-24· regulatory· severity 3· lithium
🇿🇼 Zimbabwe Ministry of Mines suspends all raw-mineral and lithium-concentrate exports indefinitely
2026-02-25· export-control· severity 4· lithium, chrome, platinum-group-metals
🇬🇭 Ghana Minerals Commission revokes 300+ small-scale mining licences and launches sector-wide local content reform package
2026-02-18· regulatory· severity 3· gold, lithium, bauxite
🇪🇺 EU Council Regulation 2025/2605: revised autonomous tariff suspensions, including new 0% lines for battery-grade lithium, rare earths and cobalt inputs
2025-12-30· tariff· severity 2· lithium, rare-earths, cobalt
🇿🇼 Zimbabwe Finance Act No. 7 of 2025 — Three-Tier Lithium Beneficiation Tax and VAT Incentive Escalator
2025-12-29· industrial-policy· severity 2· lithium
🇧🇴 Bolivia DS 5503 — Economic/Financial/Energy/Social Emergency Declaration and Comprehensive Stabilization Package
2025-12-17· industrial-policy· severity 4· lithium
🇺🇸 US DOI / USGS Final 2025 List of Critical Minerals — 60-mineral statutory designation under the Energy Act of 2020
2025-11-06· regulatory· severity 3· copper, silicon, uranium, phosphate
🇺🇸 US-China Economic and Trade Arrangement (Busan Summit) — one-year mutual suspension of reciprocal tariff escalation, China rare-earth/critical-minerals export controls, and US affiliates rule; soybean and agricultural purchase commitments
2025-10-30· tariff· severity 5· rare-earth-elements, lithium-battery-materials, graphite, tungsten
🇨🇳 China MOFCOM + GAC Announcement No. 58 (2025) — Export Controls on High-Energy-Density Lithium Batteries, Artificial Graphite Anode Materials, and Production Equipment
2025-10-09· export-control· severity 2· lithium batteries, artificial graphite anode materials, lithium
🇦🇺 Australia Net Zero Plan 2050 and Six Sector Emissions Reduction Plans
2025-09-18· industrial-policy· severity 4· critical-minerals, hydrogen, lithium, cobalt

+ 25 more in the register.

Art. 24(2)(c) · vulnerability to disruption

Stress test — two plausible scenarios

The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:

Both stress-test scenariosShow

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).

Which of your plants carries the binding exposure

Under the 🇨🇳 CN shock, your disclosed plant carries the binding Lithium exposure:

🇦🇷 AR · Cauchari-Olaroz (Salares de Cauchari and Olaroz, Jujuy Province) — technical- and battery-grade lithium carbonate from brine, via conventional evaporation ponds

Disclosed plant-level detail matched to the binding material — descriptive, from the company's own disclosures; a plant not listed here is undisclosed, not unexposed. Country weights still drive the score above.

Closest real precedent — an output-market event, not a supply vulnerability

Indonesia hilirisasi ladder — battery-mineral extension

value-chain ladder (material-set)

Counterfactual: Indonesia extends the hilirisasi ore-ban template (2020 nickel → 2023 bauxite) to the next rung of battery-mineral exports — tightening upstream supply for cobalt intermediates, lithium feedstock and graphite alongside the existing nickel + aluminium regime. Direct-hit lines are basket issuers whose binding material is a battery-cell input (nickel, cobalt, lithium, graphite) — irrespective of controller, since the template-export is global supply-chain pressure not bilateral targeting.

The binding exposure this precedent lands on — Lithium — is a material Minera Exar S.A. (Cauchari-Olaroz) 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.

Trace the precedent to its primary source via the link above (/actions/2023-06-10-indonesia-bauxite-ore-export-ban). Producer/consumer side is taken from an explicit dossier role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-05) — for this company the basis is a disclosed dossier tag. It enters no score.

🇨🇳 CN has issued 6 restrictive actions on Lithium since 2021 — cadence accelerating (mean gap 339d → 306d), severity flat (3.3 → 2.7).A descriptive trajectory of past official actions — not a forecast.

🇨🇳 CN's demonstrated restriction sequence — has restricted 13 materials since 2021, in this demonstrated order:

Lithium (2021)Graphite (2023)Gallium (2025)Lithium carbonate (2025)Lithium hydroxide (2025)Cobalt (2026)Copper (2026)Aluminium (2026)Chromium (2026)Uranium (2026)Neodymium (2026)Iron-ore (2026)Platinum-palladium (2026)

You hold exposure to 1 of these 13 materials (Lithium) — your binding Lithium exposure is one of them.

Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 20.8 months apart across 4 distinct restriction dates since 2021 (n=3 intervals).

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	Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime	61	66	+5
Concentration	Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly)	61	80	+19

A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.

Art. 24(4) · mitigation trigger

Significant-vulnerability conclusion

No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Minera Exar S.A. (Cauchari-Olaroz) produces, and Art. 24 addresses the use of a strategic raw material as an input. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.

Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the 0 materials this company buys (the 1 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.

Proposed — not yet law

Upcoming regulatory threats

Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.

The upcoming threatsShow

🇨🇳 Zhejiang Huayou Cobalt — USD 210m acquisition of Atlantic Lithium Ltd (Ewoyaa Lithium Project, Ghana)
announced→low likelihood·flagged 26d ago · not yet law·matches Lithium
If passed — On 11 May 2026 Huayou Cobalt announced an all-cash agreement to acquire ASX/AIM-listed Atlantic Lithium for USD 210m, taking control of the Ewoyaa project (~1. 13Mt LCE JORC resource, ~110km from Takoradi port) whose mining lease Ghana's Parliament ratified in March 2026 (already filed as 2026-03-19-ghana-ewoyaa-lithium-mining-lease-ratification). This is a distinct instrument from that ratification — a change-of-control transaction giving a Chinese battery-materials producer direct upstream ownership of Ghana's first lithium mine, the same cn-outbound-mining-fdi pattern already tracked for CMOC/Zijin/Ganfeng (cf. the parked CMOC–Equinox Gold entry above). Deal awaits Atlantic Lithium shareholder vote scheduled November 2026; no MOFCOM/NDRC outbound-investment approval confirmed yet in reporting. Ghana has no China-outbound-FDI action filed to date, closing a first-coverage gap for a chokepoint-adjacent material (Ghana is a new, non-priority-tier lithium source; polarity is acquisition/control, not a host-country restriction).
Caveat — Definitive agreement signed, not yet closed — same board-approval/pre-MOFCOM stage as the parked CMOC-Equinox Gold entry above; distinct target (lithium, Ghana) and acquirer. Do not conflate with the already-filed Ghana mining-lease ratification (host-government instrument, different actor).
https://www.huayou.com/Public/Uploads/uploadfile2/files/20260507/AnnouncementofHuayouCobaltonProposedAcquistionofSharesinAtlanticLithiumLimited.pdf
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Lithium🇨🇳 today 61→66+5
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 66d ago · not yet law·matches Lithium
If passed — On 10 July 2026 the African Development Bank Group, with the African Union Commission, the AfCFTA Secretariat and UNECA, convened African ministers of mining/energy/industry in Abidjan for the "Ministerial Forum on Critical Minerals Value Chain and Beneficiation: Pathways for African Transformation". The stated ambition is continental: move the bloc off raw-ore exports toward regional value chains and in-country processing, with reporting of a push to HARMONISE African mining legislation by end-2026 around a ban on unprocessed ore exports, alongside a headline mobilisation figure of ~USD 63bn for critical-minerals value-chain investment. Why this matters as axis-2 early warning rather than noise: the register already holds a dense cluster of INDIVIDUAL national instruments moving in exactly this direction — Zimbabwe's 2026-02-25 indefinite raw-mineral/lithium-concentrate export suspension, Guinea's 2026-06-19 raw-gold export ban + domestic-refining mandate, Gabon's announced 2029 crude-manganese export ban, Nigeria's RMRDC 30% value-addition bill, Indonesia-style downstreaming copied across the continent, and CEMAC's regional Common Mining Code (all already filed or queued). A binding AU/AfCFTA-level harmonisation instrument would convert that scattered set into a coordinated continental supply shock across cobalt, copper, bauxite, manganese and lithium simultaneously — which is a materially different exposure event from any single-country ban, because it removes the substitute-jurisdiction escape route that currently absorbs each national ban.
Caveat — DELIBERATELY likelihood=low, not moderate. com) is low-quality and was NOT relied on. AU-level harmonisation instruments historically take years and frequently stall at the model-law stage (cf. the known ecb-spf 400 pattern) to establish whether a formal Abidjan Declaration text exists and what it actually commits signatories to.
https://www.afdb.org/en/documents/high-level-ministerial-forum-critical-minerals-value-chain-and-beneficiation-pathways-african-transformation
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇱 Chile — outgoing Boric government's fast-tracked batch of 5 additional CEOL lithium salt flats (Ascotán, Quillagua Sur, Hilaricos, Piedra Parada, Agua Amarga) submitted to the Contraloría for toma de razón
awaiting-signature→high likelihood·flagged 83d ago · not yet law·matches Lithium
If passed — In March 2026 the outgoing Boric administration reportedly fast-tracked and submitted to the Contraloría General de la República (Chile's comptroller) a batch of ~5 further Contratos Especiales de Operación de Litio (CEOL) covering the Ascotán, Quillagua Sur, Hilaricos, Piedra Parada and Agua Amarga salares — extending the state-controlled-lithium footprint of the National Lithium Strategy (2023-04-20, filed) beyond the already-filed CEOLs (ENAMI Salares Altoandinos 2025-09-05, Codelco–Rio Tinto Maricunga 2026-02-12, CleanTech Laguna Verde 2026-03-10). Codelco separately moved on Ascotán brine assets in April 2026. Each CEOL, once it clears toma de razón and is decreed, gates who may extract lithium (a designated strategic substance in Chile, reserved to the state) at that salar and on what state-participation terms — incrementally re-pricing the Chilean (Andean lithium-triangle) chokepoint and locking in state operational control before the incoming government.
Caveat — floated), nor the exact toma-de-razón status per salar. Not speculative (named salares + submitting government + instrument type + March-2026 date are corroborated across two outlets, and the Ascotán move is independently reported), but below register-grade precision — hence parked here as an early-warning batch marker rather than filed. DISTINCT from all filed CL CEOL/lithium actions: 2023-04-20 National Lithium Strategy, 2025-09-05 ENAMI Salares Altoandinos CEOL, 2025-12-27 NovaAndino Codelco–SQM JV, 2026-01-27 National Critical Minerals Strategy, 2026-02-12 Maricunga CEOL definitivo, 2026-03-10 Laguna Verde CEOL. A future wake/GTA will likely catch each of the five as it is formally decreed — resolve this batch marker salar-by-salar as they promote.
https://www.riotimesonline.com/chile-lithium-2026-guide/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Lithium
If passed — Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
Caveat — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
https://www.madini.go.tz/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Lithium
If passed — First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2447259
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Lithium
If passed — Second wave of CRMA Art. 14 strategic projects (drawn from 160+ applications: 95 EU-domestic + 66 third-country including 40 from strategic-partnership countries) gains fast-track permitting (27-month EU cap, 15-month Member State cap), EIB/EBRD financing-hub priority, and off-taker certainty; 75 battery-value-chain projects + 21 REE-for-permanent-magnets in pool; widens the EU's 2030 extraction/processing benchmarks pipeline beyond the first 60 projects
Caveat — Second call for applications closed January 15, 2026 (September 2025 launch). Commission stated ~4-month assessment period → designation expected May–June 2026. As of 2026-06-15, no Commission press release or OJ publication confirmed. EUR-Lex CELEX 32026D0923 verified via web search to be an unrelated EU animal-disease implementing decision. Moved from filing. md 2026-06-15. Distinct from: 2025-03-25-eu-crma-strategic-projects-first-designation (60 projects, first round) and 2024-05-23-eu-crma-entry-into-force (base regulation). Severity 3 expected (same as first-round designation).
https://single-market-economy.ec.europa.eu/news/strategic-projects-critical-raw-materials-gain-momentum-second-selection-round-potential-funding-and-2026-01-19_en
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 113d ago · not yet law·matches Lithium
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
https://www.mining.com/web/congo-adds-lithium-to-strategic-minerals-in-higher-tax-bracket
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇳🇦 Namibia new Minerals Bill (Minerals Prospecting and Mining Act overhaul)
in-consultation→moderate likelihood·flagged 113d ago · not yet law·matches Lithium
If passed — 10% free-carried state equity in ALL new mining and energy projects (no-cost government stake via Epangelo Mining); consultations on 51% Namibian ownership in new mining ventures; maximum royalty rate rise from 5% to potentially 10% for strategic minerals; introduction of profit-based windfall-tax mechanism; tighter local-content and environmental obligations; affects Uranium One/NamCor (uranium), Osino Resources, B2Gold, and lithium juniors in Namibia
Caveat — Reforms the 1992 Minerals (Prospecting and Mining) Act — the foundational mining law since independence. MME announced that Government is also consulting on mechanisms to promote 51% Namibian ownership in new ventures (more aggressive than the 10% headline). The Extractor Magazine (July 17, 2025) and Veridicor (Sep 16, 2025) also confirm reform scope. Distinct from already-filed NA actions: 2023-06-06 Cabinet export ban on unprocessed critical minerals; 2024-12-04 National Upstream Petroleum Local Content Policy; 2025-09-23 Nuclear Industry Strategy. The 2025 Nuclear Strategy covers uranium value-chain capture but not the broader Minerals Act reform. Namibia is the 3rd-largest uranium producer globally (Rössing, Husab) and an emerging lithium jurisdiction.
https://www.cliffedekkerhofmeyr.com/en/news/publications/2025/Sectors/Mining-Minerals/mining-and-minerals-alert-2-september-developments-in-namibias-mining-law-underway
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches Lithium
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.
https://www.nationalaccordnewspaper.com/turning-point-for-nigeria-as-rmrdcs-30-value-addition-bill-nears-presidential-assent/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Lithium
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.
https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining Policy
passed-committee→elevated likelihood·flagged 110d ago · not yet law·matches Lithium
If passed — Cabinet-cleared bill to replace the 2006 Minerals and Mining Act, Act 703: raises mining royalties from current 3–5% range to 9–12% (price-linked sliding scale), introduces a new medium-scale mining licence category bridging artisanal and large-scale operations, mandates district-level community and traditional-authority consultation before applications reach national regulators, scraps unlimited concession renewals (currently indefinitely renewable), and strengthens Ghanaian ownership provisions; National Mining Policy approved by Cabinet simultaneously; affects Newmont (Ahafo/Akyem), AngloGold Ashanti, Kinross (Chirano), Gold Fields (Tarkwa, post-Damang reversion), and Atlantic Lithium (Ewoyaa lithium project); royalty more than doubles at current gold prices — material cost increase for large-scale operators
Caveat — Distinct from all 6 filed GH actions: distinct from 2025-12-19-ghana-minerals-mining-royalty-regulations-2025 (those set sliding royalty under existing Act 703 — this bill replaces Act 703 entirely and raises the ceiling well beyond current regulations); distinct from 2026-03-13-ghana-growth-sustainability-levy-amendment (profit-based tax, not royalty); distinct from 2026-03-19-ghana-atlantic-lithium-ewoyaa-mining-lease and 2026-04-07-ghana-damang-engineers-planners-lease (specific lease grants, not legislation). The Green Minerals Policy (cabinet-approved July 2023, banning raw mineral exports) has not been separately enacted as of June 2026 — if the new Mining Act incorporates its provisions, that becomes the first statutory export restriction for Ghana's lithium and critical minerals. Filed upcoming 2026-06-17.
https://gna.org.gh/2026/06/govt-hints-scrapping-unlimited-years-of-mining-concession-renewals/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Lithium🇨🇳 today 61→66+5
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 110d ago · not yet law·matches Lithium
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.
https://www.mineria.gob.bo/index.php/nota_prensa/bolivia-activa-reforma-minera-integral-y-sale-a-captar-inversiones-con-respaldo-del-banco-mundial/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Lithium
If passed — Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
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 ↗
https://ustr.gov/about/policy-offices/press-office/press-releases/2026/february/ustr-seeks-public-comment-design-plurilateral-agreement-trade-critical-minerals-and-policy-actions
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 101d ago · not yet law·matches Lithium
If passed — Ministry of Mines issued operational guidelines for the Mining Sector Reforms component under Scheme for Special Assistance to States for Capital Investment (SASCI) FY2026-27, with total ₹5,000 crore (~USD 600M) incentive envelope to states; key components: (i) ₹250 crore one-time incentive to any state where ≥10% of pre-March-2026 auctioned major mineral blocks begin production+dispatch by end-2026; (ii) ₹100 crore baseline for systemic reforms (Unified Mining Portal integration, Pre-Auction Committees); (iii) ₹20 crore per block auctioned with pre-embedded forest and environmental clearances; scheme targets removing the "auction gap" — India has auctioned hundreds of mineral blocks since 2015 MMDR amendments but operationalisation lag remains a structural bottleneck; critical minerals relevance: India is running parallel programme of critical+strategic mineral auctions (7 tranches, 56 blocks auctioned by June 24, 2026) and this scheme incentivises states to bring those blocks into production faster; directly accelerates lithium (Rajasthan), REE (Andhra Pradesh, Tamil Nadu), graphite (Odisha), and nickel (Odisha, Jharkhand) pipelines
Caveat — Source is secondary (PolicyEdge news aggregator). To migrate to filing. md, filer must verify the primary notification on mines. gov. in or pib. gov. in (search "SASCI Mining 2026-27" on PIB search). India BHAVYA industrial parks scheme (₹33,660 crore, March 18, 2026) is separately filed — SASCI is a distinct scheme targeting state-level mining-sector governance reform. Distinct from filed India Union Budget 2026-27 Customs notifications and Semiconductor Mission 2. 0. Severity 2 (supply-side demand-unlock rather than export control or FDI gate).
https://www.policyedge.in/p/centre-launches-5000-crore-incentive-scheme-to-speed-up-mine-auctions-and-production
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Lithium🇨🇳 today 61→66+5
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 100d ago · not yet law·matches Lithium
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
https://mono.mn/n/government_approves_draft
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇳 Zhejiang Huayou Cobalt — US$210M acquisition of Atlantic Lithium (control of the Ewoyaa lithium project, Ghana) via Australian scheme of arrangement
awaiting-signature→high likelihood·flagged 99d ago · not yet law·matches Lithium
If passed — Chinese battery-materials major Zhejiang Huayou Cobalt (603799. SH) signed a BINDING Scheme Implementation Deed (7 May 2026) to acquire 100% of Atlantic Lithium Ltd (AIM/ASX: ALL) for ~US$210M all-cash (US$0. 25486/share; 26. 6% premium), gaining control of the Ewoyaa lithium project — Ghana's first parliament-ratified lithium mine (Central Region, 15-yr lease ratified Mar 2026). The Atlantic Lithium board unanimously recommends; largest holder Assore (~26. 4%) supports; deed has no financing/DD conditions. This is a Chinese-SOE-adjacent capture of a West-African hard-rock lithium chokepoint that had been positioned as a NON-China / Western-aligned supply source (Atlantic Lithium previously had US DFC / Piedmont offtake-JV ties), so the transaction re-prices Ewoyaa from a diversification asset into Chinese-controlled lithium supply — directly relevant to the cn-outbound-mining-fdi exposure series and to Ghana's local-ownership/beneficiation policy.
Caveat — As of 2026-06-28 the binding deed is signed but the deal is NOT consummated (shareholder vote Nov 2026, completion targeted Dec 2026, multiple regulatory approvals + Australian court order outstanding), hence awaiting-signature/upcoming not enacted. Likelihood ELEVATED: binding deed, unanimous board + 26. 4%-holder support, no financing/DD conditions — but Chinese-acquirer FIRB risk, MOFCOM outbound approval, and Ghanaian political resistance to foreign control of Ewoyaa's local-ownership model are real gates. Huayou has 0 records in the register. Severity 3 if completed.
https://www.londonstockexchange.com/news-article/ALL/binding-scheme-implementation-deed-with-huayou/17580344
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Lithium
If passed — RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Lithium🇨🇳 today 61→66+5
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 31d ago · not yet law·matches Lithium
If passed — Draft law amending Morocco's 2015 Mining Code (led by the Ministry of Energy Transition and Sustainable Development, Minister Leila Benali), with public consultations reported open since ~Feb 2025. Three structural changes: (1) a National Commission for Strategic and Critical Minerals empowered to designate an official list of "strategic and critical minerals" — Morocco's first formal legal mechanism to do so, which would sit upstream of and interact directly with the phosphate chokepoint (Morocco holds ~70% of world phosphate-rock reserves via OCP); (2) the digital mining cadastre (governance/transparency layer — this component has ALREADY gone live, launched 2026-04-07, and is queued separately to filing. md as an enacted action); (3) sharply increased penalties for illegal mining/prospecting (unauthorised prospecting: MAD 100k-1m; illegal extraction/transport/sale: up to MAD 2m). Morocco is chokepoint-tier and thinly covered (only 4 prior MA actions: 2022 Investment Charter, an AfDB agriculture loan, the 2026 Loi de Finances, and a Feb-2026 mining-tender notice — none creates a minerals-designation regime).
Caveat — distinct from the already-filed 2026-04-07 digital-cadastre launch (enacted, queued to filing. Dedup: no MA action in the index covers a strategic-minerals designation commission or mining-code amendment; the 3 other MA entries (Investment Charter 2022, Loi de Finances 2026, Feb-2026 mining tender) are distinct instruments.
https://fr.apanews.net/news/le-maroc-revise-son-code-minier-pour-stimuler-linvestissement/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇦 Canada — Attorney General Federal Court enforcement application vs. Gator Capital Ltd re: Investment Canada Act s.40 (first-ever ICA divestiture enforcement litigation)
announced→low likelihood·flagged 29d ago · not yet law·matches Lithium
If passed — On 11 Feb 2025 the Attorney General of Canada filed a Notice of Application (Federal Court file T-472-25) seeking a court order under ICA s. 40 directing Gator Capital Ltd to divest its ~20% stake in Lithium Chile Inc within 30 days to a trustee (subject to Minister approval of purchaser/terms), or alternatively to compel Gator to respond to outstanding information demands within 30 days; also seeks an injunction against Gator disposing of its shares and monetary penalties (up to C$10,000/day, potentially rising to C$50,000/day). This is the first time the Government of Canada has gone to court to enforce the ICA's national-security-review regime. Background: Chengze Lithium International Limited was ordered in Nov 2022 to divest its Lithium Chile stake (already in the register's ISED national-security-decisions record); Chengze sold to Gator in Feb 2023; the government's Notice of Application alleges it never confirmed Gator met the qualifications required of a divestiture buyer and that Gator (led by Wing Hong Chan, reportedly paid ~USD 34m for the 20% stake) has not complied with subsequent information demands (a "Third Demand" under a Sept 2024 FIRES administrative note). FDI-screening vs. Chinese-linked lithium/critical-minerals investment (thin action_type: investment-screening, ~71 filed). Severity 3-4 expected (first-ever court enforcement, direct critical-minerals/lithium chokepoint, but the underlying stake is a single ~20% minority position in one junior miner).
Caveat — Charter §6 verify-or-don't-file: ran 2 searches + fetched the ISED national-security-decisions page (only lists the Nov-2022 Chengze order, not this Feb-2025 enforcement application) + the ISED ICA Annual Report 2024-2025 (no mention) + probed the Federal Court's own file-search page (fct-cf. ca — no stable per-file docket URL exists; file search is a form/query tool, not a linkable record). Dedup: no existing CA action in filing. md/upcoming. md covers Gator Capital or this enforcement filing; the 2022 Chengze divestiture order itself does not appear to be in the register either (checked docs/iptm/actions/ for "gator"/"lithium chile"/"chengze" — no match), so a filer who later locates its primary source should consider filing that antecedent action too.
https://www.mccarthy.ca/en/insights/publications/canadian-government-initiates-investment-canada-act-enforcement-proceedings-national-security-matter
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)
in-consultation→moderate likelihood·flagged 26d ago · not yet law·matches Lithium
If passed — Minister of Mines, Petroleum and Energy Mamadou Sangafowa-Coulibaly formally launched the revision of Côte d'Ivoire's 2014 Mining Code on 13 June 2026, standing up an expert team drawn from his ministry, other state institutions and international bodies to rewrite Loi n° 2014-138 du 24 mars 2014. Stated goals: raise state revenue share, fix "disparate and sometimes poorly negotiated" mining conventions, and modernise the mining cadastre. No draft bill text published yet — this is a mandate/committee-formation stage, distinct from and earlier than the already-filed 2026-02-04 Assafou/Doropo gold-permit decrees and the 2025-12-03 PIRME minerals-energy policy (2025-2040), both of which operate under the CURRENT 2014 code rather than proposing to replace it. Chokepoint-relevant: register's only prior CI code-minier-lineage entries are the 2014 code itself and a 2022 local-content oil/gas law — no entry tracks this active rewrite.
Caveat — Dedup: checked action-index and both queues for "code minier"/"mining code" + CI — only hits are the already-filed 2014 code, the 2022 local-content petroleum law, and the 2024-12 gold-royalty finance law, none of which is this revision effort. Distinct from Senegal's and Morocco's already-queued mining-code amendments (different issuer/instrument).
https://www.energie.gouv.ci/actualite/sangafowa-coulibaly-veut-booster-lattractivite-du-code-minier
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇿 Czech Republic — €360M Government Grant for Cinovec Lithium Project (European Metals Holdings / CEZ JV)
awaiting-signature→high likelihood·flagged 16d ago · not yet law·matches Lithium
If passed — On 28-Nov-2025 European Metals Holdings announced the Czech government approved a grant of up to EUR 360M under the Ministry of Industry and Trade's "Strategic Investments for a Climate-Neutral Economy" programme for the Cinovec lithium/tin project (EU Critical Raw Materials Act strategic project, Czech-designated strategic deposit) — one of the largest single-project CRM grants in the EU. Award is government-approved in principle but "subject to completion of administrative processes, after which a formal grant decision would be issued" (final amount could be lower). Liberalising/supply-relief polarity: EU-domestic lithium capacity build, not a restriction. Genuine gap: CZ carries only 4 actions in the register, none touching lithium/CRMA-strategic-project funding — thin Central European coverage flagged in Step 0. 5. action_type: subsidy; yet assigned (CRMA-strategic-project funding). Primary-ish source: company RNS/ASX announcement — https://www. miningweekly. com/article/360m-grant-for-cinovec-lithium-project-2025-11-28; https://www. miragenews. gov. cz (Ministry of Industry and Trade) before filing — no MPO. gov.
Caveat — Dedup: checked "cinovec" and "czech. *lithium" across filing. md, upcoming. md, and action-index — zero hits, not previously queued.
https://www.miningweekly.com/article/360m-grant-for-cinovec-lithium-project-2025-11-28
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5

Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.

What to watch next

Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.

The watch listShow

Lithium is the line to war-game: 🇨🇳 CN already controls 65% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.

Art. 24(4) · diversification & substitution

Priority mitigations

Every scored material here is one Minera Exar S.A. (Cauchari-Olaroz) produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.

The mitigation optionsShow

Track demand-side substitution against your own book. The buyer levers listed for consumers of Lithium — qualifying alternative suppliers, designing the material out — are the demand risk to Minera Exar S.A. (Cauchari-Olaroz)'s revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by CN on a material Minera Exar S.A. (Cauchari-Olaroz) produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The material above is concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.

Annex A · regulatory basis

CRMA Art. 24 compliance crosswalk

Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).

The full crosswalkShow

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.

Why this dependence is structural, not transitional. The EU's own external auditor — the European Court of Auditors, Special Report “Critical raw materials for the energy transition — Not a rock-solid policy” (Feb 2026) — judges the bloc's 2030 extraction, processing and recycling targets to be out of reach (recycling runs 1–5% for 7 of 26 materials, and diversification shows no measurable effect). A separate industry-analyst assessment (Adamas Intelligence & Tradium, EU CRMA report, Apr 2024 — an interested-party commercial view, not an independent verdict) reaches a compatible conclusion that the 2030 rare-earth targets will be missed without an expedited push. The chokepoint this report maps is therefore a durable constraint the Act has not yet closed, not a gap that resolves on its own.

Annex B · Art. 24(1) · Art. 2(29)

Scope & applicability

Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.

Scope detailsShow

Threshold test	This assessment
Average employees (last FY) > 500	company input
Net worldwide turnover (last FY) > €150M	company input
Uses a strategic raw material as an input	company input — all 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology	mining-metals (confirm against Annex)
Formally identified by a Member State authority	company input

Evidence & sources

Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.

All sourcesShow

Methodology

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 2026-08-06; 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 2026-10-05

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.

← All companies

Geopolitical Supply-Risk Report·EU CRMA Art. 20–25 assessment · DRAFT·MacroLens · CiconiaLabs

Minera Exar S.A. (Cauchari-Olaroz)

1 critical material scored · binding chokepoint: Lithium (🇨🇳 CN 65% of refining) · 40 restrictive government measures on record

Subject

minera-exar · 🇦🇷 AR

Sector

mining-metals

Materials scored

As of

2026-08-06

Draft — not yet independently re-checked

This dossier's claims have not yet been independently re-checked against their cited sources. Treat every score, band and stress figure below as provisionalpending that re-check.

Risk Office verdict

Elevated · 61/100Not yet independently re-checkedCompany supply-risk index · consumer-side read

Role check · this company is a producer, not a buyer

Competitor cohort · mining metals

Minera Exar S.A. (Cauchari-Olaroz) ranks 236th of 445 verified mining metals companies, tied with 28 others at 61.

95🇺🇸 TdVibDysprosium
95🇦🇺 Northern Minerals LimitedDysprosium
93🇺🇸 Alta Resource TechnologiesDysprosium
93🇬🇧 Mkango Resources LimitedDysprosium
93🇨🇦 Defense Metals Corp.Dysprosium
93🇨🇦 Ucore Rare MetalsDysprosium
92🇺🇸 Phoenix TailingsDysprosium
91🇨🇦 Appia Rare Earths & Uranium Corp.Dysprosium
91🇦🇺 Arafura Rare Earths LimitedDysprosium
91🇦🇺 Hastings Technology Metals LimitedDysprosium
91🇦🇺 VHM LimitedDysprosium
91🇦🇺 Vital Metals LtdDysprosium
90🇨🇦 NioCorp DevelopmentsDysprosium
90🇺🇸 Energy Fuels Inc.Dysprosium
61🇦🇷 Minera Exar S.A. (Cauchari-Olaroz)Lithium

Disclosed production sites

AR · Cauchari-Olaroz (Salares de Cauchari and Olaroz, Jujuy Province) — technical- and battery-grade lithium carbonate from brine, via conventional evaporation pondslithium

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.

Minera Exar S.A. (Cauchari-Olaroz)

> The exposure report this dossier powers is at > /intelligence/dossiers/minera-exar/report.

What they do

Critical-material exposure

Lithium — the product itself, not an input. Lithium carbonate is

Sources

Lithium Argentina AG — Form 20-F, FY2024 (SEC) — Minera Exar as the Cauchari-Olaroz operating entity, brine processing to battery-quality lithium carbonate, Stage 2 expansion
Lithium Argentina AG — Form 6-K, period ended 30 June 2026 (SEC) — 44.8% / 46.7% / 8.5% Lithium Argentina / Ganfeng / JEMSE ownership split
Cauchari-Olaroz Lithium Project, Jujuy province, Argentina — NS Energy — Phase 1 40,000 t/y nameplate, mid-2023 first production

The exposure register

Ranked by buyer-relative risk, highest first.

0 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
Lithium	🇨🇳 CN 65% refining	61	61	Elevated	within 65%	High	some	40	▲ rising

Supply-risk factor analysis

The factor-by-factor analysisShow

Material	Geopolitical	Concentration	Price / market	Substitutability	Import reliance	Logistics · ESG · Supplier
Lithium	4	3	5	3	3	company input

Material factors (scored 4–5) — evidence

Lithium
- 4Geopolitical: 40 restrictive actions, peak severity 5, 21 in last 24mo, less 3 liberalising actions
- 5Price / market: price up, as of 2026-09-01

Change log

last 30 days

Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.

No filings or amendments in this window — the register has been quiet on this company's materials.

The laws that threaten it

Restrictive government measures on this company's materials, newest first — each links to its primary government source.

The full list of lawsShow

🇺🇸 BIS DPAS Directive Allocation Order — 100% domestic-sale mandate for black mass and tungsten waste/scrap
2026-08-06· export-control· severity 4· lithium, cobalt, nickel, manganese
🇿🇦 South Africa: Industrial Development Strategy 2026 — Permit-Conditioned Beneficiation Mandate for Critical Minerals
2026-06-03· industrial-policy· severity 3· chrome, platinum-group-metals, cobalt, lithium
🇺🇸 US USTR Section 301 Forced Labor Findings and Proposed Action — 60 Economies
2026-06-02· tariff· severity 3· cotton, polysilicon, cobalt, lithium
🇨🇳 China Customs Tariff Commission — Zero-Tariff Treatment for All 53 African Diplomatic Partners (May 2026–April 2028)
2026-04-28· tariff· severity 3· cobalt, copper, bauxite, lithium
🇿🇼 Zimbabwe Cabinet approves Minerals Value Chain Framework
2026-04-15· industrial-policy· severity 2· lithium, chromite, platinum-group-metals, vanadium
🇲🇽 Mexico SCJN rules lithium nationalisation constitutional (Acción de Inconstitucionalidad 78/2022)
2026-03-24· regulatory· severity 3· lithium
🇿🇼 Zimbabwe Ministry of Mines suspends all raw-mineral and lithium-concentrate exports indefinitely
2026-02-25· export-control· severity 4· lithium, chrome, platinum-group-metals
🇬🇭 Ghana Minerals Commission revokes 300+ small-scale mining licences and launches sector-wide local content reform package
2026-02-18· regulatory· severity 3· gold, lithium, bauxite
🇪🇺 EU Council Regulation 2025/2605: revised autonomous tariff suspensions, including new 0% lines for battery-grade lithium, rare earths and cobalt inputs
2025-12-30· tariff· severity 2· lithium, rare-earths, cobalt
🇿🇼 Zimbabwe Finance Act No. 7 of 2025 — Three-Tier Lithium Beneficiation Tax and VAT Incentive Escalator
2025-12-29· industrial-policy· severity 2· lithium
🇧🇴 Bolivia DS 5503 — Economic/Financial/Energy/Social Emergency Declaration and Comprehensive Stabilization Package
2025-12-17· industrial-policy· severity 4· lithium
🇺🇸 US DOI / USGS Final 2025 List of Critical Minerals — 60-mineral statutory designation under the Energy Act of 2020
2025-11-06· regulatory· severity 3· copper, silicon, uranium, phosphate
🇺🇸 US-China Economic and Trade Arrangement (Busan Summit) — one-year mutual suspension of reciprocal tariff escalation, China rare-earth/critical-minerals export controls, and US affiliates rule; soybean and agricultural purchase commitments
2025-10-30· tariff· severity 5· rare-earth-elements, lithium-battery-materials, graphite, tungsten
🇨🇳 China MOFCOM + GAC Announcement No. 58 (2025) — Export Controls on High-Energy-Density Lithium Batteries, Artificial Graphite Anode Materials, and Production Equipment
2025-10-09· export-control· severity 2· lithium batteries, artificial graphite anode materials, lithium
🇦🇺 Australia Net Zero Plan 2050 and Six Sector Emissions Reduction Plans
2025-09-18· industrial-policy· severity 4· critical-minerals, hydrogen, lithium, cobalt

+ 25 more in the register.

Art. 24(2)(c) · vulnerability to disruption

Stress test — two plausible scenarios

Both stress-test scenariosShow

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).

Which of your plants carries the binding exposure

Under the 🇨🇳 CN shock, your disclosed plant carries the binding Lithium exposure:

🇦🇷 AR · Cauchari-Olaroz (Salares de Cauchari and Olaroz, Jujuy Province) — technical- and battery-grade lithium carbonate from brine, via conventional evaporation ponds

Closest real precedent — an output-market event, not a supply vulnerability

Indonesia hilirisasi ladder — battery-mineral extension

value-chain ladder (material-set)

🇨🇳 CN's demonstrated restriction sequence — has restricted 13 materials since 2021, in this demonstrated order:

You hold exposure to 1 of these 13 materials (Lithium) — your binding Lithium exposure is one of them.

Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 20.8 months apart across 4 distinct restriction dates since 2021 (n=3 intervals).

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	Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime	61	66	+5
Concentration	Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly)	61	80	+19

Art. 24(4) · mitigation trigger

Significant-vulnerability conclusion

Proposed — not yet law

Upcoming regulatory threats

The upcoming threatsShow

🇨🇳 Zhejiang Huayou Cobalt — USD 210m acquisition of Atlantic Lithium Ltd (Ewoyaa Lithium Project, Ghana)
announced→low likelihood·flagged 26d ago · not yet law·matches Lithium
If passed — On 11 May 2026 Huayou Cobalt announced an all-cash agreement to acquire ASX/AIM-listed Atlantic Lithium for USD 210m, taking control of the Ewoyaa project (~1. 13Mt LCE JORC resource, ~110km from Takoradi port) whose mining lease Ghana's Parliament ratified in March 2026 (already filed as 2026-03-19-ghana-ewoyaa-lithium-mining-lease-ratification). This is a distinct instrument from that ratification — a change-of-control transaction giving a Chinese battery-materials producer direct upstream ownership of Ghana's first lithium mine, the same cn-outbound-mining-fdi pattern already tracked for CMOC/Zijin/Ganfeng (cf. the parked CMOC–Equinox Gold entry above). Deal awaits Atlantic Lithium shareholder vote scheduled November 2026; no MOFCOM/NDRC outbound-investment approval confirmed yet in reporting. Ghana has no China-outbound-FDI action filed to date, closing a first-coverage gap for a chokepoint-adjacent material (Ghana is a new, non-priority-tier lithium source; polarity is acquisition/control, not a host-country restriction).
Caveat — Definitive agreement signed, not yet closed — same board-approval/pre-MOFCOM stage as the parked CMOC-Equinox Gold entry above; distinct target (lithium, Ghana) and acquirer. Do not conflate with the already-filed Ghana mining-lease ratification (host-government instrument, different actor).
https://www.huayou.com/Public/Uploads/uploadfile2/files/20260507/AnnouncementofHuayouCobaltonProposedAcquistionofSharesinAtlanticLithiumLimited.pdf
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Lithium🇨🇳 today 61→66+5
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 66d ago · not yet law·matches Lithium
If passed — On 10 July 2026 the African Development Bank Group, with the African Union Commission, the AfCFTA Secretariat and UNECA, convened African ministers of mining/energy/industry in Abidjan for the "Ministerial Forum on Critical Minerals Value Chain and Beneficiation: Pathways for African Transformation". The stated ambition is continental: move the bloc off raw-ore exports toward regional value chains and in-country processing, with reporting of a push to HARMONISE African mining legislation by end-2026 around a ban on unprocessed ore exports, alongside a headline mobilisation figure of ~USD 63bn for critical-minerals value-chain investment. Why this matters as axis-2 early warning rather than noise: the register already holds a dense cluster of INDIVIDUAL national instruments moving in exactly this direction — Zimbabwe's 2026-02-25 indefinite raw-mineral/lithium-concentrate export suspension, Guinea's 2026-06-19 raw-gold export ban + domestic-refining mandate, Gabon's announced 2029 crude-manganese export ban, Nigeria's RMRDC 30% value-addition bill, Indonesia-style downstreaming copied across the continent, and CEMAC's regional Common Mining Code (all already filed or queued). A binding AU/AfCFTA-level harmonisation instrument would convert that scattered set into a coordinated continental supply shock across cobalt, copper, bauxite, manganese and lithium simultaneously — which is a materially different exposure event from any single-country ban, because it removes the substitute-jurisdiction escape route that currently absorbs each national ban.
Caveat — DELIBERATELY likelihood=low, not moderate. com) is low-quality and was NOT relied on. AU-level harmonisation instruments historically take years and frequently stall at the model-law stage (cf. the known ecb-spf 400 pattern) to establish whether a formal Abidjan Declaration text exists and what it actually commits signatories to.
https://www.afdb.org/en/documents/high-level-ministerial-forum-critical-minerals-value-chain-and-beneficiation-pathways-african-transformation
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇱 Chile — outgoing Boric government's fast-tracked batch of 5 additional CEOL lithium salt flats (Ascotán, Quillagua Sur, Hilaricos, Piedra Parada, Agua Amarga) submitted to the Contraloría for toma de razón
awaiting-signature→high likelihood·flagged 83d ago · not yet law·matches Lithium
If passed — In March 2026 the outgoing Boric administration reportedly fast-tracked and submitted to the Contraloría General de la República (Chile's comptroller) a batch of ~5 further Contratos Especiales de Operación de Litio (CEOL) covering the Ascotán, Quillagua Sur, Hilaricos, Piedra Parada and Agua Amarga salares — extending the state-controlled-lithium footprint of the National Lithium Strategy (2023-04-20, filed) beyond the already-filed CEOLs (ENAMI Salares Altoandinos 2025-09-05, Codelco–Rio Tinto Maricunga 2026-02-12, CleanTech Laguna Verde 2026-03-10). Codelco separately moved on Ascotán brine assets in April 2026. Each CEOL, once it clears toma de razón and is decreed, gates who may extract lithium (a designated strategic substance in Chile, reserved to the state) at that salar and on what state-participation terms — incrementally re-pricing the Chilean (Andean lithium-triangle) chokepoint and locking in state operational control before the incoming government.
Caveat — floated), nor the exact toma-de-razón status per salar. Not speculative (named salares + submitting government + instrument type + March-2026 date are corroborated across two outlets, and the Ascotán move is independently reported), but below register-grade precision — hence parked here as an early-warning batch marker rather than filed. DISTINCT from all filed CL CEOL/lithium actions: 2023-04-20 National Lithium Strategy, 2025-09-05 ENAMI Salares Altoandinos CEOL, 2025-12-27 NovaAndino Codelco–SQM JV, 2026-01-27 National Critical Minerals Strategy, 2026-02-12 Maricunga CEOL definitivo, 2026-03-10 Laguna Verde CEOL. A future wake/GTA will likely catch each of the five as it is formally decreed — resolve this batch marker salar-by-salar as they promote.
https://www.riotimesonline.com/chile-lithium-2026-guide/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Lithium
If passed — Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
Caveat — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
https://www.madini.go.tz/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Lithium
If passed — First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2447259
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Lithium
If passed — Second wave of CRMA Art. 14 strategic projects (drawn from 160+ applications: 95 EU-domestic + 66 third-country including 40 from strategic-partnership countries) gains fast-track permitting (27-month EU cap, 15-month Member State cap), EIB/EBRD financing-hub priority, and off-taker certainty; 75 battery-value-chain projects + 21 REE-for-permanent-magnets in pool; widens the EU's 2030 extraction/processing benchmarks pipeline beyond the first 60 projects
Caveat — Second call for applications closed January 15, 2026 (September 2025 launch). Commission stated ~4-month assessment period → designation expected May–June 2026. As of 2026-06-15, no Commission press release or OJ publication confirmed. EUR-Lex CELEX 32026D0923 verified via web search to be an unrelated EU animal-disease implementing decision. Moved from filing. md 2026-06-15. Distinct from: 2025-03-25-eu-crma-strategic-projects-first-designation (60 projects, first round) and 2024-05-23-eu-crma-entry-into-force (base regulation). Severity 3 expected (same as first-round designation).
https://single-market-economy.ec.europa.eu/news/strategic-projects-critical-raw-materials-gain-momentum-second-selection-round-potential-funding-and-2026-01-19_en
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 113d ago · not yet law·matches Lithium
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
https://www.mining.com/web/congo-adds-lithium-to-strategic-minerals-in-higher-tax-bracket
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇳🇦 Namibia new Minerals Bill (Minerals Prospecting and Mining Act overhaul)
in-consultation→moderate likelihood·flagged 113d ago · not yet law·matches Lithium
If passed — 10% free-carried state equity in ALL new mining and energy projects (no-cost government stake via Epangelo Mining); consultations on 51% Namibian ownership in new mining ventures; maximum royalty rate rise from 5% to potentially 10% for strategic minerals; introduction of profit-based windfall-tax mechanism; tighter local-content and environmental obligations; affects Uranium One/NamCor (uranium), Osino Resources, B2Gold, and lithium juniors in Namibia
Caveat — Reforms the 1992 Minerals (Prospecting and Mining) Act — the foundational mining law since independence. MME announced that Government is also consulting on mechanisms to promote 51% Namibian ownership in new ventures (more aggressive than the 10% headline). The Extractor Magazine (July 17, 2025) and Veridicor (Sep 16, 2025) also confirm reform scope. Distinct from already-filed NA actions: 2023-06-06 Cabinet export ban on unprocessed critical minerals; 2024-12-04 National Upstream Petroleum Local Content Policy; 2025-09-23 Nuclear Industry Strategy. The 2025 Nuclear Strategy covers uranium value-chain capture but not the broader Minerals Act reform. Namibia is the 3rd-largest uranium producer globally (Rössing, Husab) and an emerging lithium jurisdiction.
https://www.cliffedekkerhofmeyr.com/en/news/publications/2025/Sectors/Mining-Minerals/mining-and-minerals-alert-2-september-developments-in-namibias-mining-law-underway
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 113d ago · not yet law·matches Lithium
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.
https://www.nationalaccordnewspaper.com/turning-point-for-nigeria-as-rmrdcs-30-value-addition-bill-nears-presidential-assent/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Lithium
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.
https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining Policy
passed-committee→elevated likelihood·flagged 110d ago · not yet law·matches Lithium
If passed — Cabinet-cleared bill to replace the 2006 Minerals and Mining Act, Act 703: raises mining royalties from current 3–5% range to 9–12% (price-linked sliding scale), introduces a new medium-scale mining licence category bridging artisanal and large-scale operations, mandates district-level community and traditional-authority consultation before applications reach national regulators, scraps unlimited concession renewals (currently indefinitely renewable), and strengthens Ghanaian ownership provisions; National Mining Policy approved by Cabinet simultaneously; affects Newmont (Ahafo/Akyem), AngloGold Ashanti, Kinross (Chirano), Gold Fields (Tarkwa, post-Damang reversion), and Atlantic Lithium (Ewoyaa lithium project); royalty more than doubles at current gold prices — material cost increase for large-scale operators
Caveat — Distinct from all 6 filed GH actions: distinct from 2025-12-19-ghana-minerals-mining-royalty-regulations-2025 (those set sliding royalty under existing Act 703 — this bill replaces Act 703 entirely and raises the ceiling well beyond current regulations); distinct from 2026-03-13-ghana-growth-sustainability-levy-amendment (profit-based tax, not royalty); distinct from 2026-03-19-ghana-atlantic-lithium-ewoyaa-mining-lease and 2026-04-07-ghana-damang-engineers-planners-lease (specific lease grants, not legislation). The Green Minerals Policy (cabinet-approved July 2023, banning raw mineral exports) has not been separately enacted as of June 2026 — if the new Mining Act incorporates its provisions, that becomes the first statutory export restriction for Ghana's lithium and critical minerals. Filed upcoming 2026-06-17.
https://gna.org.gh/2026/06/govt-hints-scrapping-unlimited-years-of-mining-concession-renewals/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Lithium🇨🇳 today 61→66+5
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 110d ago · not yet law·matches Lithium
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.
https://www.mineria.gob.bo/index.php/nota_prensa/bolivia-activa-reforma-minera-integral-y-sale-a-captar-inversiones-con-respaldo-del-banco-mundial/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Lithium
If passed — Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
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 ↗
https://ustr.gov/about/policy-offices/press-office/press-releases/2026/february/ustr-seeks-public-comment-design-plurilateral-agreement-trade-critical-minerals-and-policy-actions
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 101d ago · not yet law·matches Lithium
If passed — Ministry of Mines issued operational guidelines for the Mining Sector Reforms component under Scheme for Special Assistance to States for Capital Investment (SASCI) FY2026-27, with total ₹5,000 crore (~USD 600M) incentive envelope to states; key components: (i) ₹250 crore one-time incentive to any state where ≥10% of pre-March-2026 auctioned major mineral blocks begin production+dispatch by end-2026; (ii) ₹100 crore baseline for systemic reforms (Unified Mining Portal integration, Pre-Auction Committees); (iii) ₹20 crore per block auctioned with pre-embedded forest and environmental clearances; scheme targets removing the "auction gap" — India has auctioned hundreds of mineral blocks since 2015 MMDR amendments but operationalisation lag remains a structural bottleneck; critical minerals relevance: India is running parallel programme of critical+strategic mineral auctions (7 tranches, 56 blocks auctioned by June 24, 2026) and this scheme incentivises states to bring those blocks into production faster; directly accelerates lithium (Rajasthan), REE (Andhra Pradesh, Tamil Nadu), graphite (Odisha), and nickel (Odisha, Jharkhand) pipelines
Caveat — Source is secondary (PolicyEdge news aggregator). To migrate to filing. md, filer must verify the primary notification on mines. gov. in or pib. gov. in (search "SASCI Mining 2026-27" on PIB search). India BHAVYA industrial parks scheme (₹33,660 crore, March 18, 2026) is separately filed — SASCI is a distinct scheme targeting state-level mining-sector governance reform. Distinct from filed India Union Budget 2026-27 Customs notifications and Semiconductor Mission 2. 0. Severity 2 (supply-side demand-unlock rather than export control or FDI gate).
https://www.policyedge.in/p/centre-launches-5000-crore-incentive-scheme-to-speed-up-mine-auctions-and-production
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Lithium🇨🇳 today 61→66+5
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 100d ago · not yet law·matches Lithium
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
https://mono.mn/n/government_approves_draft
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇳 Zhejiang Huayou Cobalt — US$210M acquisition of Atlantic Lithium (control of the Ewoyaa lithium project, Ghana) via Australian scheme of arrangement
awaiting-signature→high likelihood·flagged 99d ago · not yet law·matches Lithium
If passed — Chinese battery-materials major Zhejiang Huayou Cobalt (603799. SH) signed a BINDING Scheme Implementation Deed (7 May 2026) to acquire 100% of Atlantic Lithium Ltd (AIM/ASX: ALL) for ~US$210M all-cash (US$0. 25486/share; 26. 6% premium), gaining control of the Ewoyaa lithium project — Ghana's first parliament-ratified lithium mine (Central Region, 15-yr lease ratified Mar 2026). The Atlantic Lithium board unanimously recommends; largest holder Assore (~26. 4%) supports; deed has no financing/DD conditions. This is a Chinese-SOE-adjacent capture of a West-African hard-rock lithium chokepoint that had been positioned as a NON-China / Western-aligned supply source (Atlantic Lithium previously had US DFC / Piedmont offtake-JV ties), so the transaction re-prices Ewoyaa from a diversification asset into Chinese-controlled lithium supply — directly relevant to the cn-outbound-mining-fdi exposure series and to Ghana's local-ownership/beneficiation policy.
Caveat — As of 2026-06-28 the binding deed is signed but the deal is NOT consummated (shareholder vote Nov 2026, completion targeted Dec 2026, multiple regulatory approvals + Australian court order outstanding), hence awaiting-signature/upcoming not enacted. Likelihood ELEVATED: binding deed, unanimous board + 26. 4%-holder support, no financing/DD conditions — but Chinese-acquirer FIRB risk, MOFCOM outbound approval, and Ghanaian political resistance to foreign control of Ewoyaa's local-ownership model are real gates. Huayou has 0 records in the register. Severity 3 if completed.
https://www.londonstockexchange.com/news-article/ALL/binding-scheme-implementation-deed-with-huayou/17580344
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Lithium
If passed — RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Lithium🇨🇳 today 61→66+5
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 31d ago · not yet law·matches Lithium
If passed — Draft law amending Morocco's 2015 Mining Code (led by the Ministry of Energy Transition and Sustainable Development, Minister Leila Benali), with public consultations reported open since ~Feb 2025. Three structural changes: (1) a National Commission for Strategic and Critical Minerals empowered to designate an official list of "strategic and critical minerals" — Morocco's first formal legal mechanism to do so, which would sit upstream of and interact directly with the phosphate chokepoint (Morocco holds ~70% of world phosphate-rock reserves via OCP); (2) the digital mining cadastre (governance/transparency layer — this component has ALREADY gone live, launched 2026-04-07, and is queued separately to filing. md as an enacted action); (3) sharply increased penalties for illegal mining/prospecting (unauthorised prospecting: MAD 100k-1m; illegal extraction/transport/sale: up to MAD 2m). Morocco is chokepoint-tier and thinly covered (only 4 prior MA actions: 2022 Investment Charter, an AfDB agriculture loan, the 2026 Loi de Finances, and a Feb-2026 mining-tender notice — none creates a minerals-designation regime).
Caveat — distinct from the already-filed 2026-04-07 digital-cadastre launch (enacted, queued to filing. Dedup: no MA action in the index covers a strategic-minerals designation commission or mining-code amendment; the 3 other MA entries (Investment Charter 2022, Loi de Finances 2026, Feb-2026 mining tender) are distinct instruments.
https://fr.apanews.net/news/le-maroc-revise-son-code-minier-pour-stimuler-linvestissement/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇦 Canada — Attorney General Federal Court enforcement application vs. Gator Capital Ltd re: Investment Canada Act s.40 (first-ever ICA divestiture enforcement litigation)
announced→low likelihood·flagged 29d ago · not yet law·matches Lithium
If passed — On 11 Feb 2025 the Attorney General of Canada filed a Notice of Application (Federal Court file T-472-25) seeking a court order under ICA s. 40 directing Gator Capital Ltd to divest its ~20% stake in Lithium Chile Inc within 30 days to a trustee (subject to Minister approval of purchaser/terms), or alternatively to compel Gator to respond to outstanding information demands within 30 days; also seeks an injunction against Gator disposing of its shares and monetary penalties (up to C$10,000/day, potentially rising to C$50,000/day). This is the first time the Government of Canada has gone to court to enforce the ICA's national-security-review regime. Background: Chengze Lithium International Limited was ordered in Nov 2022 to divest its Lithium Chile stake (already in the register's ISED national-security-decisions record); Chengze sold to Gator in Feb 2023; the government's Notice of Application alleges it never confirmed Gator met the qualifications required of a divestiture buyer and that Gator (led by Wing Hong Chan, reportedly paid ~USD 34m for the 20% stake) has not complied with subsequent information demands (a "Third Demand" under a Sept 2024 FIRES administrative note). FDI-screening vs. Chinese-linked lithium/critical-minerals investment (thin action_type: investment-screening, ~71 filed). Severity 3-4 expected (first-ever court enforcement, direct critical-minerals/lithium chokepoint, but the underlying stake is a single ~20% minority position in one junior miner).
Caveat — Charter §6 verify-or-don't-file: ran 2 searches + fetched the ISED national-security-decisions page (only lists the Nov-2022 Chengze order, not this Feb-2025 enforcement application) + the ISED ICA Annual Report 2024-2025 (no mention) + probed the Federal Court's own file-search page (fct-cf. ca — no stable per-file docket URL exists; file search is a form/query tool, not a linkable record). Dedup: no existing CA action in filing. md/upcoming. md covers Gator Capital or this enforcement filing; the 2022 Chengze divestiture order itself does not appear to be in the register either (checked docs/iptm/actions/ for "gator"/"lithium chile"/"chengze" — no match), so a filer who later locates its primary source should consider filing that antecedent action too.
https://www.mccarthy.ca/en/insights/publications/canadian-government-initiates-investment-canada-act-enforcement-proceedings-national-security-matter
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)
in-consultation→moderate likelihood·flagged 26d ago · not yet law·matches Lithium
If passed — Minister of Mines, Petroleum and Energy Mamadou Sangafowa-Coulibaly formally launched the revision of Côte d'Ivoire's 2014 Mining Code on 13 June 2026, standing up an expert team drawn from his ministry, other state institutions and international bodies to rewrite Loi n° 2014-138 du 24 mars 2014. Stated goals: raise state revenue share, fix "disparate and sometimes poorly negotiated" mining conventions, and modernise the mining cadastre. No draft bill text published yet — this is a mandate/committee-formation stage, distinct from and earlier than the already-filed 2026-02-04 Assafou/Doropo gold-permit decrees and the 2025-12-03 PIRME minerals-energy policy (2025-2040), both of which operate under the CURRENT 2014 code rather than proposing to replace it. Chokepoint-relevant: register's only prior CI code-minier-lineage entries are the 2014 code itself and a 2022 local-content oil/gas law — no entry tracks this active rewrite.
Caveat — Dedup: checked action-index and both queues for "code minier"/"mining code" + CI — only hits are the already-filed 2014 code, the 2022 local-content petroleum law, and the 2024-12 gold-royalty finance law, none of which is this revision effort. Distinct from Senegal's and Morocco's already-queued mining-code amendments (different issuer/instrument).
https://www.energie.gouv.ci/actualite/sangafowa-coulibaly-veut-booster-lattractivite-du-code-minier
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Lithium🇨🇳 today 61→66+5
🇨🇿 Czech Republic — €360M Government Grant for Cinovec Lithium Project (European Metals Holdings / CEZ JV)
awaiting-signature→high likelihood·flagged 16d ago · not yet law·matches Lithium
If passed — On 28-Nov-2025 European Metals Holdings announced the Czech government approved a grant of up to EUR 360M under the Ministry of Industry and Trade's "Strategic Investments for a Climate-Neutral Economy" programme for the Cinovec lithium/tin project (EU Critical Raw Materials Act strategic project, Czech-designated strategic deposit) — one of the largest single-project CRM grants in the EU. Award is government-approved in principle but "subject to completion of administrative processes, after which a formal grant decision would be issued" (final amount could be lower). Liberalising/supply-relief polarity: EU-domestic lithium capacity build, not a restriction. Genuine gap: CZ carries only 4 actions in the register, none touching lithium/CRMA-strategic-project funding — thin Central European coverage flagged in Step 0. 5. action_type: subsidy; yet assigned (CRMA-strategic-project funding). Primary-ish source: company RNS/ASX announcement — https://www. miningweekly. com/article/360m-grant-for-cinovec-lithium-project-2025-11-28; https://www. miragenews. gov. cz (Ministry of Industry and Trade) before filing — no MPO. gov.
Caveat — Dedup: checked "cinovec" and "czech. *lithium" across filing. md, upcoming. md, and action-index — zero hits, not previously queued.
https://www.miningweekly.com/article/360m-grant-for-cinovec-lithium-project-2025-11-28
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Lithium🇨🇳 today 61→66+5

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 listShow

Lithium is the line to war-game: 🇨🇳 CN already controls 65% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.

Art. 24(4) · diversification & substitution

Priority mitigations

The mitigation optionsShow

Track demand-side substitution against your own book. The buyer levers listed for consumers of Lithium — qualifying alternative suppliers, designing the material out — are the demand risk to Minera Exar S.A. (Cauchari-Olaroz)'s revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by CN on a material Minera Exar S.A. (Cauchari-Olaroz) produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The material above is concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.

Annex A · regulatory basis

CRMA Art. 24 compliance crosswalk

The full crosswalkShow

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

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 detailsShow

Threshold test	This assessment
Average employees (last FY) > 500	company input
Net worldwide turnover (last FY) > €150M	company input
Uses a strategic raw material as an input	company input — all 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology	mining-metals (confirm against Annex)
Formally identified by a Member State authority	company input

Evidence & sources

Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.

All sourcesShow

Methodology

MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-05

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.