Loading…
Loading…
5 critical materials scored · binding chokepoint: Dysprosium (🇨🇳 CN 99% of refining) · 51 restrictive government measures on record
MP Materials Corp. produces 5 of the 5 scored materials above (Dysprosium, Terbium, Neodymium, Praseodymium, Samarium). 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 Critical · 93/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-06) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Dysprosium — 🇨🇳 CN controls 99% of global refining. On this company's production footprint that scores 95/100 (adversarial chokepoint; global 88). The register holds 51 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Dysprosium MP Materials Corp. is the 7th-most-exposed of the 266 named companies we track on 🇨🇳 CN's Dysprosium chokepoint; the most-exposed is TdVib (95/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
MP Materials Corp. ranks 1st of 2 verified critical minerals companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 93/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 5 scored materials. Buyer-relative (first-order): weighted by where the company produces (US 100%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Also listed in the dossier but not platform-scored: Bastnaesite-concentrate, Ndfeb-magnets — no supply-risk series is tracked for these here.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
MP Materials (NYSE: MP) operates Mountain Pass in California — the only commercial-scale rare-earth mine and separation facility in the Western Hemisphere — together with a downstream Fort Worth, Texas magnet-manufacturing facility (Stage III, NdFeB metal → alloy → magnet) commissioning across 2024-2026. The company's structural significance is the vertical span: within a single corporate entity it now controls bastnaesite extraction, separation into individual REE oxides (Stage II, operating since 2023), metal/alloy/magnet manufacture (Stage III, commissioning), and — from 19 November 2025 — a US Department of War-financed offshore refining joint venture in Saudi Arabia. Revenue FY24 is small in absolute terms (≈USD 200m) relative to the policy footprint; the company trades as a strategic-asset proxy rather than on near-term earnings multiples.
MP's policy beta is concentrated in NdPr (neodymium-praseodymium) oxide — the magnet feedstock for EV motors, wind turbines, and defence platforms (F-35 alone consumes ~417 kg of REE per aircraft per US GAO estimates that the policy community uses). Specific material dependencies:
bastnaesite concentrate naturally rich in light REEs; Stage II separation runs the concentrate to individual oxides. NdPr is the highest-value cut and the policy-targeted one.
Mountain Pass bastnaesite is heavy-REE-poor; the Saudi JV (refinery with Ma'aden) is designed to process globally-sourced ore including heavy-REE-bearing streams, and the partnership with Lynas USA Texas (a separate state-supported HREE separation facility) gives MP indirect HREE optionality. (Merged from mp-materials.md 2026-08-14 — a fourth channel this dossier did not carry, and the nearest-dated one.) MP has been stockpiling a heavy/medium rare-earth concentrate branded SEG+ at Mountain Pass since late 2023, and per its Q4/FY2025 results (Feb 2026) is targeting commissioning of a dedicated Dy/Tb separation facility at Mountain Pass in mid-2026, initial nameplate ~200 t/yr of product from ~3,000 t/yr of feedstock. Dy and Tb are the coercivity dopants that make NdFeB magnets usable at traction-motor and defence operating temperatures, and China's grip on Dy/Tb separation is tighter than on NdPr — so this is simultaneously the highest-value and highest-concentration-risk step on MP's roadmap, and it is domestic rather than dependent on Saudi or Lynas capacity.
downstream extension; once running at nameplate the facility becomes a non-China supplier of magnet precursors and finished magnets to GM (10-year offtake, signed 2021) and US-defence customers.
the action narrative of China MOFCOM's February 2025 W/Te/Bi/Mo/In controls as an expected beneficiary of follow-on DPA Title III obligations covering tungsten and tellurium, suggesting strategic scope-creep beyond REEs into broader critical-minerals positioning.
(Merged from mp-materials.md 2026-08-14.) Two calibration points this dossier lacked. Scale: Mountain Pass produced over 45,000 t of rare-earth oxide in concentrate and roughly 1,300 t of separated NdPr oxide in 2024 — company-reported, and all-time highs for US primary production. Read against the FY24 revenue of ≈USD 200m noted above, that is the arithmetic behind the "strategic-asset proxy rather than an earnings multiple" framing. Exclusion: cerium and lanthanum are separated at Mountain Pass as co-products but are deliberately absent from material_exposures — they sit outside the scored critical-mineral index on a lower supply-risk profile and a much larger global supply base. Their omission is a judgement already made, not a gap.
| Action | Issuer | Type | Sev | Why it touches MP |
|---|---|---|---|---|
| 2025-11-18 US-Saudi Strategic Framework, Critical Minerals | US/SA | industrial-policy | 4 | Anchor action — operationalised on day +1 by the binding 19 Nov 2025 MP / DoW / Ma'aden term sheet. US side JV (DoW + MP) holds ≈49%; DoW finances the US-side equity contribution; MP supplies process technology transferred from Mountain Pass / Fort Worth. First DoW-financed REE-refining capex outside the US-AU-CA axis. |
| 2025-10-09 China MOFCOM Announcements No. 61 + 62 (extraterritorial REE controls) | CN | export-controls | 5 | Action narrative names "Mountain Pass / MP Materials separation facility (DoD $400M equity + $150M loan, 2025)" alongside Noveon as still years from displacing PRC capacity at scale. The Oct-Nov 2025 DoD response — additional MP offtake commitments and Lynas USA Texas acceleration — is the structural reflex named explicitly in the action. The Nov-2025 MOFCOM Announcement No. 70 suspension expiry on 2026-11-10 is the hard macro-monitoring date for MP's offtake-pricing trajectory. |
| 2025-04-04 China MOFCOM heavy-rare-earths export licensing | CN | export-controls | 5 | Action explicitly names DoD's accelerated funding for MP Materials, USA Rare Earth, and Lynas USA Texas in Q2-2025 (allocations "roughly doubled prior-year run-rate"). Heavy-REE list excluded NdPr — leaving MP's primary product line outside the licensing perimeter but inside the political-pressure cone. |
| 2025-12-11 Vietnam Law on Geology & Minerals Amendment 147/2025 | VN | regulatory | 4 | MP named alongside Lynas, Shin-Etsu, POSCO, Solvay as foreign rare-earth processors whose access to Vietnam Dong Pao feedstock is gated by the new Vinacomin/Masan-JV state-approved-operator requirement. Architectural question for MP: pursue Vietnam upstream or rely on Saudi feedstock pipeline. |
| 2025-11-26 India REPM Sintered Rare-Earth Magnets Scheme | IN | industrial-policy | 4 | Action open question explicitly asks whether scheme "will attract greenfield FDI from Lynas / MP Materials / Solvay or be captured by domestic incumbents." Action also names MP as "bullish" beneficiary of Indian downstream demand for non-FEOC oxide as natural extension of US §45X / DOD demand. |
| 2025-03-20 EO 14241 Domestic Mineral Production / DPA | US | industrial-policy | 4 | MP named first in the "US rare-earth + strategic-mineral juniors (REMX)" cluster — direct beneficiary of DFC §303 financing and stockpile-offtake commitments that derisk midstream REE capex beyond what IRA §45X alone could underwrite. |
| 2026-01-14 US Section 232 Critical Minerals Proclamation | US | trade-defense | 4 | MP named as US miner/refiner directly affected by realised pricing once Section 232 instruments land. The proclamation defers the binary tariff outcome — creating a 12-18 month structural uncertainty band over MP's realised-vs-spot pricing. |
| 2026-02-04 US State FORGE Critical Minerals Launch | US | industrial-policy | 4 | MP listed first in action company_refs as State Department FORGE programme beneficiary — diplomatic-capital channel deploying for upstream-supply diversification deals that backfill MP's external-feedstock needs for Mountain Pass and Saudi JV. |
| 2025-12-12 US Pax Silica Initiative | US | industrial-policy | 4 | MP listed in coalition company_refs; positions MP as US-side participant in the multi-signatory critical-minerals coalition (US + 10 partners, India added Feb 2026). Membership-by-default in coalition-channel offtake mechanisms. |
| 2025-02-04 China MOFCOM W/Te/Bi/Mo/In export controls | CN | export-controls | 4 | Action narrative names MP as expected recipient of "accelerated DPA Title III obligations" covering W and Te — strategic-scope-creep flag suggesting MP's policy footprint extends beyond REEs into broader critical-minerals positioning. |
| 2025-12-03 EU ResourceEU Action Plan COM(2025) 945 | EU | industrial-policy | 5 | MP named as REMX cluster member receiving "material tailwind from EUR 3bn flowing into ex-China REE projects" and as supplier into the new EU CRM Centre joint-purchasing facility — opens an EU sovereign off-take channel separate from US DoD. |
| 2026-04-28 China MIIT rare-earth penalty discretion standards | CN | regulatory | 3 | Action names MP as "Western producer beneficiary" of any tightening of Chinese domestic supply discipline. Critical watchpoint: the action flags that the 2025-04-04 MOFCOM heavy-REE list pointedly excluded NdPr — MIIT discretion is the perimeter-creep channel for NdPr inclusion, which would directly re-price MP's largest revenue line. |
| 2025-11-14 Indonesia Permen ESDM 18/2025 Rare-Earth Management | ID | regulatory | 4 | Action notes Western REE processors including MP are "unlikely to find easy entry" to Indonesia REE downstreaming; Chinese-aligned capital follows the path of least resistance per the nickel template. Negative-list flag rather than opportunity. |
| 2026-01-02 Saudi Arabia 9th Mining Exploration Licensing Round | SA | industrial-policy | 3 | Action explicitly aligns the SAR 4.5bn investment commitment and 220% YoY surge with the MP/Ma'aden/DoW refinery term sheet — embedding the Saudi licensing-round outcomes as MP's de-facto upstream feedstock pipeline. |
| 1950-09-08 US Defense Production Act 1950 (parent statute) | US | statutory | 5 | DPA Title III is the originating authority under which every DoD investment in MP (including the $400M equity / $150M loan flagged in the Oct-2025 MOFCOM action) flows. Structural authority-stack root. |
automatic reinstatement of the Oct 2025 extraterritorial REE control architecture absent further US-China negotiation. Hard macro-monitoring date for MP's offtake pricing and additional DoD reflex spending.
2026-01-14 proclamation defers the binary tariff decision into a Commerce-led investigation. Outcome determines whether MP's realised pricing structurally re-rates upward (tariff protection) or remains subject to spot-market dumping risk.
ResourceEU Action Plan envisions an EU sovereign off-take channel. Once operational, opens a non-US-DoD offtake destination for Mountain Pass and Fort Worth output.
term sheet is binding but pre-construction; commissioning timeline, capex split between DoW underwriting and MP technology-licensing fees, and feedstock-sourcing arrangements are the next public disclosure waypoints.
discretion standards are the perimeter-creep channel by which NdPr could enter the controlled list; this would invert MP's competitive-positioning thesis from "outside the perimeter" to "inside the policy crosshairs."
("Independence"). Binding long-term agreement Dec 2021, definitive supply agreement April 2022: finished NdFeB magnets, alloy, and NdPr metal for Ultium-platform EV motors (Hummer EV, Cadillac Lyriq, Silverado EV, 12+ models). GM paid a $50M initial prepayment (April 2024) and the final $50M magnetic-precursor prepayment (per MP's Q4 2025 results). Magnet production ramp for GM expected 2026.
US-made magnets from Fort Worth, made from 100%-recycled feedstock via a new recycling line to be built at Mountain Pass (5-year prior pilot between the two companies). ~$200M prepaid. Destined for "hundreds of millions of Apple devices" (product line unspecified; RE magnets are used in iPhone haptic engines, speakers, microphones). Shipments expected to begin 2027 — a forward commitment, nothing shipped yet.
partnership: $400M DoD preferred-equity investment (~15% as-converted, largest shareholder), up to $350M additional, a $150M heavy-REE separation loan, a 10-year $110/kg NdPr price floor (~2x market price at signing), and DoD ensuring 100% of the planned "10X" facility's 7,000 t/yr output (Northlake, TX, targeted commissioning 2028) is purchased by defense + commercial customers combined — plus a $140M/yr EBITDA guarantee for 10 years post-completion. No specific defense platform (F-35 etc.) is contractually named — that linkage in press coverage is generic industry framing, not disclosed allocation.
oxide/metal into Japan under the Feb 2023 Distribution Agreement, which MP's FY2025 10-K discloses was extended through end-2030 (initial term ran only through end-2025). The contracting entity is the US subsidiary, not the Tokyo-listed parent Sumitomo Corporation (TSE: 8053). MP also sells into South Korea/broader Asia, end-customers there undisclosed. Separately tolls NdPr oxide-to-metal conversion via Vietnam Rare Earth Company.
(2026-02-26) as a "significant NdPr oxide offtake agreement," widely reported as a US automaker but not yet named by MP.
ENDED. Shenghe funded MP's 2017 restart and was, per MP's own Q1 2025 10-Q, the "principal customer of the Materials segment" at >60% of Q1-2025 consolidated revenue (>80% in Q1-2024). MP halted concentrate shipments to China 2025-04-17 (following China's April 2025 export controls — see the 2025-04-04 action in the table above, already linked in this dossier) and ceased all China sales in Q3 2025; the Shenghe offtake agreement expired January 2026, not renewed. This is the clearest example in either dossier of a named customer relationship ending as a direct, dated consequence of a policy action already in our own register — and today nothing in this dossier or the scoring engine states that link explicitly; it's two separate facts sitting near each other in prose.**
customer.
10-Q (period ended 2026-06-30) discloses customer concentration by anonymized letter code, not name — the "Concentration of Customer Risk" note states: "Customer A in the Materials segment accounted for 40% in both applicable periods; Customer B in the Materials segment accounted for 32% and 29%, respectively; and Customer C, primarily in the Magnetics segment, accounted for 15% and 19%, respectively" (Q2-2026 / H1-2026). The prior-year comparative (Q2/H1-2025) used different letters — "Customer D in the Materials segment accounted for 22% and 43%, respectively; Customer A ... accounted for 25% and 22%, respectively; and Customer C ... accounted for 35% and 21%" — and Customer D, present only in the 2025 table at up to 43% of Materials-segment revenue, drops out entirely by Q2-2026, consistent with Shenghe's China sales cessation (2025-04/Q3) and unrenewed offtake (expired Jan 2026). Do not assume a letter denotes the same counterparty across the two tables — MP does not state that the codes are stable identities, only Materials vs. Magnetics segment and the percentage. Candidates for the now-anonymized Materials-segment buyers include Sumitomo (NdPr oxide/metal into Japan) and the undisclosed "new strategic OEM" NdPr oxide offtake noted above, but neither is confirmed against these specific letters. Source: MP Materials 10-Q for the quarter ended 2026-06-30, Note 2 (Significant Accounting Policies), sec.gov/Archives/edgar/data/0001801368/000180136826000048/mp-20260630.htm.
MP's strategic-positioning asymmetry is that no other US-listed REE entity controls the full mine-through-magnet vertical stack plus a state-financed offshore refining JV. Lynas (ASX: LYC) controls mine (Mt Weld) + separation (Malaysia / Texas) but no magnet manufacturing; Iluka (ASX: ILU) is building Eneabba separation but has no magnet stage; USA Rare Earth (USAR), Energy Fuels (UUUU), Ucore Rare Metals are mid-stream-only with no operating mine. The policy stack MP can combine: DPA Title III + DFC §303 + IRA §45X + Section 232 tariff protection + State FORGE diplomatic channel + Pax Silica coalition + EU CRM Centre joint-purchasing + Saudi Ma'aden offtake. No public Lynas or USAR disclosure shows comparable multi-jurisdictional state-aid stacking. Downstream alternatives MP does not need to pursue but could optionalise: Indian REPM PLI (greenfield magnet JV), EU CRMA Strategic Project (separation expansion at a continental European node), Vietnam Dong Pao JV (upstream feedstock via Vinacomin/Masan).
The standard sell-side comp set values MP against Lynas (mine + separation, AU + MY + TX), Iluka (mine + separation-in-build), and the US juniors (USAR, Energy Fuels, Ucore — mid-stream only). That comp framework treats all of them as "miner / separator" peers with NdPr-spot leverage. The framework misses three structural facts that arrived in 2024-2025: (a) Fort Worth Stage III magnet manufacturing moves MP downstream of the separation stage that defines every comp — the company sells metal, alloy and finished NdFeB magnets, not oxide; (b) the Nov 2025 Saudi JV extends MP across a state border with US Department of War financing on the US-side equity, putting MP inside an offshore refining vehicle that has no peer-comparable structure in the comp set; (c) the DoD Q2-2025 funding doubling (per the 2025-04-04 MOFCOM action's structural-effects section) signals that the state-investor presence in MP's capital structure is active and responsive to PRC-policy events rather than a one-off historical injection. The combined effect is that MP's correct comp set is not "REE miners" but "state-aided industrial-supply champions with multi-stage vertical scope" — closer to a chip foundry on a national-security mandate than to a junior miner. This re-comp has not hit published consensus.
Pre-November 2025, every state-financed REE-processing facility that mattered to US supply security sat in one of three jurisdictions: US (Mountain Pass, Lynas Texas, USA Rare Earth Stillwater), Australia (Lynas Kalgoorlie, Iluka Eneabba), or Canada (Saskatchewan Research Council, Vital Metals stranded attempt). The 19 November 2025 MP / DoW / Ma'aden binding term sheet is the first time Department of War balance-sheet has underwritten 49% equity in an offshore REE refining facility outside that perimeter — and it sits in Saudi Arabia, a GCC jurisdiction with no prior REE-processing footprint. The structural consequences are not yet priced in sell-side comps: (a) MP gains a non-US, non-Chinese feedstock-and-processing optionality node that can serve allied defence and industrial customers under separate sanctions perimeter; (b) the Saudi side gains a non-China refining alternative that may eventually attract third-country ore that previously flowed to Chinese refiners by default — re-shaping global REE-ore trade flows; (c) MP's technology-licensing fees from the Saudi JV become a non-mine-revenue line item that sell-side models treating MP as a commodity-pricing proxy do not have a slot for. None of MP's listed peers has a comparable state-financed offshore refining JV.
The Solvay dossier (filed 2026-05-30) flagged the Vietnam Amendment 147/2025 vs India REPM binary as an architectural decision Solvay has not publicly resolved. For Solvay the calculus is asymmetric in favour of Vietnam — Solvay owns the separation stage and needs upstream feedstock; India REPM funds downstream sintered-magnet manufacturing, which Solvay would have to greenfield. For MP the same binary inverts: MP already owns Fort Worth Stage III sintered-magnet manufacturing (in commissioning); the India REPM PLI funds exactly the downstream stage MP is already standing up, making it a natural JV target for a Mountain-Pass-oxide-to-India-magnet supply chain with PLI subsidy support. Conversely, Vietnam Dong Pao upstream access is less load-bearing for MP because Mountain Pass plus the Saudi JV are likely to satisfy MP's near-term feedstock needs without committing to a Vinacomin/Masan JV with attached political risk. The Vietnam vs India binary therefore presents different optimal answers to MP and to Solvay for structural reasons — and the same multi-jurisdictional decision matrix has structurally different resolutions across the comp set. Sell-side coverage has not flagged this asymmetry; it shows up only when both dossiers are read against each other.
The 2025-04-04 MOFCOM heavy-REE export licensing announcement deliberately excluded NdPr from the controlled list, even though NdPr is the highest-value REE cut and the magnet-feedstock chokepoint China has the most market power over. The exclusion preserves Chinese magnet-makers' access to upstream MOFCOM-perimeter licensing flexibility while denying US/EU/JP magnet projects access to the same heavy-REE inputs. The 2026-04-28 MIIT rare-earth penalty discretion standards are explicitly flagged in the IPTM register as the perimeter-creep channel by which NdPr could later enter the controlled list — without requiring a new MOFCOM announcement. The structural implication for MP: the largest revenue-line risk MP carries is not heavy-REE controls (which it benefits from via DoD reflex spending) but a quiet MIIT-discretion decision to include NdPr in the existing perimeter. Tracking MIIT enforcement-practice releases (rather than MOFCOM announcements) is therefore the right policy-monitoring posture for MP's NdPr revenue line. Sell-side coverage almost universally tracks MOFCOM and misses MIIT — a defensible monitoring-channel edge.
Refresh triggers: any new MOFCOM rare-earth Announcement; any MIIT rare-earth penalty-discretion practice release; any change in DoD direct equity / loan structure in MP; any Saudi JV construction milestone; any Section 232 critical-minerals tariff determination; any India REPM scheme award round; any Vietnam Dong Pao state-approved-operator designation; any Mountain Pass Stage III commissioning update; any EU CRM Centre joint-purchasing activation. Default refresh cadence: quarterly review of action- table relevance; annual structural re-read.
Q4 2024 / Q1 2025 / Q3 2025 10-Q filings.
Title III equity and loan structures (referenced via the IPTM Oct-2025 MOFCOM action narrative).
MP Materials / DoW / Ma'aden binding term sheet press release (19 November 2025).
(11 December 2025).
notification (26 November 2025).
Ma'aden Saudi JV (Nov 2025); CSIS analysis "What's in the New U.S.-Saudi Minerals Agreement?" (Nov 2025).
Production" (press release, Jan 2025)](https://mpmaterials.com/news/mp-materials-restores-u-s-rare-earth-magnet-production/) (merged from mp-materials.md 2026-08-14)
the Department of Defense" (Jul 2025)](https://mpmaterials.com/news/mp-materials-announces-transformational-public-private-partnership-with-the-department-of-defense-to-accelerate-u-s-rare-earth-magnet-independence/) (merged from mp-materials.md 2026-08-14)
(Feb 2026; Dy/Tb separation-facility timeline)](https://mpmaterials.com/news/mp-materials-reports-fourth-quarter-and-full-year-2025-results) (merged from mp-materials.md 2026-08-14)
From the company’s own filings and dated disclosures — top-5 concentration and related-party tables where the filer’s regime compels them, named supply and offtake agreements where it does not. This is a disclosure, not a netting: a named supplier concentration is shown beside the exposure score and never adjusts it. Figures are the fiscal years labelled, not a current snapshot.
Toll processor, not a materials supplier: converts MP's NdPr oxide to metal. A named third-country conversion dependency sitting outside both the US stack and China.
MP's self-described 'foundational customer' for Fort Worth (Independence). Binding long-term agreement Dec 2021, definitive supply agreement April 2022 for finished NdFeB magnets, alloy and NdPr metal for Ultium EV motors across 12+ models. GM paid a $50m initial prepayment (April 2024) and a final $50m magnetic-precursor prepayment; magnet ramp expected 2026. (Re-checked 2026-08-21: figures match MP's own disclosures.)
$500m multi-year agreement announced 2025-07-15 for US-made Fort Worth magnets from 100%-recycled feedstock, with a new recycling line at Mountain Pass; ~$200m prepaid. Shipments expected to begin 2027 — a forward commitment with nothing shipped yet, so it is revenue-relevant only from 2027. (Re-checked 2026-08-21: date, amount, feedstock and 2027 timing confirmed against MP's own release; prepayment split not independently re-confirmed this pass.)
July 2025 partnership: $400m preferred-equity investment (~15% as-converted, making DoD MP's largest shareholder), up to $350m more, a $150m heavy-REE separation loan, a 10-year $110/kg NdPr price floor (~2x market at signing), an offtake guarantee for 100% of the planned 7,000 t/yr Northlake TX 10X facility, and a $140m/yr EBITDA guarantee for 10 years post-completion. `related_party: false` because DoD is not under common control, but a customer that is simultaneously the largest shareholder and the price-floor guarantor is not an arm's-length third-party sale either — read the row with that caveat. No specific defense platform is contractually named; the F-35 linkage in press coverage is generic framing, not disclosed allocation. (Re-checked 2026-08-21: all figures confirmed verbatim against MP's own press release.)
Re-checked 2026-10-03: prior source_url (direct .htm filing document, accession 0001801368-26-000008) returned HTTP 403; replaced with the live SEC EDGAR 10-K filing list for CIK 0001801368, which lists that same accession (filed 2026-02-26) as the FY2025 10-K. Contracting entity per MP's own FY2025 10-K is 'Sumitomo Corporation of Americas', the US subsidiary — not the Tokyo-listed parent 'Sumitomo Corporation (TSE: 8053)'; corpus rule is verbatim legal-entity names from the primary source. The Feb 2023 Distribution Agreement's initial term (through end-2025, renewable annually) has since been extended: the FY2025 10-K states Sumitomo is the exclusive distributor of MP's NdPr oxide and NdPr metal to Japanese customers 'through the end of 2030'. Route: 'NdPr oxide and metal revenue consists of sales of NdPr oxide and metal produced at Mountain Pass under individual sales agreements, as well as sales under our distribution agreement with Sumitomo Corporation of Americas', and Sumitomo distributes that output 'to Japanese customers' — Mountain Pass, California (US) to Japan; amounts per customer not disclosed. Because it is a distributor, the Japanese end-customers behind this row remain undisclosed — the same is true of MP's South Korea/broader-Asia sales.
ENDED, and this is the most policy-legible counterparty event in the corpus. Per MP's Q1 2025 10-Q, Shenghe was the 'principal customer of the Materials segment' at more than 60% of Q1-2025 consolidated revenue (more than 80% in Q1-2024) — no share_pct is recorded here because the filing states floors, not exact figures, and a rendered '60%' would be a precision the source does not have. MP halted concentrate shipments to China on 2025-04-17 following China's April 2025 export controls (the 2025-04-04 action already linked in this dossier), ceased all China sales in Q3 2025, and the offtake agreement expired January 2026 unrenewed. Route per MP FY2024 10-K (accession 0001801368-25-000009, filed 2025-02-28, listed at the SEC EDGAR link above): rare earth concentrate from Mountain Pass (California) is principally sold under the Offtake Agreements to Shenghe, which typically sells that product to refiners in China; Shenghe was about 80% of FY2024 consolidated revenue.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
4 of 4 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Dysprosium | 🇨🇳 CN 99% refining | 95 | 88 | Critical | EXCEEDS 99% | Low | none | 51 | ▲ rising |
| Terbium | 🇨🇳 CN 99% refining | 93 | 84 | Critical | EXCEEDS 99% | Low | limited | 51 | ▲ rising |
| Neodymium | 🇨🇳 CN 85% refining | 86 | 72 | Critical | EXCEEDS 85% | High | some | 50 | ▲ rising |
| Praseodymium | 🇨🇳 CN 85% refining | 85 | 72 | Critical | EXCEEDS 85% | High | some | 48 | ▲ rising |
| Samarium | 🇨🇳 CN 97% refining | 85 | 69 | Critical | — | Low | ready | 48 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Dysprosium | 4 | 5 | 5 | 5 | 3 | company input |
| Terbium | 4 | 5 | 5 | 4 | 3 | company input |
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Praseodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Samarium | 4 | 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.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 36 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, these disclosed plants carry the binding Dysprosium exposure:
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
The binding exposure this precedent lands on — Dysprosium — is a material MP Materials Corp. produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-06) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 4 restrictive actions on Dysprosium since 2024 — cadence accelerating (mean gap 483d → 152d), severity flat (3.5 → 3.5).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 5 of these 26 materials (Neodymium, Dysprosium, Praseodymium, Samarium, Terbium) — your binding Dysprosium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 4.7 months apart across 5 distinct restriction dates since 2024 (n=4 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Dysprosium — 🇨🇳 CN escalates dysprosium controls to a full export-licensing / ban regime | 95 | 96 | +1 |
| Concentration | Dysprosium — 🇨🇳 CN becomes the single source for dysprosium — the second source is lost (full 99%+ monopoly) | 95 | 95 | 0 |
| Policy | Terbium — 🇨🇳 CN escalates terbium controls to a full export-licensing / ban regime | 93 | 94 | +1 |
| Concentration | Terbium — 🇨🇳 CN becomes the single source for terbium — the second source is lost (full 99%+ monopoly) | 93 | 93 | 0 |
| Policy | Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime | 86 | 88 | +2 |
| Concentration | Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly) | 86 | 92 | +6 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one MP Materials Corp. 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.
Reported separately (not an Art. 24(4) trigger): Dysprosium clears the same numeric bar but is a material MP Materials Corp. produces. That is an output-market concentration — relevant to revenue and to counterparties who buy from this company — not an input dependency the company must mitigate under Art. 24(4).
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 5 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one MP Materials Corp. produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 5 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | critical-minerals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-30; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-06
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.