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4 critical materials scored · binding chokepoint: Uranium (🇷🇺 RU 45% of refining) · 39 restrictive government measures on record
NAC Kazatomprom JSC produces 4 of the 4 scored materials above (Uranium, Niobium, Beryllium, Tantalum). 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 · 55/100 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 Uranium — 🇷🇺 RU controls 45% of global refining. On this company's production footprint that scores 57/100 (neutral exposure; global 57). The register holds 39 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Uranium NAC Kazatomprom JSC is the 52nd-most-exposed of the 55 named companies we track on 🇷🇺 RU's Uranium chokepoint; the most-exposed is Appia Rare Earths & Uranium Corp. (67/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
NAC Kazatomprom JSC ranks 295th of 449 verified mining metals companies, tied with 33 others at 55.
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 55/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 4 scored materials. Buyer-relative (first-order): weighted by where the company produces (KZ 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
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.
> The exposure report this dossier powers is at > /intelligence/dossiers/nac-kazatomprom/report.
NAC Kazatomprom JSC, headquartered in Astana, is the national atomic company of the Republic of Kazakhstan and the world's largest uranium producer. In 2025 it produced 25,839 tU on a 100% basis and 13,519 tU on an attributable basis, which the company puts at approximately 20% of global primary uranium production. All of its mining operations are located in Kazakhstan, and it mines almost entirely by in-situ recovery — a low-cost method that is a large part of why Kazakh output sets the global cost floor.
Beyond the mine, Kazatomprom has been extending down the fuel cycle. Its Ulba Metallurgical Plant at Ust-Kamenogorsk makes uranium fuel pellets and fuel assemblies, and the Kazakh-Chinese joint venture Ulba-FA LLP reached its 200-tonne-per-year design capacity for low-enriched-uranium fuel assemblies by the end of 2024. The same Ulba complex is also the group's rare-metals business, processing tantalum, niobium and beryllium.
Kazatomprom is ~75% state-controlled — 62.99% via the sovereign wealth fund Samruk-Kazyna and 12.01% directly by the Ministry of Finance since a July 2024 restructuring — with a 14.92% free float. Its shares trade on the Astana International Exchange and its GDRs on the London Stock Exchange.
position, not a purchasing dependency: Kazatomprom is roughly a fifth of world primary uranium output on its own, and Kazakhstan as a whole is the dominant single-country source. The concentration risk in the global nuclear fuel chain therefore largely is this company, which inverts the usual reading of a dossier — utilities and fuel fabricators elsewhere in this register carry Kazatomprom's operational and jurisdictional risk as their own. Its own vulnerabilities are correspondingly upstream-specific: sulphuric acid supply for ISR leaching, wellfield development rates, and export routing, which for Kazakh uranium has historically leaned on transit through Russia.
outsized*. Processed at Ulba. Global beryllium supply is one of the most concentrated of any scored material — a very small number of producers worldwide — so Ulba's position matters far more than the segment's contribution to Kazatomprom's revenue would suggest. Beryllium's end uses (aerospace structures, nuclear reflectors, X-ray windows, copper-beryllium alloys for connectors) are ones where substitution is poor.
supply chain is otherwise weighted toward Central African mine supply routed through Asian processors, so a Kazakh processing node is a genuine diversification point for capacitor-grade and alloy tantalum users.
supply is overwhelmingly Brazilian and Kazatomprom is not a material share of it; this is listed as a real, company-disclosed product line rather than as a chokepoint position.
On the rare-metals segment generally. Kazatomprom's FY2025 results release lists rare metals as a business segment but publishes no separate revenue or output figures for it, and the Integrated Annual Report 2025 PDF could not be read this pass (it exceeded the fetch size limit). So the relative weight of beryllium, tantalum and niobium against uranium is not established here — they are almost certainly a small fraction of group revenue, but that is an inference we have not sourced, and no magnitude band has been set on any of the four exposures for exactly that reason. Treat the three rare metals as confirmed product lines of unquantified size, not as quantified positions.
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.
Long-term contract for sale and purchase of natural uranium concentrates, signed 9 Nov 2023 at CIIE Shanghai; Kazatomprom's release identifies the buyer as 'a subsidiary of China National Nuclear Corporation - CNNC'; volumes and terms not disclosed for confidentiality.
Cameco's 2024 AIF states Cameco (40% JV Inkai interest) 'received 2.7 million pounds of its total share of Inkai's 2024 production,' with the remainder stored at JV Inkai for future delivery -- physical natural uranium delivered from the Kazatomprom-operated (60%) Inkai JV to Cameco in Canada.
Kazatomprom: 'Kazakhstan concluded a contract with Swedish Company Vattenfall AB for the supply of natural uranium' (competitive tender). Origin KZ (Kazatomprom ISR mines). Destination NOT pinned: natural U3O8 is delivered to a converter's account (no conversion plant in Sweden), so the physical flow is KZ>converter country, not KZ>SE; Sweden-bound material would be fabricated fuel from Västerås/Framatome. 2018 evidence, pre-2022 — needs a current confirmation.
ImportGenius US import records, importer page Converdyn: bills of lading MLBGSPIEPOTHOU02 (714,287 kg) and MLBGSPIEPOTHOU01 (286,766 kg), both arriving 2026-02-22, shipper JSC NAC KAZATOMPROM, consignee Converdyn, 'URANIUM (NAT.) UN, CLASS RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY', sea freight loaded in Georgia (Trans-Caspian route; Kazatomprom's uranium is mined by ISR in Kazakhstan). ConverDyn is the US marketing agent for UF6 conversion at Metropolis Works, Illinois. Gross weights include packaging; no value stated. Whether title passed to ConverDyn or the uranium is customer-owned conversion feed is not stated.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Uranium | 🇷🇺 RU 45% refining | 57 | 57 | Elevated | — | — | limited | 25 | ▲ rising |
| Niobium | 🇧🇷 BR 89% refining | 54 | 61 | Moderate | — | — | some | 5 | ▲ rising |
| Beryllium | 🇺🇸 US 89% mining | 49 | 49 | Moderate | — | — | limited | 1 | ▲ rising |
| Tantalum | 🇨🇳 CN 50% refining | 44 | 44 | Moderate | — | — | some | 12 | ▲ 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 |
|---|---|---|---|---|---|---|
| Uranium | 4 | 2 | 5 | 4 | 3 | company input |
| Niobium | 3 | 4 | 3 | 3 | 3 | company input |
| Beryllium | 3 | 4 | – | 4 | 1 | company input |
| Tantalum | 4 | 2 | – | 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.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
Two independent lenses: USGS official puts China at 50% of global refining output (by tonnage); US filers' own disclosures independently name China for 43% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| F&X Electro-Materials Ltd.CID460 | China | 14 | SEC |
| Hengyang King Xing Lifeng New Materials Co., Ltd.CID2492 | China | 14 | SEC |
| JiuJiang JinXin Nonferrous Metals Co., Ltd.CID914 | China | 14 | SEC |
| Ningxia Orient Tantalum Industry Co., Ltd.CID1277 | China | 14 | SEC |
| Ulba Metallurgical Plant JSCCID1969 | Kazakhstan | 14 | SEC |
Source: US SEC Form SD / Conflict Minerals Report exhibits (EDGAR full-text search), aggregated from RMI smelter tables. “US filers naming it” = distinct US-listed companies whose most-recent CMR names that refiner — disclosure-derived presence, not verified throughput. Link opens the SEC exhibit.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 24 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 🇷🇺 RU shock, these disclosed plants carry the binding Uranium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Uranium — 🇷🇺 RU escalates uranium controls to a full export-licensing / ban regime | 57 | 63 | +6 |
| Concentration | Uranium — 🇷🇺 RU becomes the single source for uranium — the second source is lost (full 45%+ monopoly) | 57 | 83 | +26 |
| Policy | Niobium — 🇧🇷 BR escalates niobium controls to a full export-licensing / ban regime | 54 | 62 | +8 |
| Concentration | Niobium — 🇧🇷 BR becomes the single source for niobium — the second source is lost (full 89%+ monopoly) | 54 | 60 | +6 |
| Policy | Beryllium — 🇺🇸 US escalates beryllium controls to a full export-licensing / ban regime | 49 | 64 | +15 |
| Concentration | Beryllium — 🇺🇸 US becomes the single source for beryllium — the second source is lost (full 89%+ monopoly) | 49 | 56 | +7 |
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 NAC Kazatomprom JSC 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 4 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one NAC Kazatomprom JSC 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 4 scored SRMs here are ones 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 |
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 2026-08-21; 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.