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8 critical materials scored · binding chokepoint: Dysprosium (🇨🇳 CN 99% of refining) · 63 restrictive government measures on record
A verification pass re-checked this dossier's ownership/corporate-structure fields against their cited sources. It did not re-read the material_exposures claim the score, band and stress figures below are built on — treat those as not yet independently re-checked.
Neo Performance Materials produces 8 of the 8 scored materials above (Dysprosium, Terbium, Gallium, Neodymium, Praseodymium, Niobium, Indium, 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 Critical · 85/100 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 Dysprosium — 🇨🇳 CN controls 99% of global refining. On this company's production footprint that scores 95/100 (adversarial chokepoint; global 88). The register holds 63 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Dysprosium Neo Performance Materials is the 116th-most-exposed of the 273 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.
Neo Performance Materials ranks 1st of 98 verified metals refining companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 39 further metals refining 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 85/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 8 scored materials. Buyer-relative (first-order): weighted by where the company produces (EE 55% · CN 35% · CA 10%, 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.
Neo Performance Materials (TSX: NEO) is a Toronto-headquartered, vertically diversified rare-earth and critical-metals processor operating in three segments: Magnequench (neodymium-iron-boron magnetic powders and, since 2025, finished sintered permanent magnets for EV traction motors and wind turbines), Chemicals & Oxides (separated rare-earth oxides — NdPr, heavy rare earths, and lanthanum/cerium products for catalysts), and Rare Metals (tantalum, niobium, gallium, indium and other specialty metals). Neo does not mine; it buys mixed rare-earth concentrate/metal feedstock and processes it downstream. Its Sillamäe (Estonia) plant is the only industrial-scale rare-earth separation facility outside Asia, and its 2025 Narva (Estonia) plant is Europe's first new sintered NdFeB magnet factory, explicitly positioned as a China+1 supply-chain alternative for European automakers and wind-turbine makers.
Neo separates NdPr oxide at Sillamäe and converts it into NdFeB magnetic powder (Tianjin) and finished sintered magnets (Narva). Unlike most dossier subjects, Neo sits upstream in the rare-earth chain rather than merely consuming magnets — but it is still exposed to Chinese-controlled mixed rare-earth concentrate feedstock and to China's ~90% share of global NdFeB magnet-making capacity that it competes against.
small-scale heavy rare earth (Tb/Dy) separation line at Sillamäe in 2024–2025, described as the first dysprosium/terbium solutions produced in Europe. These elements dope NdFeB magnets for high-temperature coercivity in EV motors; China dominates global heavy-rare-earth separation capacity.
produces and trades these specialty metals (electronics, superalloys, optics, semiconductors). Tantalum/niobium supply is concentrated in a handful of producing countries (DRC, Rwanda, Brazil); gallium and indium are both subject to Chinese export-licensing controls introduced 2023–2025, directly affecting this segment's feedstock costs.
China's April 2025 rare-earth export licensing regime is widely cited as the reason European automakers have paid premium pricing to Neo for supply security — Neo is a beneficiary of, and simultaneously exposed to, Chinese rare-earth policy. Neo also sold its majority stake in a China (Jiangyin/Zibo) separation JV to Shenghe Resources in 2024–2025, reducing its direct China separation footprint while keeping the Tianjin Magnequench operation.
the EU Just Transition Fund and is publicly framed as advancing the CRMA's 40%-domestic-processing target; the plant's formal status on the European Commission's CRMA Strategic Projects list was not independently verified for this profile and should be checked directly against the EC list before being asserted as fact.
(2025-09-19) reserving significant annual Narva sintered-magnet capacity. Not yet a definitive project-level offtake per the MoU structure. (A quotation attributed here to CEO Rahim Suleman was removed 2026-08-18 — it appears in none of the reachable cited sources.)
reporting; Schaeffler's e-Drives purchasing VP described 7+ years of supply-chain collaboration predating the Narva plant.
award (via subsidiary NPM Narva OÜ) covering ~35% of Narva Phase 1A finished-magnet capacity, revenue window 2026-2033, peak 2029; (2) a separate July 2025 award with a different Tier-1/OEM, ~$50M cumulative, deliveries from mid-2026. ~18,000 sample magnets shipped for PPAP; mass production later 2026.
catalysts; top-3 global producer for this category. 4 of 5 major customers requalified as of early 2025; names undisclosed.
magnets; supplies "some of the largest motor manufacturers in the world" for EV/PHEV traction motors, appliances, pumps, HDDs. Customer names generally confidential; Bosch is the one longstanding named relationship.
hybrid/fuel-cell vehicles and fuel injectors; customers unnamed.
semiconductors, MRI, capacitors; sole North American gallium recycler to semiconductor grade, Europe's largest hafnium recycler; customer names undisclosed.
Energy Fuels (US, monazite-derived carbonate) and Lynas — consistent with the facilities-registry Silmet entry's Russia (Solikamsk) diversification note.
Facility-identity correction, carried over from the source research: Neo has no Pori, Finland magnet plant. Its plant is Narva, Estonia (fed by Silmet in Sillamäe, ~30km away). The Pori-area facility (Ulvila, Finland) is Neorem Magnets, owned by Germany's Vacuumschmelze — a competitor, not Neo. Worth checking this dossier and the facilities registry never conflate the two.
6. Neo Performance Materials secures supply contract with major European motor manufacturer: https://projectblue.com/blue/news-analysis/976/neo-performance-materials-secures-supply-contract-with-major-european-motor-manufacturer 7. Neo's Narva Plant Lands First Major EV Magnet Deal with European Partners: https://emobilityplus.com/2025/07/10/neos-narva-plant-lands-first-major-ev-magnet-deal-with-european-partners/ 8. Neo Performance Materials Inc. Awarded New Supply Contract For Permanent Rare Earth Magnets (the unnamed ~$50M Tier-1/OEM award, mid-2026 deliveries; this article names neither Bosch nor Schaeffler, only an anonymized "European Tier 1 supplier"/"major OEM") [dead 2026-09-20, unreachable]: https://www.canadianmanufacturing.com/manufacturing/neo-performance-materials-inc-awarded-new-supply-contract-for-permanent-rare-earth-magnets-310760/ 9. Taking on China from Russia's border: Inside Neo's rare earths factory (CNBC, 2025-12-04) [dead 2026-09-20, 403]: https://www.cnbc.com/2025/12/04/taking-on-china-from-russias-border-inside-neos-rare-earths-factory.html 10. Neo Extends Strategic Partnership for High-Performance Magnets with Bosch (Neo's own press release, 2025-09-19 — primary source for the Robert Bosch GmbH MoU): https://www.neomaterials.com/neo-extends-strategic-partnership-for-high-performance-magnets-with-bosch/ 11. [SUPERSEDED 2026-09-20, ajot.com now 403] Rare earth magnet users jolted into paying premium prices for ex-China supply (Reuters, syndicated via AJOT, 2025-07-01): https://www.ajot.com/news/rare-earth-magnet-users-jolted-into-paying-premium-prices-for-ex-china-supply -- replaced by: Europe's EV Makers Line Up at Estonia's New Rare-Earth Magnet Plant (Bloomberg, 2025-09-19, Neo-announced signed Schaeffler/Bosch contracts): https://www.bloomberg.com/news/articles/2025-09-19/europe-s-ev-makers-line-up-at-estonia-s-new-rare-earth-magnet-plant 12. Wyloo to form Yangibana Joint Venture with Hastings and becomes largest shareholder in Neo Performance Materials (Wyloo/Tattarang press release, 2025-02-19/20 — 19.99% stake acquisition, ownership): https://www.newswire.ca/news-releases/wyloo-to-form-yangibana-joint-venture-with-hastings-and-becomes-largest-shareholder-in-neo-performance-materials-884714573.html
1. Neo Performance Materials — Q4 2025 results (segment revenue, Magnequench/C&O/Rare Metals): https://www.neomaterials.com/neo-performance-materials-reports-fourth-quarter-2025-results/ 2. Neo Performance Materials — heavy rare earth (Tb/Dy) separation line commissioning, Sillamäe: https://www.neomaterials.com/neo-successfully-commissions-heavy-rare-earth-separation-small-scale-production-line-in-europe/ 3. Invest in Estonia — Neo's Sillamäe (Silmet) and Narva facilities: https://investinestonia.com/neo/ 4. Mining.com — Neo's Estonia rare-earth separation facility, sustainability recognition: https://www.mining.com/neo-performances-estonia-ree-facility-recognized-for-sustainability-performance/ 5. Neo Performance Materials — sale of majority equity in China separation JV to Shenghe Resources [dead 2026-09-20, 404; claim not independently re-confirmed this pass]: https://www.neomaterials.com/neo-completes-sale-of-majority-equity-interest/
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.
Energy Fuels FY2025 Form 10-K (filed 2026-02-26): between 2021 and 2023 the company recovered MREC (mixed rare earth carbonate) from monazite sands at the White Mesa Mill, Utah (US), and the MREC was then sold to Neo Performance Materials for commercial separation into NdPr oxide at its separation facility in Silmet, Estonia (EE). The same filing says Energy Fuels itself began separated NdPr production in 2024, so these sales ended in 2023; the destination is Estonia, not Canada. Re-checked 2026-10-04: source_url resolves fine via direct fetch (the PACKET's automated HTTP probe 403s on SEC EDGAR's bot-blocking, not a dead filing).
Second named Silmet feedstock partner. Together with Energy Fuels this is the non-Russian diversification away from the Solikamsk supply noted in the facilities-registry Silmet entry — the two rows are the substance behind that note. Refresh 2026-09-29: no 2024+ source found stating which Lynas plant (Mt Weld AU or Kuantan MY) ships to Silmet (Estonia); origin left unstated.
A roughly 30-year bonded-magnet customer, and the one longstanding named relationship on the Magnequench side. Multi-year MoU dated 2025-09-19 reserving significant annual Narva sintered-magnet capacity — confirmed 2026-08-26 directly against Neo's own press release (source_url above); the previously-cited canadianmanufacturing.com/...-310760/ article does not mention Bosch or Schaeffler at all (it covers the separate unnamed ~$50M Tier-1 award below) and has been removed as a citation for this row. An MoU is not a definitive project-level offtake — do not render it as contracted volume. (A quotation previously attributed here to CEO Rahim Suleman was removed 2026-08-18: it appears in none of the reachable cited sources — checked canadianmanufacturing.com and projectblue.com live; emobilityplus.com returns 403.)
Named automotive customer of Narva output. Corrected 2026-10-04: the prior source_url (bloomberg.com/.../europe-s-ev-makers-line-up...) returns 403 as of this pass and was dropped. Replacement: Mining.com's coverage of the Narva plant's official 2025-09-19 opening reports Neo announced it had signed contracts with Schaeffler and Bosch for Narva sintered-magnet output. Still `websearch`/`secondary` (not a Neo filing or Neo-issued release).
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.
5 of 5 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% | Med | none | 51 | ▲ rising |
| Terbium | 🇨🇳 CN 99% refining | 93 | 84 | Critical | EXCEEDS 99% | Med | limited | 51 | ▲ rising |
| Gallium | 🇨🇳 CN 98% refining | 70 | 74 | High | EXCEEDS 98% | Med | ready | 9 | ▲ rising |
| Neodymium | 🇨🇳 CN 85% refining | 67 | 72 | Elevated | EXCEEDS 85% | High | some | 50 | ▲ rising |
| Praseodymium | 🇨🇳 CN 85% refining | 67 | 72 | Elevated | EXCEEDS 85% | High | some | 48 | ▲ rising |
| Niobium | 🇧🇷 BR 89% refining | 61 | 61 | Elevated | — | Med | some | 5 | ▲ rising |
| Indium | 🇨🇳 CN 69% refining | 61 | 64 | Elevated | — | Med | limited | 2 | ▲ rising |
| Tantalum | 🇨🇳 CN 50% refining | 41 | 44 | Moderate | — | Med | 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 |
|---|---|---|---|---|---|---|
| Dysprosium | 4 | 5 | 5 | 5 | 3 | company input |
| Terbium | 4 | 5 | 5 | 4 | 3 | company input |
| Gallium | 5 | 5 | 3 | 3 | 3 | company input |
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Praseodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Niobium | 3 | 4 | 3 | 3 | 3 | company input |
| Indium | 4 | 3 | 5 | 3 | 4 | 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.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 48 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 Neo Performance Materials 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 2026-10-05) — 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 6 of these 31 materials (Gallium, Neodymium, Dysprosium, Praseodymium, Terbium, Indium) — your binding Dysprosium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 4.5 months apart across 9 distinct restriction dates since 2023 (n=8 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 | Gallium — 🇨🇳 CN escalates gallium controls to a full export-licensing / ban regime | 70 | 73 | +3 |
| Concentration | Gallium — 🇨🇳 CN becomes the single source for gallium — the second source is lost (full 98%+ monopoly) | 70 | 71 | +1 |
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 Neo Performance Materials 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 Neo Performance Materials 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 8 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 Neo Performance Materials 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 8 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | metals-refining (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 2026-10-05
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