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5 critical materials scored · binding chokepoint: Graphite (🇨🇳 CN 85% of refining) · 89 restrictive government measures on record
The binding exposure is Graphite — 🇨🇳 CN controls 85% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 77). The register holds 89 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Graphite Northvolt AB (in restructuring / receivership) is the 39th-most-exposed of the 205 named companies we track on 🇨🇳 CN's Graphite chokepoint; the most-exposed is Leading Edge Materials (Norra Kärr) (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Company supply-risk index 83/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 5 scored materials. Buyer-relative (first-order): weighted by where the company produces (SE 70% · DE 12% · CA 10% · PL 5% · US 3%, 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: Electrolyte-additives — no supply-risk series is tracked for it here.
This is the first dossier in the corpus on a company in receivership. Northvolt AB — Europe's flagship gigafactory champion — filed US Chapter 11 in Q4 2024 (parent + key US/SE subsidiaries) and the Swedish parent moved into konkurs in Q1 2025 after Chapter 11 reorganisation could not close operating-cash gaps. As of this dossier's 2026-08-24 recheck, most of the disposition has already resolved: Skellefteå, Northvolt Labs, Cuberg's production assets and Revolt Ett recycling have all been acquired by a single US buyer (Lyten Inc.); Northvolt Drei (Heide, Germany) is under exclusive MoU targeting a Q3 2026 close; and the Saint-Basile-le-Grand QC greenfield project was declared dead by the Québec government in Sep 2025 and is no longer a live disposition asset. See "What they did / what remains" for the corrected, sourced detail.
The dossier is therefore framed differently from the other 16: rather than "how does the policy stack reshape this operating company's options," it is "what does the EU industrial-policy stack do with a failed champion, and what does the failure reveal about the stack itself?" This is the value the closure-case dossier adds to the corpus that no operating-company dossier can.
Northvolt was built 2016-2024 as the European answer to the Asian Tier-1 battery-cell concentration (CATL, BYD, LG ES, Samsung SDI, SK On, Panasonic). The footprint at peak operating intent:
multi-phase; integrated cathode-active-material (CAM) → cell line designed as the EU's only large-scale non-Chinese full-stack cell manufacture.
closed-loop Ni-Co-Li-Mn recovery feeding back into CAM line.
customer-sample manufacturing.
off-take commitments; ~16 GWh first phase. Suspended Q4 2024 then partially divested in restructuring.
backed greenfield, ~30 GWh; was the IRA-Canada-EU triangulation asset (CMETC + Stellantis-NextStar-corridor adjacency + EU origin under EU-Canada strategic partnership).
R&D; Northvolt's principal next-gen chemistry option.
Customer offtake commitments at peak: BMW (cancelled Q2 2024, ~EUR 2bn order to Samsung SDI), VW, Volvo, Polestar, Scania + EU energy-storage utilities. Cumulative equity + debt raised over the 2017-2024 period was reported in excess of EUR 14bn — making the failure the largest single industrial-startup bankruptcy in modern European history.
acquired the production facilities/assets Nov 2024.
(Västerås) — Lyten's acquisition completed 27 Feb 2026**, after clearing Swedish ISP FDI screening (Sweden Act 2023:560) — the screening-outcome question this dossier's Surface 2 posed is answered: approved, not prohibited or conditioned in a way that blocked the deal. Gives Lyten ~16 GWh of existing manufacturing capacity, 160+ hectares, and the R&D center.
with KfW/federal/Schleswig-Holstein state sellers, ~EUR 60m; Lyten assumed some operating costs from 1 Jul 2026; definitive sale agreement targeted Q3 2026 and not yet closed as of this check.
dead by the Québec government in Sep 2025 (before this dossier's 2026-08-20 last-refresh): Québec ended all further financing and wrote off its CAD 270m investment (of CAD 510m committed). Lyten had expressed interest but talks stalled — Lyten wanted more government funding than Québec would offer and more due-diligence time; no transaction resulted. This project should be treated as effectively wound down**, not as a live receiver-disposition asset.
acquired by Lyten; one Lyten statement expects to supply Dwa with cells from H2 2026, which is a customer relationship, not an acquisition. Status otherwise unconfirmed this pass — flagged, not asserted.
Net effect: this is now much closer to a single-acquirer consolidation story than the multi-bidder FDI-screening stress test the dossier previously framed it as. The Sweden ISP / IAA conditionality questions below are largely resolved for the Swedish assets (Lyten cleared) and still open only for the Germany close and (moot) Québec.
Northvolt is the named counterfactual of EU industrial-policy intent. Every other dossier in the corpus is a company adapting to the post-2023 EU/US industrial-policy stack; Northvolt is the company the stack was — in significant part — designed to support, and which failed anyway. The 16 Dec 2025 EU Automotive Package (Battery Booster Strategy + Automotive Omnibus + CO2 averaging) and the 4 Mar 2026 Industrial Accelerator Act are the institutional EU-side response to that failure. The IPTM action prose for both explicitly names Northvolt's restructuring as the trigger event. Reading those instruments without Northvolt as the case is reading them with the precipitating event removed.
| Date | Action | Severity | Why it touches Northvolt |
|---|---|---|---|
| 2023-08-17 | EU Battery Regulation 2023/1542 | 4 | Northvolt-architected carbon-footprint / due-diligence / recycled-content rules — designed in significant part to translate Northvolt's circularity story (Revolt Ett + low-Nordic-grid-carbon CAM) into a regulatory moat. The moat survived; the company didn't. |
| 2023-12-01 | Sweden Act 2023:560 FDI screening | 4 | Northvolt explicitly listed in ISP's first-year company_refs. 30/50/65/90% notification thresholds + "critical raw materials/metals/minerals" + "emerging or strategically protected technologies" perimeter cover Skellefteå CAM line + Revolt Ett + Cuberg IP. Every prospective receiver-asset acquirer is in scope. |
| 2024-06-22 | EU Net-Zero Industry Act | 3 | NZIA's strategic-project status conferred on EU gigafactories including Northvolt SE; this was the structural top-up to capex grants under IPCEI Battery I/II. NZIA support was capex-side, not operating-cash-side — the binding constraint Northvolt actually hit. |
| 2024-07-19 | EU-Serbia Strategic Partnership MoU — Critical Raw Materials | 3 | Designed to feed lithium into Northvolt + ACC + InoBat. Action prose explicitly names "Northvolt successor projects" — already framed in the post-bankruptcy register. |
| 2024-10-01 | Canada China-surtax order | 4 | Provided direct fiscal cover for Northvolt Saint-Basile-le-Grand QC under the trilateral EV-tariff perimeter (US §301 100% → CA 100% → EU CVD). The protection didn't reach the working-capital line. |
| 2025-02-26 | EU Clean Industrial Deal | 4 | First major EU instrument to acknowledge that the cell-maker EU footprint requires operating-cash support, not just capex grants. Battery Booster's design lineage starts here. Northvolt is named in CID's beneficiary illustrations. |
| 2025-03-05 | EU Industrial Action Plan — Automotive Sector COM(2025) 95 | 5 | Names "surviving Northvolt assets post-restructuring" as direct beneficiary of EUR 1.8bn IF earmark per kWh (§45X-import mechanism); 2025-2027 averaged CO2 compliance window quietly transfers EUR 15-20bn from pool-fine enforcement to OEM balance sheets, freeing customer demand for surviving cell capacity. |
| 2025-03-25 | EU CRMA — Strategic Projects first designation | 4 | Action prose explicitly references "Northvolt successors" as beneficiary downstream of upstream lithium/nickel/graphite SPs. The naming pattern signals Brussels has institutionally accepted that the cell-maker layer will be acquirer-rebuilt, not greenfield-reconstructed. |
| 2025-07-10 | Finland — EasPring CAM Kotka subsidy | 3 | Chinese-affiliated CAM supplier inside the EU; supply-chain adjacent. Demonstrates EU member states are willing to subsidise Chinese-affiliated upstream supply into the cell layer — the layer Northvolt was supposed to anchor non-Chinese. |
| 2025-07-10 | Portugal Despacho 7824/2025 — Savannah lithium Barroso | 3 | Action prose names Northvolt among prospective EU-battery offtakers for Barroso lithium. Now post-bankruptcy, Savannah's offtake architecture re-orients toward ACC/Verkor/InoBat. |
| 2025-10-09 | China MOFCOM Announcement No. 58 — lithium battery + graphite export controls | 3 (suspended) | Synthetic-graphite-anode licensing regime over Chinese ~95% global share. Pending re-activation 10 Nov 2026. Skellefteå's anode line was the one large non-Chinese anode capacity nominally coming online in EU; its loss + Announcement-58 re-activation risk leaves the EU cell sector structurally non-resilient at the anode layer. |
| 2025-12-03 | EU ResourceEU Action Plan COM(2025) 945 | 5 | LIT / battery-materials cluster names "Northvolt" in upstream-offtake architecture. Confirms ResourceEU treats Skellefteå / Saint-Basile as recoverable infrastructure rather than written-off assets. |
| 2025-12-16 | EU Battery Booster Strategy C(2026) 682 | 3 | The single most consequential post-failure instrument. EUR 1.5bn interest-free loan facility framed as "triage instrument - keeping European-headquartered cell makers solvent." Open question (action prose, line 169-170): "Will the EUR 1.5bn envelope be sufficient to keep all three of ACC, Verkor and Northvolt-successor entities operational, or will the Facility de-facto crown one or two national champions?" |
| 2026-03-04 | EU Industrial Accelerator Act COM(2026) 100 | 5 | Action prose names "Northvolt successors" in the EU domestic clean-tech procurement-pull cluster. Made-in-EU procurement preference + FDI conditions on EU equity/IP/employment for >EUR 100m projects directly conditions any prospective Chinese/PRC-affiliated acquirer of Skellefteå/Saint-Basile. |
| 2026-04-24 | EU-US Critical Minerals Strategic Partnership | 4 | Saint-Basile-le-Grand QC was structured to be the IRA-Canada-EU triangulation. The EU-US partnership operationalises that triangulation post-hoc — receiver-disposition acquirers of Saint-Basile gain access to §30D-eligible cell supply into the US, provided FEoC perimeter cleared. |
Register-state note added 2026-08-24: the table above is the IPTM register's record as filed and is left as-is (this dossier does not edit the register). Two rows' forward-looking framing has since been overtaken by events this dossier's recheck confirmed independently: the 2025-12-03 ResourceEU Action Plan (row above) describes Saint-Basile as "recoverable infrastructure," and the 2026-04-24 EU-US partnership describes a "receiver-disposition acquirer of Saint-Basile" scenario — but Québec declared the Saint-Basile project dead and ended financing in Sep 2025, before both of those actions were filed. Whether the EU drafting was unaware of the Québec decision or intentionally describes an option that no longer has a live provincial funding partner is not resolvable from this dossier's sources; flagged for the IPTM audit process rather than corrected here.
C(2026) 682 sets the framework; per-project allocations are forthcoming. Corrected framing: the highest-impact watch event is no longer "does a Northvolt-successor entity at Skellefteå" get funded — Skellefteå is now Lyten's (US-owned) — but whether Lyten's Swedish/ German operations qualify as "European-headquartered cell makers" under the Facility's eligibility criteria at all, given US ownership.
RESOLVED for the Skellefteå/Labs disposition: Swedish authorities approved Lyten's acquisition, completed 27 Feb 2026 — the "cleanest read on Sweden's actual willingness to use the Act for industrial-strategic purposes" this dossier asked for is: approved, not prohibited or conditioned into collapse, for a US (not EU, not PRC) acquirer. Still open: the Drei/Heide transaction close.
Member-state implementation drift (FR/IT protectionist enthusiasm vs. DE/SE/NL open-market preservation) is now most relevant to whether the Drei/Heide close (KfW/federal/state sellers, Lyten buyer) draws FDI-conditionality scrutiny under the >EUR 100m threshold — the Korean/PRC-affiliated-acquirer framing this bullet previously used did not end up applying to any of the actual dispositions.
decision** (10 Nov 2026 suspension expiry). If re-activated, the EU cell-sector anode-layer non-resilience becomes operational rather than theoretical.
Sell-side and policy press treat the 2025-12-16 EU Automotive Package + 2026-03-04 IAA as forward-looking industrial-policy upgrades. The structural read is that they are also the institutional response to a specific failure: the EUR 1.5bn interest-free loan envelope is explicitly described in C(2026) 682 as a triage instrument for existing cell makers, and the Industrial Action Plan COM(2025) 95 explicitly names "surviving Northvolt assets post-restructuring" as a direct beneficiary class.
The shift from capex grants (IPCEI Battery I/II, NZIA strategic-project status) toward operating-cash instruments (interest-free loans, §45X- mechanism per-kWh, CO2 averaging deferring fines) is a methodological change in EU industrial policy that the Northvolt failure precipitated. Before the failure, the EU theory of the case was "fund the capex, operations will be commercially viable." After the failure, the theory is "fund the operations through the ramp gap." That is the most important shift in EU industrial-policy doctrine of 2025-2026, and Northvolt is its named precipitating case.
The Sweden FDI Act covers acquisitions of ≥10% (with notification thresholds at 30/50/65/90%) in entities conducting "skyddsvärd verksamhet" defined to include critical raw materials, dual-use goods, emerging or strategically protected technologies. Northvolt qualifies under multiple sub-categories simultaneously. ISP's first-year enforcement record (1 prohibition, 5 conditional approvals on 1,206 notifications) was light-touch. The Skellefteå CAM line + Cuberg lithium-metal IP + Revolt Ett recycling architecture is the most-protected-business-activity-laden single bankruptcy estate ISP has ever seen.
This is also the first post-IAA-anticipation test: prospective acquirers know the IAA's >EUR 100m FDI conditionality threshold is moving toward final adoption, and structurally have an incentive to phase transactions sub-threshold or route through Korean/Japanese intermediaries (per the IAA action prose, line 149-150). The Sweden ISP decision on the Skellefteå disposition is therefore not just a single-asset decision — it is the methodological precedent for how the EU FDI-screening apparatus polices industrial-policy infrastructure inherited via bankruptcy rather than acquired going-concern.
Resolved, 2026-08-24 recheck: Swedish authorities approved Lyten's (US) acquisition of Northvolt Ett/Ett Expansion and Northvolt Labs, completed 27 Feb 2026 — the precedent this surface anticipated now exists, and the answer is approval, not prohibition or a golden-share-style condition, for a non-EU/non-PRC acquirer. The IAA-conditionality boundary case this surface flagged (Korean/Japanese routing to phase sub-threshold) did not end up being tested — no Korean or PRC-affiliated bidder acquired any Northvolt asset.
China's ~95% global share of synthetic graphite anode means every non-Chinese cell maker — Northvolt, ACC, Verkor, PowerCo — depends on Chinese-origin anode material directly or through Chinese equipment OEMs. MOFCOM Announcement No. 58 (suspended through 10 Nov 2026 by Announcement No. 70) is the policy instrument that would weaponise that dependency.
Skellefteå's anode line was the one large-scale non-Chinese anode capacity nominally coming online inside the EU. Corrected 2026-08-24: this dossier previously framed its fate as "loss via receiver- disposition." On recheck, the Skellefteå/Ett line and Revolt Ett (recycling, which the anode-adjacent process scope sits within) were both acquired by Lyten (completed 27 Feb 2026 and announced 13 Mar 2026 respectively) rather than shut down or stranded — so the capacity is not lost, but it is now under US ownership, which changes rather than resolves the "non-Chinese but is it EU/Made-in-EU-eligible" question this surface raises: Lyten's Swedish anode line may qualify as non-Chinese capacity for MOFCOM-Announcement-58-resilience purposes while still raising the separate question of whether US ownership counts toward Battery Booster / IAA "Made-in-EU" or European-headquartered-cell-maker eligibility criteria. That eligibility question — not physical loss of the line — is the live uncertainty heading into the 10 Nov 2026 MOFCOM re-activation decision.
Saint-Basile-le-Grand was structured to capture both Canada's CMETC + First/Last-Mile Fund + Strategic Innovation Fund support, NextStar-corridor adjacency to Stellantis-LGES Windsor, IRA §30D eligibility via Canada-as-FTA jurisdiction, and EU origin under the EU-Canada Strategic Partnership. The triangulation should have made Saint-Basile the highest-fiscal-support cell-maker geography in the world. It did not save the parent — and, updated 2026-08-24, it did not survive the parent's failure either: Québec declared the project dead and ended all further financing in Sep 2025, writing off CAD 270m of a CAD 510m commitment. Lyten expressed interest in acquiring it alongside the Swedish and German assets but talks stalled (Lyten wanted more due-diligence time and more government funding than Québec would offer); no transaction resulted. The triangulation thesis below is best read as a closed historical case, not a live disposition asset.
The structural lesson — now encoded into the EU Battery Booster's "operating-cash" methodology and the IAA's Made-in-EU procurement- pull design — is that fiscal support stacked on capex is not substitutable for operating-cash support stacked on ramp-phase working capital. The Class-1 nickel sulphate cost premium during 2024 (Indonesian hilirisasi-routed Class-1 supply at a premium that producer-state royalty + smelter moratorium effectively transmitted to EU cell-maker BOM costs) was the binding constraint, and no capex grant could absorb it.
This reads cross-axis to case #2 (Indonesia Hilirisasi Ladder): the hilirisasi instrument's full economic effect was its transmission into EU cell-maker working-capital pressure via Class-1 sulphate pricing. The EU side had no instrument to absorb it. The Battery Booster's interest-free loans are designed for exactly that transmission hole.
in progress. A 2023-2024 strategic shift to sodium-ion at scale would have eliminated the Class-1 nickel sulphate + cobalt sulphate cost-of-materials exposure that drove the working-capital crunch. Northvolt prioritised the all-in NMC + LFP roadmap. CATL's parallel sodium-ion commercialisation by Q4 2025 shows the technical path was available; equity-research consensus did not price sodium-ion as a viable EV-cell chemistry until late 2024, by which point Northvolt's pivot window was closed by liquidity.
Skellefteå + Drei (DE) + Saint-Basile (CA) + Dwa (PL) + Cuberg (US) footprint required parallel capex commitment that the balance sheet couldn't sustain. A 2023 strategic decision to ringfence Skellefteå and divest/delay the rest would have preserved the Swedish-anchor narrative and reduced operating cash burn by an order of magnitude. The BMW order cancellation (Q2 2024) was the signal the demand-side believed multi-site execution had become unviable.
strategic equity injection from LG ES / Samsung SDI / SK On during the 2023-2024 capital-raise window would have provided working-capital backstop at the cost of technology-transfer optics. The Korean Tier-1 cell makers are below the 40% global- share trigger under IAA conditionality and would not have invited FDI prohibition. The political optics in Sweden + EU industrial- policy circles framed Tier-1 Asian equity as a strategic loss; the structural read is that the alternative — full bankruptcy + receiver-disposition with PRC-affiliated acquirers in the bidder pool — was strictly worse.
Disposition architecture of Skellefteå under Sweden Act 2023:560. This dossier previously framed the receiver-level decision as a binary among (a) a Korean Tier-1 acquirer, (b) a Swedish-led re-organised vehicle, or (c) a PRC-affiliated acquirer. None of those three materialised. The actual outcome: Lyten Inc. (US) — not named among the three illustrative options — acquired Northvolt Ett + Ett Expansion and Northvolt Labs, completed 27 Feb 2026, after clearing Swedish ISP FDI screening. Lyten also holds an exclusive MoU (1 Jul 2026, not yet a closed definitive agreement) for Northvolt Drei/Heide in Germany, and announced acquisition of Revolt Ett recycling (13 Mar 2026).
The still-open question, narrower than before: does the Drei/Heide deal close as MoU'd in Q3 2026, and does German FDI/subsidy-clawback review (the KfW/federal/state sellers are themselves the counterparties) attach conditions. Saint-Basile-le-Grand is no longer part of the live decision space — Québec ended financing and declared the project dead in Sep 2025.
Watch events (updated):
2026-Q3) — the one remaining unresolved disposition milestone.
now a question about Lyten's Swedish/German operations' eligibility as the "European-headquartered cell maker" beneficiary class, not about Northvolt AB itself.
the EU-cell-maker-side translation of the Indonesian hilirisasi policy. The Class-1 nickel sulphate cost premium driven by Permen ESDM 17/2025 RKAB quota + PP 19/2025 tiered royalty + PP 28/2025 smelter moratorium transmitted directly to Northvolt's BOM. Case #2 thus has a named industrial-failure counterfactual inside the EU.
via the Sonic Bay HPAL JV (BASF + Eramet pulled out July 2024); the parallel withdrawal of both BASF (precursor side) and the Northvolt-customer-side is not coincidence — it reflects the joint working-capital and cost-of-materials thesis collapsing simultaneously.
battery-precursor JV and Northvolt's Q4 2024 Chapter 11 filing are the two ends of the same EU-Class-1-precursor-chain failure. The Ludwigshafen rationalisation announcement and the Northvolt bankruptcy share an industrial-policy backdrop.
arbitrage; the Northvolt-supply alternative would have stress- tested ACC's pricing leverage. Without it, Stellantis is more bound to ACC's Termoli (IT) restart timing + LFP-chemistry shift.
matte non-FEoC Class-1 pathway was structurally one of the few IRA-eligible Asian Class-1 sourcing chains available to Northvolt; the offtake architecture would have stabilised both sides. Vale's Class-1 strategy pivot is now decoupled from a named EU-cell-maker counterparty for the first time.
supply was a structural Northvolt offtake. The post-failure Marketing-book re-routes toward CATL / BYD / LG ES Tier-1 demand at the structural margin that Northvolt's solvency would have preserved for European cell makers.
Refresh triggers, updated 2026-08-24: (i) Northvolt Drei/Heide definitive sale agreement close (targeted 2026-Q3) — the one remaining open disposition milestone; (ii) Battery Booster first-tranche implementing decision, now specifically whether Lyten's Swedish/German operations qualify as eligible beneficiaries under US ownership; (iii) IAA final adopted text including final member-state implementation guidance; (iv) MOFCOM Announcement No. 58 re-activation decision in Nov 2026; (v) any German FDI/subsidy-clawback condition attached to the Drei/Heide close. Saint-Basile-le-Grand and the Skellefteå/Labs/Cuberg/ Revolt Ett dispositions are resolved and no longer refresh triggers. The dossier is maintained as a postmortem-plus-live-disposition artefact and should be re-frozen to "historical postmortem only" once the Drei/ Heide close finalises (estimated 2026-Q3/Q4).
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.
BMW signed a long-term battery-cell supply contract with Northvolt in 2020 for its fifth-generation cells (Skellefteå, 100% renewable-powered); cancelled the ~EUR2bn order in June 2024 after Northvolt fell ~2 years behind schedule with high reject rates. Samsung SDI took the replacement order. BMW retained Northvolt as supplier for next-gen Neue Klasse cells at time of cancellation per this source.
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.
3 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 |
|---|---|---|---|---|---|---|---|---|---|
| Graphite | 🇨🇳 CN 85% refining | 88 | 77 | Critical | EXCEEDS 85% | High | hard | 27 | ▲ rising |
| Manganese | 🇨🇳 CN 90% refining | 83 | 69 | High | EXCEEDS 90% | Low | none | 12 | ▲ rising |
| Cobalt | 🇨🇳 CN 78% refining | 75 | 62 | High | EXCEEDS 78% | Low | some | 37 | ▲ rising |
| Lithium | 🇨🇳 CN 65% refining | 72 | 61 | High | within 65% | High | some | 40 | ▲ rising |
| Nickel | 🇨🇳 CN 36% refining | 64 | 55 | Elevated | within 36% | High | limited | 29 | ▲ 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 |
|---|---|---|---|---|---|---|
| Graphite | 4 | 4 | 5 | 4 | 4 | company input |
| Manganese | 4 | 4 | 1 | 5 | 3 | company input |
| Cobalt | 4 | 3 | 3 | 3 | 3 | company input |
| Lithium | 4 | 3 | 5 | 3 | 3 | company input |
| Nickel | 4 | 2 | 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.
+ 74 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:
Counterfactual: Indonesia extends the hilirisasi ore-ban template (2020 nickel → 2023 bauxite) to the next rung of battery-mineral exports — tightening upstream supply for cobalt intermediates, lithium feedstock and graphite alongside the existing nickel + aluminium regime. Direct-hit lines are basket issuers whose binding material is a battery-cell input (nickel, cobalt, lithium, graphite) — irrespective of controller, since the template-export is global supply-chain pressure not bilateral targeting.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 88 → 92 (+4) — a relative official policy-pressure magnitude, not a price drawdown.
🇨🇳 CN has issued 5 restrictive actions on Graphite since 2023 — cadence accelerating (mean gap 360d → 129d), severity flat (4.5 → 2.3).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 3 of these 16 materials (Cobalt, Lithium, Graphite) — your binding Graphite exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 10.7 months apart across 7 distinct restriction dates since 2016 (n=6 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 | Graphite — 🇨🇳 CN escalates graphite controls to a full export-licensing / ban regime | 88 | 92 | +4 |
| Concentration | Graphite — 🇨🇳 CN becomes the single source for graphite — the second source is lost (full 85%+ monopoly) | 88 | 94 | +6 |
| Policy | Manganese — 🇨🇳 CN escalates manganese controls to a full export-licensing / ban regime | 83 | 88 | +5 |
| Concentration | Manganese — 🇨🇳 CN becomes the single source for manganese — the second source is lost (full 90%+ monopoly) | 83 | 88 | +5 |
| Policy | Cobalt — 🇨🇳 CN escalates cobalt controls to a full export-licensing / ban regime | 75 | 81 | +6 |
| Concentration | Cobalt — 🇨🇳 CN becomes the single source for cobalt — the second source is lost (full 78%+ monopoly) | 75 | 89 | +14 |
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.
This assessment identifies 2 significant vulnerabilities — Graphite, Manganese — each a High/Critical exposure that is hard to substitute and already under at least one in-force restrictive measure. This engages the duty under Art. 24(4) to take mitigating efforts, including assessing diversification of the supply chain or substitution of the material (see Priority mitigations below).
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 materials this company buys. The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — 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.
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Graphite).
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 | Yes — 5 scored SRMs on the input side (binding: Graphite) |
| Manufactures a listed strategic technology | ev-battery-cells (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.