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1 critical material scored · binding chokepoint: Silicon (🇨🇳 CN 80% of refining) · 19 restrictive government measures on record
The binding exposure is Silicon — 🇨🇳 CN controls 80% of global refining. On this company's production footprint that scores 76/100 (adversarial chokepoint; global 64). The register holds 19 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Silicon NVIDIA Corporation is the 422nd-most-exposed of the 832 named companies we track on 🇨🇳 CN's Silicon chokepoint; the most-exposed is aerodyn Engineering GmbH (77/100). 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 76/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 1 scored material. Buyer-relative (first-order): weighted by where the company produces (TW 75% · MX 10% · US 8% · KR 5% · TH 2%, 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.
NVIDIA is a fabless semiconductor designer whose H100, H200, B100/B200, GB200 NVL72 and successor accelerator generations are the de facto training and inference substrate of the global AI build-out. The business sits on five revenue franchises: (1) data-center compute — GPU accelerator systems (HGX, DGX, NVL72 reference designs) plus the CUDA / cuDNN / TensorRT software estate that constitutes the dominant moat; (2) networking — Spectrum-X Ethernet, Quantum-X InfiniBand, BlueField DPUs and the NVLink/NVSwitch fabric (the post-Mellanox acquisition gear is now structurally inside every advanced-AI cluster sold); (3) gaming and professional visualisation — GeForce RTX and RTX Pro / Quadro lines, increasingly cross-subsidised by data-center silicon; (4) automotive and embedded — DRIVE Orin / Thor compute modules into ADAS and L4-aspiring stacks (BYD, Mercedes, Volvo Cars, Hyundai, Toyota); and (5) Omniverse / industrial simulation — the synthetic-data and digital-twin franchise that is the long-tail option on robotics and physical AI. The customer base for the data-center franchise concentrates into Microsoft Azure, Amazon AWS, Google Cloud, Meta, Oracle Cloud, CoreWeave and a fast-growing sovereign-AI tier (G42 Abu Dhabi, Humain Saudi Arabia, AI Singapore, UK DSIT, KR Naver/ KT/Kakao via MSIT, JP Sakura/SoftBank, India via SovAI). Manufacturing is captive to TSMC (wafer + CoWoS advanced packaging at Fab 18 / AP6 / AP7), Samsung Foundry (limited second-source), SK Hynix (HBM3E lead supplier), Samsung and Micron (HBM3E / HBM4 second/third source), and Foxconn / Wistron / Quanta (system assembly in Mexico, Taiwan and mainland China).
NVIDIA's bill of materials is concentrated in a small set of inputs where the supply or the routing has become structurally policy- exposed:
GB200, GB300 and successor SKU carries 80-192 GB of HBM3 / HBM3E / HBM4. SK Hynix is the lead supplier (62% of global HBM shipments, 57% of HBM revenue as of Q2/Q3 2025 per Counterpoint Research), Samsung the contested second source, Micron the third. The 2024-12 BIS package (action table) put HBM stacks meeting the BIS performance threshold under licensing for export to China — the control is structurally about the memory stack sold separately, but the read-across is that any future tightening of HBM3E/HBM4 export rules would compress NVIDIA's China-compliant SKU envelope before it compresses NVIDIA's chip-side. Cross-reference: docs/minerals/materials/hbm-dram.md (placeholder until populated).
capacity at TSMC AP6 / AP7 / AP8 is the single hardest physical bottleneck on NVIDIA's data-center ramp. The capacity is not formally regulated, but every Taiwan-side controls action (Taiwan-MOEA SHTC Entity List additions of Huawei/SMIC, Statute for Industrial Innovation Article 22.67.3 outbound-investment screening) and every TSMC-EU/US fab-build incentive (EU Chips Act, US CHIPS Act ESMC Dresden / Fab 21 Arizona) sits upstream. Cross-reference: docs/minerals/materials/cowos.md (placeholder).
cooling fans (Asia Vital Components, Foxconn) and DGX/HGX power- delivery servo motors run on Nd / Dy / Tb-doped magnets. China controls ≥85% of the heavy-rare-earth refining step. The 2025-04 heavy-rare-earths export licensing and 2025-10 extraterritorial control regime sit upstream of this dependency. Cross-reference: docs/minerals/materials/neodymium.md.
NVIDIA's direct exposure but propagates from the foundry layer. Cross-reference: docs/minerals/materials/helium.md.
Not policy-controlled but a CoWoS-adjacent bottleneck.
Tijuana), Wistron Mexico, Quanta Tennessee. The 2026-01-14 Section 232 25% tariff on advanced computing chips and derivative products applies at HTS-classification of finished AI systems landed in the US — this is the most operationally consequential post-tariff event for NVIDIA's gross-margin line, and is structurally distinct from the chip-side export-control regime.
Rendered live from the register below, driven by this dossier's action_relevance: frontmatter (migrated 2026-08-21, queue #128) — date, severity and severity_basis are read directly from each action's current frontmatter and can never drift from the hand-typed table this replaced.
Five ongoing policy processes carry asymmetric NVIDIA exposure and warrant active monitoring:
suspension expires by default unless extended. NVIDIA's channel- KYC function has to be ready to re-screen the full ≥50%-owned affiliate tree of all listed parents — a structurally significant reset for the distribution / reseller estate. Calendar event.
Proclamation directs Commerce to enumerate "derivative products" in subsequent FR notices — initial list narrow, but each addition expands the HTS-classification perimeter under which finished AI systems landed in the US carry the 25% tariff. The 90-day Commerce comment cycles are the watch event.
General-Purpose AI obligations entered into force Aug 2025; high-risk-AI system obligations enter into force Aug 2027. NVIDIA's DRIVE Thor automotive stack and DGX Cloud customer-deployment model fall under transparency, traceability and CE-marking obligations.
implementation)**. The upstream signal for the next EU Delegated Regulation Annex I update. Items to watch: ECCN 3A090.a / 4A090.a performance-threshold parity with BIS, plus possible high-NA- fabrication-related categories that propagate into NVIDIA's CoWoS-equipment second-order supply.
Brazil**. The RTE template is the architectural product. Each bilateral concluded (and there are 6-10 actively negotiated) is a forward booking of a dedicated GB300 / Rubin allocation and a consolidation of NVIDIA as the de facto sovereign-AI integrator.
Four credible adjustment paths under further policy stress, with the trade-off costs visible:
material commercial export-compliance instrument the industry has built. The strategic decision is whether to spin out the RTE template — as a "Sovereign AI Compliance Stack" SKU bundled with the chip — to Humain (KSA), SovAI (IN), Stargate Brazil (BR), PIDC-Singapore. If executed, NVIDIA captures revenue from the compliance wrapper (a structurally moated channel), and the BIS perimeter becomes a commercial product of NVIDIA's rather than a binding constraint on it. If not executed, the H20-style precedent risks compression on each export-control cycle.
is partially structural (HBM3E qualified first into H100/H200/B100) and partially policy-vulnerable (Korean-fab consolidation under September 2025 VEU revocation). The B200/GB300/Rubin generations ought to ramp Samsung HBM4 qualification and Micron HBM4 second- source as a hard de-concentration target — material to FY27-28 margin stability under any Korea-side disruption.
Houston/Austin GB200 NVL72 line and Quanta Tennessee expansion are the principal Section-232-mitigation paths. The capex velocity at these sites determines how much of the 25% chip tariff is absorbed vs. passed through; FY27 capital plan disclosures are the watch event.
AI tier (G42 / Humain / SovAI / DSIT / MSIT / Sakura / Singapore) collectively absorbs an increasingly large share of forward bookings. Concentration risk inverts the historical hyperscaler concentration risk — sovereign customers are politically rather than commercially driven, and their procurement cycles are asynchronous with hyperscaler refresh. Watch the share-of-revenue disclosure for sovereign-tier customers.
The biggest open management decision is whether to productise the G42 RTE compliance wrapper as a standalone Sovereign AI Stack SKU. The framework was negotiated as a bilateral arrangement; commercialising it as a multi-jurisdictional product is the highest-leverage path to turning the export-control architecture into an NVIDIA revenue moat rather than a binding constraint. Capital allocation, channel-management hires, and Commerce/State Department engagement frequency are the signals to watch.
Refreshed quarterly by default, or on any of: (a) a new IPTM-registered action by US BIS, US Treasury / OFAC, EU DG TRADE, JP METI, KR MOTIE or TW MOEA with target_sectors including semiconductors or ai-compute; (b) a PRC MOFCOM rare-earth, HBM-relevant or country- specific dual-use control update; (c) an NVIDIA capital-allocation event (HBM second-source qualification, US system-assembly capex, Section-232 derivative-list response); (d) a sovereign-AI bilateral concluded under the RTE template (Humain / SovAI / Stargate-BR / etc.); (e) a Section-232 derivative-products list expansion FR notice. Re-write triggers the last_refreshed field above and a new entry in the §Sources section below.
Primary action records:
Related case studies:
Related dossiers:
docs/intelligence/dossiers/asml.md](./asml.md) — supply-side lithography counterpartydocs/intelligence/dossiers/tsm.md](./tsm.md) — foundry / CoWoS counterpartyownership: block above (jointly with the web check cited in ownership_source).Company disclosures, not yet independently verified (v1 deliberately stays on policy actions as the spine; flagged rather than asserted):
second-source qualification status
H20 / B100 / B200 mix
RTE Sovereign Stack productisation signals
Section-232 mitigation capex velocity
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.
NVIDIA's own corporate blog names TSMC as its wafer-fabrication partner of 'three decades' and jointly announces the first NVIDIA Blackwell wafer produced on US soil, fabricated at TSMC Arizona, October 2025 (quote attributed to TSMC Arizona CEO Ray Chuang). No purchase share or dollar volume is disclosed in this release; NVIDIA's 10-K risk factors describe TSMC dependency only in qualitative terms without a percentage.
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.
1 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Silicon | 🇨🇳 CN 80% refining | 76 | 64 | High | EXCEEDS 80% | — | limited | 19 | ▲ 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 |
|---|---|---|---|---|---|---|
| Silicon | 4 | 4 | 1 | 4 | 4 | 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.
+ 4 more in the register.
An analyst traced these register actions to a specific, named effect on this company — date and severity below are read live from the register, not hand-typed.
The October-2022 BIS rule is the anchor of NVIDIA's entire China-compliance architecture. Performance thresholds for ECCN 3A090 designed around the H100; NVIDIA's first-ever compliance-engineered SKUs (A800, H800) were spun out within months. Every subsequent SKU bifurcation runs from this rule.
Closed the most-obvious geographic loophole around the October-2022 rule and signalled BIS would treat HK/Macau as PRC-equivalent for advanced-computing — a precedent that propagates into every subsequent ROW-routing question (Malaysia 2025, UAE 2025, Vietnam-watch).
Closed the A800/H800 loophole and introduced the IPR/TPP-based control threshold. Forced NVIDIA to design and tape out the H20 — the most successful compliance-engineered SKU in industry history (USD 12-15bn estimated FY24-25 China revenue at peak before later restrictions).
Created the *pre-authorisation* pathway that the G42 RTE later operationalised. Specifically named AE / SA / QA / OM / EG / PK as eligible — the regulatory framing of "sovereign AI in friendly third-country jurisdictions" begins here and is downstream of NVIDIA's Gulf customer ramp.
Three NVIDIA-relevant layers: (i) HBM stacks meeting the BIS performance threshold under license for China-export, (ii) 140+ Entity List adds include major Chinese AI-foundry customers narrowing NVIDIA's China-compliant addressable market, (iii) BIS performance-control thresholds tightened to the point where the H20 itself sits inside the licensable envelope rather than safely outside it — first signal that the compliance-engineered SKU strategy is reaching its design ceiling.
The most under-priced near-existential precedent for the NVIDIA franchise. The Framework created **ECCN 4E091** — model weights of frontier AI systems trained above a compute threshold — as a controllable export item. The structural read: the regulatory locus shifts from the chip (NVIDIA's product) to the *trained weights running on the chip* (the CSP's product). If retained, the cluster-export regulatory perimeter would have moved to AWS / Azure / GCP / Oracle / CoreWeave and made NVIDIA's largest customers the licensed parties. Tiered country caps (Tier 1 unrestricted, Tier 2 capped per-entity, Tier 3 denied) would have hard-rationed NVIDIA's ROW data-center demand growth.
The Trump-administration EO 14179 was the *political* signal that triggered the Diffusion Framework rescission in May 2025. Read as the durable pro-NVIDIA policy posture of the second Trump term: clear sovereign-AI export consensus, dismantling Biden-era multilateral compute-export coordination, leaving BIS guidance as the principal control instrument rather than a Federal Register rule.
First Entity List addition cycle of the Trump-Lutnick BIS naming Beijing Academy of Artificial Intelligence (BAAI) and Beijing Innovation Wisdom under supercomputer-end-use. Material because BAAI is a major Chinese-domestic foundation-model training shop — narrows the legitimate-NVDA-chip end-user set inside PRC.
The Diffusion Framework was killed two days before its 15 May effective date. The replacement architecture (GP10 guidance + industry-warning policy statement + diligence guidance) does *not* re-introduce model-weight controls — meaning the regulatory locus snaps back to the chip, where NVIDIA is the controlled party but also the architectural negotiator. GP10 itself names Huawei Ascend 910B/910C/910D as presumptively EAR-violative anywhere in the world — that is structurally pro-NVIDIA (it raises the legal-compliance cost of supplying the only credible Chinese-domestic substitute).
Malaysia adopted US ECCN performance thresholds verbatim and made transshipment / re-export of US-origin AI chips through Malaysian territory subject to a Strategic Trade Permit + 30-day prior notification. Closes one of the largest grey-market routing channels into PRC and signals the **architecture is becoming exportable** — partner-implemented enforcement reduces NVIDIA's diversion liability *and* removes the soft revenue floor diversion historically provided. Net read: structurally NVIDIA-positive on legal-risk, mildly negative on near-term revenue.
Indirect but structurally important: the VEU revocations on the three foreign-owned advanced fabs in China (Dalian, SCS / Xi'an, Wuxi) compress the addressable customer set for NVIDIA's H20 — they were major H20 deployers via captive Korean / US-parent demand pull. The under-read consequence: it also drives a Korean-fab consolidation back into the US-Korea perimeter, lifting demand certainty for the NVDA→KR-CSP channel (MSIT National AI Computing Center).
The dynamic-perimeter extension instrument. For NVIDIA the principal impact is on the distribution-channel KYC perimeter — every Chinese system integrator, cloud reseller and AI start-up has to be re-screened against the ≥50%-affiliate tree of every listed parent. The 2025-11-10 one-year suspension (post-Busan) is structurally a reversible negotiation chip with a fixed 2026-11-10 re-entry calendar — NVIDIA's compliance and channel-management functions have to plan for that hard date.
The Busan understanding is the bilateral framework under which (a) the Affiliates Rule was suspended for one year and (b) the 2026-01-13 sub-H200 case-by-case review was conceded. Net read: NVIDIA was the principal commercial beneficiary of the post-Busan settlement architecture, even though the framework does not name the company.
The architectural breakthrough. Authorises ~35,000 GB300 chips into the Stargate UAE 1 GW campus (G42 / OpenAI / Oracle / NVIDIA / SoftBank partnership) under an Emirati-designed governance framework that BIS pre-approves. The RTE is the first formal compliance *product* that pairs the chip export with an audit / governance wrapper — and it is explicitly marketed as replicable for Saudi (Humain), India (SovAI), and other Tier-2 sovereign-AI customers.
The first material commercial concession of the Trump-Lutnick BIS to NVIDIA / AMD. Pivots H200-and-below from presumption-of-denial to case-by-case. The under-read consequence: this is a soft commit to keep H100-class advanced-computing legally exportable to Chinese hyperscalers under reviewable licence — material to FY27-28 China-exposed revenue planning. Sell-side priced it as "license uncertainty"; the structural read is "legalised channel".
The single most operationally consequential post-export-control event for NVIDIA's gross-margin line. The HTS classification applies to *finished AI systems imported into the US* (GB200 NVL72 racks landed from Mexico-assembled lines, DGX H200 from Taiwan-assembled lines, HGX system boards from PRC-assembled CoWoS-output paths). Country coverage (TW / KR / CN / MY / VN) names every NVIDIA system-assembly geography simultaneously — the COGS exposure is on the order of low-single-digit GPM points if fully passed through, and the FY27 capex re-allocation incentive toward US-domiciled system assembly (Foxconn Texas / Quanta TN expansion) accelerates from this point.
Operationalises EO 14320's industrial-policy frame: pre-set US industry-led consortia offer "full-stack American AI export packages" (NVDA accelerator + Cisco/Arista networking + Dell/SMCI servers + OpenAI / Anthropic model + Oracle / Azure / AWS cloud services). The structural read: NVIDIA becomes the anchor SKU of a USG-coordinated sovereign-AI export instrument — a re-rating of the AI-export channel from commercial-pull to industrial-policy-push.
UK sovereign-AI compute envelope (and the parallel KR MSIT National AI Computing Center action below) is the demand-side counterpart to the export architecture. Watch closely as the *budget envelope cumulative across sovereign-AI tier-1 jurisdictions* — every multi-billion-dollar sovereign-AI capex commitment is a forward booking of the GB200 / GB300 / Rubin demand curve.
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: the 50%-ownership automatic extension of Entity List designations runs to its full perimeter (one-year suspension at 2025-11-10 lifted on schedule). Direct-hit lines are basket issuers in semiconductor / chip-equipment / AI-compute sectors — the perimeter where the rule's 50% controller-affiliate test compounds with existing Entity List names.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 76 → 81 (+5) — a relative official policy-pressure magnitude, not a price drawdown.
🇨🇳 CN has issued 2 restrictive actions on Silicon since 2021, severity hardening (3.0 → 4.0).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 1 of these 2 materials (Silicon) — your binding Silicon exposure is one of them.
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime | 76 | 81 | +5 |
| Concentration | Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly) | 76 | 88 | +12 |
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. 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 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.
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 (Silicon).
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 — 1 scored SRM on the input side (binding: Silicon) |
| Manufactures a listed strategic technology | semiconductor-design (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 2026-09-22; 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).
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