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1 critical material scored · binding chokepoint: Uranium (🇷🇺 RU 45% of refining) · 25 restrictive government measures on record
Orano SA produces 1 of the 1 scored material above (Uranium). For those, a supply restriction by the controlling country is a tailwind, not a headwind — the exposure is to disruption of a market this company supplies, not to a chokepoint it depends on. Every scored material here sits on its output side, so the Elevated · 60/100 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 2026-10-07) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Uranium — 🇷🇺 RU controls 45% of global refining. On this company's production footprint that scores 60/100 (adversarial chokepoint; global 57). The register holds 25 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Uranium Orano SA is the 38th-most-exposed of the 56 named companies we track on 🇷🇺 RU's Uranium chokepoint; the most-exposed is Appia Rare Earths & Uranium Corp. (67/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Company supply-risk index 60/100 — 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 (FR 60% · KZ 25% · CA 10% · MN 5%, 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.
Orano is the French state-controlled vertically-integrated nuclear fuel-cycle specialist (the ex-AREVA upstream/back-end successor, rebranded January 2018). Ownership per Orano's FY2024 Annual Activity Report (shareholding as of 31 Dec 2024, corrected 2026-08-24 — see ownership: frontmatter) is 90.33% French State (direct) + 4.83% Japan Nuclear Fuel Ltd + 4.83% Mitsubishi Heavy Industries + a nominal 1-share CEA stake; equity is unlisted, bonds trade publicly. The business spans four legs — (1) uranium mining (KATCO JV in Kazakhstan with Kazatomprom, the now-suspended SOMAÏR/COMINAK/Imouraren stack in Niger, the McClean Lake JV with Cameco in Canada, the developing Zuuvch-Ovoo ISL project in Mongolia, Trekkopje in Namibia); (2) uranium conversion at Comurhex (Malvési + Tricastin, the only commercial-scale UF6 conversion capacity in the EU); (3) uranium enrichment at Georges Besse II (GBII) centrifuge plant at Tricastin (~7.5M SWU/yr, expanding to 11M SWU/yr by 2030 per Oct 2024 announcement); (4) back-end — spent-fuel reprocessing at La Hague and MOX fabrication at Melox. Customers are predominantly Western utility fleets (EDF, US/EU/Asia LWR operators); EDF is ~30-35% of revenue. Framatome (reactor vendor / fuel assemblies) is not part of Orano — it is 80.5%-owned by EDF and 19.5%-owned by Mitsubishi Heavy Industries post the 2018 split (corrected 2026-08-24; the figure was previously misstated as 75%-EDF, sourced from Wikipedia's Framatome infobox — no contradicting primary source found).
legs (yellowcake U3O8 upstream → UF6 → enriched UF6 LEU → fresh-fuel pellets at Framatome → reprocessed MOX). Orano-controlled primary-production capacity post-Niger is ~3,500 tU/yr (KATCO ~2,000 tU/yr, McClean Lake share ~600 tU/yr, Trekkopje paused, Zuuvch-Ovoo ramping to ~2,500 tU/yr by 2030).
structurally the binding bottleneck for European utility supply independence from ConverDyn (US) and Cameco-Port-Hope (Canada).
centrifuge plant; Orano holds ~25-30% of global non-Russian SWU capacity alongside Urenco (~33%), Centrus (small), and the Russian TENEX block that the US has now structurally banned (see policy table below).
HF for Comurhex, nitric acid for La Hague) are scored separately as out-of-scope here; they are real cost-of-goods inputs but neither rare nor concentrated.
| Date | Action | Issuer | Sev | Why it touches Orano |
|---|---|---|---|---|
| 2024-04-19 | Mongolia SWF Law + Minerals Law amendments — 34% strategic-deposit cap | MN | 4 | Sets the Erdenes Mongol mandatory-state-share scaffolding under which Orano's October 2024 Zuuvch-Ovoo investment agreement was signed; mid-development re-pricing risk |
| 2024-05-13 | US Prohibiting Russian Uranium Imports Act (PL 118-50) | US | 4 | Bans Russian-origin LEU effective 2024-05-13 with DOE waivers through 2027 → structural displacement of ~24% of US enrichment supply onto Urenco + Orano GBII + Centrus |
| 2024-06-21 | Niger revokes Orano's Imouraren uranium-mine operating permit | NE | 4 | First Niger-Orano break event; direct revocation of Orano-controlled licence (Imouraren SA 63.4% Orano / 36.6% Sopamin) |
| 2024-11-15 | Russia Resolution 1544 — temporary ban on enriched uranium exports to the US | RU | 4 | Symmetric counter to PL 118-50; compresses TENEX supply into the DOE-waiver window only → tightens the same Western SWU shortfall GBII is positioned to absorb |
| 2024-11-21 | Mongolia Nuclear Energy Law Amendments — dynamic royalty + Zuuvch-Ovoo framework | MN | 4 | Layers dynamic uranium royalty + ore-export ban + Erdenes Mongol JV scaffolding on top of the SWF-Law base; codifies the parliamentary terms governing Zuuvch-Ovoo ramp |
| 2025-06-19 | Niger nationalises SOMAÏR uranium JV | NE | 4 | Removes the operating Arlit-region mine from Orano's order book (vs. Imouraren which was paused since 2011); triggered EUR 700M+ asset write-down in H1 2025 |
| 2025-11-05 | Sweden repeals 2018 uranium mining moratorium | SE | 3 | Opens permitted-friendly EU jurisdiction for upstream supply diversification; Aura Energy Häggån + District Metals Viken become potential offtake / JV counterparties |
| 2025-12-26 | Kazakhstan Subsoil Code amendments — Kazatomprom statutory uranium-block priority | KZ | 4 | KATCO is grandfathered as a pre-existing JV — Kazakhstan converts from flat-political-risk to deeply-defended for Orano's largest remaining primary-production line |
| 2026-02-12 | France PPE3 — Programmation Pluriannuelle de l'Énergie 2026-2035 | FR | 3 | Codifies the EPR2 6+8-unit build programme; PPE3 §nuclear explicitly names Orano as the fuel-cycle supplier for the new-build LEU demand trajectory |
| 2023-05-11 | France €500m Critical Metals Fund + Stratégie Nationale Métaux Critiques | FR | 4 | Orano named in the Stratégie list as a critical-metals downstream actor (fuel-cycle qualification under "métaux stratégiques") |
Upstream replacement for Niger. The 2024-25 Niger break removed ~1,200-1,500 tU/yr of operating capacity. Replacement options ranked by realism:
ISL, already permitted, lowest-cost — preferred but capacity- constrained by Kazatomprom JV-partner priorities and water-table permitting); (b) Zuuvch-Ovoo Mongolia ramp to nameplate 2,500 tU/yr (multi-year; construction-permit dependent); (c) McClean Lake Saskatchewan expansion (JV with Cameco; Cameco is the operator, Orano is a minority offtake partner — limited unilateral control); (d) Sweden greenfield via Aura Energy / District Metals (long permitting cycle, 2030+ at earliest).
Downstream defence — enrichment capacity arbitrage. GBII expansion to 11M SWU/yr (announced Oct 2024) is the single highest-IRR Orano capital allocation of the cycle, driven by the PL 118-50 + Resolution 1544 induced Western SWU shortfall. Customer-contracting posture is multi-year fixed-price, not uranium-linked spot — the structural margin captured here is independent of the spot-uranium gyration.
Geographic diversification beyond Kazakhstan-Mongolia bilateral. Sweden uranium-mining repeal (effective 2026-01-01) opens a permitted- friendly EU jurisdiction for the first time since 2018; the strategically-defensive (not offensively additive) play is for Orano to participate as offtake / minority-equity partner in Aura Energy or District Metals projects to secure long-term EU-domestic supply optionality.
(Surface 1) The two Niger events are not equivalent loss events — and markets conflate them. Imouraren (revocation June 2024) was a stranded-asset paused since the 2011 Fukushima uranium-price collapse; its operating revenue was zero, so the licence revocation hit option-value reserves (~200,000 t U Orano-disclosed) but did not disturb the FY24 cash-flow waterfall. SOMAÏR (nationalisation announced June 2025; loss-of-operational-control declared December 2024) was the in-the-money asset — the Arlit mine was producing ~1,200-1,500 tU/yr at the moment of loss, and the H1 2025 EUR 700M+ asset write-down traces to SOMAÏR + COMINAK book values, not Imouraren. Equity-analyst write-ups treating Niger as "one event" miss the asymmetry: Imouraren is an arbitration-recovery-value optionality (ICSID claim has potential settlement upside even if the deposit is never developed), while SOMAÏR is a revenue-line compression event that forces accelerated KATCO + Zuuvch-Ovoo ramp economics. The two should be priced as independent claims.
(Surface 2) PL 118-50 + Resolution 1544 create a 2024-2027 Western SWU bottleneck that markets price as uranium-spot-linked rather than as a multi-year SWU-contract take-or-pay arbitrage. Russian TENEX supplied ~24% of US enrichment at the time of PL 118-50 enactment; Russia's Resolution 1544 retaliatory ban compressed even the DOE-waiver flow. The non-Russian Western SWU stack is Urenco (~33% of global non-Russian capacity) + Orano GBII (~25-30%) + Centrus (small; HALEU-focused). Centrus's HALEU mandate means it is structurally not substitutable for the LWR LEU shortfall. GBII's October 2024 expansion-to-11M-SWU announcement is the single Western capacity addition committed to absorb this — the structurally interesting fact that markets miss is that the incremental capacity is contracted forward under multi-year fixed-price SWU contracts with Western utility customers, not under uranium-price-linked spot terms. This converts what looks like uranium-equity exposure into a SWU-toll business with regulated-utility-credit counterparty risk and a multi-year revenue lock — a different asset class than the URA / URNM ETF holdings reflect.
(Surface 3) The Mongolia SWF Law (Apr 2024) is a textbook mid- development resource-nationalism re-pricing applied to Zuuvch-Ovoo, and the Nuclear Energy Law (Nov 2024) is the parliamentary scaffold layered on top. The October 2024 Orano-Mongolia binding investment agreement on Zuuvch-Ovoo was signed AFTER the SWF Law was enacted (so the mandatory-state-share provisions were known at signing) but BEFORE the Nuclear Energy Law Amendments (so the dynamic-royalty + ore-export-ban provisions were added during the development cycle). The structural read: Mongolia is mid-curve, not late-curve, on resource-nationalism escalation — the legal architecture is still being built around the single project. This implies a non-trivial probability of additional parliamentary action (e.g. extension of the 34% strategic-deposit equity cap to existing JVs without grandfathering) during the construction phase. Orano's reported project IRR threshold has not been disclosed, but the project was structured to support ~$35/lb uranium economics at signing; current spot of ~$75/lb gives substantial headroom, but a uranium price reversion to <$50/lb (plausible if KazAtomProm restart-and-expand accelerates 2027+) compresses IRR below threshold simultaneously with Mongolia-side legal-uncertainty risk.
(Surface 4) Kazakhstan, post the December 2025 Subsoil Code amendments, is now Orano's most deeply-defended primary-production jurisdiction — not its highest-risk one. The amendments grant Kazatomprom statutory priority over uranium blocks prospectively; existing JVs (Inkai/Cameco, KATCO/Orano, Semizbai/CGN, Inkai/Cameco) are explicitly grandfathered. Post-Niger, KATCO is Orano's largest single uranium-revenue line (~2,000 tU/yr from Tortkuduk-Moinkum ISL blocks). The structural fact markets miss: Kazakhstan converted in twelve months (Dec 2024 → Dec 2025) from flat-political-risk to deeply-defended-by-grandfathering. The probability of an arbitrary re-opening of the KATCO JV is now structurally lower than the probability of an arbitrary re-opening of the Cameco-Inkai JV in Saskatchewan (Cameco's Canadian assets face Indigenous-consultation re-opener risk that has no Kazakh analogue). For asset-allocation purposes, the geographic risk ranking of Orano's portfolio has inverted: Niger (was: backbone) → no revenue; Mongolia (was: option) → construction-phase legal-uncertainty; Kazakhstan (was: passive JV) → most-defended single asset.
Refreshed on (a) any ICSID procedural ruling in Orano v. Niger, (b) any DOE NOFO Round 2 release for LEU procurement, (c) Erdenes Mongol board ratification of Zuuvch-Ovoo construction phase, (d) any Kazakhstan implementing-regulation on the December 2025 Subsoil Code that touches existing JV terms, (e) Orano FY/H1 results disclosing further Niger write-downs or GBII expansion contracting milestones.
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.
US CBP bill of lading via ImportGenius importer page (retrieved 2026-09-27): BoL CMDULHV4089436, arrival 2026-08-13; shipper ORANO CHIMIE ENRICHISSEMENT, consignee WESTINGHOUSE ELECTRIC COMPANY LLC; 1 x 20ft flat rack, 4 x 30B cylinders in COG-OP-30B packages, UN2977 radioactive material uranium hexafluoride (enriched UF6), 99,785 kg gross; port of lading in France (Le Havre). Orano Chimie-Enrichissement operates the Georges Besse II enrichment plant at Tricastin, France; Westinghouse fabricates fuel at Columbia, South Carolina, US.
Orano and SHINE Technologies (Wisconsin-based fusion/medical-isotope developer) signed a Memorandum of Understanding to jointly develop a US pilot plant applying Orano's La Hague used-fuel recycling expertise combined with SHINE's separation technology, targeting operation by the early 2030s. An MOU, not yet a binding commercial contract — recorded as a development-stage strategic partner, not a revenue counterparty.
Centrus 10-K: 'We also have an agreement with Orano for the long-term supply of SWU contained in LEU, with deliveries that commenced in 2023 and extend through 2030.'
EDF: 'Conversion and enrichment are handled by France's Orano at Malvési/Pierrelatte and the Georges Besse II plant at Tricastin' for EDF's ~7,000 t/yr natural-uranium fuel-cycle needs. Both HQ'd in France — no cross-border corridor stated beyond domestic France, so no flow is credited.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Uranium | 🇷🇺 RU 45% refining | 60 | 57 | Elevated | — | High | limited | 25 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Uranium | 4 | 2 | 5 | 4 | 3 | company input |
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.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 10 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇷🇺 RU shock, these disclosed plants carry the binding Uranium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Uranium — 🇷🇺 RU escalates uranium controls to a full export-licensing / ban regime | 60 | 66 | +6 |
| Concentration | Uranium — 🇷🇺 RU becomes the single source for uranium — the second source is lost (full 45%+ monopoly) | 60 | 86 | +26 |
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 Orano SA produces, and Art. 24 addresses the use of a strategic raw material as an input. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the 0 materials this company buys (the 1 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one Orano SA 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 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | nuclear-fuel-cycle (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-08-21; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-07
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.