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1 critical material scored · binding chokepoint: Nickel (🇨🇳 CN 36% of refining) · 29 restrictive government measures on record
Pacific Metals produces 1 of the 1 scored material above (Nickel). 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 · 64/100 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 Nickel — 🇨🇳 CN controls 36% of global refining. On this company's production footprint that scores 64/100 (adversarial chokepoint; global 55). The register holds 29 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Nickel Pacific Metals is the 310th-most-exposed of the 742 named companies we track on 🇨🇳 CN's Nickel chokepoint; the most-exposed is MagREEsource (64/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Pacific Metals ranks 191st of 458 verified mining metals companies, tied with 15 others at 64.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 133 further mining metals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 64/100 — 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 (JP 100%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Pacific Metals Co., Ltd. (PAMCO, TSE 5541) makes ferronickel, an alloy of about 15 % nickel and 85 % iron that stainless-steel mills use as their main raw material. It buys oxidised (laterite) nickel ore from overseas and smelts it in electric furnaces at its Hachinohe Works in Aomori, Japan. It sells the slag left over from smelting as civil-engineering aggregate. It describes itself as the number-one domestic ferronickel producer in Japan and says "about 50% of our sales are made overseas", through a network centred on East Asia. It does not publish a country-level revenue split, so sales_geography is left blank.
company's revenue tracks the LME nickel price times the exchange rate, and its costs depend on imported ore. FY2022 (year to March 2023) volume fell to 12,393 Ni t, from 27,060 the year before. In the same year it posted an operating loss of 12.6 bn yen on 34.9 bn yen of sales.
imported, from the Philippines (the Rio Tuba and Taganito joint ventures) and from New Caledonia (Société Minière Georges Montagnat, Mai Kouaoua Mines). Its own report records Indonesia's ban on unprocessed-ore exports: in force since January 2014, partly eased from 2017 to 2019, and reinstated in January 2020. That ban removed an alternative source and pushed stainless production toward Indonesian NPI. The company names this shift as a pressure on its ferronickel prices.
FY2025 17-A records saprolite ore sales to PAMCO of ₱266.5m in 2025 (₱365.0m in 2024, ₱487.2m in 2023). PAMCO is a shareholder in NAC and owns 36 % of RTN; its own report gives a 33.5 % stake in TMC. The supply agreements run until 31 December 2026, so renewal is a near-term event to watch.
SCORED_MATERIALS). No other critical material islisted. Chromium and cobalt are each mentioned only 2-3 times in the Integrated Report, and never as a product input, so no exposure is filed for them.
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.
NAC's FY2025 17-A (Item 12 / Note 30a): 'The Group supplies saprolite ore to PAMCO. PAMCO is a stockholder of the Parent Company, RTN and TMC.' RTN supplies saprolite ore to PAMCO with Sojitz as agent; 'PAMCO owns 36% and Sojitz owns 4% of the outstanding capital stock of RTN'; TMC also sells ore to PAMCO. 'The Group's revenue from sale of ore to PAMCO and/or Sojitz amounted to P266.5 million, P365.0 million and P487.2 million in 2025, 2024 and 2023.' PAMCO 'uses the material as feed for its ferronickel smelters.'
PAMCO annual securities report FY ended March 2025, material contracts table: 'MAI KOUAOUA MINES S.A.R.L (New Caledonia)' nickel ore long-term purchase contract (ニッケル鉱石 長期購入契約) signed 2024-09-12, term Jan 2024 to Dec 2033 (10 years), plus a second MKM Graziella contract signed 2025-03-15 for Jan 2026 to Dec 2035. The report states nickel ore 'is currently imported from the Philippines and New Caledonia' under long-term purchase contracts with each supplier mine. Mines in New Caledonia; ore is smelted to ferronickel at PAMCO Hachinohe Works, Aomori, Japan. The FY ended March 2024 results briefing puts New Caledonia at 40 % of PAMCO's 5,500 Ni-t ore purchases. No tonnage per supplier disclosed.
PAMCO annual securities report FY ended March 2025, material contracts table: 'Societe Miniere Georges Montagnat S.A.R.L. (New Caledonia)' nickel ore long-term purchase contract signed 2015-09-30, term Apr 2016 to Mar 2026 (10 years); the report states ore 'is currently imported from the Philippines and New Caledonia'. The FY ended March 2024 results briefing says PAMCO 'has had transactional relations with Montagna for more than 20 years' and puts New Caledonia at 40 % of ore purchased. Mines in New Caledonia; smelter Hachinohe Works, Aomori, Japan. No tonnage per supplier disclosed.
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.
0 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 |
|---|---|---|---|---|---|---|---|---|---|
| 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 |
|---|---|---|---|---|---|---|
| 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.
+ 14 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.
The binding exposure this precedent lands on — Nickel — is a material Pacific Metals produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-07) — for this company the basis is a disclosed dossier tag. It enters no score.| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Nickel — 🇨🇳 CN escalates nickel controls to a full export-licensing / ban regime | 64 | 71 | +7 |
| Concentration | Nickel — 🇨🇳 CN becomes the single source for nickel — the second source is lost (full 36%+ monopoly) | 64 | 91 | +27 |
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 Pacific Metals 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.
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.
Every scored material here is one Pacific Metals 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 | mining-metals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-30; 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 2026-10-07
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.