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2 critical materials scored · binding chokepoint: Terbium (🇨🇳 CN 99% of refining) · 56 restrictive government measures on record
The binding exposure is Terbium — 🇨🇳 CN controls 99% of global refining. On this company's production footprint that scores 93/100 (adversarial chokepoint; global 84). The register holds 56 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Terbium Photonis Technologies SAS is the 39th-most-exposed of the 191 named companies we track on 🇨🇳 CN's Terbium chokepoint; the most-exposed is TdVib (93/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Photonis Technologies SAS ranks 6th of 95 verified defence companies, tied with 3 others at 89.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 33 further defence 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 89/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 2 scored materials. Buyer-relative (first-order): weighted by where the company produces (FR 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.
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.
> The exposure report this dossier powers is at > /intelligence/dossiers/photonis/report.
Photonis (Photonis France SAS, Brive, ~500 employees; group HQ Mérignac) makes photon-detection and low-light imaging hardware: image intensifier tubes for night vision, microchannel plates (MCPs), photomultiplier tubes, and camera cores for defence, scientific and life-sciences customers. The Photonis Group rebranded its parent holding company to Exosens (2023, backed by Groupe HLD; Euronext Paris listed), which now also houses Xenics (SWIR/InGaAs imaging) and El-Mul — but Photonis' own French manufacturing and product line continue under the Photonis name.
tubes use P43 (green) and P45 (white) phosphor screens to convert the electron avalanche from the microchannel plate back into visible light — Photonis was the first manufacturer to bring white-phosphor (P45) tubes to market (Exosens' own product page, confirmed). "P43" is an EIA/JEDEC industry-standard phosphor-type designation, independently defined as terbium-doped gadolinium oxysulfide (Gd₂O₂S:Tb, dopant fraction on the order of 0.03-0.5%) by phosphor-screen manufacturer datasheets (e.g. Proxivision's P43 datasheet, added as a source 2026-09-06) — a few-hundred-ppm additive in a gram-scale phosphor coating, not a bulk input. Terbium separation/refining is overwhelmingly concentrated in China, which is the supply-chokepoint risk even at trace-additive scale.
Hi-QE line specifically.** Photonis' image-intensifier and photomultiplier tubes use multialkali (S-20/S-25-type) photocathodes — the industry-standard technology for this device class, conventionally a sodium-potassium- antimony film activated with caesium (Na₂KSb:Cs), antimony being the photoemissive base layer deposited as a nanometers-thick film, not a structural or bulk material. Checked 2026-09-06: Exosens' own public pages for the Hi-QE photocathode line (the announcement, the general photocathode product page, and a technical article on single-photon detection) describe performance (quantum efficiency, dark-count rate, spectral range) but do not disclose photocathode chemistry, so the Na₂KSb:Cs composition is not independently confirmed for Hi-QE specifically — it is asserted here on the general multialkali-tube claim, which is standard for this product class, not on an Exosens disclosure of Hi-QE's own formulation. China dominates global antimony mine and refined-metal supply and imposed export licensing controls on antimony in 2023, making it a live policy-risk material even at this scale.
multialkali (Gen 2) photocathode technology rather than adopting gallium-arsenide (GaAs) Gen 3 cathodes used by some US/Israeli competitors — one 2019 Photonis patent describes a GaAs electron-focusing film, but there is no evidence it is in shipped product, so gallium is deliberately excluded rather than assumed.
scripts/py/intelligence/gleif_lookup.pyFrom 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.
Exosens-group press release (2025-12-10): contract with Theon International/OCCAR for 100,000 MIKRON night-vision binoculars carrying 200,000 Exosens 16mm image-intensifier tubes (plus 4,000 further binoculars/8,000 tubes for Belgium), ~EUR 500m total, billed as the largest night-vision contract on record. Tubes of this type are Photonis' own product line (Brive plant, this dossier's subject); the press release itself is issued at the Exosens group level, not the Photonis Technologies SAS legal entity specifically, hence confidence: secondary rather than primary-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.
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 |
|---|---|---|---|---|---|---|---|---|---|
| Terbium | 🇨🇳 CN 99% refining | 93 | 84 | Critical | EXCEEDS 99% | Low | limited | 51 | ▲ rising |
| Antimony | 🇨🇳 CN 78% refining | 73 | 60 | High | — | Low | limited | 9 | ▲ 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 |
|---|---|---|---|---|---|---|
| Terbium | 4 | 5 | 5 | 4 | 3 | company input |
| Antimony | 4 | 3 | 1 | 3 | 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.
+ 41 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Terbium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Terbium — 🇨🇳 CN escalates terbium controls to a full export-licensing / ban regime | 93 | 94 | +1 |
| Concentration | Terbium — 🇨🇳 CN becomes the single source for terbium — the second source is lost (full 99%+ monopoly) | 93 | 93 | 0 |
| Policy | Antimony — 🇨🇳 CN escalates antimony controls to a full export-licensing / ban regime | 73 | 81 | +8 |
| Concentration | Antimony — 🇨🇳 CN becomes the single source for antimony — the second source is lost (full 78%+ monopoly) | 73 | 88 | +15 |
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 (Terbium).
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 — 2 scored SRMs on the input side (binding: Terbium) |
| Manufactures a listed strategic technology | defence (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.