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2 critical materials scored · binding chokepoint: Lithium (🇨🇳 CN 65% of refining) · 51 restrictive government measures on record
PLS Group Ltd. produces 2 of the 2 scored materials above (Lithium, Tantalum). 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 · 68/100 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 2026-10-05) — 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 Lithium — 🇨🇳 CN controls 65% of global refining. On this company's production footprint that scores 72/100 (adversarial chokepoint; global 61). The register holds 51 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Lithium PLS Group Ltd. is the 228th-most-exposed of the 490 named companies we track on 🇨🇳 CN's Lithium chokepoint; the most-exposed is Momentum Technologies (72/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
PLS Group Ltd. ranks 133rd of 448 verified mining metals companies, tied with 19 others at 68.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 127 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 68/100 — 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 (AU 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/pls/report.
PLS Group Ltd. (ASX: PLS), the former Pilbara Minerals Limited, is an Australian hard-rock lithium producer. Its business is the wholly-owned Pilgangoora operation about 120 km south of Port Hedland in Western Australia — an open-pit pegmatite mine and concentrator that ships chemical-grade and technical-grade spodumene concentrate, with tantalite concentrate recovered as a by-product from the same ore. Plant capacity has been expanded in stages (the P680 and P1000 projects), and in FY2025, the year to 30 June 2025, the operation produced roughly 754,600 t of spodumene concentrate, above its 700,000–740,000 t guidance range, on revenue of about A$769 million in a sharply weaker lithium price environment.
The company sells concentrate under long-term offtake agreements to Chinese and Korean converters, and has extended past the mine gate in two directions: it holds an 18% equity stake in a South Korean joint venture with POSCO whose lithium hydroxide plant — nameplate up to about 43,000 t/y — completed construction in November 2024, and in 2025 it acquired Latin Resources in an all-stock deal of roughly US$377 million, bringing in the Colina hard-rock lithium project near Salinas in Minas Gerais, Brazil. Neither is producing PLS mine output today; both are forward positions.
This is a producer dossier: the materials below are what PLS supplies to the market, not inputs it buys. Its register exposure is to measures aimed at producers and at its operating jurisdiction, rather than to input chokepoints.
whole business: one mine, one product stream, one commodity price. That concentration cuts both ways for a supply-risk read — PLS is a jurisdictionally low-risk source of lithium units (Western Australia, wholly owned, no state-concession dependency of the kind that governs brine production in Chile), but it carries no commodity diversification whatsoever, as the ~39% revenue fall in FY2025 on a higher production volume shows. Its downstream reach is deliberately limited: the Korean hydroxide JV is an 18% minority stake, so PLS is predominantly a concentrate seller rather than a chemical producer.
by its operator and in trade coverage as a lithium-tantalum project: the same pegmatite ore and the same processing circuits yield tantalite concentrate alongside spodumene, with a stated recovery target on the order of 274,000 lb of tantalite a year. This is a real and listable producer exposure — tantalum is a scored material with genuine concentration risk, and by-product suppliers outside the DRC-linked coltan chain are strategically relevant — but it must be read at its true scale: a few hundred thousand pounds a year against three-quarters of a million tonnes of spodumene. Tantalum output is also structurally coupled to lithium economics, since it is recovered from ore mined for its lithium content; a lithium-price-driven cut to mining rates would reduce tantalite units regardless of the tantalum market.
Forward positions not counted as output. The Colina project in Brazil and the 18%-held Korean hydroxide JV are both real, sourced assets, but Colina is pre-production and the Korean plant is downstream conversion in which PLS is a minority holder. Neither is folded into the production footprint, which stays AU 1.0 to reflect where PLS actually mines today.
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.
PLS June Quarter 2025 activities report (ASX, 2025-07-30), s.3.3 'Downstream Joint Venture with POSCO - South Korea': 'customer certification and ramp-up activities continued at the POSCO Pilbara Lithium Solution Co. Ltd (P-PLS) Lithium Hydroxide (LH) chemical facility in Gwangyang, South Korea. Train 1 produced 3,037t of LH during the June Quarter'. PLS AGM presentation 2025-11-25 (p.4, https://www.pls.com/storage/announcements/2025-agm-presentation-2025-11-25.pdf) lists 'GWANGYANG, SOUTH KOREA POSCO Pilbara Lithium Solution' among 'Key offtake partners' beside the Pilgangoora Operation. Offtake terms (2021, via miningweekly.com/article/pilbara-finalises-downstream-jv-with-posco-2021-10-26): 315,000 t/y chemical-grade spodumene concentrate from Pilgangoora (Western Australia) to the P-PLS LHM facility in Gwangyang. P-PLS is 82% POSCO / 18% PLS, hence related_party. Pilgangoora AU > Gwangyang KR.
Trade-press report on Pilbara Minerals' 15 Jan 2024 ASX announcement: 'The recent amendment results in a total allocation of up to 310,000tpa of spodumene concentrate over CY24, CY25 and CY26,' expanding the 2017 agreement under which Pilbara supplies 160,000 t/y of spodumene concentrate from Pilgangoora to Ganfeng. The primary ASX PDF (announcements.asx.com.au/asxpdf/20240115/pdf/05zf9p7cc6ys2g.pdf) could not be parsed this pass, so channel/confidence are downgraded to websearch/secondary pending a primary re-check, consistent with the POSCO row above. Ganfeng is a Chinese converter (see 002460.md); flow follows that.
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 |
|---|---|---|---|---|---|---|---|---|---|
| Lithium | 🇨🇳 CN 65% refining | 72 | 61 | High | within 65% | High | some | 40 | ▲ rising |
| Tantalum | 🇨🇳 CN 50% refining | 53 | 44 | Moderate | — | Low | some | 12 | ▲ 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 |
|---|---|---|---|---|---|---|
| Lithium | 4 | 3 | 5 | 3 | 3 | company input |
| Tantalum | 4 | 2 | – | 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.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
Two independent lenses: USGS official puts China at 50% of global refining output (by tonnage); US filers' own disclosures independently name China for 43% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| F&X Electro-Materials Ltd.CID460 | China | 14 | SEC |
| Hengyang King Xing Lifeng New Materials Co., Ltd.CID2492 | China | 14 | SEC |
| JiuJiang JinXin Nonferrous Metals Co., Ltd.CID914 | China | 14 | SEC |
| Ningxia Orient Tantalum Industry Co., Ltd.CID1277 | China | 14 | SEC |
| Ulba Metallurgical Plant JSCCID1969 | Kazakhstan | 14 | SEC |
Source: US SEC Form SD / Conflict Minerals Report exhibits (EDGAR full-text search), aggregated from RMI smelter tables. “US filers naming it” = distinct US-listed companies whose most-recent CMR names that refiner — disclosure-derived presence, not verified throughput. Link opens the SEC exhibit.
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.
+ 36 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 Lithium exposure:
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 — Lithium — is a material PLS Group Ltd. 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 2026-10-05) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 6 restrictive actions on Lithium since 2021 — cadence accelerating (mean gap 339d → 306d), severity flat (3.3 → 2.7).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 1 of these 13 materials (Lithium) — your binding Lithium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 20.8 months apart across 4 distinct restriction dates since 2021 (n=3 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 | Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime | 72 | 78 | +6 |
| Concentration | Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly) | 72 | 91 | +19 |
| Policy | Tantalum — 🇨🇳 CN escalates tantalum controls to a full export-licensing / ban regime | 53 | 60 | +7 |
| Concentration | Tantalum — 🇨🇳 CN becomes the single source for tantalum — the second source is lost (full 50%+ monopoly) | 53 | 83 | +30 |
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 PLS Group Ltd. 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 2 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 ↗
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 PLS Group Ltd. 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 2 scored SRMs here are ones 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 2026-08-06; 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
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