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2 critical materials scored · binding chokepoint: Silver (🇲🇽 MX 24% of mining) · 12 restrictive government measures on record
Compañía Minera Poderosa S.A. produces 1 of the 2 scored materials above (Silver). 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. The remaining 1 (Zinc) is genuine buyer dependencies and drive the mitigations below. The two sides are reported separately and never netted against each other.
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 Silver — 🇲🇽 MX controls 24% of global mining. On this company's production footprint that scores 39/100 (partially hedged; global 43). The register holds 12 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Silver Compañía Minera Poderosa S.A. is the 309th-most-exposed of the 331 named companies we track on 🇲🇽 MX's Silver chokepoint; the most-exposed is Omron Corporation (43/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Compañía Minera Poderosa S.A. ranks 422nd of 462 verified mining metals companies, tied with 11 others at 39.
Company supply-risk index 39/100 — 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 (PE 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/poderosa/report.
Compañía Minera Poderosa S.A. is a Peruvian precious-metals producer operating a single underground gold mine complex in the Pataz district of La Libertad, northern Peru, on the gold-bearing quartz-vein system of the Pataz batholith. It has been in production since 1982 and is one of Peru's larger domestic gold miners, reporting output above 300,000 ounces of gold in 2022.
The company is vertically integrated through to finished metal. Ore is treated at two plants — Marañón, at Vijus, which began at 120 dry tonnes per day in 1982 and had reached 800 t/d by 2019 with an expansion to 1,000 t/d planned, and Santa María. Both recover metal by cyanide dissolution followed by precipitation and smelting, and Poderosa has added a chemical refinery at the Marañón unit producing 99.99%-purity gold and silver bars on site rather than shipping precipitate to a third-party refiner.
Poderosa is an upstream producer, so most of this dossier describes what it supplies rather than what it depends on. Note also that gold — its principal product by value — is not a scored critical material here, so the company's economic core is deliberately absent from the list below.
inferred: Poderosa's Marañón chemical refinery produces silver bars at 99.99% purity alongside gold, so silver is recovered with the gold in the Merrill-Crowe precipitate and refined in-house. This is a exposure — Poderosa adds to silver supply, and policy pressure on silver reaches it through price and export terms, not through input scarcity. It should not be read as a buy-side chokepoint.
Ranked by buyer-relative risk, highest first.
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 |
|---|---|---|---|---|---|---|
| Silver | 3 | 1 | 5 | 3 |
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.
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 🇲🇽 MX shock, these disclosed plants carry the binding Silver exposure:
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 1 material 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.
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 (Zinc). The 1 material Compañía Minera Poderosa S.A. produces (Silver) is excluded from these buyer levers — see the role check in the verdict and the significant-vulnerability conclusion above.
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) |
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: Zinc); 1 further scored SRM produced, not consumed |
| 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 2026-04-29; 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.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 132 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.
The published process route (dissolution → precipitation → smelting) is Merrill-Crowe, which cements dissolved gold and silver out of pregnant cyanide solution onto zinc dust; zinc is consumed continuously and stoichiometrically at any plant running that route, which is why it is listed as a bulk consumable rather than a trace one. No Poderosa bill-of-materials, memoria anual or sustainability document naming zinc dust was located this pass, and the company's own site returns HTTP 403 to this host, so this rests on the process chemistry implied by Poderosa's own process description rather than on a company inputs table.
Dropped from the sector default: cobalt, copper, chromium, manganese, nickel, aluminium, niobium and vanadium — the full mining-metals sector template. Poderosa mines a precious-metals vein system, not a base-metals, laterite or ferroalloy deposit; none of these eight is a Poderosa product, and none is named as an input in any source found. Carrying them forward would have described a diversified base-metals miner that does not exist.
| ▲ rising |
| Zinc | 🇨🇳 CN 32% mining | 37 | 37 | Low | — | Med | ready | 7 | ▲ 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 ↗
| 3 |
| company input |
| Zinc | 4 | 2 | 3 | 3 | 2 | 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.
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Silver — 🇲🇽 MX escalates silver controls to a full export-licensing / ban regime | 39 | 47 | +8 |
| Concentration | Silver — 🇲🇽 MX becomes the single source for silver — the second source is lost (full 24%+ monopoly) | 39 | 65 | +26 |
| Policy | Zinc — 🇨🇳 CN escalates zinc controls to a full export-licensing / ban regime | 37 | 46 | +9 |
| Concentration | Zinc — 🇨🇳 CN becomes the single source for zinc — the second source is lost (full 32%+ monopoly) | 37 | 66 | +29 |
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.
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.
| 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.