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1 critical material scored · binding chokepoint: Platinum-palladium (🇿🇦 ZA 54% of mining) · 12 restrictive government measures on record
A verification pass re-checked this dossier's ownership/corporate-structure fields against their cited sources. It did not re-read the material_exposures claim the score, band and stress figures below are built on — treat those as not yet independently re-checked.
The binding exposure is Platinum-palladium — 🇿🇦 ZA controls 54% of global mining. On this company's production footprint that scores 62/100 (neutral exposure; global 62). The register holds 12 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Platinum-palladium PowerCell Sweden AB is the 52nd-most-exposed of the 114 named companies we track on 🇿🇦 ZA's Platinum-palladium chokepoint; the most-exposed is Isuzu Motors Limited (62/100). 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 62/100 — 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 (SE 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.
PowerCell (Volvo Group spinout, founded 2008, HQ Gothenburg) develops PEM hydrogen fuel-cell stacks and complete systems, sold across five customer segments: aviation, marine, power generation, off-road and on-road. Its S3 stack (up to 145 kW) is licensed exclusively to Bosch for automotive applications -- PowerCell addresses the on-road segment indirectly through that relationship and sells directly into the other four. FY2025 net sales MSEK 385.0 (+15% y/y), gross margin 45.2%, operating loss MSEK -22.9. Listed on Nasdaq Stockholm's Main Market since December 2023.
The single relevant critical-material exposure is [platinum-palladium](/minerals/platinum-palladium), from the PGM catalyst layer inside every PEM fuel-cell stack -- but this is an application-inferred exposure, not a PowerCell disclosure: neither the 2025 Annual Report nor the 2025 Sustainability Report mentions platinum, PGMs, or conflict-minerals sourcing at all. What PowerCell does disclose is a general supplier-due-diligence process (Supplier Code of Conduct, country-risk-indexed ESG questionnaire, 20 supplier evaluations completed in 2025 on a rolling 3-year schedule) that is not metal-specific.
PowerCell is the origin of the stack technology Bosch manufactures inside its FCPM -- the 2019 licence is where Bosch's PEM-stack capability came from, and the 2023 role inversion (Bosch now builds finished stacks and ships them back to PowerCell) is one of the more structurally interesting findings of the 2026-08-22 OSINT case study (docs/intelligence/cases/2026-08-22-bosch-fcpm-supplier-osint.md): the same company pair is simultaneously licensor/licensee, supplier/customer, and shareholder/investee, depending which angle you look from.
Bosch's 11.2% equity stake (with board representation) is disclosed in AR2025's related-party note, separate from the commercial relationship. related_party: true on the named-counterparty row above reflects that equity fact specifically -- it does not mean the license/royalty/supply terms themselves are non-arm's-length, which AR2025 does not state either way.
Not yet researched for this dossier -- flagged for a follow-up pass rather than filled with an unsourced guess.
Seeded 2026-08-22 from a single deep-research pass tied to the Bosch FCPM case study; not yet on a standing refresh cadence. Re-verify license/royalty figures against the FY2026 Annual Report once filed.
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.
Triple relationship: (1) since 2019-04-29, exclusive automotive licensee of the S3 stack design (EUR 50m+ per-unit royalties); (2) since 2023-06-02, contract manufacturer -- Bosch now makes finished S3 stacks and supplies them TO PowerCell's Gothenburg facility, inverting the original licensor/licensee direction; (3) principal shareholder at 11.2% (31 Dec 2025) with a board seat -- related_party: true reflects this equity stake, distinct from the commercial relationship. Corpus link: bosch. share_pct/share_of figures confirmed against the FY2025 year-end report (2026-09-28); source_url corrected to that report -- the 2019 JDLA press release cited previously does not contain FY2025 financial figures.
Triple relationship: (1) since 2019-04-29, exclusive automotive licensee of the S3 stack design (EUR 50m+ per-unit royalties); (2) since 2023-06-02, contract manufacturer -- Bosch now makes finished S3 stacks and supplies them TO PowerCell's Gothenburg facility, inverting the original licensor/licensee direction; (3) principal shareholder at 11.2% (31 Dec 2025) with a board seat -- related_party: true reflects this equity stake, distinct from the commercial relationship. Corpus link: bosch. share_pct/share_of figures confirmed against the FY2025 year-end report (2026-09-28); source_url corrected to that report -- the 2019 JDLA press release cited previously does not contain FY2025 financial figures.
Serial-delivery contract, up to SEK 1.51bn / 5,000 stacks (0.5 GW) of 300 kW 'superstack' modules for a 600 kW aviation powertrain, conditional on certification. Aviation is one of PowerCell's five customer segments alongside marine, power generation, off-road and on-road (the last addressed via Bosch).
EUR 19.2m order, Marine System 200 units (~13 MW total) for two hydrogen ferries on the Bodo-Lofoten route. The press release states Torghatten Nord and PowerCell 'intend to enter into' a long-term service agreement -- it does not specify a term length; the '15-year, through 2040' figure in an earlier version of this note was not supported by this or any other source checked (wake-verify, 2026-08-22) and has been dropped rather than left standing.
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 |
|---|---|---|---|---|---|---|---|---|---|
| Platinum-palladium | 🇿🇦 ZA 54% mining | 62 | 62 | Elevated | within 54% | Low | limited | 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 |
|---|---|---|---|---|---|---|
| Platinum-palladium | 4 | 3 | 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.
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 🇿🇦 ZA shock, your disclosed plant carries the binding Platinum-palladium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Platinum-palladium — 🇿🇦 ZA escalates platinum-palladium controls to a full export-licensing / ban regime | 62 | 67 | +5 |
| Concentration | Platinum-palladium — 🇿🇦 ZA becomes the single source for platinum-palladium — the second source is lost (full 54%+ monopoly) | 62 | 83 | +21 |
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 (Platinum-palladium).
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 — 1 scored SRM on the input side (binding: Platinum-palladium) |
| Manufactures a listed strategic technology | fuel-cell-systems (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 2026-06-03; 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.