2 critical materials scored · binding chokepoint: Titanium (🇨🇳 CN 70% of refining) · 17 restrictive government measures on record
Subject
precheza · 🇨🇿 CZ
Sector
chemicals
Materials scored
2
As of
2026-04-27
Risk Office verdict
Elevated · 65/100Company supply-risk index
The binding exposure is Titanium — 🇨🇳 CN controls 70% of global refining. On this company's production footprint that scores 71/100 (adversarial chokepoint; global 59). The register holds 17 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · TitaniumPrecheza a.s. is the 73rd-most-exposed of the 132 named companies we track on 🇨🇳 CN's Titanium chokepoint; the most-exposed is VHM Limited (71/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · chemicals
Precheza a.s. ranks 50th of 101 verified chemicals companies, tied with 5 others at 65.
89🇯🇵 Shin-Etsu Chemical Co., Ltd.Dysprosium
82🇩🇪 Merck KGaATungsten
81🇯🇵 Mitsubishi Chemical Group CorporationGraphite
81🇺🇸 Dow Inc.Tungsten
81🇯🇵 Tosoh CorporationManganese
80🇦🇹 Treibacher Industrie AGTungsten
79🇩🇪 CeramTecTungsten
79🇪🇸 Colorobbia España, S.A.Praseodymium
79🇺🇸 Solstice Advanced Materials, Inc.Manganese
77🇩🇪 AlzChem GroupSilicon
75🇫🇷 Air Liquide S.A.Tungsten
75🇺🇸 Ecolab Inc.Silicon
75🇩🇪 PCC SE (parent of PCC BakkiSilicon silicon-metal plant, Húsavík, Iceland — idled since mid-2025)Silicon
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 14 further chemicals 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 65/100 — 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 (CZ 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.
Precheza a.s. (Přerov, Czech Republic; part of the Agrofert group) is a titanium-dioxide pigment and inorganic-chemicals producer. Its flagship line, PRETIOX titanium dioxide, is made from ilmenite ore via the sulfate process; it is also the Czech Republic's largest sulfuric-acid manufacturer (most of which feeds its own TiO2 line) and makes iron-oxide pigments (FEPREN) and ferrous sulfate (MONOSAL) as related product lines. Over 90% of output is exported.
Critical-material exposure
Titanium — bulk input. PRETIOX titanium dioxide, made by digesting
ilmenite ore in sulfuric acid (the sulfate process), is described by the company as its single most important product — monthly TiO2 output has reached ~4,700 tonnes.
Sulfur — bulk input. Precheza is the largest sulfuric-acid producer in
the Czech Republic, and the acid is consumed internally as the primary reagent for TiO2 (and ferrous-sulfate/iron-oxide) production — a direct input constraint on its core process.
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 ↗
Supply-risk factor analysis
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.
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.
Material factors (scored 4–5) — evidence
Titanium
4Geopolitical: 14 restrictive actions, peak severity 4, 10 in last 24mo, less 1 liberalising action
4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 63/100 (long-horizon, all major uses). Prior analyst short-run rating 0.80: USGS: few materials match titanium metal's strength-to-weight/corrosion resistance in aerospace/defence structures (specialty steels, aluminium, composites carry weight or temperature penalties); TiO2 pigment more substitutable
4Import reliance: Eurostat Comext 2025: 72% extra-EU imports, top partner ZA 23% (partner HHI 1106)
Sulfur
4Substitutability: byproduct of oil/gas desulfurization + smelting — cannot be produced on demand, so supply is price-inelastic; sulfuric acid has no substitute in phosphate fertilizer or copper SX-EW leaching (USGS: no substitute for the sulfur plant nutrient)
Change log
last 30 days
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.
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:
Both stress-test scenariosShowHide
Policy shock — the controlling country escalates to a full export-licensing / ban regime.
Concentration shock — the supply structure collapses to a single source (second-source loss / full monopoly).
Type
Scenario
Today
Stressed
Δ
Policy
Titanium — 🇨🇳 CN escalates titanium controls to a full export-licensing / ban regime
71
77
+6
Concentration
Titanium — 🇨🇳 CN becomes the single source for titanium — the second source is lost (full 70%+ monopoly)
71
89
+18
Policy
Sulfur — 🇨🇳 CN escalates sulfur controls to a full export-licensing / ban regime
40
57
+17
Concentration
Sulfur — 🇨🇳 CN becomes the single source for sulfur — the second source is lost (full 23%+ monopoly)
40
78
+38
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.
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
No material crosses the significant-vulnerability threshold. The Art. 24(4) mitigation duty is not triggered on the factors we could score (1 of 10 inputs unrated across the materials bought). Absence of data is not evidence of low risk — an unrated factor enters the score as zero, not as an estimate, so this conclusion could change once those inputs are rated. 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 — not yet law
Upcoming regulatory threats
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.
The upcoming threatsShowHide
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 72d ago · not yet law·matches Sulfur
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Sulfur🇨🇳 today 40→57+17
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Titanium
If passed — Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
Caveat — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Titanium🇨🇳 today 71→77+6
🇸🇳 Senegal New Code Minier
passed-committee→elevated likelihood·flagged 114d ago · not yet law·matches Titanium
If passed — Replaces 2016 Code Minier; embeds 'sovereignty doctrine' with stronger state participation, local-transformation mandate, and WAEMU-conformity requirements; President Faye targeted adoption before end-2025; PM Sonko's May 2026 dismissal may have delayed/revised the bill
Caveat — Council of Ministers approved the bill Nov 12, 2025 for transmission to National Assembly. Distinct from already-filed Senegal Code des Investissements 2025 (Loi 2025-16) and March 2026 contract-renegotiation findings. Replaces Loi n° 2016-32 (2016 code) — that base law not separately filed in register. Moderate likelihood pending new-government confirmation under PM Amadou Makhtar Ba.
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Titanium🇨🇳 today 71→77+6
🇸🇱 Sierra Leone No Raw Minerals Export Commitment (VP Jalloh, Mining Week May 2026)
announced→low likelihood·flagged 113d ago · not yet law·matches Titanium
If passed — VP declared no new large-scale mining agreement will be concluded without a binding value-addition commitment; Mines Minister referenced Zimbabwe, Tanzania, Ghana, and Malawi precedents for raw-mineral export bans; if codified as a Statutory Instrument or Finance Act amendment, would impose export duties or licensing requirements on unprocessed rutile (Sierra Rutile / Iluka/Anglo American), ilmenite, zircon, bauxite, and diamond rough from new concessions; SL = world's top-5 rutile producer — a value-addition mandate on rutile concentrates would affect the entire global TiO2/titanium feedstock supply chain
Caveat — Declared May 2026 at Mining Week (coinciding with 2026-2031 National Critical Minerals Strategy launch, already filed). VP wording "new large-scale mining agreement" suggests concession-by-concession contract conditionality rather than a blanket statutory export ban; no bill, statutory instrument, or gazette reference found as of 2026-06-14. Distinct from SL CI national strategy (2026-05-20, filed) and SI 11/2024 SLMMDMC asset allocation (2026-06-02, filed as amendment to SLMMDMC Act).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Titanium🇨🇳 today 71→77+6
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Titanium
If passed — Establishes the first legally binding "safe level" benchmark for EU strategic stocks of each of the 17 strategic raw materials listed in the CRMA Annex I; benchmarks used as reference by Member States, financial institutions, and industrial consumers to assess strategic supply risk; mandated every 2 years, so this is the first edition setting the baseline; informs CRMA Art. 23 monitoring obligations and is the evidential basis for Art. 24 corporate-reporting thresholds
Caveat — The May 24, 2026 deadline set by Parliament and Council in Reg. (EU) 2024/1252 has now passed. No OJ publication confirmed as of June 15, 2026 — Commission may have adopted quietly or is overdue. This is the first CRMA Art. 22 benchmark cycle and is legally distinct from: (1) the CRMA base regulation (filed 2024-05-23); (2) the Strategic Projects first designation (filed 2025-03-25); (3) the RESourceEU Amendment — CRMA revision (filed 2026-03-04). If confirmed adopted, severity=2 (establishes the measurement baseline for EU strategic material supply risk assessment and directly feeds corporate Art. 24 reporting obligations). Distinct from all filed EU-CRMA actions. Not in filing. md or upcoming. md.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Titanium🇨🇳 today 71→77+6
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 101d ago · not yet law·matches Titanium
If passed — TZ Finance Bill establishes the Mineral Research Fund capitalised at 10% of gross mineral revenue (~TZS 141 billion/yr at 2025 collection levels); amends the Income Tax Act to formally recognise tax exemptions granted under individual mining Framework Agreements and introduces standard operating procedures — reduces discretionary government risk for large mining investors (Panda Hill niobium, graphite juniors, Buzwagi gold); parallel VAT amendments give equivalent statutory certainty for VAT exemptions; taken together, the bill moves Tanzania from discretionary tax administration toward a rule-of-law-based investor regime for all critical-mineral projects; budget targets Tanzania for top-4 niobium producer status (Panda Hill DA already signed March 24, 2026) and 50% geophysical survey coverage by 2030
Caveat — Tanzania fiscal year starts July 1; the Finance Act signature typically occurs last week of June. Budget speech delivered June 11, 2026 by Finance Minister Khamis Mussa Omar; Parliament approved June 23. Mining provisions in §§ amending Income Tax Act (Cap. 332) and VAT Act (Cap. 148) and establishing the Mineral Research Fund. Distinct from: filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year), filed 2026-03-24-tanzania-panda-hill-niobium-ferroniobium-development-agreement (the specific project DA), and filed 2026-04-15-tanzania-ministry-of-minerals-revokes-40-idle-mineral-exploration-licences. Severity 2: institutional reform that de-risks the investor regime rather than a direct trade restriction.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Titanium🇨🇳 today 71→77+6
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.
What to watch next
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The watch listShowHide
Titanium is the line to war-game: 🇨🇳 CN already controls 70% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Sulfur carries 3 restrictive measures on record (🇨🇳 CN 23% of mining) — a secondary escalation candidate.
Art. 24(4) · diversification & substitution
Priority mitigations
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 (Titanium).
The mitigation optionsShowHide
Map your real exposure to Titanium. Trace it from the component back to the smelter/refiner and country of origin — most buyers discover the dependence is one tier deeper than their direct supplier.
Qualify a non-CN source. Identify and validate at least one supplier outside CN for the binding input before it is needed, even at a cost premium — optionality is the hedge.
Lead-time to re-source is ~3 months (0-6mo). The largest tracked non-CN producer of Titanium is 🇯🇵 JP (~14% of refining); scaling it into a replacement is roughly a 0-6mo ramp. A share-of-stage substitution heuristic derived from current production share, not a firm supplier quote.
Design for substitution where feasible. Titanium has at least partial substitutes; specify them into next-generation products to cut the dependence structurally.
Hold strategic inventory / contract forward. For materials with no substitute and active export controls, a buffer stock or long-dated offtake converts a shock into a managed cost.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.
Annex A · regulatory basis
CRMA Art. 24 compliance crosswalk
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)).
The full crosswalkShowHide
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.
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.
Why this dependence is structural, not transitional. The EU's own external auditor — the European Court of Auditors, Special Report “Critical raw materials for the energy transition — Not a rock-solid policy” (Feb 2026) — judges the bloc's 2030 extraction, processing and recycling targets to be out of reach (recycling runs 1–5% for 7 of 26 materials, and diversification shows no measurable effect). A separate industry-analyst assessment (Adamas Intelligence & Tradium, EU CRMA report, Apr 2024 — an interested-party commercial view, not an independent verdict) reaches a compatible conclusion that the 2030 rare-earth targets will be missed without an expedited push. The chokepoint this report maps is therefore a durable constraint the Act has not yet closed, not a gap that resolves on its own.
Annex B · Art. 24(1) · Art. 2(29)
Scope & applicability
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.
Scope detailsShowHide
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: Titanium)
Manufactures a listed strategic technology
chemicals (confirm against Annex)
Formally identified by a Member State authority
company input
Evidence & sources
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 2026-04-27; the register is continuously maintained and should be re-pulled against each new policy action.
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).
Refresh SLA
New government measures — polled hourly; a filed action can appear on this report within the hour it's picked up.
Dossier verification (this company's exposure list, sourced against its own disclosures) — the auto-onboarded backlog drains on a 30-minute cycle; a specific company's upgrade timing depends on queue position, not a fixed date.
Live-quoted materials (currently: neodymium, praseodymium, dysprosium, terbium, indium, tellurium — see the price row on each material's page) — refreshed daily.
Other material prices — hand-maintained; flagged STALE on the minerals index past 45 days without a fresh source, rather than left silently out of date.
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.