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2 critical materials scored · binding chokepoint: Tin (🇨🇳 CN 55% of refining) · 23 restrictive government measures on record
The binding exposure is Tin — 🇨🇳 CN controls 55% of global refining. On this company's production footprint that scores 56/100 (neutral exposure; global 56). The register holds 23 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Tin Qarmet (formerly ArcelorMittal Temirtau) is the 397th-most-exposed of the 483 named companies we track on 🇨🇳 CN's Tin chokepoint; the most-exposed is Stanley Black & Decker, Inc. (66/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Qarmet (formerly ArcelorMittal Temirtau) ranks 79th of 98 verified metals refining companies, tied with 2 others at 52.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 39 further metals refining 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 52/100 — 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 (KZ 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/qarmet/report.
Qarmet is Kazakhstan's largest steelmaker, built around the integrated Karaganda Metallurgical Plant at Temirtau. It runs a full blast-furnace / basic-oxygen-furnace route — four blast furnaces and three 350-tonne converters — casting slabs and square billets on continuous casters, and produced 3.8 million tonnes of steel in 2025. The plant is unusually vertically integrated: the group also owns a Coal Department of eight underground mines with the Vostochnaya preparation plant (7.5 million tonnes of coal in 2025) and an Iron Ore Department, Orken LLP, spanning four operations (3.5 million tonnes of concentrate in 2025).
Its finished-product range runs from slabs, billets and long products (rebar, angle, channel) through hot- and cold-rolled coil and sheet to three coated lines that matter for this dossier: hot-dip galvanized steel, polymer-coated steel applied over a galvanized substrate, and white tinplate. It also makes small-diameter longitudinally welded pipe.
The company was ArcelorMittal Temirtau until December 2023, when ArcelorMittal exited Kazakhstan following the Kostenko mine disaster and the assets passed to the state-linked Qazaqstan Investment Corporation and were renamed.
Two of the three exposures below are confirmed from Qarmet's own product descriptions rather than inferred from the sector; the third is labelled inference. Note that Qarmet's two largest raw-material flows by tonnage — coking coal and iron ore — are both mined captively by the group and neither is a scored critical material here, so the bulk of its physical input base does not appear below.
hot-dip galvanizing line in exactly these terms: "rolled metal is immersed in molten zinc, resulting in the formation of a strong and durable protective layer". A continuous hot-dip line consumes zinc as a bulk metallic input in proportion to coated tonnage, not as an additive, and the polymer-coated product line sits on top of the same galvanized substrate, so it draws on the same zinc bath. This is the company's strongest genuine buy-side critical-material dependency.
The site lists "White tinplate" among its products. Tinplate is cold-rolled steel electrolytically coated with a thin tin layer, so the line is a direct and continuous tin consumer — but the coating is microns thick and the product is one line among a dozen, so the absolute tin volume is far smaller than the zinc volume. Listed as a real dependency, not a headline-scale one.
Qarmet-confirmed*. No Qarmet document naming ferroalloy purchases was located this pass. It is retained because manganese is effectively compulsory in BF-BOF steelmaking — the standard deoxidiser, desulphuriser and strength-alloying addition, with no substitute at scale — so a 3.8 Mt/yr converter shop is necessarily a steady ferromanganese or silicomanganese buyer. Treated as inference and flagged as such rather than asserted as disclosure.
Dropped from the sector default: silver, copper, nickel and antimony. Qarmet is a carbon-steel producer with captive coal and iron ore, not a base- or precious-metals refinery; none of the four appears as a product or a named input in any source located. Also considered and dropped: silicon — ferrosilicon is common in steelmaking, but aluminium killing is a genuine alternative, so unlike manganese it is not near-certain for this plant and no source names it. Absence of a disclosure is recorded here as absence of evidence, not as evidence the input is unused.
Ranked by buyer-relative risk, highest first.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Tin | 🇨🇳 CN 55% refining | 56 | 56 | Elevated | — | Low | ready | 18 | ▲ rising |
| Zinc | 🇨🇳 CN 32% mining | 37 | 37 | Low | — | High | 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 ↗
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 |
|---|---|---|---|---|---|---|
| Tin | 4 | 2 | 5 | 2 | 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.
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 55% of global refining output (by tonnage); US filers' own disclosures independently name China for 28% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| China Tin Group Co., Ltd.CID1070 | China | 20 | SEC |
| PT Mitra Stania PrimaCID1453 | Indonesia | 18 | SEC |
| Gejiu Kai Meng Industry and Trade LLCCID942 | China | 18 | SEC |
| PT ATD Makmur Mandiri JayaCID2503 | Indonesia | 17 | SEC |
| PT Prima Timah UtamaCID1458 | Indonesia | 17 | 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.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 8 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 Tin exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Tin — 🇨🇳 CN escalates tin controls to a full export-licensing / ban regime | 56 | 60 | +4 |
| Concentration | Tin — 🇨🇳 CN becomes the single source for tin — the second source is lost (full 55%+ monopoly) | 56 | 79 | +23 |
| 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.
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 (Tin).
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: Tin) |
| Manufactures a listed strategic technology | metals-refining (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 2026-09-17; 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
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.