2 critical materials scored · binding chokepoint: Gallium (🇨🇳 CN 98% of refining) · 52 restrictive government measures on record
Subject
rusal-marketing · 🇨🇭 CH
Sector
commodity-trading
Materials scored
2
As of
2026-08-26
Risk Office verdict
High · 80/100Company supply-risk index · consumer-side read
Role check · this company is a producer, not a buyer
Rusal Marketing GmbH produces 2 of the 2 scored materials above (Gallium, Aluminium). 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 High · 80/100 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 Gallium — 🇨🇳 CN controls 98% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 74). The register holds 52 restrictive government measures touching this company's materials — each traced to its primary source below.
Competitor cohort · commodity trading
Where the 22 verified commodity trading companies we track sit.
88🇩🇪 Deutsche Rohstoff AGTungsten
81🇨🇭 Mercuria Energy GroupTungsten
81🇯🇵 Sumitomo CorporationDysprosium
79🇱🇺 Traxys S.A.Dysprosium
73🇩🇪 Klöckner & Co SEManganese
71🇯🇵 Marubeni CorporationCobalt
69🇯🇵 Itochu CorporationRhodium-iridium
69🇯🇵 Mitsui & Co., Ltd.Manganese
63🇸🇬 Trafigura GroupCobalt
62🇨🇾 Gunvor GroupCopper
Company supply-risk index 80/100 — 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 (IE 68% · IT 14% · SE 18%, estimated split — no cited source states these exact shares, covering 22% of stated output — shares are renormalised across that portion, so the remaining 78% is unmodelled), applied across all materials — it does not yet trace each input to its specific sourcing step.
IT · Eurallumina alumina refinery (Portovesme, Sardinia) — alumina refining (bauxite -> alumina) — curtailed/care-and-maintenance since 2009, EU-frozen assets since May 2023, no active output as of 2026
SE · Kubikenborg Aluminium AB / KUBAL (Sundsvall) — primary aluminium smelting — Sweden's only primary-aluminium smelter, ~135,000 t/yr saleable aluminium, 100% RUSAL-owned; two executives arrested Mar-2026 over alleged EU-sanctions breachesaluminium
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.
Rusal Marketing GmbH (Zug, Switzerland; Swiss company register CHE-113.641.597) is the international trading and marketing arm of United Company RUSAL, the largest aluminium producer outside China and Russia's only primary aluminium producer. Its registered purpose is "trade in metallic and non-metallic raw materials, in particular aluminium, alumina and goods used in aluminium production." RUSAL is vertically integrated from bauxite mining through alumina refining to aluminium smelting, and reported 2025 group aluminium sales volumes of 4.49 million tonnes.
Critical-material exposure
Aluminium — the group's core product at every stage of the value
chain (bauxite mining, alumina refining, aluminium smelting), marketed internationally through this Swiss entity. RUSAL's alumina supply chain runs partly through Aughinish Alumina in Ireland (Europe's largest alumina refinery), which shipped over 540,000 tonnes of alumina worth $307.85m to RUSAL entities between April 2024 and March 2025 even as the EU has progressively sanctioned Russian aluminium imports (16th/21st packages) — the EU has so far stopped short of banning the reverse alumina-to-Russia flow, making this a live, contested policy chokepoint rather than a settled one.
Gallium — RUSAL's own product catalogue lists 99.99% and 99.999%
purity metallurgical gallium as a current, active product line, recovered as a byproduct of its bauxite/alumina refining. This makes RUSAL one of a small number of primary gallium producers outside China, which dominates global gallium supply and imposed gallium export controls in 2023.
Named counterparties — who actually buys and sells
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.
The full counterparty breakdownShowHide
Named customers (1)
Glencore International AG33.00% of RUSAL group global aluminium production under the original 2020 contract terms (one-third of a 5.24Mt maximum) — NOT this Swiss trading entitys own volumes, and actual shipments since 2023 have run far below the contracted maximum · 2020 5-year deal, rolled over into 2025 (2024-05 reporting)arm's lengthwebsearchsecondarysource ↗
Source (mining/trade press, May 2024) names the counterparty only as \"Rusal\" / \"Russian aluminium giant\", not a specific legal entity; Rusal Marketing GmbH is RUSAL's own-stated international trading/marketing arm per this dossier's sourced description, so it is the most plausible contracting entity but this is an inference, not a directly named subsidiary match. Glencore is legally continuing the contract because RUSAL is not itself directly sanctioned.
The exposure register
Ranked by buyer-relative risk, highest first.
1 of 2 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
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.
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.
2026-09-11amendedIndonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform— Kepmen ESDM No. 363.K/MB.01/MEM.B/2026 supersedes the Kepmen 144/2026 HPM formula for low-grade limonite: the nickel Correction Factor (CF) for 1.2%-Ni-or-lower ore is reset to 14% (falling 1pp per 0.1pp of grade below that), and the cobalt by-product coefficient is cut from 30% to 17%. Net effect on 1.2%-Ni ore: HPM falls ~45%, from USD 44.97/wmt to USD 24.89/wmt. The change targets the low-grade limonite/HPAL feedstock segment specifically — the 1.6%-grade CF set by 144/2026 is not disclosed as changed in available reporting.
The laws that threaten it
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:
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
Gallium — 🇨🇳 CN escalates gallium controls to a full export-licensing / ban regime
88
90
+2
Concentration
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Rusal Marketing GmbH 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 — 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
🇬🇳 Guinea — Ministry of Mines plan to reduce bauxite export volumes to support prices (differential quota/allocation tied to downstream-investment commitments)
announced→low likelihood·flagged 66d ago · not yet law·matches Aluminium
If passed — On 18 March 2026 Guinea's Minister of Mines Bouna Sylla told Reuters that Guinea — the world's top bauxite exporter (~40% of global seaborne supply, 2025 exports ~183 Mt, +25% y/y) — would reduce export volumes "in the coming weeks" to support prices and protect small producers, explicitly declining to call it a formal quota ("it is not really a quota, but we will reduce the volumes we export") and ruling out an outright ban. The plan requires major miners (SMB, Chalco/Winning-linked entities, CBG) to submit three-year production plans aligned with their downstream/alumina-investment commitments, with an unofficial target of cutting annual exports toward ~150 Mt. As of end-June 2026 no formal decree had been issued; market reporting through June/July 2026 still describes the mechanism as pending/rumoured. Distinct from all filed Guinea actions (bauxite reference-price arrêté 2022, GUITRAM freight mandate, GAC/EGA concession revocation+settlement, Chalco/SPIC alumina refinery deals, June 2026 raw-gold export ban) — none of which is a bauxite export-volume/quota control. Materiality: Guinea is the Step-0. 5 priority-tier chokepoint for bauxite (feeds the aluminium value chain); a formal quota would be the first-ever volume control on Guinea's dominant bauxite export stream.
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
Gallium is the line to war-game: 🇨🇳 CN already controls 98% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Aluminium carries 43 restrictive measures on record (🇨🇳 CN 61% of refining) — a secondary escalation candidate.
Art. 24(4) · diversification & substitution
Priority mitigations
Every scored material here is one Rusal Marketing GmbH 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.
The mitigation optionsShowHide
Track demand-side substitution against your own book. The buyer levers listed for consumers of Gallium, Aluminium — qualifying alternative suppliers, designing the material out — are the demand risk to Rusal Marketing GmbH's revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by CN on a material Rusal Marketing GmbH produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The materials above are concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
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)
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
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
commodity-trading (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 2026-08-26; 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.
61🇨🇦 Franco-Nevada CorporationRhodium-iridium
60🇯🇵 Mitsubishi CorporationPlatinum-palladium
60🇨🇭 Transamine Trading S.A.Lithium
59🇨🇭 Open Mineral AGLithium
59🇨🇭 Duferco GroupNickel
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 6 further commodity trading 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.
Not included: manganese, chromium, vanadium, niobium, tantalum, tin, cobalt, nickel, lithium, neodymium, dysprosium — these appeared in the sector-derived commodity-trading stub but no evidence was found that RUSAL Marketing GmbH or the wider RUSAL group is materially exposed to them; RUSAL is an aluminium/alumina/bauxite specialist, not a diversified metals trader.
Zefix (Swiss Central Business Names Index), RUSAL Marketing GmbH (CHE-113.641.597) register entry: https://www.zefix.ch/en/search/entity/list/firm/873057
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.
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 ↗
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
Gallium
5Geopolitical: 9 restrictive actions, peak severity 5, 7 in last 24mo, less 1 liberalising action
5Concentration: refining HHI 9684 (extreme); top CN 98%
Aluminium
4Geopolitical: 43 restrictive actions, peak severity 5, 26 in last 24mo, less 1 liberalising action
Gallium — 🇨🇳 CN becomes the single source for gallium — the second source is lost (full 98%+ monopoly)
88
89
+1
Policy
Aluminium — 🇨🇳 CN escalates aluminium controls to a full export-licensing / ban regime
49
55
+6
Concentration
Aluminium — 🇨🇳 CN becomes the single source for aluminium — the second source is lost (full 61%+ monopoly)
49
76
+27
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.
Caveat — gov. gn/Journal Officiel instrument or a specific quota tonnage figure attributed to government.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 49→55+6
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 66d ago · not yet law·matches Aluminium
If passed — On 10 July 2026 the African Development Bank Group, with the African Union Commission, the AfCFTA Secretariat and UNECA, convened African ministers of mining/energy/industry in Abidjan for the "Ministerial Forum on Critical Minerals Value Chain and Beneficiation: Pathways for African Transformation". The stated ambition is continental: move the bloc off raw-ore exports toward regional value chains and in-country processing, with reporting of a push to HARMONISE African mining legislation by end-2026 around a ban on unprocessed ore exports, alongside a headline mobilisation figure of ~USD 63bn for critical-minerals value-chain investment. Why this matters as axis-2 early warning rather than noise: the register already holds a dense cluster of INDIVIDUAL national instruments moving in exactly this direction — Zimbabwe's 2026-02-25 indefinite raw-mineral/lithium-concentrate export suspension, Guinea's 2026-06-19 raw-gold export ban + domestic-refining mandate, Gabon's announced 2029 crude-manganese export ban, Nigeria's RMRDC 30% value-addition bill, Indonesia-style downstreaming copied across the continent, and CEMAC's regional Common Mining Code (all already filed or queued). A binding AU/AfCFTA-level harmonisation instrument would convert that scattered set into a coordinated continental supply shock across cobalt, copper, bauxite, manganese and lithium simultaneously — which is a materially different exposure event from any single-country ban, because it removes the substitute-jurisdiction escape route that currently absorbs each national ban.
Caveat — DELIBERATELY likelihood=low, not moderate. com) is low-quality and was NOT relied on. AU-level harmonisation instruments historically take years and frequently stall at the model-law stage (cf. the known ecb-spf 400 pattern) to establish whether a formal Abidjan Declaration text exists and what it actually commits signatories to.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 49→55+6
🇬🇳 Guinea — Nimba Mining Company (NMC, 100% state-owned) / Glencore bauxite pre-financing and marketing agreement
announced→low likelihood·flagged 13d ago · not yet law·matches Aluminium
If passed — On 7 September 2026 Guinea's state-owned Nimba Mining Company and Glencore signed a five-year pre-financing agreement, announced by the government and Glencore on 10 September 2026, worth over USD 300 million and covering marketing of 10-12 Mt/yr of bauxite (50-60 Mt over the contract term) — a trader advance repaid via physical bauxite delivery rather than conventional debt. Minister of Mines and Geology Bouna Sylla is quoted on-record calling the signing a milestone for Guinean state participation in the mining value chain, and Guinea is separately reported discussing alumina-refining and energy investment with Glencore. This sits alongside the register's other Guinea bauxite-sector state-control instruments (2022 reference-price arrêté, GUITRAM freight mandate, GAC/EGA concession revocation, the parked export-volume-reduction plan below) and is part of the government's "Simandou 2040" push to expand national participation in extractives. Theme candidate: em-resource-upstream-capture. Polarity: none declared (a financing/offtake deal, not a restrictive or liberalising regulatory measure — but materially entrenches state-company control of a bauxite export stream at Guinea's dominant chokepoint, ~40% of global seaborne bauxite supply).
Caveat — gov. gn directly (reachable, HTTP 200) and searched its site for "Nimba Glencore" (no results); a mining. com direct fetch also 403'd. Parked here per verify-or-don't-file rather than filed on secondaries alone. Distinct from the already-parked "Guinea — Ministry of Mines plan to reduce bauxite export volumes" entry below (a volume-quota policy proposal, not this specific NMC-Glencore commercial financing/offtake contract).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 49→55+6
🇬🇳 Guinea Bauxite Export Volume Controls 2026
announced→low likelihood·flagged 114d ago · not yet law·matches Aluminium
If passed — GN ≈ 60% global seaborne bauxite; a ~150 Mt/yr cap (vs 183 Mt 2025) tightens the alumina→aluminium chain — direct hit to EU aluminium-vertical names
Caveat — ministerial-announcement stage since 2026-06-01; repeatedly skipped by filing for lack of a gazetted decree — relocated here 2026-06-13. Sev 3 if decree issued, sev 2 if still announcement-stage.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 49→55+6
🇸🇱 Sierra Leone No Raw Minerals Export Commitment (VP Jalloh, Mining Week May 2026)
announced→low likelihood·flagged 113d ago · not yet law·matches Aluminium
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)
Aluminium🇨🇳 today 49→55+6
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Gallium
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)
Gallium🇨🇳 today 88→90+2
🇪🇺 EU CBAM Scope Expansion to ~180 Downstream Steel/Aluminum Products (COM(2025) 989 final)
draft-published→moderate likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Extends the Carbon Border Adjustment Mechanism from the existing Regulation (EU) 2023/956 sectors (steel, aluminium, cement, fertilisers, hydrogen, electricity) to approximately 180 downstream products with high steel and/or aluminium content — including car parts, domestic appliances (refrigerators, washing machines), power transformers, cables, farming machinery, construction products, and a wide range of industrial equipment; ~2. 5% additional EU imports brought into CBAM scope; entry-into-force proposed from 1 January 2028; also introduces new anti-circumvention provisions (concept of "abusive practices" in proposed Art. 3(35)) targeting operators who split shipments or route via third countries to avoid CBAM liability; affects manufacturers in third countries (China, India, Vietnam, Turkey, ASEAN) that export steel- and aluminium-intensive goods to the EU; raises cost of embedded carbon in European supply chains for all downstream industrial inputs; structurally adjacent to CBAM definitive-phase commencement (January 1, 2026, already filed) — this is a legislative extension, not an implementing regulation
Caveat — Public consultation on downstream scope extension ran July 1 – August 26, 2025 (taxation-customs. ec. europa. eu); Commission adopted proposal December 17, 2025 alongside CBAM implementing acts package; Parliament lead committee is ENVI; Council working group active as of early 2026; no trilogue date announced. Distinct from: filed 2023-05-10-eu-carbon-border-adjustment-mechanism-2023-956 (base regulation, original scope) and 2023-05-10-eu-cbam-definitive-phase-entry-into-force (January 1, 2026 definitive-phase transition). Likelihood is elevated (not high): political consensus on CBAM base regulation was strong, but downstream expansion faces pushback from importing industries and some Member States worried about competitiveness. Secondary: https://taxation-customs. ec. europa. eu/news/cbam-public-consultation-extension-cbam-downstream-products-2025-07-02_en
▲Extends an already-in-force regime (not a new law) (strong) — This amends the existing CBAM Regulation (definitive period live since 2026) rather than creating a new instrument — extensions of in-force EU regulations carry high passage odds vs. novel files.source ↗
▲Council general approach adopted (strong) — The Council reached a general approach on the downstream extension on Jun 12, 2026 — the Council leg of the ordinary legislative procedure is aligned, leaving EP plenary + trilogue.source ↗
▲EP rapporteur appointed and progressing (moderate) — MEP Mohammed Chahim named rapporteur Feb 23, 2026; the Parliament file is moving through committee, not stalled.source ↗
in-consultation→moderate likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Guinea = world's #2 bauxite producer (183 Mt exported in 2025, ~45% of China's bauxite imports); Mines Minister Bouna Sylla confirmed in March 2026 that export volume curbs will be applied by early April 2026 to halt a ~50% price collapse from 2025 overproduction; target cap ~150 Mt/yr (≈18% reduction from 2025 actual); enforced via licence compliance — operators exceeding feasibility-study production ceilings face volume restrictions, not an outright export ban; formal policy instrument expected June 2026 per Bloomberg/Mining. com; mechanism: production-cap enforcement rather than new legislation, but a ministerial arrêté is the likely vehicle
Caveat — Distinct from all 7 filed GN actions: distinct from 2025-07-14-guinea-guitram-freight-mandate (state shipping — different instrument), 2025-08-05-guinea-presidential-decrees-gac-ega (concession revocations — different target), 2026-05-21-guinea-chalco-alumina-refinery-boffa (investment agreement — not export control). This action is the first GN volume-cap mechanism targeting all bauxite exporters. Severity estimate: 3 (affects ~45% of China's bauxite import supply; price-floor mechanism with direct feedthrough to aluminium production costs for smelters globally). Filed in upcoming queue 2026-06-16 per chokepoint-tier gap (Guinea = key bauxite chokepoint). No formal arrêté confirmed as of 2026-06-16.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Aluminium🇨🇳 today 49→55+6
🇬🇳 Guinea Alumina Refinery Ultimatum — SMB and CBG 10-Day Deadline to Submit Construction Timeline (June 2026)
announced→low likelihood·flagged 111d ago · not yet law·matches Aluminium
If passed — Guinea's CNRD junta gives Societe Minière de Boke (SMB, China-linked, ~50% of Guinea's bauxite output) and Compagnie des Bauxites de Guinée (CBG, joint venture: Halco Mining/Alcoa/Rio Tinto/Dadco) 10 days to present binding alumina refinery construction timelines; May deadline was missed; government stated "the companies had already committed to developing local refineries"; failure to comply risks concession revocation or conditions — the August 2025 GAC/EGA revocation provides the enforcement precedent; Guinea government has publicly stated intent to move up the bauxite value chain toward alumina and aluminum
Caveat — Distinct from 2025-08-05-guinea-presidential-decrees-gac-ega (that action revoked GAC/EGA specifically; this action targets SMB and CBG, which are Guinea's two largest bauxite operators — combined ~70% of Guinea's total bauxite exports). Distinct from 2026-05-21-guinea-chalco-alumina-refinery-boffa (Chalco/Chinalco positive investment agreement — contrast: that was a new investor welcomed in; this is a threat to incumbents). If a revocation or binding condition follows, severity = 4 (SMB + CBG together = dominant share of global seaborne bauxite supply). Filed upcoming 2026-06-16.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 49→55+6
🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining Policy
passed-committee→elevated likelihood·flagged 110d ago · not yet law·matches Aluminium
If passed — Cabinet-cleared bill to replace the 2006 Minerals and Mining Act, Act 703: raises mining royalties from current 3–5% range to 9–12% (price-linked sliding scale), introduces a new medium-scale mining licence category bridging artisanal and large-scale operations, mandates district-level community and traditional-authority consultation before applications reach national regulators, scraps unlimited concession renewals (currently indefinitely renewable), and strengthens Ghanaian ownership provisions; National Mining Policy approved by Cabinet simultaneously; affects Newmont (Ahafo/Akyem), AngloGold Ashanti, Kinross (Chirano), Gold Fields (Tarkwa, post-Damang reversion), and Atlantic Lithium (Ewoyaa lithium project); royalty more than doubles at current gold prices — material cost increase for large-scale operators
Caveat — Distinct from all 6 filed GH actions: distinct from 2025-12-19-ghana-minerals-mining-royalty-regulations-2025 (those set sliding royalty under existing Act 703 — this bill replaces Act 703 entirely and raises the ceiling well beyond current regulations); distinct from 2026-03-13-ghana-growth-sustainability-levy-amendment (profit-based tax, not royalty); distinct from 2026-03-19-ghana-atlantic-lithium-ewoyaa-mining-lease and 2026-04-07-ghana-damang-engineers-planners-lease (specific lease grants, not legislation). The Green Minerals Policy (cabinet-approved July 2023, banning raw mineral exports) has not been separately enacted as of June 2026 — if the new Mining Act incorporates its provisions, that becomes the first statutory export restriction for Ghana's lithium and critical minerals. Filed upcoming 2026-06-17.
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Aluminium🇨🇳 today 49→55+6
🇬🇳 Guinea Ministry of Mines — Bauxite Export Volume Cap (~150 Mt/yr, 2026)
in-consultation→moderate likelihood·flagged 108d ago · not yet law·matches Aluminium
If passed — ~25% reduction in Guinea's annual bauxite shipments to China (150 Mt target vs. 183 Mt in 2025 and projected ~200 Mt unconstrained); directly re-prices alumina feedstock costs for Chinese refineries (Guinea supplies ~70% of China's imported bauxite); raises spot bauxite prices; affects CBG/Rio Tinto, SMB-Winning Consortium, Emirates Global Aluminium, UC RUSAL affiliates
Caveat — As of June 19, 2026 no formal decree text confirmed; mechanism described as "licence enforcement" (operators aligned to three-year production plans) not new legislation — formal finalisation expected June 2026. Once decree confirmed, migrate to filing. md as new action (action_type=export-control; sub: export-volume-cap / quota-allocation / bauxite; severity=3). Dedup gate: DISTINCT from 2025-07-14-guinea-guitram-bauxite-shipping-mandate (maritime routing mandate, not volume cap); DISTINCT from 2025-05-26-guinea-ministerial-order-129-mining-permits-revoked (permit revocations); DISTINCT from 2026-05-21-guinea-chalco-alumina-refinery-boffa (downstream investment, not export restriction). Filed upcoming 2026-06-19.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Aluminium🇨🇳 today 49→55+6
🇬🇭 Ghana Minerals and Mining Act 703 Amendment — Cabinet-Approved Proposal (Royalty 9-12%, Lease Cuts, DA Abolition)
draft-published→moderate likelihood·flagged 104d ago · not yet law·matches Aluminium
If passed — Gold mining royalties rise from 3-5% to 9-12% sliding-scale (price-indexed); mining lease maximum cut 30→15 years with renewals limited to 2×10-year additional terms; Development Agreements and Investment Agreements abolished; stability period capped 30→5 years with labour/environment/H&S issues removed from stability protection scope; affects Newmont (Ahafo/Akyem), Gold Fields (Damang/Tarkwa), AngloGold Ashanti (Obuasi) and all major operators in Ghana's ~120 t/yr gold sector
Caveat — Cabinet approved proposed amendments and targeted parliamentary tabling by March 2026; as of June 2026 still pending Parliament (not yet enacted). The amendment is a primary statute overhaul of the Minerals and Mining Act 2006 (Act 703). DISTINCT from: 2025-12-19-ghana-minerals-mining-royalty-regulations (that LI set royalty rates under existing Act 703 — the amendment SUPERSEDES this LI's royalty structure AND adds structural changes); 2026-03-13-ghana-growth-sustainability-levy-amendment (mining levy reduction, separate statute); 2026-03-19-ghana-parliament-atlantic-lithium (individual mining lease ratification); 2026-04-07-ghana-ministry-lands-damang-mining-lease (lease award). Also distinct from the Minerals Commission localisation enforcement already filed (2026-02-18). Q2 2026 was the target passage window per King & Spalding — the bill may be delayed into H2 2026. Severity 3 expected (structural fiscal change affecting all DM gold producers with Ghana operations).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Aluminium🇨🇳 today 49→55+6
🇬🇳 Guinea Bauxite Exchange (GBX) — Mines Minister Bouna Sylla announced July 2025 national bauxite price index targeting FOB pricing transparency and closing gap between declared export values and market prices; planned launch end-2025; Prospect Intel confirmed Guinea-Conakry launched GBX to reclaim pricing control; no enacted arrêté/décret confirmed in primary gazette sources
announced→low likelihood·flagged 102d ago · not yet law·matches Aluminium
If passed — Supersedes 2022 bauxite reference price arrêté; establishes real-time FOB benchmark for all Guinea bauxite exports (~182 Mt/yr, world's largest supplier); estimated >$1bn/yr additional government revenue if fully enforced; directly constrains Chinese alumina refinery price negotiating leverage (60%+ of Guinea bauxite goes to China)
Caveat — Announcement-only at this stage; no decree number or OJ publication found. The 2022 bauxite reference price arrêté (queued separately in filing. md) is the last enacted instrument; GBX is positioned as its successor and upgrade. Distinct from filed 2025-07-14-guinea-guitram-bauxite-shipping-mandate (freight mandate, separate instrument). Severity 3 expected if enacted: Guinea accounts for ~55% of global bauxite trade; mandatory FOB index would restructure all supply contracts for European and Chinese aluminium producers.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 49→55+6
🇪🇺 STAGE UPDATE — EU CBAM COM(2025)989 Downstream Extension: Council adopts general approach June 12, 2026
passed-committee→elevated likelihood·flagged 101d ago · not yet law·matches Aluminium
If passed — Council's general approach expands the Commission's proposed downstream scope further (more products than Commission proposed); mandates annual Commission review for future scope additions; adds anti-circumvention provisions targeting operators who split shipments or route via third countries; Council position now feeds into EP committee and trilogues; entry into force still targeted at 2028 under the proposal
Caveat — Stage advance from "draft-published" to "passed-committee" for the COM(2025)989 proposal flagged 2026-06-16. Council refined the downstream product list beyond Commission's original proposal. EP lead committee ENVI has yet to report; no trilogue date announced as of June 26, 2026. Likelihood remains elevated: Council political consensus secured June 12 — strongest signal since Commission proposal December 2025. Distinct from filed actions: 2023-05-10-eu-cbam-regulation-2023-956 (base regulation) and 2023-05-10-eu-cbam-definitive-phase-entry-into-force. Secondary: https://www. esgtoday. com/eu-member-states-agree-to-expand-cbam-carbon-import-tax-to-downstream-products/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Aluminium🇨🇳 today 49→55+6
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 101d ago · not yet law·matches Aluminium
If passed — Ministry of Mines issued operational guidelines for the Mining Sector Reforms component under Scheme for Special Assistance to States for Capital Investment (SASCI) FY2026-27, with total ₹5,000 crore (~USD 600M) incentive envelope to states; key components: (i) ₹250 crore one-time incentive to any state where ≥10% of pre-March-2026 auctioned major mineral blocks begin production+dispatch by end-2026; (ii) ₹100 crore baseline for systemic reforms (Unified Mining Portal integration, Pre-Auction Committees); (iii) ₹20 crore per block auctioned with pre-embedded forest and environmental clearances; scheme targets removing the "auction gap" — India has auctioned hundreds of mineral blocks since 2015 MMDR amendments but operationalisation lag remains a structural bottleneck; critical minerals relevance: India is running parallel programme of critical+strategic mineral auctions (7 tranches, 56 blocks auctioned by June 24, 2026) and this scheme incentivises states to bring those blocks into production faster; directly accelerates lithium (Rajasthan), REE (Andhra Pradesh, Tamil Nadu), graphite (Odisha), and nickel (Odisha, Jharkhand) pipelines
Caveat — Source is secondary (PolicyEdge news aggregator). To migrate to filing. md, filer must verify the primary notification on mines. gov. in or pib. gov. in (search "SASCI Mining 2026-27" on PIB search). India BHAVYA industrial parks scheme (₹33,660 crore, March 18, 2026) is separately filed — SASCI is a distinct scheme targeting state-level mining-sector governance reform. Distinct from filed India Union Budget 2026-27 Customs notifications and Semiconductor Mission 2. 0. Severity 2 (supply-side demand-unlock rather than export control or FDI gate).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 49→55+6
🇧🇷 Brazil BNDES "Mais Inovação" loan to Wave Aluminium Brasil SA (New Wave) — BRL 221m demonstration plant financing for bauxite-residue processing (Barcarena, Pará)
announced→low likelihood·flagged 87d ago · not yet law·matches Aluminium
If passed — On 16 November 2025 Brazil's national development bank BNDES signed a BRL 221 million (~USD 41. 4m) loan under its "Mais Inovação" program with Wave Aluminium Brasil SA (trading arm of New Wave, founded 2019 by Gustavo Emina) to help finance a semi-industrial demonstration plant that recovers metallic "green iron" from bauxite residue (red mud) using a proprietary microwave-based extraction process. The plant is being built on land inside Hydro Alunorte's Barcarena (Pará) alumina refinery site — which itself generates ~5m tonnes/year of bauxite residue — with total project cost ~BRL 250m and >70% physical progress as of the announcement; commissioning targeted H2 2026. GTA logged this as two linked interventions (a state loan + a local-content incentive) off the same state-act. Relevant to bauxite/alumina residue-valorisation industrial policy — an emerging sub-theme distinct from primary bauxite mining/export actions already in the register (Guinea, Indonesia).
Caveat — Charter §6 verify-or-don't-file: exhausted GTA state-act/intervention pages (sign-in-gated, no primary link exposed even via fetch), searched agenciadenoticias. bndes. gov. br directly (no matching press release — BNDES appears not to have issued a news release for this smaller/startup-scale operation, unlike its R$700m+-class loans which do get releases, e. g. the filed CBA/Eldorado/Suzano BNDES actions), and could not construct a direct link into BNDES's JS-rendered "Consulta a operações" transparency panel. This is NOT speculative: BRL amount, program name pattern (Mais Inovação — confirmed as a real BNDES product at bndes. gov. br/wps/portal/site/home/financiamento/produto/programa-bndes-mais-inovacao), signing date, beneficiary, plant location and physical-progress detail are corroborated by two independent Pará/mining trade outlets and match GTA's independently-logged state-act — so it does not fit the "reject, not credible" bucket. Parked here per the same precedent as the Sudan PM-directive / Egypt 548/2025 / Morocco lines above (real, already-implemented action; primary gov URL not independently locatable this wake). If a working primary URL is found, promote directly to filing. md — likely as TWO linked actions (state loan + local-content incentive) mirroring the two GTA intervention IDs, or one action with both instruments described if a single BNDES source covers both; action_type subsidy; issuer_agency BNDES; severity 1-2 (single mid-size demonstration-plant loan), severity_basis quant off the BRL 221m figure. The second filing. md queue item (local content incentive, intervention 150840) covers the same underlying signing — when promoting/rejecting, resolve both filing. md lines together rather than re-researching from scratch.
announced→low likelihood·flagged 83d ago · not yet law·matches Aluminium
If passed — Guinea — the world's largest bauxite exporter (~single-largest feed to China's alumina/aluminium chain) — is preparing a sector-wide measure to CAP/reduce bauxite exports to stabilise falling prices (benchmark cargoes down 20-35% from 2025 highs, ~$60-70/t). Mines & Geology Minister Bouna Sylla publicly stated (March 2026, reiterated May-June 2026 to Bloomberg) that the government would align each company's 2026 production/export volumes with the levels committed in their feasibility-study reports / mining conventions, using a compliance-based enforcement mechanism (rewarding operators who honoured downstream railway/port/refinery investment pledges, penalising pure-volume extractors) rather than a uniform hard quota. All producers were ordered to submit three-year production plans now under government review; the top-two producers SMB (Société Minière de Boké) and CBG (Compagnie des Bauxites de Guinée) face a parallel refinery ultimatum (government wants 5 new alumina refineries, ~7. 2 Mt/yr combined capacity). If enacted this re-prices a binding aluminium-supply-chain chokepoint and would join the register's existing GN bauxite actions as a NEW export-control instrument.
Caveat — As of end-June 2026 NO formal decree has been issued — total quota, per-company allocations and any retroactive clauses remain pending official confirmation, so this is announced/early-warning, NOT enacted (hence upcoming. md, not filing. md). Distinct from filed GN actions: 2022-09-01 bauxite reference-price arrêté (price mechanism, not volume cap), 2025-07-14 GUITRAM 50% freight mandate (shipping, not export volume), 2025-05-26 Order revoking 129 expired permits, 2026-06-19 raw-gold export ban (different material). The refinery-ultimatum strand overlaps the register's alumina-refinery actions (2025-03-26 SPIC Boffa, 2026-05-21 Chalco Boffa) but the export-cap instrument itself is new.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Aluminium🇨🇳 today 49→55+6
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Gallium
If passed — RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Gallium🇨🇳 today 88→90+2
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Aluminium
If passed — President Peter Mutharika signed an executive order (dated 23 Oct 2025, effective 21 Oct 2025, announced at Sanjika Palace during a cabinet swearing-in) prohibiting the export of raw/unprocessed minerals extracted in Malawi — uranium, rare earth elements, niobium, graphite, tantalum, bauxite, coal, limestone, gemstones, heavy mineral sands, vermiculite, phosphate, rutile, gold, diamonds, copper and others — with an exemption for minerals processed/refined/value-added domestically per Malawian mining law. Announced alongside a suspension of new mining-licence issuance and a review of mining laws (2026/27 State of the Nation Address), plus a planned sovereign wealth fund. Stated rationale: local beneficiation, targeting up to USD 500m/yr once the Kasiya rutile/graphite deposit (Lilongwe) and Kangankunde rare-earth project (Balaka, Mkango Resources — Africa's prospective first new REE mine since 2017, targeting late-2026 production) are fully developed. Violators face fines/penalties under Malawian law. MW is currently the THINNEST country in the register (1 prior action) despite this breadth of minerals covered. Export-ban/beneficiation-mandate, same instrument class as Zimbabwe's SI 213/2022 raw-mineral bans and Guinea's 2026 gold-export ban already in the register.
Caveat — ENACTED (signed order, in force since 21 Oct 2025) but parked here rather than filing. gov. mw directly (TLS cert mismatch: cert is issued for agriculture. gov. mw, not statehouse. gov. mw) and the malawiace. com implementation-analysis piece cites no gov URL either. Same park-lot convention as the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines above (real, already-enacted action; primary URL not independently locatable this wake). Dedup: action-index has only 1 Malawi action total, none overlapping (no prior MW export-ban or beneficiation-mandate action exists). Severity 3-4 expected given the breadth of minerals covered and MW's fast-growing REE/graphite production profile.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Aluminium🇨🇳 today 49→55+6
🇲🇬 Madagascar — Council of Ministers lifts 16-year moratorium on new mining-permit issuance (except gold), effective ~29 Jan 2026
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Aluminium
If passed — Madagascar's Council of Ministers approved resumption of mining-permit issuance on ~28-29 Jan 2026, ending a moratorium in place since 2010 (imposed during a political transition amid mining-title speculation). Roughly 1,650-3,000 pending permit applications accumulated during the freeze can now be processed — Mining Cadastre Bureau (BCMM) confirmed first-come-first-served processing with a maximum 3-month target for first issuances. Covers nickel, cobalt, graphite, rare earths, mineral sands/ilmenite, bauxite, sapphire, quartz and mica; GOLD remains explicitly excluded pending further review. Legal basis: implementation of the 2023 mining code (Loi n°2023-007, promulgated 27 Jul 2024) following mining-cadastre cleanup. SUPPLY-RELIEF — opens Madagascar's graphite (6 large projects, ~3% of global production / 8% of global reserves), nickel-cobalt (Ambatovy) and rare-earth potential to new entrants after a 16-year freeze; MG is currently one of the thinnest countries in the register (2 prior actions) despite this graphite/nickel relevance.
Caveat — ENACTED (Cabinet approved, permits already being processed per BCMM statements) but parked here rather than filing. primature. gov. mg returned a self-signed-certificate error on direct fetch, and app. primature. gov. mg's Conseil des Ministres listing did not surface a January 2026 session in the portion fetched. Same park-lot convention as the Malawi entry above and the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines earlier in this file. Dedup: action-index has only 2 Madagascar actions total, neither about the permit moratorium. Severity 3 expected — moratorium lift affects licensing for nickel/cobalt/graphite/REE projects nationwide.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Aluminium🇨🇳 today 49→55+6
🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)
in-consultation→moderate likelihood·flagged 26d ago · not yet law·matches Aluminium
If passed — Minister of Mines, Petroleum and Energy Mamadou Sangafowa-Coulibaly formally launched the revision of Côte d'Ivoire's 2014 Mining Code on 13 June 2026, standing up an expert team drawn from his ministry, other state institutions and international bodies to rewrite Loi n° 2014-138 du 24 mars 2014. Stated goals: raise state revenue share, fix "disparate and sometimes poorly negotiated" mining conventions, and modernise the mining cadastre. No draft bill text published yet — this is a mandate/committee-formation stage, distinct from and earlier than the already-filed 2026-02-04 Assafou/Doropo gold-permit decrees and the 2025-12-03 PIRME minerals-energy policy (2025-2040), both of which operate under the CURRENT 2014 code rather than proposing to replace it. Chokepoint-relevant: register's only prior CI code-minier-lineage entries are the 2014 code itself and a 2022 local-content oil/gas law — no entry tracks this active rewrite.
Caveat — Dedup: checked action-index and both queues for "code minier"/"mining code" + CI — only hits are the already-filed 2014 code, the 2022 local-content petroleum law, and the 2024-12 gold-royalty finance law, none of which is this revision effort. Distinct from Senegal's and Morocco's already-queued mining-code amendments (different issuer/instrument).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Aluminium🇨🇳 today 49→55+6
🇬🇳 Guinea — Nimba Mining Company (NMC SA) Signs First Base Mining Convention (Tinguilinta Bauxite Concession, Boké)
passed-vote→high likelihood·flagged 25d ago · not yet law·matches Aluminium
If passed — On 6 August 2026, at a ceremony at the Petit Palais of the Presidency chaired by Djiba Diakité (Minister Chief of Staff, chair of the Simandou 2040 Strategic Committee), Guinea's wholly state-owned Nimba Mining Company (NMC SA) signed its first mining convention, covering bauxite extraction at Tinguilinta and export via the Port of Kamsar — a 690. 20 km² concession in Boké Prefecture, 25-year term, refinery requirement, no tax exemptions. This operationalises NMC, which was created by the 5 August 2025 presidential decree revoking GAC/EGA's bauxite concession (already filed: 2025-08-05-guinea-presidential-decree-gac-nimba-mining-sa) — since start-up NMC has extracted ~5 Mt bauxite, exported ~4 Mt in 2026, and the Mines Ministry projects 8-10 Mt for 2026, 12 Mt 2027, 14 Mt 2028. Executive-signed and in force operationally, but multiple outlets state the convention text still requires National Transition Council ratification before Journal Officiel publication — parked on axis 2 rather than filed as enacted pending that primary text. Guinea = priority-tier chokepoint (bauxite, ~world's top exporter).
Caveat — Dedup: checked action-index and both queues for "Nimba"/"NMC"/"Tinguilinta" — the only existing GN hits are the Aug-2025 NMC-creation decree and the May-2026 GAC/EGA settlement, neither of which covers this specific convention signing. No primary Guinean government URL (mines. gov.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Aluminium🇨🇳 today 49→55+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.
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.
Metals industry broadly supportive (asks for more)
(weak)
EU metals producers publicly called for the downstream scope to go even further — the affected domestic industry is not the opposition here, reducing blocking risk.
▼Large new compliance burden (~7,500 importers) (weak) — Extending to ~180 downstream codes pulls in ~7,500 new importers; downstream-importer pushback could slow (not block) the file in trilogue.source ↗
Sourced OSINT observations, not a forecast — a qualitative second read beside the stage-derived band. We do not publish a passage probability of our own until the accrual record proves it is calibrated (never a fabricated %).