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6 critical materials scored · binding chokepoint: Tungsten (🇨🇳 CN 90% of refining) · 54 restrictive government measures on record
The binding exposure is Tungsten — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 76). The register holds 54 restrictive government measures touching this company's materials — each traced to its primary source below.
Where the 180 verified electronics companies we track sit.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 26 further electronics 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 80/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 6 scored materials. Buyer-relative (first-order): weighted by where the company produces (KR 100%, HQ proxy), applied across all materials — it does not yet trace each input to its specific sourcing step.
> The exposure report this dossier powers is at > /intelligence/dossiers/samsung-display/report.
Samsung Display Co., Ltd. (SDC) is the display-panel manufacturing arm of the Samsung group and a majority-owned subsidiary of Samsung Electronics Co., Ltd. It designs and fabricates OLED and LCD display panels — principally small-and-medium OLED panels for smartphones, along with larger OLED panels for IT and TV applications — which it sells to device makers, including but not limited to its own parent.
It is a component manufacturer rather than a finished-device brand: its output is the panel stack itself — the TFT backplane that switches each pixel, the transparent electrode that injects charge into the organic layers, and the reflective and encapsulation layers around them. That stack is where its critical-material exposure sits, and unusually for this register, Samsung Display publishes enough technical and supply-chain detail to identify it from company sources alone.
Two Samsung Display-published source families support the list below: the SDC Responsible Minerals Report 2025, which names the minerals SDC actively manages in its supply chain, and SDC's own "Learn Display" technical explainers, which name the materials in the panel stack. Nothing here is carried over from Samsung Electronics' separate and broader minerals report.
a display maker. SDC's own explainer on indium tin oxide describes mixing indium oxide (In₂O₃) with tin oxide (SnO₂) to form the transparent conducting electrode, used in LCDs to control backlight transmission and in OLEDs to inject holes from the anode into the organic hole-injection layer. There is no drop-in substitute at scale — silver nanowire and other alternatives remain research-stage for mass production — and indium refining is heavily concentrated in China, making this a genuine chokepoint rather than a commodity line item.
over by two independent SDC disclosures: it is the other half of the ITO electrode in the Learn Display explainer, and it is one of the 3TG minerals SDC tracks in its minerals report (67 tin smelters in the supply chain in 2024, the largest count of any 3TG mineral and the only one that rose over the five-year series).
metal. SDC's LTPS explainer describes crystallising amorphous silicon with a laser into low-temperature polycrystalline silicon to raise electron mobility, and calls LTPS the representative TFT technology for high-resolution smartphone displays. The backplane is present in every panel SDC ships.
describes light passing the electrode to reach an Ag (silver) layer and reflecting — the microcavity structure that sets colour and efficiency in top-emission OLED. Thin-film quantities, but not optional to the design.
with 34 tantalum smelters in the supply chain in 2024. Consistent with the capacitor and thin-film content of driver and control electronics; SDC's report confirms presence in its products but does not state the application.
in 2024. As with tantalum, SDC confirms it is present and managed but does not publish the end use.
a critical mineral, with 76 cobalt smelters in the supply chain in 2024 — the count that has moved most over the five-year series (41 → 76). SDC's report attributes cobalt use generally to lithium-ion batteries and to fasteners in electrical and electronic products; it does not state which applies to its own panels, so the application is recorded as unresolved rather than assumed.
Named by Samsung Display but not scored here — gold. Gold is the fourth 3TG mineral and carries SDC's largest smelter count by a wide margin (89 in 2024). It is not in this register's scored material set, so SDC's single largest managed-mineral supply chain does not appear in its score at all. That is a gap in our coverage, not evidence of low exposure.
Dropped from the sector default: neodymium, lithium, antimony and copper. The first three have no support whatsoever for a panel maker. Copper is the closer call — large-format panels conventionally use copper gate and data lines — but no Samsung Display document naming it was located, and the dossier does not need a guessed eighth material when seven are sourced.
Open question — gallium. SDC publishes a Learn Display article on Oxide TFT, and the standard oxide semiconductor in this application is IGZO (indium gallium zinc oxide). If SDC's own article confirms the gallium content, gallium becomes a scored exposure. It is left off pending that check rather than inferred from the technology name.
Ranked by buyer-relative risk, highest first.
2 of 2 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Tungsten | 🇨🇳 CN 90% refining | 88 | 76 | Critical | EXCEEDS 90% | — | some | 16 | ▲ rising |
| Silicon | 🇨🇳 CN 80% refining | 77 | 64 | High | EXCEEDS 80% | — | limited | 19 | ▲ rising |
| Indium | 🇨🇳 CN 69% refining | 76 | 64 | High | — | — | limited | 2 | ▲ rising |
| Tin | 🇨🇳 CN 55% refining | 66 | 56 | Elevated | — | — | ready | 18 | ▲ rising |
| Tantalum | 🇨🇳 CN 50% refining | 53 | 44 | Moderate | — | — | some | 12 | ▲ rising |
| Silver | 🇲🇽 MX 24% mining | 43 | 43 | Moderate | — | — | some | 5 | ▲ 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 |
|---|---|---|---|---|---|---|
| Tungsten | 4 | 4 | 5 | 3 | 3 | company input |
| Silicon | 4 | 4 | 1 | 4 | 4 | company input |
| Indium | 4 | 3 | 5 | 3 | 4 | company input |
| Tin | 4 | 2 | 5 | 2 | 3 | company input |
| Tantalum | 4 | 2 | – | 3 | 3 | company input |
| Silver | 3 | 1 | 5 | 3 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
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 90% of global refining output (by tonnage); US filers' own disclosures independently name China for 54% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| Jiangwu H.C. Starck Tungsten Products Co., Ltd.CID2551 | China | 15 | SEC |
| Chongyi Zhangyuan Tungsten Co., Ltd.CID258 | China | 14 | SEC |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd.CID2315 | China | 14 | SEC |
| Ganzhou Seadragon W & Mo Co., Ltd.CID2494 | China | 14 | SEC |
| Jiangxi Gan Bei Tungsten Co., Ltd.CID2321 | China | 14 | SEC |
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 |
Two independent lenses: USGS official puts China at 50% of global refining output (by tonnage); US filers' own disclosures independently name China for 43% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| F&X Electro-Materials Ltd.CID460 | China | 14 | SEC |
| Hengyang King Xing Lifeng New Materials Co., Ltd.CID2492 | China | 14 | SEC |
| JiuJiang JinXin Nonferrous Metals Co., Ltd.CID914 | China | 14 | SEC |
| Ningxia Orient Tantalum Industry Co., Ltd.CID1277 | China | 14 | SEC |
| Ulba Metallurgical Plant JSCCID1969 | Kazakhstan | 14 | 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.
+ 39 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:
Counterfactual: the 50%-ownership automatic extension of Entity List designations runs to its full perimeter (one-year suspension at 2025-11-10 lifted on schedule). Direct-hit lines are basket issuers in semiconductor / chip-equipment / AI-compute sectors — the perimeter where the rule's 50% controller-affiliate test compounds with existing Entity List names.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 88 → 91 (+3) — a relative official policy-pressure magnitude, not a price drawdown.
🇨🇳 CN has issued 4 restrictive actions on Tungsten since 2025 — cadence accelerating (mean gap 264d → 103d), severity flat (4.0 → 4.0).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 4 of these 15 materials (Silicon, Tungsten, Indium, Silver) — your binding Tungsten exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 6.5 months apart across 5 distinct restriction dates since 2021 (n=4 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Tungsten — 🇨🇳 CN escalates tungsten controls to a full export-licensing / ban regime | 88 | 91 | +3 |
| Concentration | Tungsten — 🇨🇳 CN becomes the single source for tungsten — the second source is lost (full 90%+ monopoly) | 88 | 92 | +4 |
| Policy | Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime | 77 | 82 | +5 |
| Concentration | Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly) | 77 | 89 | +12 |
| Policy | Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime | 76 | 86 | +10 |
| Concentration | Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly) | 76 | 91 | +15 |
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 factors we could score (1 of 30 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, 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 (Tungsten).
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 — 6 scored SRMs on the input side (binding: Tungsten) |
| Manufactures a listed strategic technology | electronics (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 2026-09-22; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-07
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.