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2 critical materials scored · binding chokepoint: Fluorspar (🇨🇳 CN 60% of mining) · 43 restrictive government measures on record
The binding exposure is Fluorspar — 🇨🇳 CN controls 60% of global mining. On this company's production footprint that scores 28/100 (footprint-hedged; global 45). The register holds 43 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Fluorspar Shenzhen Senior Technology Material Co., Ltd. ('Senior' / 星源材质) is the 24th-most-exposed of the 26 named companies we track on 🇨🇳 CN's Fluorspar chokepoint; the most-exposed is Solvay SA (52/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Shenzhen Senior Technology Material Co., Ltd. ('Senior' / 星源材质) ranks 67th of 67 verified battery companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 8 further battery 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 27/100 — 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 (CN 90% · SE 5% · MY 5%, 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.
Shenzhen Senior Technology Material Co., Ltd. (SZSE: 300568.SZ; brand "Senior," Chinese name 星源材质) is one of China's largest producers of lithium-ion battery separator film — the microporous membrane that physically isolates a cell's cathode and anode while letting lithium ions pass through. Coated separators (base film finished with a ceramic or polymer coating for thermal-shrinkage resistance and adhesion) make up roughly 73% of net sales; uncoated wet-process and dry-process separators make up the rest. Senior supplies EV and energy-storage battery makers — its first overseas plant, a ~€250M facility in Eskilstuna, Sweden announced in 2022, was built to supply Northvolt — and has a second overseas base under construction in Malaysia. Roughly 90% of production capacity still sits in China (Shenzhen, Hefei, Changzhou ×2, Nantong, Foshan).
line):** Senior's "SH"-family ceramic-coated separators use an alumina/boehmite (aluminium-oxide) coating layer to resist thermal shrinkage in a cell short. China refines the large majority of the world's alumina, so the coating input sits behind the same chokepoint as much of Senior's own production base.
uses PVDF-type coating/binder chemistry; PVDF's feedstock (vinylidene fluoride, made via hydrofluoric acid) traces back to fluorspar, a mineral in which China holds a dominant share of global mine output.
— those are cathode-active-material, anode-material and current-collector inputs used by cell makers (e.g., CATL, BYD), not by a separator producer. The sector-derived AUTO-stub defaults included them because "battery" sector defaults are drawn from cell-level BOM; dropped here as unsupported for this specific company.
China-specific alumina or fluorspar export restriction would compound — hitting both Senior's coating-input supply chain and the bulk of its own manufacturing footprint at once.
Source for this entire section: Senior's 2016 ChiNext IPO prospectus (首次公开发行股票并在创业板上市招股说明书), filed with SZSE via cninfo 2016-11-18 — static.cninfo.com.cn/finalpage/2016-11-18/1202834050.PDF (§前五名客户/前五名供应商 pp.50, 157-158; §应收账款金额前五名客户情况 pp.307-308; §重大合同 on the Hefei Guoxuan JV). This is a pre-listing snapshot covering FY2013-FY2015 plus H1-2016 — nine years stale relative to today. Checked 2026-09-10: every annual/semi-annual report Senior has filed since listing anonymizes its top-5 customer and supplier tables by rank only (no names), so the prospectus remains the only named-counterparty source this lane has found for this filer. Confidence: primary-source throughout.
The prospectus discloses top-5 concentration on two separate bases that this section keeps distinct:
1. Revenue-based aggregate top-5 (risk-factor prose, no per-name split): customers 50.82% (FY2013) -> 72.59% (FY2014) -> 78.21% (FY2015) -> 79.61% (H1-2016) of net sales; suppliers 56.24% -> 54.40% -> 54.04% -> 54.22% of procurement cost. Recorded as counterparty_concentration (H1-2016 vintage). 2. Accounts-receivable-based top-5, named per entity (the table below) — a narrower, debtor-balance metric, not a sales metric. A customer can rank highly on one basis and not the other depending on payment terms; treat the two as separate lenses on the same customer base, not reconcilable line items.
| Debtor | H1-2016 | FY2015 | FY2014 | FY2013 |
|---|---|---|---|---|
| Tianjin Lishen Battery Co., Ltd. and subsidiaries | 24.83% | 14.25% | 24.29% | — |
| LG Chem, Ltd. | 18.90% | 13.13% | 6.54% | 9.31% |
| BYD Co., Ltd. and subsidiaries / Huizhou BYD Battery Co., Ltd. | 7.42% | 22.91% | 14.63% | 15.56% |
| Tianjin Jiewei Power Industry Co., Ltd. | 6.69% | 8.77% | — | — |
| Jiangsu Sanjie New Energy Co., Ltd. | 4.79% | — | — | — |
| Wanxiang Group and subsidiaries | — | 4.25% | — | — |
| Zhongju Battery and subsidiaries | — | — | 7.87% | — |
| Shenzhen Haiying Technology Co., Ltd. | — | — | 5.09% | — |
| Henan Huanyu Saier New Energy Technology Co., Ltd. | — | — | — | 9.09% |
| CALB (Luoyang) Co., Ltd. | — | — | — | 8.39% |
| Zhongshan Tianmao Battery Co., Ltd. | — | — | — | 4.04% |
All rows disclosed 非关联方 (non-related party) — no arm's-length correction needed, unlike the intra-group-heavy pattern seen elsewhere in this corpus (e.g. yunnan-tin). BYD's own debtor entity is named more narrowly (Huizhou BYD Battery Co., Ltd., its main separator-buying subsidiary) in FY2013-2014 and as the group roll-up from FY2015 — kept as separate rows rather than force-joined, since the filing changed the aggregation scope itself.
LG Chem is the one dual-role entity: customer on this table, and separately the licensor of Senior's ceramic-coating patents under a technology-license agreement disclosed in the same prospectus (customer + IP-supplier, not two trade flows — recorded with role: both).
Korea Petrochemical Ind. Co.'s trading subsidiary is Senior's rank-1 supplier in every disclosed period, on the PP/PE polyolefin resin that forms the separator's uncoated base film: 41.09% of procurement cost (FY2013) -> 38.12% (FY2014) -> 43.74% (FY2015) -> 37.47% (H1-2016). The prospectus states this explicitly as an import-price dependency (imported resin carries a price premium over domestic alternatives), not a volume-availability risk — the polyolefin market itself is described as competitive with ample alternative suppliers. Not material-relevant to this dossier's scored exposures (aluminium and fluorspar sit in the ceramic/PVDF coating layer; PP/PE is the separate uncoated base-film substrate) — recorded for procurement- concentration completeness, not as a chokepoint. Several smaller suppliers (packaging board, wax-oil pore-forming agent for the wet-process line) also appear in the table at 2-7% of procurement each; not structured here as immaterial to both the concentration picture and the scored-material thesis.
An October 2015 strategic-cooperation agreement created a Hefei joint venture (Senior 51% / Hefei Guoxuan 高科动力能源 35% / a third party 14%) to build wet-process separator and ceramic-coating lines, with all JV output committed first to Hefei Guoxuan's own offtake before any third-party sale. Hefei Guoxuan already has its own dossier in this corpus (gotion-high-tech) — this is a direct cross-dossier supply link, not a new entity.
From the company’s own mandatory filings — the CSRC top-5 customer/supplier concentration disclosure and the related-party tables. 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.
Revenue-based aggregate top-5, prospectus risk-factor disclosure (not a named table). Trend across the prospectus's 4 disclosed periods: customers 50.82% (FY2013) -> 72.59% (FY2014) -> 78.21% (FY2015) -> 79.61% (H1-2016); suppliers 56.24% (FY2013) -> 54.40% (FY2014) -> 54.04% (FY2015) -> 54.22% (H1-2016). No related-party share stated for either side at this vintage.
H1-2016 · Dual relationship: LG Chem buys separator film (this row, accounts-receivable table) AND separately licensed Senior its ceramic-coating patents under a technology-license agreement disclosed in the same prospectus — role 'both' reflects customer + IP-supplier, not two trade flows. Name spacing normalized from the filing's inconsistent 'LG Chem,Ltd'/'LG Chem, Ltd' across vintages; same entity.source ↗
H1-2016 · Rank-1 supplier every disclosed period — Korean petrochemical major KPIC's subsidiary supplying the PP/PE polyolefin feedstock for Senior's base film. Not material-relevant to this dossier's scored exposures (aluminium, fluorspar are the coating-layer inputs; PP/PE is the uncoated base-film substrate) — recorded for procurement-concentration completeness, not as a chokepoint row.source ↗
H1-2016 · Dual relationship: LG Chem buys separator film (this row, accounts-receivable table) AND separately licensed Senior its ceramic-coating patents under a technology-license agreement disclosed in the same prospectus — role 'both' reflects customer + IP-supplier, not two trade flows. Name spacing normalized from the filing's inconsistent 'LG Chem,Ltd'/'LG Chem, Ltd' across vintages; same entity.source ↗
H1-2016 · FY2013-2014 rows below name the BYD-group debtor more narrowly as '惠州比亚迪电池有限公司' (Huizhou BYD Battery Co., Ltd.; prospectus pp. 1-1-308/309) rather than the group roll-up used from FY2015 on — kept verbatim per vintage rather than force-joined, since the filing itself changed the aggregation scope, not just the label.source ↗
Qualitative, unquantified: an Oct-2015 strategic-cooperation agreement created a Hefei JV (Senior 51% / Hefei Guoxuan 35% / a third party 14%) to build wet-process separator + ceramic-coating lines, with all JV output committed first to Hefei Guoxuan unless its own offtake can't absorb capacity. In-corpus dossier: gotion-high-tech.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: A-share issuers anonymise counterparties they are not required to name. · section source filing ↗
Ranked by buyer-relative risk, highest first.
0 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Fluorspar | 🇨🇳 CN 60% mining | 28 | 45 | Low | — | Low | hard | — | ▬ stable |
| Aluminium | 🇨🇳 CN 61% refining | 21 | 40 | Low | within 61% | High | some | 43 | ▲ 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 |
|---|---|---|---|---|---|---|
| Fluorspar | 1 | 3 | 3 | 4 | 5 | company input |
| Aluminium | 4 | 3 | 1 | 3 | – | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 28 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:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Fluorspar — 🇨🇳 CN escalates fluorspar controls to a full export-licensing / ban regime | 28 | 39 | +11 |
| Concentration | Fluorspar — 🇨🇳 CN becomes the single source for fluorspar — the second source is lost (full 60%+ monopoly) | 28 | 37 | +9 |
| Policy | Aluminium — 🇨🇳 CN escalates aluminium controls to a full export-licensing / ban regime | 21 | 23 | +2 |
| Concentration | Aluminium — 🇨🇳 CN becomes the single source for aluminium — the second source is lost (full 61%+ monopoly) | 21 | 30 | +9 |
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 10 inputs unrated across the materials bought). Absence of data is not evidence of low risk — an unrated factor enters the score as zero, not as an estimate, so this conclusion could change once those inputs are rated. The mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the materials this company buys. The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, 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.
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 %).
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 (Fluorspar).
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: Fluorspar) |
| Manufactures a listed strategic technology | battery (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 2026-08-26; 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.