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1 critical material scored · binding chokepoint: Helium (🇺🇸 US 43% of mining) · 3 restrictive government measures on record
The binding exposure is Helium — 🇺🇸 US controls 43% of global mining. On this company's production footprint that scores 40/100 (footprint-hedged; global 49). The register holds 3 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Helium Siemens Healthineers AG is the 25th-most-exposed of the 58 named companies we track on 🇺🇸 US's Helium chokepoint; the most-exposed is JSC Angstrem (56/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
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 40/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 1 scored material. Buyer-relative (first-order): weighted by where the company produces (DE 33% · US 27% · CN 16% · GB 9% · IE 5% · IN 5% · SK 4%, estimated split — no cited source states these exact shares, covering 92% of stated output — shares are renormalised across that portion, so the remaining 8% is unmodelled), 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/shl-de/report.
Siemens Healthineers AG is a German medical technology company (majority owned by Siemens AG, which holds a stake stated as "currently circa 67 percent" per Siemens AG's own 2025-11-12 press release announcing a planned deconsolidation — a 30% spin-off of Healthineers shares to Siemens AG shareholders, which would leave Siemens AG at ~37%; this supersedes the ~75%/73.0% figures from earlier 2025 sales, checked 2026-10-02) manufacturing MRI systems, CT scanners, X-ray/fluoroscopy and angiography systems, ultrasound, molecular imaging and radiation oncology equipment, and in-vitro diagnostics/lab equipment. Its largest manufacturing hubs are Forchheim/Erlangen, Germany (diagnostic imaging, advanced therapies) and Malvern, PA / Newark, DE (US diagnostics), with further sites in China, the UK/Ireland (including Oxford MRI magnets), India and Slovakia.
Traditional MAGNETOM systems use up to ~1,500 liters of liquid helium; the newer low-helium "DryCool" sealed-circuit platforms (MAGNETOM Free.Max, Free.Star, the 1.5T Flow) cut the charge to ~0.7 liters in a sealed, non-refilled circuit — a large reduction in helium intensity, but still a superconducting-magnet design that depends on helium, not an elimination of the dependency.
niobium-titanium superconducting wire). Siemens's MRI magnets are confirmed superconducting rather than permanent-magnet designs; NbTi wire is the universal industry-standard superconductor for this application. The company does not separately disclose alloy composition, so this rests on well-established industry practice rather than a Siemens-specific spec citation.
Tungsten (or tungsten-molybdenum alloy) is the standard focal-track material in essentially all medical CT/X-ray tubes industry-wide, chosen for its high atomic number and heat tolerance. No Siemens-specific tube spec sheet was located, but this is universal medical-imaging-industry practice.
(silicon, copper, tin, tantalum, indium, neodymium, cobalt, lithium, silver, antimony) is a generic electronics-sector bill-of-materials. No Siemens Healthineers-specific disclosure (conflict-minerals report, sustainability report materials breakdown) confirming any of these was found in this research pass, so none are retained.
Ranked by buyer-relative risk, highest first.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Helium | 🇺🇸 US 43% mining | 40 | 49 | Moderate | — | High | none | 3 | ▬ stable |
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 |
|---|---|---|---|---|---|---|
| Helium | 3 | 2 | 3 | 5 | 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.
No filings or amendments in this window — the register has been quiet on this company's materials.
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:
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: 40 → 47 (+7) — a relative official policy-pressure magnitude, not a price drawdown.
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Helium — 🇺🇸 US escalates helium controls to a full export-licensing / ban regime | 40 | 47 | +7 |
| Concentration | Helium — 🇺🇸 US becomes the single source for helium — the second source is lost (full 43%+ monopoly) | 40 | 57 | +17 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the materials this company buys. The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Helium).
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 — 1 scored SRM on the input side (binding: Helium) |
| 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 2025-04-23; 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.