Geopolitical Supply-Risk Report·EU CRMA Art. 20–25 assessment·MacroLens · CiconiaLabs

Siemens AG

3 critical materials scored · binding chokepoint: Neodymium (🇨🇳 CN 85% of refining) · 105 restrictive government measures on record

Subject

SIE.DE · 🇩🇪 DE

Sector

industrial

Materials scored

As of

2026-09-30

Risk Office verdict

High · 71/100Company supply-risk index

The binding exposure is Neodymium — 🇨🇳 CN controls 85% of global refining. On this company's production footprint that scores 74/100 (neutral exposure; global 72). The register holds 105 restrictive government measures touching this company's materials — each traced to its primary source below.

Peer rank · Neodymium Siemens AG is the 376th-most-exposed of the 539 named companies we track on 🇨🇳 CN's Neodymium chokepoint; the most-exposed is Alta Resource Technologies (86/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.

Competitor cohort · industrial

Siemens AG ranks 152nd of 286 verified industrial companies, tied with 9 others at 71.

91🇯🇵 Sojitz CorporationDysprosium
90🇦🇹 Fill GmbHDysprosium
87🇦🇹 Anton Paar GmbHDysprosium
86🇯🇵 Omron CorporationDysprosium
85🇩🇪 Siemens Energy AGDysprosium
85🇩🇪 Grob-Werke GmbH & Co. KGDysprosium
84🇺🇸 Core Laboratories Inc.Tungsten
84🇪🇸 M Torres GroupTungsten
84🇮🇹 Pittini Group SpAGraphite
83🇫🇷 Fives GroupTungsten
83🇺🇸 Hyster-Yale Materials Handling, Inc.Graphite
83🇯🇵 Mitsubishi Electric CorporationDysprosium
82🇯🇵 KeyenceTungsten
82🇵🇹 FapricelaManganese
71🇩🇪 Siemens AGNeodymium

Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 60 further industrial 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 71/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 3 scored materials. Buyer-relative (first-order): weighted by where the company produces (DE 44% · CN 22% · US 19% · CZ 7% · IN 7%, estimated split — no cited source states these exact shares, covering 72% of stated output — shares are renormalised across that portion, so the remaining 28% is unmodelled), applied across all materials — it does not yet trace each input to its specific sourcing step.

Siemens AG

The exposure report this dossier powers is at /intelligence/dossiers/sie-de/report.

What they do

Siemens AG is the German industrial conglomerate parent, distinct from the separately-listed Siemens Healthineers AG (majority-owned subsidiary, shl-de) and Siemens Energy AG (fully spun off). Its current segments are Digital Industries (factory and process automation — PLCs, servo motors and drives, machine-tool automation, industrial software), Smart Infrastructure (electrification, low/medium-voltage switchgear, building automation, digital grid solutions), and Mobility (rail vehicles, rail automation, and related services).

Critical-material exposure

Copper — bulk input, Smart Infrastructure electrification and

switchgear (busbars, grid hardware). Siemens' own newsroom states its new DC-technology portfolio cuts raw-material use, "including copper, by up to half" versus conventional AC infrastructure — confirming copper as a baseline structural input to this business line.

Silicon — as silicon carbide (SiC), Smart Infrastructure power

electronics. Infineon supplies SiC power modules (62 mm CoolSiC MOSFET, 1200 V) for Siemens' SENTRON 3QD2 solid-state circuit breaker, per trade-press reporting of the 2026-06 Siemens/Infineon announcement — no Siemens- or Infineon-published source was reachable to confirm this directly, so it is weaker sourcing than the copper claim above.

Neodymium — structural component, Mobility traction motors. Siemens

Mobility markets "permanent magnet synchronous motor" (PMSM) traction technology for trains. The company does not name the magnet alloy directly, but PMSM traction drives at this scale overwhelmingly use NdFeB permanent magnets industry-wide, so this rests on a confirmed technology class plus well-established industry composition, not a Siemens-named alloy disclosure.

Not verified / dropped: the sector-derived guess for this dossier

(nickel, chromium, cobalt, tungsten, niobium, vanadium, manganese, aluminium) is a generic industrial-sector bill-of-materials. No Siemens AG-specific source confirming any of these was found in this research pass. Siemens AG's public responsible-minerals page references OECD conflict-minerals due diligence in general terms without naming specific metals, so 3TG (tin, tantalum, tungsten, gold) could not be itemized as confirmed exposures either — note any such disclosure found for "Siemens" in search results for cobalt/lithium/gold belongs to the separately-listed Siemens Energy AG, not this company.

Sources

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 breakdownShow

Named suppliers (1)

Infineon Technologies AG · 2026arm's length trade-press secondarysource ↗
Infineon supplies silicon-carbide (SiC) power modules -- 62mm CoolSiC MOSFET module, 1200V -- for Siemens' SENTRON 3QD2 semiconductor circuit breaker (Smart Infrastructure). No share/value disclosed.

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.

The exposure register

Ranked by buyer-relative risk, highest first.

2 of 3 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
Neodymium	🇨🇳 CN 85% refining	74	72	High	EXCEEDS 85%	Med	some	50	▲ rising
Silicon	🇨🇳 CN 80% refining	66	64	Elevated	EXCEEDS 80%	Med	limited	19	▲ rising
Copper	🇨🇳 CN 48% refining	60	59	Elevated	within 48%	High	limited	52	▲ 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 ↗

Supply-risk factor analysis

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.

The factor-by-factor analysisShow

Material	Geopolitical	Concentration	Price / market	Substitutability	Import reliance	Logistics · ESG · Supplier
Neodymium	4	4	5	3	3	company input
Silicon	4	4	1	4	4	company input
Copper	4	2	5	4	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.

Material factors (scored 4–5) — evidence

Neodymium
- 4Geopolitical: 50 restrictive actions, peak severity 5, 35 in last 24mo, less 4 liberalising actions
- 4Concentration: refining HHI 7306 (extreme); top CN 85%
- 5Price / market: price up, as of 2026-10-05
Silicon
- 4Geopolitical: 19 restrictive actions, peak severity 4, 14 in last 24mo
- 4Concentration: refining HHI 6498 (extreme); top CN 80%
- 4Substitutability: limited substitutes in electronics/electrical steel
- 4Import reliance: Eurostat Comext 2025: 63% extra-EU imports, top partner NO 47% (partner HHI 2698)
Copper
- 4Geopolitical: 52 restrictive actions, peak severity 5, 33 in last 24mo, less 3 liberalising actions
- 5Price / market: price up, as of 2026-09-01
- 4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 70/100 (long-horizon, all major uses). Prior analyst short-run rating 0.50: USGS: aluminium substitutes in some electrical/heat-exchange uses

Change log

last 30 days

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.

2026-09-30filedIndia Ministry of Mines launches first offshore mineral block auction (Andaman Sea)
2026-09-22filedUS BIS temporary final rule restricting polysilicon stockpiling ahead of Proclamation 11052 Section 232 tariffs and minimum import prices
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.
2026-09-07filedChina MOFCOM Preliminary Anti-Dumping Ruling on Japanese Dichlorosilane (DCS) Imports

The laws that threaten it

Restrictive government measures on this company's materials, newest first — each links to its primary government source.

The full list of lawsShow

🇮🇳 India Ministry of Mines launches first offshore mineral block auction (Andaman Sea)New since 2026-09-05
2026-09-30· industrial-policy· severity 2· cobalt, nickel, manganese, copper
🇺🇸 US BIS temporary final rule restricting polysilicon stockpiling ahead of Proclamation 11052 Section 232 tariffs and minimum import pricesNew since 2026-09-05
2026-09-22· regulatory· severity 3· polysilicon, silicon
🇨🇳 China MOFCOM Preliminary Anti-Dumping Ruling on Japanese Dichlorosilane (DCS) ImportsNew since 2026-09-05
2026-09-07· tariff· severity 4· silicon
🇺🇸 US Commerce continues antidumping duty orders (Bosnia, Iceland, Malaysia) and countervailing duty order (Kazakhstan) on silicon metal after five-year sunset review
2026-09-03· tariff· severity 3· silicon-metal
🇪🇺 EU opens interim review of anti-dumping duties on silicon metal from China
2026-09-01· tariff· severity 2· silicon-metal
🇵🇪 Peru DS 014-2026-EM — Mining exploration DIA fast-track platform threshold raised 40→60
2026-07-20· regulatory· severity 2· copper
🇨🇳 China MOFCOM Announcement No. 27 [2026] — 20 more Japanese entities incl. National Institute for Defense Studies added to Control List
2026-06-29· export-control· severity 4· rare-earths, gallium, germanium, antimony
🇨🇳 China MOFCOM Announcement No. 26 (2026) — Strategic Mineral Export Control Reporting and Whistleblower Mechanism
2026-06-24· regulatory· severity 2· rare-earth-elements, gallium, germanium, antimony
🇨🇳 China MOFCOM Announcement No. 23 (2026) — 10 US Entities Added to Export Control Management List, Including MP Materials and USA Rare Earth
2026-06-22· export-control· severity 4· rare-earth-elements, neodymium, dysprosium, praseodymium
🇺🇸 US USTR Section 301 Determination — Proposed 25% Tariff on All Brazilian Goods
2026-06-04· tariff· severity 3· niobium, copper, iron-ore
🇿🇦 South Africa: Industrial Development Strategy 2026 — Permit-Conditioned Beneficiation Mandate for Critical Minerals
2026-06-03· industrial-policy· severity 3· chrome, platinum-group-metals, cobalt, lithium
🇺🇸 US USTR Section 301 Forced Labor Findings and Proposed Action — 60 Economies
2026-06-02· tariff· severity 3· cotton, polysilicon, cobalt, lithium
🇺🇸 US Proclamation 11032 — Further Adjusting Section 232 Tariff Regimes for Aluminum, Steel, and Copper
2026-06-01· tariff· severity 2· aluminum, steel, copper
🇨🇳 China State Council Order No. 839 — Regulations for the Implementation of the Mineral Resources Law
2026-05-20· regulatory· severity 3· rare-earths, gallium, germanium, antimony
🇦🇺 Australia — Treasurer's FATA s.69(2) orders direct six China-linked investors to divest 1.68 billion Northern Minerals shares (Orders (No. 1) 2026)
2026-05-17· fdi-screen· severity 5· dysprosium, terbium, rare-earth-elements

+ 90 more in the register.

Art. 24(2)(c) · vulnerability to disruption

Stress test — two plausible scenarios

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 scenariosShow

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).

Closest real precedent — this isn’t hypothetical

MOFCOM Announcements 61 + 62 — full REE export-control escalation

export-control escalation (material-controller)

Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.

Modelled buyer-relative move on the binding exposure if this precedent escalates: 74 → 78 (+4) — a relative official policy-pressure magnitude, not a price drawdown.

Trace the precedent to its primary source via the link above (/actions/2025-10-09-china-mofcom-rare-earths-extraterritorial-export-controls).

🇨🇳 CN has issued 13 restrictive actions on Neodymium since 2024 — cadence accelerating (mean gap 103d → 29d), severity flat (3.8 → 3.4).A descriptive trajectory of past official actions — not a forecast.

🇨🇳 CN's demonstrated restriction sequence — has restricted 28 materials since 2016, in this demonstrated order:

You hold exposure to 3 of these 28 materials (Copper, Silicon, Neodymium) — your binding Neodymium exposure is one of them.

Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 6.1 months apart across 8 distinct restriction dates since 2016 (n=7 intervals).

Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —

🇺🇸 US has historically countered a median of 3.9 months later (n=23 recorded episodes since 2024). Counter-move intensity: median severity 3/5 (3 of 23 via quantified basis).
🇮🇳 IN has historically countered a median of 9.9 months later (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5 (0 of 4 via quantified basis).

Descriptive history of recorded counter-actions in our causal register — not a forecast; the gap is what the controller's past moves drew in response.

Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —

when 🇨🇳 CN restricts your Silicon, 🇺🇸 US has historically countered (median 3.8 months later) — and those counter-moves have also restricted Neodymium, which you also depend on (n=16 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 of 16 via quantified basis).
when 🇨🇳 CN restricts your Neodymium, 🇺🇸 US has historically countered (median 3.9 months later) — and those counter-moves have also restricted Copper, which you also depend on (n=9 recorded episodes since 2025). Counter-move intensity: median severity 3/5, hardest 4/5 (1 of 9 via quantified basis).

Descriptive history of recorded counter-actions in our causal register, intersected with your dependency basket — not a forecast; it shows where a controller's past retaliations have landed across your materials.

The ordered history of what this controller has restricted, each step traced to /actions/{id} — a descriptive sequence, not a forecast.

Type	Scenario	Today	Stressed	Δ
Policy	Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime	74	78	+4
Concentration	Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly)	74	84	+10
Policy	Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime	66	70	+4
Concentration	Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly)	66	78	+12
Policy	Copper — 🇨🇳 CN escalates copper controls to a full export-licensing / ban regime	60	64	+4
Concentration	Copper — 🇨🇳 CN becomes the single source for copper — the second source is lost (full 48%+ monopoly)	60	86	+26

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.

Art. 24(4) · mitigation trigger

Significant-vulnerability conclusion

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 — 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 threatsShow

🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)
passed-vote→high likelihood·flagged 55d ago · not yet law·matches Copper
If passed — On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
Caveat — ENACTED / already in force (signed 29 June 2026, five independent Congolese/international outlets corroborate the ministers, date and substance) but parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. cd unreachable per prior wakes — same constraint noted on the DRC Strategic Mineral Reclassification, ARECOMS forfeiture, and 5% Worker Equity entries elsewhere in this file). DISTINCT from: 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (ARECOMS sectoral cobalt-hydroxide quota system, cobalt-only), 2025-12-19-drc-artisanal-copper-cobalt-processing-suspension (artisanal-sector only), the queued ARECOMS H1-2026 quota-forfeiture entry above (operationalises the ARECOMS quota, not this arrêté), 2026-04-10-drc-strategic-reserve-minerals-arecoms, and 2026-05-29-drc-strategic-mineral-expansion-decree. This arrêté is the FIRST instrument in the register banning concentrate exports for BOTH copper and cobalt jointly and replacing the 2023 commercialisation/export/nomenclature framework wholesale — a materially broader legal basis than any of the above. Re-check mines. gouv. cd and jocc.
https://actualite.cd/2026/08/06/rdc-kinshasa-interdit-lexportation-des-concentres-de-cuivre-et-de-cobalt-pour-encourager
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 66d ago · not yet law·matches Copper
If passed — Minister of Finance, acting under s. 89 of the Customs and Excise Act, cut the copper-concentrate export duty to ZERO for tariff headings 2603. 00. 21 / 2603. 00. 22 / 2603. 00. 23 / 2603. 00. 29, capped at 271,742 t, effective 1 June 2026 with automatic lapse 30 September 2026, with per-entity tonnage caps and (per one secondary) a requirement that exempt shipments channel through Industrial Resources Limited. This is a SUPPLY-RELIEF (liberalising) action — a net EASING of a copper/cobalt chokepoint for ~4 months, explicitly to clear stockpiled unprocessed concentrate while Zambia's major smelters are down for extended maintenance. It is the "(No. 2)" successor instrument to the already-filed 2026-03-05-zambia-si-15-2026-copper-concentrates-export-duty-suspension (a distinct SI with its own number, tonnage cap and validity window). Severity ~2 expected.
Caveat — ENACTED / already in force per multiple independent secondary sources (all agree on SI number, exact citation title, s. org URL pattern that resolves for the parent SI 15/2026 (`/akn/zm/act/si/2026/43/eng@<date>`) across several plausible dates, all 404; zambialii's SI-list index page for 2026 also 404s directly. Parked here per the standing verify-or-don't-file convention (cf. DRC ARECOMS, Pakistan chloroform, China sulfuric-acid entries below) rather than filed on secondaries alone. Re-check zambialii.
https://www.zambiamonitor.com/govt-suspends-export-duty-on-copper-concentrates/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
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 Copper, Neodymium
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.
https://www.afdb.org/en/documents/high-level-ministerial-forum-critical-minerals-value-chain-and-beneficiation-pathways-african-transformation
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 72d ago · not yet law·matches Copper
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
https://www.spglobal.com/energy/en/news-research/latest-news/metals/041526-chinas-sulfuric-acid-restrictions-set-to-squeeze-miners
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Neodymium
If passed — Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
Caveat — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
https://www.madini.go.tz/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Neodymium🇨🇳 today 74→78+4
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 98d ago · not yet law·matches Copper, Neodymium
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
https://senate.parlam.kz/en-US/news/details/14628
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 99d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in advanced negotiations to acquire a 15-20% equity stake (deal value ~USD 1. 5-2bn) in First Quantum Minerals' Zambian copper and nickel operations — i. e. the Kansanshi and Sentinel/Trident copper complex (Zambia's largest copper mines, ~0. 4-0. 5 Mt/yr combined) plus nickel. This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) directly into a binding African copper chokepoint, paralleling Manara's filed Vale Base Metals 10% stake (2024-03-01-sa-manara-minerals-vale-metals-10pct-stake) and its in-negotiation Reko Diq stake (queued below), and mirroring UAE IRH's Mopani (Zambia) acquisition. Gives Saudi Arabia an equity claim on a major non-China copper supply source and injects fresh capital into FQM as it recovers from the Cobre Panamá shutdown — a Gulf-capital re-pricing of Zambian copper supply risk that the exposure engine should track.
Caveat — As of 2026-06-28 this is in advanced negotiation, no signed SPA — hence announced/upcoming not enacted. DISTINCT from the Reko Diq (Pakistan) Manara stake queued below (different asset, different host country) and from the filed Vale Base Metals 10% stake. If completed, severity 2-3.
https://www.miningsee.eu/saudi-arabias-manara-minerals-eyes-stake-in-first-quantums-zambian-copper-and-nickel-assets/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Neodymium, Copper
If passed — First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2447259
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
- Copper🇨🇳 today 60→64+4
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Neodymium, Silicon
If passed — Second wave of CRMA Art. 14 strategic projects (drawn from 160+ applications: 95 EU-domestic + 66 third-country including 40 from strategic-partnership countries) gains fast-track permitting (27-month EU cap, 15-month Member State cap), EIB/EBRD financing-hub priority, and off-taker certainty; 75 battery-value-chain projects + 21 REE-for-permanent-magnets in pool; widens the EU's 2030 extraction/processing benchmarks pipeline beyond the first 60 projects
Caveat — Second call for applications closed January 15, 2026 (September 2025 launch). Commission stated ~4-month assessment period → designation expected May–June 2026. As of 2026-06-15, no Commission press release or OJ publication confirmed. EUR-Lex CELEX 32026D0923 verified via web search to be an unrelated EU animal-disease implementing decision. Moved from filing. md 2026-06-15. Distinct from: 2025-03-25-eu-crma-strategic-projects-first-designation (60 projects, first round) and 2024-05-23-eu-crma-entry-into-force (base regulation). Severity 3 expected (same as first-round designation).
https://single-market-economy.ec.europa.eu/news/strategic-projects-critical-raw-materials-gain-momentum-second-selection-round-potential-funding-and-2026-01-19_en
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Neodymium🇨🇳 today 74→78+4
- Silicon🇨🇳 today 66→70+4
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 113d ago · not yet law·matches Neodymium
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
https://www.mining.com/web/congo-adds-lithium-to-strategic-minerals-in-higher-tax-bracket
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 113d ago · not yet law·matches Copper
If passed — Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mining concessions for first time in Peruvian law history, making concessions revocable by administrative authority; introduces higher annual fees and stronger production/investment requirements; threatens legal certainty for Peru's undeveloped copper and silver project pipeline — Peru = #2 copper, #4 silver, #1 lead, #2 zinc globally
Caveat — Approved by Energy and Mining Commission March 17, 2026 by 11 votes to 1 with 3 abstentions — driven by left-aligned Juntos por el Perú (JPP) and Podemos Peru majority. Bill also introduces "comuneros como accionistas" (community shareholders) in mining concessions — first legislative insertion of indigenous community equity rights. MINEM, SNMPE, ComexPerú, and Ingemmet publicly opposed; MINEM warns reform would incentivise illegal mining expansion. Full plenary debate pending as of June 2026. Distinct from all filed PE actions (all executive/regulatory decrees — no prior legislative amendment to Ley General de Minería in register). Also distinct from filed PE actions on REINFO extension (2025-12-26), illegal-mining criminalization (2026-01-20), and Tía María revocation (2026-03-19).
https://elcomercio.pe/economia/peru/comision-de-energia-aprueba-cambios-en-la-ley-de-mineria-y-reaviva-alertas-por-impacto-en-inversion-y-estabilidad-juridica-noticia/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 60→64+4
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Neodymium, Silicon
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.
https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
- Silicon🇨🇳 today 66→70+4
🇺🇸 US-China Bilateral Rare Earth Minerals Deal Framework
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Neodymium
If passed — Framework agreed "in principle" between Trump and Xi following June 5, 2026 call and subsequent negotiations; Trump stated June 11, 2026 "Our deal with China is done, subject to final approval with President Xi and me" — China to supply "full magnets, and any necessary rare earths, up front" to US; if formally enacted, would suspend or ease China's April 2025 rare earth export licensing regime (filed 2025-04-04-china-mofcom-rare-earth-export-licensing) for US-bound shipments; China's Vice Commerce Minister Li Chenggang confirmed "in principle" framework consensus from the June 5 Trump-Xi call; tariff framework: US 55% / China 10%; China April 2025 rare earth controls (heavy/medium REEs, including Dy/Tb NdFeB magnets, SmCo magnets) remain formally active — no MOFCOM suspension announcement found as of June 15, 2026; the deal is political but not yet implemented as a formal regulation or bilateral MOU
Caveat — Distinct from filed 2025-11-09-china-mofcom-announcement-72 (which suspended October 2025 US-targeted controls but left April 2025 REE licensing in place). Distinct from filed 2025-04-04-china-mofcom-rare-earth-export-licensing (April 2025 seven-REE licensing, which this deal may eventually suspend/amend). If formally enacted, this represents a structural easing of the most consequential REE supply-risk action in the register. Severity estimate: 3 if enacted (direct re-routing of ~$3–5bn/yr US rare earth magnet imports; reshapes REE concentration score for US/China interdependence axis).
https://www.yahoo.com/news/trump-says-u-china-deal-155232342.html
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
🇮🇩 Indonesia PP 19/2025 Mining Royalty Rate Hike — Implementation Postponed Indefinitely (May 2026)
announced→low likelihood·flagged 111d ago · not yet law·matches Copper
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
https://en.antaranews.com/news/415656/indonesia-delays-mining-royalty-and-export-levy-plan
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 110d ago · not yet law·matches Copper
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
https://www.mineria.gob.bo/index.php/nota_prensa/bolivia-activa-reforma-minera-integral-y-sale-a-captar-inversiones-con-respaldo-del-banco-mundial/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 60→64+4
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Neodymium, Copper
If passed — Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
https://ustr.gov/about/policy-offices/press-office/press-releases/2026/february/ustr-seeks-public-comment-design-plurilateral-agreement-trade-critical-minerals-and-policy-actions
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Neodymium🇨🇳 today 74→78+4
- Copper🇨🇳 today 60→64+4
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 109d ago · not yet law·matches Copper
If passed — Full replacement of the Mining Act 1992 with sweeping new statute: state acquires up to 30% equity in any new mining project (Kumul Minerals free-carry); special mining leases (SML) issued for initial 30-month periods with FID requirement to renew; mandatory landowner and community consultation before licence grant; Mining Development Authority (MDA) replaces current Mineral Resources Authority (MRA) as the sector regulator; CGT on extractive asset transfers now in force since the 2025 Income Tax Act (separate filed action); bill as drafted would reshape FDI terms for all existing and future mining permits including Wafi-Golpu (Newmont/Harmony 26 Moz Au, 4. 8 Mt Cu — SML long-delayed), Frieda River copper-gold (PanAust), and Ok Tedi expansion; PNG's 2023 Mining (New Porgera) Amendment Act handled Porgera separately
Caveat — The public-consultation-draft stage is already filed in the register as 2025-02-25-papua-new-guinea-mining-bill-2025 (filed action records the consultation launch). This upcoming entry tracks the NEXT stage: parliamentary enactment. Consultations closed April 4, 2025; minister aimed for September 2025 tabling but no confirmed passage found as of June 2026. Likelihood moderate — bill has broad government backing and a 15-year development history, but PNG legislative timelines are frequently extended; the May 2025 Marape cabinet reshuffle may have shifted ministerial priorities. Distinct from: 2023-10-13-papua-new-guinea-mining-new-porgera-amendment-act (single-mine statute); 2025-03-12-papua-new-guinea-national-petroleum-authority-act (petroleum, not mining); 2025-03-20-papua-new-guinea-income-tax-act-2025 (CGT on extractive transfers — already enacted separately).
https://www.businessadvantagepng.com/papua-new-guineas-draft-mining-bill-sweeping-reforms-to-overhaul-the-sector/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 101d ago · not yet law·matches Copper, Neodymium
If passed — TZ Finance Bill establishes the Mineral Research Fund capitalised at 10% of gross mineral revenue (~TZS 141 billion/yr at 2025 collection levels); amends the Income Tax Act to formally recognise tax exemptions granted under individual mining Framework Agreements and introduces standard operating procedures — reduces discretionary government risk for large mining investors (Panda Hill niobium, graphite juniors, Buzwagi gold); parallel VAT amendments give equivalent statutory certainty for VAT exemptions; taken together, the bill moves Tanzania from discretionary tax administration toward a rule-of-law-based investor regime for all critical-mineral projects; budget targets Tanzania for top-4 niobium producer status (Panda Hill DA already signed March 24, 2026) and 50% geophysical survey coverage by 2030
Caveat — Tanzania fiscal year starts July 1; the Finance Act signature typically occurs last week of June. Budget speech delivered June 11, 2026 by Finance Minister Khamis Mussa Omar; Parliament approved June 23. Mining provisions in §§ amending Income Tax Act (Cap. 332) and VAT Act (Cap. 148) and establishing the Mineral Research Fund. Distinct from: filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year), filed 2026-03-24-tanzania-panda-hill-niobium-ferroniobium-development-agreement (the specific project DA), and filed 2026-04-15-tanzania-ministry-of-minerals-revokes-40-idle-mineral-exploration-licences. Severity 2: institutional reform that de-risks the investor regime rather than a direct trade restriction.
https://www.tanzaniainvest.com/economy/budget-2026-2027-parliament-approved
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇹🇿 Tanzania Finance Bill 2026/27 — NEW raw-mineral EXPORT LEVY on quartz (HS 25.06) and feldspar (HS 2529.10.00) under the Export Tax Act, Cap. 196
awaiting-signature→high likelihood·flagged 99d ago · not yet law·matches Silicon
If passed — The same Finance Bill 2026/27 already tabled (Parliament-passed 23 June 2026, effective 1 July 2026) inserts a NEW export levy of "10% of the FOB value of the cargo OR TZS 200 per kilogram, whichever is higher" on exports of quartz minerals (HS 25. 06) and feldspar (HS 2529. 10. 00) via amendment to the Export Tax Act, Cap. 196 — a distinct beneficiation-forcing EXPORT-TAX instrument that pushes raw quartz/feldspar exporters toward in-country value-addition. 196), and neither existing entry mentions it; (2) material-relevant — quartz HS 25. 06 covers high-purity/silica quartz feeding the silicon→semiconductor/solar value chain, so a Tanzanian export tax re-prices a raw-silica supply node; the same "rocks to riches" beneficiation logic Tanzania applies elsewhere; (3) part of the wider African raw-mineral-export-tax wave (cf. Zimbabwe 10% lithium-concentrate levy, Namibia unprocessed-mineral ban, Guinea bauxite reference price).
Caveat — On enactment, fold into that one TZ Finance Act 2026 action with action_type capturing both the fiscal-incentive and the export-levy (export-control/tariff) provisions; do NOT double-file. Distinct from filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year — no quartz/feldspar export levy). Severity 2 (sectoral raw-mineral export tax, niche HS lines).
https://polis.bunge.go.tz/uploads/bills/1781852249-Muswada_wa_Sheriia_ya_Fedha_wa_Mwaka_2026_(The_Finance_Bill,_2026).pdf
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Silicon🇨🇳 today 66→70+4
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 104d ago · not yet law·matches Copper
If passed — All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension; effectively forces equity restructuring across the entire DRC copper-cobalt belt; miners seeking moratorium as of June 18, 2026 — enforcement outcome by August 2026 will set the precedent
Caveat — Ministerial enforcement letter issued January 30, 2026 by Mines Minister Louis Watum Kabamba — activates dormant Art. 71 bis (5% employee equity in mining company capital) and Art. 144 bis (mechanics) of DRC Mining Code (Loi n° 18/001). Filed here (not filing. md) because DRC government websites (mines. gouv. cd, primature. gouv. cd) remain inaccessible per prior wakes — same constraint as the DRC Strategic Mineral Reclassification entry. Action IS already in effect and enforcement is underway (July 31, 2026 deadline); this is NOT speculative. DRC Chamber of Mines convened June 11, 2026 industry response meeting; companies arguing retroactive application is legally contested. Severity 3 expected if enforced. Distinct from: 2018-01-27-drc-mining-code-revision (underlying law), 2026-04-10-drc-strategic-reserve (ARECOMS mechanism), 2026-04-24-drc-tshisekedi-mining-export-revenue-audit.
https://www.kitco.com/news/off-the-wire/2026-06-18/congo-miners-seek-delay-5-worker-equity-rule-july-deadline
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 104d ago · not yet law·matches Copper
If passed — Revises 30 CFR Part 580 to streamline 10 provisions governing prospecting, leasing, and operations for hard minerals (manganese nodules, cobalt-rich crusts, seafloor massive sulfides) on the US Outer Continental Shelf; eliminates environmental notification to adjacent state governors (§580. 31) and BOEM's own environmental review requirement (§580. 29); accelerates OCS hard mineral leasing pipeline in line with EOs 14285 and 14154 ("unleashing" OCS resources); comment period closed April 27, 2026; awaiting final rule
Caveat — First substantive revision of US OCS hard minerals regulatory framework in ~35 years; distinct from all filed US actions (no prior OCS hard minerals action in register). Severity 2: regulatory infrastructure that enables future OCS leasing rather than a direct production/export instrument; secondary-boem: https://www. boem. gov/newsroom/press-releases/boem-proposes-rule-changes-support-critical-mineral-exploration-and
Reference-class base rate
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — a base rate for comparable bills, not a forecast for this one. source ↗
https://www.federalregister.gov/documents/2026/02/24/2026-03690/administrative-revisions-to-regulations-related-to-outer-continental-shelf-minerals-other-than-oil
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 60→64+4
🇮🇳 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 Copper, Neodymium
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).
https://www.policyedge.in/p/centre-launches-5000-crore-incentive-scheme-to-speed-up-mine-auctions-and-production
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇪🇺 EU Permanent-Magnet Scrap & Waste Export Restriction
announced→low likelihood·flagged 100d ago · not yet law·matches Neodymium
If passed — Under the RESourceEU action plan (COM(2025) 945, adopted 3 Dec 2025 and already filed as 2025-12-03-eu-resourceeu-action-plan-com-2025-945), the European Commission committed to PROPOSE, by Q2 2026, restrictions on the export of scraps and waste of permanent magnets — an essential feedstock for European NdFeB recyclers that is increasingly shipped abroad (notably to China). Recycling could meet ~20% of the EU's ~20,000 t/yr permanent-magnet demand, so retaining end-of-life and pre-consumer magnet scrap in the EU is framed as a supply-security measure to reduce China dependence. Accompanying measures: a new EU-level Combined Nomenclature sub-code + European Waste Catalogue entry to identify/track permanent magnets and EoL products containing them, plus a targeted CRMA amendment on product-labelling and pre-consumer-waste recycling. If enacted as a binding export restriction this would be the EU's first outbound control on a critical-mineral waste stream — directly relevant to anyone in the EU/China REE-magnet recycling loop, and a mirror-image to China's REE/magnet export controls (re-prices intra-bloc vs ex-bloc scrap flows). The European recycling industry (BIR) has publicly warned the measure risks market distortion, so adoption/scope is contested.
Caveat — As of 2026-06-27 (end of Q2) no formal proposal or regulation has been located — still at the action-plan-commitment stage, hence axis-2/upcoming not filing. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella plan announcing the intent — this item tracks the specific export-restriction instrument that the plan promised), from filed 2026-03-04-eu-council-crma-general-approach-resourceeu (Council general approach on the CRMA amendment), and from the EU dual-use export-control regime (2021-821 / 2025-2003). Distinct from the US-China REE deal (line 78) and EU CRMA strategic-projects round (line 58). Severity 2-3 if enacted (first EU outbound control on an REE waste stream; re-prices the EU↔China magnet-scrap loop).
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Neodymium🇨🇳 today 74→78+4
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 100d ago · not yet law·matches Copper, Neodymium
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
https://mono.mn/n/government_approves_draft
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 100d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one of the world's largest undeveloped Cu-Au deposits (phase-1 ~200,000 t/yr copper concentrate + 250,000 oz/yr gold, first production targeted end-2028, ~USD 5. 5bn phase-1 capex). The stake would be purchased from the Pakistani state's half of the project (Pakistan federal SOEs + Balochistan hold 50%; Barrick Gold holds 50% and operates). This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) into a strategic copper chokepoint, paralleling Manara's Vale Base Metals 10% stake and IRH's Mopani (Zambia) acquisition; gives Saudi Arabia an equity claim on a major future non-China copper supply source.
Caveat — As of 2026-06-27 the deal is in negotiation — Pakistan's Petroleum Minister Musadik Malik said publicly he expected a deal "within the next six months," hence announced/upcoming not enacted. Distinct from filed 2025-09-08-pakistan-us-ussm-fwo-critical-minerals-mou (US EXIM/USSM financing angle on Reko Diq), filed 2025-03-14-pakistan-balochistan-mines-and-minerals-act (the provincial mining law), and filed 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake (Manara's Vale Base Metals deal). Severity 2-3 if completed.
https://www.mining-technology.com/news/manara-minerals-acquire-20-stake-reko-diq-project/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 99d ago · not yet law·matches Copper
If passed — Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring the interest from the Government of Pakistan (Pakistan + Balochistan together own 50%; Barrick Gold holds the other 50% as operator). Reko Diq is one of the world's largest undeveloped copper-gold deposits (~$74bn projected free cash flow over a ~37-yr life). IPTM relevance: a GCC sovereign-capital upstream-mining-FDI entry (theme gcc-mining-upstream-fdi) into COPPER — a binding chokepoint material — extending the Saudi diversification-of-supply strategy beyond the filed 2024-03-01 Manara→Vale Base Metals 10% stake; would also be a Pakistan host-state instrument (federal divestment of part of its Reko Diq equity to a Gulf SWF, complementing the 2025-09-08 Pakistan–US USSM critical-minerals MoU already filed). Distinct GCC third-party capital base separate from Chinese-SOE capture and Western MSP/CRMA-aligned investment.
Caveat — As of mid-2025 the deal was reported by Pakistan's Petroleum Minister as expected "within six months" but NO binding SPA or primary gov instrument has surfaced as of 2026-06-28 — hence announced/moderate, not enacted. Dedup: only the 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake Manara action is filed; no Reko Diq/Manara slug in action-index; the filed Reko Diq item (2025-09-08 Pakistan–US USSM–FWO MoU) is a DIFFERENT instrument (US bilateral MoU, not a Saudi equity purchase). Severity 2-3.
https://www.dawn.com/news/1886746
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇪🇺 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 Neodymium, Copper
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").
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Neodymium🇨🇳 today 74→78+4
- Copper🇨🇳 today 60→64+4
🇲🇼 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 Neodymium, Copper
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.
https://www.theeastafrican.co.ke/tea/business-tech/malawi-president-mutharika-bans-exports-of-raw-minerals-5247332
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
- Copper🇨🇳 today 60→64+4
🇲🇬 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 Neodymium
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.
https://fr.allafrica.com/stories/202602040158.html
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 31d ago · not yet law·matches Neodymium
If passed — Draft law amending Morocco's 2015 Mining Code (led by the Ministry of Energy Transition and Sustainable Development, Minister Leila Benali), with public consultations reported open since ~Feb 2025. Three structural changes: (1) a National Commission for Strategic and Critical Minerals empowered to designate an official list of "strategic and critical minerals" — Morocco's first formal legal mechanism to do so, which would sit upstream of and interact directly with the phosphate chokepoint (Morocco holds ~70% of world phosphate-rock reserves via OCP); (2) the digital mining cadastre (governance/transparency layer — this component has ALREADY gone live, launched 2026-04-07, and is queued separately to filing. md as an enacted action); (3) sharply increased penalties for illegal mining/prospecting (unauthorised prospecting: MAD 100k-1m; illegal extraction/transport/sale: up to MAD 2m). Morocco is chokepoint-tier and thinly covered (only 4 prior MA actions: 2022 Investment Charter, an AfDB agriculture loan, the 2026 Loi de Finances, and a Feb-2026 mining-tender notice — none creates a minerals-designation regime).
Caveat — distinct from the already-filed 2026-04-07 digital-cadastre launch (enacted, queued to filing. Dedup: no MA action in the index covers a strategic-minerals designation commission or mining-code amendment; the 3 other MA entries (Investment Charter 2022, Loi de Finances 2026, Feb-2026 mining tender) are distinct instruments.
https://fr.apanews.net/news/le-maroc-revise-son-code-minier-pour-stimuler-linvestissement/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Neodymium🇨🇳 today 74→78+4
🇮🇳 India–Myanmar rare-earths cooperation — elevated to formal bilateral agenda at Modi–Min Aung Hlaing summit
announced→low likelihood·flagged 29d ago · not yet law·matches Neodymium
If passed — At Myanmar military-government head Min Aung Hlaing's early-June-2026 New Delhi visit (his first India visit since the 2021 coup), critical minerals and rare earths featured explicitly on the formal bilateral agenda for the first time — India's Foreign Secretary Vikram Misri confirmed both sides "agreed to stay in touch" on critical minerals/rare earths and "take cooperation forward. " This is India seeking an alternative heavy-rare-earth source (Kachin State/Wa State artisanal mining, currently ~all exported to China) amid China's 2025 rare-earth export controls. No formal supply contract, MOU, or binding mineral-cooperation instrument has been signed — this is government-to-government dialogue only, elevated from background technical talks to official summit-agenda status. Analysts place realistic commercial-scale sourcing in the 2028-2035 window, contingent on Kachin conflict resolution and connectivity infrastructure. Chokepoint-tier (MM heavy rare earths, only 4 prior MM actions in the index, all domestic Myanmar mining/export regulation — none touching an India bilateral angle).
Caveat — Dedup: no existing IN or MM action in filing. md/upcoming. md/action-index covers India-Myanmar rare-earth cooperation (checked "india. *myanmar" across all three — only hit was an unrelated DPIIT Press Note 2/2026 land-border-FDI action that separately still requires prior approval for Myanmar-domiciled investors). Distinct from the 3 filed Myanmar domestic actions (Wa State tin suspension/restart licensing, MOC Notification 93/2024, KIO rare-earth regulation) which are host-country supply-side instruments, not this demand-side sourcing-diversification angle. Severity 1-2 while at dialogue stage.
https://www.tribuneindia.com/news/bilateral-engagement/india-myanmar-to-stay-in-touch-on-issue-of-critical-minerals-rare-earths-take-cooperation-forward-mea
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Neodymium🇨🇳 today 74→78+4
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 1d ago · not yet law·matches Copper
If passed — State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar's ambassador that it will resume the Jebel Ohier copper-gold project (Red Sea State) with an $800M commitment. Third GCC sovereign upstream-mining entry after Manara Minerals/Vale Base Metals 10% stake (2024-03-01, filed) and QIA/Ivanhoe Mines strategic placement (2025-09-17, filed) — extends the GCC-as-third-capital-base pattern (theme gcc-mining-upstream-fdi) to African copper, not just battery metals.
Caveat — gov. sd not independently reachable; QMSD's own project page does not yet mention the resumption) — parked here per the same convention used for the Malawi executive-order entry above (real/firm commitment, primary URL not yet locatable). Dedup: checked "qatar mining", "jebel ohier", "qmsd" across filing. md, upcoming. md, and action-index — zero hits. Likelihood=high reflects a confirmed government-to-government commitment, not a prediction of eventual gazettal.
https://sudantribune.com/article/313934
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4

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.

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 listShow

Neodymium is the line to war-game: 🇨🇳 CN already controls 85% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Silicon carries 19 restrictive measures on record (🇨🇳 CN 80% of refining) — a secondary escalation candidate.
Copper carries 52 restrictive measures on record (🇨🇳 CN 48% of refining) — a secondary escalation candidate.

Art. 24(4) · diversification & substitution

Priority mitigations

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 (Neodymium).

The mitigation optionsShow

Map your real exposure to Neodymium. Trace it from the component back to the smelter/refiner and country of origin — most buyers discover the dependence is one tier deeper than their direct supplier.
Qualify a non-CN source. Identify and validate at least one supplier outside CN for the binding input before it is needed, even at a cost premium — optionality is the hedge.
Lead-time to re-source is ~9 months (6-12mo). The largest tracked non-CN producer of Neodymium is 🇲🇾 MY (~8% of refining); scaling it into a replacement is roughly a 6-12mo ramp. A share-of-stage substitution heuristic derived from current production share, not a firm supplier quote.
Design for substitution where feasible. Neodymium has at least partial substitutes; specify them into next-generation products to cut the dependence structurally.
Hold strategic inventory / contract forward. For materials with no substitute and active export controls, a buffer stock or long-dated offtake converts a shock into a managed cost.
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 crosswalkShow

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.

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.

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 detailsShow

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 — 3 scored SRMs on the input side (binding: Neodymium)
Manufactures a listed strategic technology	industrial (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.

All sourcesShow

Methodology

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 2026-09-30; 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 2026-10-05

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.

← All companies

Geopolitical Supply-Risk Report·EU CRMA Art. 20–25 assessment·MacroLens · CiconiaLabs

Siemens AG

3 critical materials scored · binding chokepoint: Neodymium (🇨🇳 CN 85% of refining) · 105 restrictive government measures on record

Subject

SIE.DE · 🇩🇪 DE

Sector

industrial

Materials scored

As of

2026-09-30

Risk Office verdict

High · 71/100Company supply-risk index

Competitor cohort · industrial

Siemens AG ranks 152nd of 286 verified industrial companies, tied with 9 others at 71.

91🇯🇵 Sojitz CorporationDysprosium
90🇦🇹 Fill GmbHDysprosium
87🇦🇹 Anton Paar GmbHDysprosium
86🇯🇵 Omron CorporationDysprosium
85🇩🇪 Siemens Energy AGDysprosium
85🇩🇪 Grob-Werke GmbH & Co. KGDysprosium
84🇺🇸 Core Laboratories Inc.Tungsten
84🇪🇸 M Torres GroupTungsten
84🇮🇹 Pittini Group SpAGraphite
83🇫🇷 Fives GroupTungsten
83🇺🇸 Hyster-Yale Materials Handling, Inc.Graphite
83🇯🇵 Mitsubishi Electric CorporationDysprosium
82🇯🇵 KeyenceTungsten
82🇵🇹 FapricelaManganese
71🇩🇪 Siemens AGNeodymium

Siemens AG

The exposure report this dossier powers is at /intelligence/dossiers/sie-de/report.

What they do

Critical-material exposure

Copper — bulk input, Smart Infrastructure electrification and

Silicon — as silicon carbide (SiC), Smart Infrastructure power

Neodymium — structural component, Mobility traction motors. Siemens

Not verified / dropped: the sector-derived guess for this dossier

Sources

Named counterparties — who actually buys and sells

The full counterparty breakdownShow

Named suppliers (1)

Infineon Technologies AG · 2026arm's length trade-press secondarysource ↗
Infineon supplies silicon-carbide (SiC) power modules -- 62mm CoolSiC MOSFET module, 1200V -- for Siemens' SENTRON 3QD2 semiconductor circuit breaker (Smart Infrastructure). No share/value disclosed.

The exposure register

Ranked by buyer-relative risk, highest first.

2 of 3 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
Neodymium	🇨🇳 CN 85% refining	74	72	High	EXCEEDS 85%	Med	some	50	▲ rising
Silicon	🇨🇳 CN 80% refining	66	64	Elevated	EXCEEDS 80%	Med	limited	19	▲ rising
Copper	🇨🇳 CN 48% refining	60	59	Elevated	within 48%	High	limited	52	▲ rising

Supply-risk factor analysis

The factor-by-factor analysisShow

Material	Geopolitical	Concentration	Price / market	Substitutability	Import reliance	Logistics · ESG · Supplier
Neodymium	4	4	5	3	3	company input
Silicon	4	4	1	4	4	company input
Copper	4	2	5	4	3	company input

Material factors (scored 4–5) — evidence

Neodymium
- 4Geopolitical: 50 restrictive actions, peak severity 5, 35 in last 24mo, less 4 liberalising actions
- 4Concentration: refining HHI 7306 (extreme); top CN 85%
- 5Price / market: price up, as of 2026-10-05
Silicon
- 4Geopolitical: 19 restrictive actions, peak severity 4, 14 in last 24mo
- 4Concentration: refining HHI 6498 (extreme); top CN 80%
- 4Substitutability: limited substitutes in electronics/electrical steel
- 4Import reliance: Eurostat Comext 2025: 63% extra-EU imports, top partner NO 47% (partner HHI 2698)
Copper
- 4Geopolitical: 52 restrictive actions, peak severity 5, 33 in last 24mo, less 3 liberalising actions
- 5Price / market: price up, as of 2026-09-01
- 4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 70/100 (long-horizon, all major uses). Prior analyst short-run rating 0.50: USGS: aluminium substitutes in some electrical/heat-exchange uses

Change log

last 30 days

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.

2026-09-30filedIndia Ministry of Mines launches first offshore mineral block auction (Andaman Sea)
2026-09-22filedUS BIS temporary final rule restricting polysilicon stockpiling ahead of Proclamation 11052 Section 232 tariffs and minimum import prices
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.
2026-09-07filedChina MOFCOM Preliminary Anti-Dumping Ruling on Japanese Dichlorosilane (DCS) Imports

The laws that threaten it

Restrictive government measures on this company's materials, newest first — each links to its primary government source.

The full list of lawsShow

🇮🇳 India Ministry of Mines launches first offshore mineral block auction (Andaman Sea)New since 2026-09-05
2026-09-30· industrial-policy· severity 2· cobalt, nickel, manganese, copper
🇺🇸 US BIS temporary final rule restricting polysilicon stockpiling ahead of Proclamation 11052 Section 232 tariffs and minimum import pricesNew since 2026-09-05
2026-09-22· regulatory· severity 3· polysilicon, silicon
🇨🇳 China MOFCOM Preliminary Anti-Dumping Ruling on Japanese Dichlorosilane (DCS) ImportsNew since 2026-09-05
2026-09-07· tariff· severity 4· silicon
🇺🇸 US Commerce continues antidumping duty orders (Bosnia, Iceland, Malaysia) and countervailing duty order (Kazakhstan) on silicon metal after five-year sunset review
2026-09-03· tariff· severity 3· silicon-metal
🇪🇺 EU opens interim review of anti-dumping duties on silicon metal from China
2026-09-01· tariff· severity 2· silicon-metal
🇵🇪 Peru DS 014-2026-EM — Mining exploration DIA fast-track platform threshold raised 40→60
2026-07-20· regulatory· severity 2· copper
🇨🇳 China MOFCOM Announcement No. 27 [2026] — 20 more Japanese entities incl. National Institute for Defense Studies added to Control List
2026-06-29· export-control· severity 4· rare-earths, gallium, germanium, antimony
🇨🇳 China MOFCOM Announcement No. 26 (2026) — Strategic Mineral Export Control Reporting and Whistleblower Mechanism
2026-06-24· regulatory· severity 2· rare-earth-elements, gallium, germanium, antimony
🇨🇳 China MOFCOM Announcement No. 23 (2026) — 10 US Entities Added to Export Control Management List, Including MP Materials and USA Rare Earth
2026-06-22· export-control· severity 4· rare-earth-elements, neodymium, dysprosium, praseodymium
🇺🇸 US USTR Section 301 Determination — Proposed 25% Tariff on All Brazilian Goods
2026-06-04· tariff· severity 3· niobium, copper, iron-ore
🇿🇦 South Africa: Industrial Development Strategy 2026 — Permit-Conditioned Beneficiation Mandate for Critical Minerals
2026-06-03· industrial-policy· severity 3· chrome, platinum-group-metals, cobalt, lithium
🇺🇸 US USTR Section 301 Forced Labor Findings and Proposed Action — 60 Economies
2026-06-02· tariff· severity 3· cotton, polysilicon, cobalt, lithium
🇺🇸 US Proclamation 11032 — Further Adjusting Section 232 Tariff Regimes for Aluminum, Steel, and Copper
2026-06-01· tariff· severity 2· aluminum, steel, copper
🇨🇳 China State Council Order No. 839 — Regulations for the Implementation of the Mineral Resources Law
2026-05-20· regulatory· severity 3· rare-earths, gallium, germanium, antimony
🇦🇺 Australia — Treasurer's FATA s.69(2) orders direct six China-linked investors to divest 1.68 billion Northern Minerals shares (Orders (No. 1) 2026)
2026-05-17· fdi-screen· severity 5· dysprosium, terbium, rare-earth-elements

+ 90 more in the register.

Art. 24(2)(c) · vulnerability to disruption

Stress test — two plausible scenarios

Both stress-test scenariosShow

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).

Closest real precedent — this isn’t hypothetical

MOFCOM Announcements 61 + 62 — full REE export-control escalation

export-control escalation (material-controller)

Modelled buyer-relative move on the binding exposure if this precedent escalates: 74 → 78 (+4) — a relative official policy-pressure magnitude, not a price drawdown.

Trace the precedent to its primary source via the link above (/actions/2025-10-09-china-mofcom-rare-earths-extraterritorial-export-controls).

🇨🇳 CN's demonstrated restriction sequence — has restricted 28 materials since 2016, in this demonstrated order:

You hold exposure to 3 of these 28 materials (Copper, Silicon, Neodymium) — your binding Neodymium exposure is one of them.

Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 6.1 months apart across 8 distinct restriction dates since 2016 (n=7 intervals).

Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —

🇺🇸 US has historically countered a median of 3.9 months later (n=23 recorded episodes since 2024). Counter-move intensity: median severity 3/5 (3 of 23 via quantified basis).
🇮🇳 IN has historically countered a median of 9.9 months later (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5 (0 of 4 via quantified basis).

Descriptive history of recorded counter-actions in our causal register — not a forecast; the gap is what the controller's past moves drew in response.

Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —

when 🇨🇳 CN restricts your Silicon, 🇺🇸 US has historically countered (median 3.8 months later) — and those counter-moves have also restricted Neodymium, which you also depend on (n=16 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 of 16 via quantified basis).
when 🇨🇳 CN restricts your Neodymium, 🇺🇸 US has historically countered (median 3.9 months later) — and those counter-moves have also restricted Copper, which you also depend on (n=9 recorded episodes since 2025). Counter-move intensity: median severity 3/5, hardest 4/5 (1 of 9 via quantified basis).

The ordered history of what this controller has restricted, each step traced to /actions/{id} — a descriptive sequence, not a forecast.

Type	Scenario	Today	Stressed	Δ
Policy	Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime	74	78	+4
Concentration	Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly)	74	84	+10
Policy	Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime	66	70	+4
Concentration	Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly)	66	78	+12
Policy	Copper — 🇨🇳 CN escalates copper controls to a full export-licensing / ban regime	60	64	+4
Concentration	Copper — 🇨🇳 CN becomes the single source for copper — the second source is lost (full 48%+ monopoly)	60	86	+26

Art. 24(4) · mitigation trigger

Significant-vulnerability conclusion

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.

Proposed — not yet law

Upcoming regulatory threats

The upcoming threatsShow

🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)
passed-vote→high likelihood·flagged 55d ago · not yet law·matches Copper
If passed — On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
Caveat — ENACTED / already in force (signed 29 June 2026, five independent Congolese/international outlets corroborate the ministers, date and substance) but parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. cd unreachable per prior wakes — same constraint noted on the DRC Strategic Mineral Reclassification, ARECOMS forfeiture, and 5% Worker Equity entries elsewhere in this file). DISTINCT from: 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (ARECOMS sectoral cobalt-hydroxide quota system, cobalt-only), 2025-12-19-drc-artisanal-copper-cobalt-processing-suspension (artisanal-sector only), the queued ARECOMS H1-2026 quota-forfeiture entry above (operationalises the ARECOMS quota, not this arrêté), 2026-04-10-drc-strategic-reserve-minerals-arecoms, and 2026-05-29-drc-strategic-mineral-expansion-decree. This arrêté is the FIRST instrument in the register banning concentrate exports for BOTH copper and cobalt jointly and replacing the 2023 commercialisation/export/nomenclature framework wholesale — a materially broader legal basis than any of the above. Re-check mines. gouv. cd and jocc.
https://actualite.cd/2026/08/06/rdc-kinshasa-interdit-lexportation-des-concentres-de-cuivre-et-de-cobalt-pour-encourager
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 66d ago · not yet law·matches Copper
If passed — Minister of Finance, acting under s. 89 of the Customs and Excise Act, cut the copper-concentrate export duty to ZERO for tariff headings 2603. 00. 21 / 2603. 00. 22 / 2603. 00. 23 / 2603. 00. 29, capped at 271,742 t, effective 1 June 2026 with automatic lapse 30 September 2026, with per-entity tonnage caps and (per one secondary) a requirement that exempt shipments channel through Industrial Resources Limited. This is a SUPPLY-RELIEF (liberalising) action — a net EASING of a copper/cobalt chokepoint for ~4 months, explicitly to clear stockpiled unprocessed concentrate while Zambia's major smelters are down for extended maintenance. It is the "(No. 2)" successor instrument to the already-filed 2026-03-05-zambia-si-15-2026-copper-concentrates-export-duty-suspension (a distinct SI with its own number, tonnage cap and validity window). Severity ~2 expected.
Caveat — ENACTED / already in force per multiple independent secondary sources (all agree on SI number, exact citation title, s. org URL pattern that resolves for the parent SI 15/2026 (`/akn/zm/act/si/2026/43/eng@<date>`) across several plausible dates, all 404; zambialii's SI-list index page for 2026 also 404s directly. Parked here per the standing verify-or-don't-file convention (cf. DRC ARECOMS, Pakistan chloroform, China sulfuric-acid entries below) rather than filed on secondaries alone. Re-check zambialii.
https://www.zambiamonitor.com/govt-suspends-export-duty-on-copper-concentrates/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
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 Copper, Neodymium
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.
https://www.afdb.org/en/documents/high-level-ministerial-forum-critical-minerals-value-chain-and-beneficiation-pathways-african-transformation
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 72d ago · not yet law·matches Copper
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
https://www.spglobal.com/energy/en/news-research/latest-news/metals/041526-chinas-sulfuric-acid-restrictions-set-to-squeeze-miners
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Neodymium
If passed — Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
Caveat — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
https://www.madini.go.tz/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Neodymium🇨🇳 today 74→78+4
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 98d ago · not yet law·matches Copper, Neodymium
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
https://senate.parlam.kz/en-US/news/details/14628
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 99d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in advanced negotiations to acquire a 15-20% equity stake (deal value ~USD 1. 5-2bn) in First Quantum Minerals' Zambian copper and nickel operations — i. e. the Kansanshi and Sentinel/Trident copper complex (Zambia's largest copper mines, ~0. 4-0. 5 Mt/yr combined) plus nickel. This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) directly into a binding African copper chokepoint, paralleling Manara's filed Vale Base Metals 10% stake (2024-03-01-sa-manara-minerals-vale-metals-10pct-stake) and its in-negotiation Reko Diq stake (queued below), and mirroring UAE IRH's Mopani (Zambia) acquisition. Gives Saudi Arabia an equity claim on a major non-China copper supply source and injects fresh capital into FQM as it recovers from the Cobre Panamá shutdown — a Gulf-capital re-pricing of Zambian copper supply risk that the exposure engine should track.
Caveat — As of 2026-06-28 this is in advanced negotiation, no signed SPA — hence announced/upcoming not enacted. DISTINCT from the Reko Diq (Pakistan) Manara stake queued below (different asset, different host country) and from the filed Vale Base Metals 10% stake. If completed, severity 2-3.
https://www.miningsee.eu/saudi-arabias-manara-minerals-eyes-stake-in-first-quantums-zambian-copper-and-nickel-assets/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Neodymium, Copper
If passed — First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2447259
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
- Copper🇨🇳 today 60→64+4
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Neodymium, Silicon
If passed — Second wave of CRMA Art. 14 strategic projects (drawn from 160+ applications: 95 EU-domestic + 66 third-country including 40 from strategic-partnership countries) gains fast-track permitting (27-month EU cap, 15-month Member State cap), EIB/EBRD financing-hub priority, and off-taker certainty; 75 battery-value-chain projects + 21 REE-for-permanent-magnets in pool; widens the EU's 2030 extraction/processing benchmarks pipeline beyond the first 60 projects
Caveat — Second call for applications closed January 15, 2026 (September 2025 launch). Commission stated ~4-month assessment period → designation expected May–June 2026. As of 2026-06-15, no Commission press release or OJ publication confirmed. EUR-Lex CELEX 32026D0923 verified via web search to be an unrelated EU animal-disease implementing decision. Moved from filing. md 2026-06-15. Distinct from: 2025-03-25-eu-crma-strategic-projects-first-designation (60 projects, first round) and 2024-05-23-eu-crma-entry-into-force (base regulation). Severity 3 expected (same as first-round designation).
https://single-market-economy.ec.europa.eu/news/strategic-projects-critical-raw-materials-gain-momentum-second-selection-round-potential-funding-and-2026-01-19_en
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Neodymium🇨🇳 today 74→78+4
- Silicon🇨🇳 today 66→70+4
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 113d ago · not yet law·matches Neodymium
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
https://www.mining.com/web/congo-adds-lithium-to-strategic-minerals-in-higher-tax-bracket
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 113d ago · not yet law·matches Copper
If passed — Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mining concessions for first time in Peruvian law history, making concessions revocable by administrative authority; introduces higher annual fees and stronger production/investment requirements; threatens legal certainty for Peru's undeveloped copper and silver project pipeline — Peru = #2 copper, #4 silver, #1 lead, #2 zinc globally
Caveat — Approved by Energy and Mining Commission March 17, 2026 by 11 votes to 1 with 3 abstentions — driven by left-aligned Juntos por el Perú (JPP) and Podemos Peru majority. Bill also introduces "comuneros como accionistas" (community shareholders) in mining concessions — first legislative insertion of indigenous community equity rights. MINEM, SNMPE, ComexPerú, and Ingemmet publicly opposed; MINEM warns reform would incentivise illegal mining expansion. Full plenary debate pending as of June 2026. Distinct from all filed PE actions (all executive/regulatory decrees — no prior legislative amendment to Ley General de Minería in register). Also distinct from filed PE actions on REINFO extension (2025-12-26), illegal-mining criminalization (2026-01-20), and Tía María revocation (2026-03-19).
https://elcomercio.pe/economia/peru/comision-de-energia-aprueba-cambios-en-la-ley-de-mineria-y-reaviva-alertas-por-impacto-en-inversion-y-estabilidad-juridica-noticia/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 60→64+4
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Neodymium, Silicon
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.
https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
- Silicon🇨🇳 today 66→70+4
🇺🇸 US-China Bilateral Rare Earth Minerals Deal Framework
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Neodymium
If passed — Framework agreed "in principle" between Trump and Xi following June 5, 2026 call and subsequent negotiations; Trump stated June 11, 2026 "Our deal with China is done, subject to final approval with President Xi and me" — China to supply "full magnets, and any necessary rare earths, up front" to US; if formally enacted, would suspend or ease China's April 2025 rare earth export licensing regime (filed 2025-04-04-china-mofcom-rare-earth-export-licensing) for US-bound shipments; China's Vice Commerce Minister Li Chenggang confirmed "in principle" framework consensus from the June 5 Trump-Xi call; tariff framework: US 55% / China 10%; China April 2025 rare earth controls (heavy/medium REEs, including Dy/Tb NdFeB magnets, SmCo magnets) remain formally active — no MOFCOM suspension announcement found as of June 15, 2026; the deal is political but not yet implemented as a formal regulation or bilateral MOU
Caveat — Distinct from filed 2025-11-09-china-mofcom-announcement-72 (which suspended October 2025 US-targeted controls but left April 2025 REE licensing in place). Distinct from filed 2025-04-04-china-mofcom-rare-earth-export-licensing (April 2025 seven-REE licensing, which this deal may eventually suspend/amend). If formally enacted, this represents a structural easing of the most consequential REE supply-risk action in the register. Severity estimate: 3 if enacted (direct re-routing of ~$3–5bn/yr US rare earth magnet imports; reshapes REE concentration score for US/China interdependence axis).
https://www.yahoo.com/news/trump-says-u-china-deal-155232342.html
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
🇮🇩 Indonesia PP 19/2025 Mining Royalty Rate Hike — Implementation Postponed Indefinitely (May 2026)
announced→low likelihood·flagged 111d ago · not yet law·matches Copper
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
https://en.antaranews.com/news/415656/indonesia-delays-mining-royalty-and-export-levy-plan
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 110d ago · not yet law·matches Copper
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
https://www.mineria.gob.bo/index.php/nota_prensa/bolivia-activa-reforma-minera-integral-y-sale-a-captar-inversiones-con-respaldo-del-banco-mundial/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 60→64+4
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Neodymium, Copper
If passed — Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
https://ustr.gov/about/policy-offices/press-office/press-releases/2026/february/ustr-seeks-public-comment-design-plurilateral-agreement-trade-critical-minerals-and-policy-actions
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Neodymium🇨🇳 today 74→78+4
- Copper🇨🇳 today 60→64+4
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 109d ago · not yet law·matches Copper
If passed — Full replacement of the Mining Act 1992 with sweeping new statute: state acquires up to 30% equity in any new mining project (Kumul Minerals free-carry); special mining leases (SML) issued for initial 30-month periods with FID requirement to renew; mandatory landowner and community consultation before licence grant; Mining Development Authority (MDA) replaces current Mineral Resources Authority (MRA) as the sector regulator; CGT on extractive asset transfers now in force since the 2025 Income Tax Act (separate filed action); bill as drafted would reshape FDI terms for all existing and future mining permits including Wafi-Golpu (Newmont/Harmony 26 Moz Au, 4. 8 Mt Cu — SML long-delayed), Frieda River copper-gold (PanAust), and Ok Tedi expansion; PNG's 2023 Mining (New Porgera) Amendment Act handled Porgera separately
Caveat — The public-consultation-draft stage is already filed in the register as 2025-02-25-papua-new-guinea-mining-bill-2025 (filed action records the consultation launch). This upcoming entry tracks the NEXT stage: parliamentary enactment. Consultations closed April 4, 2025; minister aimed for September 2025 tabling but no confirmed passage found as of June 2026. Likelihood moderate — bill has broad government backing and a 15-year development history, but PNG legislative timelines are frequently extended; the May 2025 Marape cabinet reshuffle may have shifted ministerial priorities. Distinct from: 2023-10-13-papua-new-guinea-mining-new-porgera-amendment-act (single-mine statute); 2025-03-12-papua-new-guinea-national-petroleum-authority-act (petroleum, not mining); 2025-03-20-papua-new-guinea-income-tax-act-2025 (CGT on extractive transfers — already enacted separately).
https://www.businessadvantagepng.com/papua-new-guineas-draft-mining-bill-sweeping-reforms-to-overhaul-the-sector/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 101d ago · not yet law·matches Copper, Neodymium
If passed — TZ Finance Bill establishes the Mineral Research Fund capitalised at 10% of gross mineral revenue (~TZS 141 billion/yr at 2025 collection levels); amends the Income Tax Act to formally recognise tax exemptions granted under individual mining Framework Agreements and introduces standard operating procedures — reduces discretionary government risk for large mining investors (Panda Hill niobium, graphite juniors, Buzwagi gold); parallel VAT amendments give equivalent statutory certainty for VAT exemptions; taken together, the bill moves Tanzania from discretionary tax administration toward a rule-of-law-based investor regime for all critical-mineral projects; budget targets Tanzania for top-4 niobium producer status (Panda Hill DA already signed March 24, 2026) and 50% geophysical survey coverage by 2030
Caveat — Tanzania fiscal year starts July 1; the Finance Act signature typically occurs last week of June. Budget speech delivered June 11, 2026 by Finance Minister Khamis Mussa Omar; Parliament approved June 23. Mining provisions in §§ amending Income Tax Act (Cap. 332) and VAT Act (Cap. 148) and establishing the Mineral Research Fund. Distinct from: filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year), filed 2026-03-24-tanzania-panda-hill-niobium-ferroniobium-development-agreement (the specific project DA), and filed 2026-04-15-tanzania-ministry-of-minerals-revokes-40-idle-mineral-exploration-licences. Severity 2: institutional reform that de-risks the investor regime rather than a direct trade restriction.
https://www.tanzaniainvest.com/economy/budget-2026-2027-parliament-approved
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇹🇿 Tanzania Finance Bill 2026/27 — NEW raw-mineral EXPORT LEVY on quartz (HS 25.06) and feldspar (HS 2529.10.00) under the Export Tax Act, Cap. 196
awaiting-signature→high likelihood·flagged 99d ago · not yet law·matches Silicon
If passed — The same Finance Bill 2026/27 already tabled (Parliament-passed 23 June 2026, effective 1 July 2026) inserts a NEW export levy of "10% of the FOB value of the cargo OR TZS 200 per kilogram, whichever is higher" on exports of quartz minerals (HS 25. 06) and feldspar (HS 2529. 10. 00) via amendment to the Export Tax Act, Cap. 196 — a distinct beneficiation-forcing EXPORT-TAX instrument that pushes raw quartz/feldspar exporters toward in-country value-addition. 196), and neither existing entry mentions it; (2) material-relevant — quartz HS 25. 06 covers high-purity/silica quartz feeding the silicon→semiconductor/solar value chain, so a Tanzanian export tax re-prices a raw-silica supply node; the same "rocks to riches" beneficiation logic Tanzania applies elsewhere; (3) part of the wider African raw-mineral-export-tax wave (cf. Zimbabwe 10% lithium-concentrate levy, Namibia unprocessed-mineral ban, Guinea bauxite reference price).
Caveat — On enactment, fold into that one TZ Finance Act 2026 action with action_type capturing both the fiscal-incentive and the export-levy (export-control/tariff) provisions; do NOT double-file. Distinct from filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year — no quartz/feldspar export levy). Severity 2 (sectoral raw-mineral export tax, niche HS lines).
https://polis.bunge.go.tz/uploads/bills/1781852249-Muswada_wa_Sheriia_ya_Fedha_wa_Mwaka_2026_(The_Finance_Bill,_2026).pdf
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Silicon🇨🇳 today 66→70+4
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 104d ago · not yet law·matches Copper
If passed — All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension; effectively forces equity restructuring across the entire DRC copper-cobalt belt; miners seeking moratorium as of June 18, 2026 — enforcement outcome by August 2026 will set the precedent
Caveat — Ministerial enforcement letter issued January 30, 2026 by Mines Minister Louis Watum Kabamba — activates dormant Art. 71 bis (5% employee equity in mining company capital) and Art. 144 bis (mechanics) of DRC Mining Code (Loi n° 18/001). Filed here (not filing. md) because DRC government websites (mines. gouv. cd, primature. gouv. cd) remain inaccessible per prior wakes — same constraint as the DRC Strategic Mineral Reclassification entry. Action IS already in effect and enforcement is underway (July 31, 2026 deadline); this is NOT speculative. DRC Chamber of Mines convened June 11, 2026 industry response meeting; companies arguing retroactive application is legally contested. Severity 3 expected if enforced. Distinct from: 2018-01-27-drc-mining-code-revision (underlying law), 2026-04-10-drc-strategic-reserve (ARECOMS mechanism), 2026-04-24-drc-tshisekedi-mining-export-revenue-audit.
https://www.kitco.com/news/off-the-wire/2026-06-18/congo-miners-seek-delay-5-worker-equity-rule-july-deadline
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 104d ago · not yet law·matches Copper
If passed — Revises 30 CFR Part 580 to streamline 10 provisions governing prospecting, leasing, and operations for hard minerals (manganese nodules, cobalt-rich crusts, seafloor massive sulfides) on the US Outer Continental Shelf; eliminates environmental notification to adjacent state governors (§580. 31) and BOEM's own environmental review requirement (§580. 29); accelerates OCS hard mineral leasing pipeline in line with EOs 14285 and 14154 ("unleashing" OCS resources); comment period closed April 27, 2026; awaiting final rule
Caveat — First substantive revision of US OCS hard minerals regulatory framework in ~35 years; distinct from all filed US actions (no prior OCS hard minerals action in register). Severity 2: regulatory infrastructure that enables future OCS leasing rather than a direct production/export instrument; secondary-boem: https://www. boem. gov/newsroom/press-releases/boem-proposes-rule-changes-support-critical-mineral-exploration-and
Reference-class base rate
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — a base rate for comparable bills, not a forecast for this one. source ↗
https://www.federalregister.gov/documents/2026/02/24/2026-03690/administrative-revisions-to-regulations-related-to-outer-continental-shelf-minerals-other-than-oil
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 60→64+4
🇮🇳 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 Copper, Neodymium
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).
https://www.policyedge.in/p/centre-launches-5000-crore-incentive-scheme-to-speed-up-mine-auctions-and-production
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇪🇺 EU Permanent-Magnet Scrap & Waste Export Restriction
announced→low likelihood·flagged 100d ago · not yet law·matches Neodymium
If passed — Under the RESourceEU action plan (COM(2025) 945, adopted 3 Dec 2025 and already filed as 2025-12-03-eu-resourceeu-action-plan-com-2025-945), the European Commission committed to PROPOSE, by Q2 2026, restrictions on the export of scraps and waste of permanent magnets — an essential feedstock for European NdFeB recyclers that is increasingly shipped abroad (notably to China). Recycling could meet ~20% of the EU's ~20,000 t/yr permanent-magnet demand, so retaining end-of-life and pre-consumer magnet scrap in the EU is framed as a supply-security measure to reduce China dependence. Accompanying measures: a new EU-level Combined Nomenclature sub-code + European Waste Catalogue entry to identify/track permanent magnets and EoL products containing them, plus a targeted CRMA amendment on product-labelling and pre-consumer-waste recycling. If enacted as a binding export restriction this would be the EU's first outbound control on a critical-mineral waste stream — directly relevant to anyone in the EU/China REE-magnet recycling loop, and a mirror-image to China's REE/magnet export controls (re-prices intra-bloc vs ex-bloc scrap flows). The European recycling industry (BIR) has publicly warned the measure risks market distortion, so adoption/scope is contested.
Caveat — As of 2026-06-27 (end of Q2) no formal proposal or regulation has been located — still at the action-plan-commitment stage, hence axis-2/upcoming not filing. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella plan announcing the intent — this item tracks the specific export-restriction instrument that the plan promised), from filed 2026-03-04-eu-council-crma-general-approach-resourceeu (Council general approach on the CRMA amendment), and from the EU dual-use export-control regime (2021-821 / 2025-2003). Distinct from the US-China REE deal (line 78) and EU CRMA strategic-projects round (line 58). Severity 2-3 if enacted (first EU outbound control on an REE waste stream; re-prices the EU↔China magnet-scrap loop).
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Neodymium🇨🇳 today 74→78+4
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 100d ago · not yet law·matches Copper, Neodymium
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
https://mono.mn/n/government_approves_draft
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 60→64+4
- Neodymium🇨🇳 today 74→78+4
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 100d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one of the world's largest undeveloped Cu-Au deposits (phase-1 ~200,000 t/yr copper concentrate + 250,000 oz/yr gold, first production targeted end-2028, ~USD 5. 5bn phase-1 capex). The stake would be purchased from the Pakistani state's half of the project (Pakistan federal SOEs + Balochistan hold 50%; Barrick Gold holds 50% and operates). This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) into a strategic copper chokepoint, paralleling Manara's Vale Base Metals 10% stake and IRH's Mopani (Zambia) acquisition; gives Saudi Arabia an equity claim on a major future non-China copper supply source.
Caveat — As of 2026-06-27 the deal is in negotiation — Pakistan's Petroleum Minister Musadik Malik said publicly he expected a deal "within the next six months," hence announced/upcoming not enacted. Distinct from filed 2025-09-08-pakistan-us-ussm-fwo-critical-minerals-mou (US EXIM/USSM financing angle on Reko Diq), filed 2025-03-14-pakistan-balochistan-mines-and-minerals-act (the provincial mining law), and filed 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake (Manara's Vale Base Metals deal). Severity 2-3 if completed.
https://www.mining-technology.com/news/manara-minerals-acquire-20-stake-reko-diq-project/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 99d ago · not yet law·matches Copper
If passed — Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring the interest from the Government of Pakistan (Pakistan + Balochistan together own 50%; Barrick Gold holds the other 50% as operator). Reko Diq is one of the world's largest undeveloped copper-gold deposits (~$74bn projected free cash flow over a ~37-yr life). IPTM relevance: a GCC sovereign-capital upstream-mining-FDI entry (theme gcc-mining-upstream-fdi) into COPPER — a binding chokepoint material — extending the Saudi diversification-of-supply strategy beyond the filed 2024-03-01 Manara→Vale Base Metals 10% stake; would also be a Pakistan host-state instrument (federal divestment of part of its Reko Diq equity to a Gulf SWF, complementing the 2025-09-08 Pakistan–US USSM critical-minerals MoU already filed). Distinct GCC third-party capital base separate from Chinese-SOE capture and Western MSP/CRMA-aligned investment.
Caveat — As of mid-2025 the deal was reported by Pakistan's Petroleum Minister as expected "within six months" but NO binding SPA or primary gov instrument has surfaced as of 2026-06-28 — hence announced/moderate, not enacted. Dedup: only the 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake Manara action is filed; no Reko Diq/Manara slug in action-index; the filed Reko Diq item (2025-09-08 Pakistan–US USSM–FWO MoU) is a DIFFERENT instrument (US bilateral MoU, not a Saudi equity purchase). Severity 2-3.
https://www.dawn.com/news/1886746
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4
🇪🇺 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 Neodymium, Copper
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").
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Neodymium🇨🇳 today 74→78+4
- Copper🇨🇳 today 60→64+4
🇲🇼 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 Neodymium, Copper
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.
https://www.theeastafrican.co.ke/tea/business-tech/malawi-president-mutharika-bans-exports-of-raw-minerals-5247332
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
- Copper🇨🇳 today 60→64+4
🇲🇬 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 Neodymium
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.
https://fr.allafrica.com/stories/202602040158.html
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Neodymium🇨🇳 today 74→78+4
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 31d ago · not yet law·matches Neodymium
If passed — Draft law amending Morocco's 2015 Mining Code (led by the Ministry of Energy Transition and Sustainable Development, Minister Leila Benali), with public consultations reported open since ~Feb 2025. Three structural changes: (1) a National Commission for Strategic and Critical Minerals empowered to designate an official list of "strategic and critical minerals" — Morocco's first formal legal mechanism to do so, which would sit upstream of and interact directly with the phosphate chokepoint (Morocco holds ~70% of world phosphate-rock reserves via OCP); (2) the digital mining cadastre (governance/transparency layer — this component has ALREADY gone live, launched 2026-04-07, and is queued separately to filing. md as an enacted action); (3) sharply increased penalties for illegal mining/prospecting (unauthorised prospecting: MAD 100k-1m; illegal extraction/transport/sale: up to MAD 2m). Morocco is chokepoint-tier and thinly covered (only 4 prior MA actions: 2022 Investment Charter, an AfDB agriculture loan, the 2026 Loi de Finances, and a Feb-2026 mining-tender notice — none creates a minerals-designation regime).
Caveat — distinct from the already-filed 2026-04-07 digital-cadastre launch (enacted, queued to filing. Dedup: no MA action in the index covers a strategic-minerals designation commission or mining-code amendment; the 3 other MA entries (Investment Charter 2022, Loi de Finances 2026, Feb-2026 mining tender) are distinct instruments.
https://fr.apanews.net/news/le-maroc-revise-son-code-minier-pour-stimuler-linvestissement/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Neodymium🇨🇳 today 74→78+4
🇮🇳 India–Myanmar rare-earths cooperation — elevated to formal bilateral agenda at Modi–Min Aung Hlaing summit
announced→low likelihood·flagged 29d ago · not yet law·matches Neodymium
If passed — At Myanmar military-government head Min Aung Hlaing's early-June-2026 New Delhi visit (his first India visit since the 2021 coup), critical minerals and rare earths featured explicitly on the formal bilateral agenda for the first time — India's Foreign Secretary Vikram Misri confirmed both sides "agreed to stay in touch" on critical minerals/rare earths and "take cooperation forward. " This is India seeking an alternative heavy-rare-earth source (Kachin State/Wa State artisanal mining, currently ~all exported to China) amid China's 2025 rare-earth export controls. No formal supply contract, MOU, or binding mineral-cooperation instrument has been signed — this is government-to-government dialogue only, elevated from background technical talks to official summit-agenda status. Analysts place realistic commercial-scale sourcing in the 2028-2035 window, contingent on Kachin conflict resolution and connectivity infrastructure. Chokepoint-tier (MM heavy rare earths, only 4 prior MM actions in the index, all domestic Myanmar mining/export regulation — none touching an India bilateral angle).
Caveat — Dedup: no existing IN or MM action in filing. md/upcoming. md/action-index covers India-Myanmar rare-earth cooperation (checked "india. *myanmar" across all three — only hit was an unrelated DPIIT Press Note 2/2026 land-border-FDI action that separately still requires prior approval for Myanmar-domiciled investors). Distinct from the 3 filed Myanmar domestic actions (Wa State tin suspension/restart licensing, MOC Notification 93/2024, KIO rare-earth regulation) which are host-country supply-side instruments, not this demand-side sourcing-diversification angle. Severity 1-2 while at dialogue stage.
https://www.tribuneindia.com/news/bilateral-engagement/india-myanmar-to-stay-in-touch-on-issue-of-critical-minerals-rare-earths-take-cooperation-forward-mea
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Neodymium🇨🇳 today 74→78+4
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 1d ago · not yet law·matches Copper
If passed — State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar's ambassador that it will resume the Jebel Ohier copper-gold project (Red Sea State) with an $800M commitment. Third GCC sovereign upstream-mining entry after Manara Minerals/Vale Base Metals 10% stake (2024-03-01, filed) and QIA/Ivanhoe Mines strategic placement (2025-09-17, filed) — extends the GCC-as-third-capital-base pattern (theme gcc-mining-upstream-fdi) to African copper, not just battery metals.
Caveat — gov. sd not independently reachable; QMSD's own project page does not yet mention the resumption) — parked here per the same convention used for the Malawi executive-order entry above (real/firm commitment, primary URL not yet locatable). Dedup: checked "qatar mining", "jebel ohier", "qmsd" across filing. md, upcoming. md, and action-index — zero hits. Likelihood=high reflects a confirmed government-to-government commitment, not a prediction of eventual gazettal.
https://sudantribune.com/article/313934
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 60→64+4

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 listShow

Neodymium is the line to war-game: 🇨🇳 CN already controls 85% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Silicon carries 19 restrictive measures on record (🇨🇳 CN 80% of refining) — a secondary escalation candidate.
Copper carries 52 restrictive measures on record (🇨🇳 CN 48% of refining) — a secondary escalation candidate.

Art. 24(4) · diversification & substitution

Priority mitigations

The mitigation optionsShow

Map your real exposure to Neodymium. Trace it from the component back to the smelter/refiner and country of origin — most buyers discover the dependence is one tier deeper than their direct supplier.
Qualify a non-CN source. Identify and validate at least one supplier outside CN for the binding input before it is needed, even at a cost premium — optionality is the hedge.
Lead-time to re-source is ~9 months (6-12mo). The largest tracked non-CN producer of Neodymium is 🇲🇾 MY (~8% of refining); scaling it into a replacement is roughly a 6-12mo ramp. A share-of-stage substitution heuristic derived from current production share, not a firm supplier quote.
Design for substitution where feasible. Neodymium has at least partial substitutes; specify them into next-generation products to cut the dependence structurally.
Hold strategic inventory / contract forward. For materials with no substitute and active export controls, a buffer stock or long-dated offtake converts a shock into a managed cost.
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

The full crosswalkShow

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

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 detailsShow

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 — 3 scored SRMs on the input side (binding: Neodymium)
Manufactures a listed strategic technology	industrial (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.

All sourcesShow

Methodology

MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-05

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.