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3 critical materials scored · binding chokepoint: Potash (🇨🇦 CA 31% of refining) · 18 restrictive government measures on record
The binding exposure is Potash — 🇨🇦 CA controls 31% of global refining. On this company's production footprint that scores 58/100 (adversarial chokepoint; global 50). The register holds 18 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Potash Sinochem Holdings Corporation Ltd. is the 5th-most-exposed of the 41 named companies we track on 🇨🇦 CA's Potash chokepoint; the most-exposed is Belaruskali (58/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Sinochem Holdings Corporation Ltd. ranks 21st of 22 verified commodity trading companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 6 further commodity trading companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 49/100 — 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 (CN 100%, HQ proxy), applied across all materials — it does not yet trace each input to its specific sourcing step.
> The exposure report this dossier powers is at > /intelligence/dossiers/sinochem-holdings/report.
Sinochem Holdings Corporation Ltd. is a Chinese central state-owned enterprise formed from the 2021 combination of Sinochem Group and ChemChina, administered directly by SASAC. It describes its activities across eight sectors: life science, materials science, basic chemicals, environmental science, rubber & tire, machinery & equipment, city operation, and industrial finance. Its best-known holdings are the Syngenta Group (crop protection and seeds — around 28% of group turnover in 2025), Pirelli (tyres), and Adisseo (animal nutrition), alongside domestic petrochemical refining and a large fertilizer business.
For critical-materials purposes the group's centre of gravity is agricultural minerals, not metals. That runs through Sinofert Holdings Limited (HKEX: 0297), China's largest fertilizer producer and distributor, in which Sinochem Hong Kong (Group) Company Limited holds a 52.65% controlling stake and Sinochem Holdings is the ultimate controlling shareholder. Sinofert covers the chain from resource sourcing through production to distribution, with reported holdings of three nitrogen, four phosphate, four compound and one potash fertilizer producer and combined annual capacity above 10 million tonnes.
Note the shape of this exposure: Sinochem is positioned on the import and distribution side of fertilizer minerals China does not have enough of domestically. Its risk is therefore concentrated in a small number of foreign supply origins and in the export policy of those origin countries — the mirror image of a Western manufacturer's China-concentration risk.
firms handling China's potash imports, sourcing from Canada and Russia. This is the sharpest exposure in the dossier: China is structurally potash-short, global supply is concentrated in a handful of jurisdictions (Canada, Russia, Belarus), and the Russian and Belarusian share of that supply has been directly disrupted by sanctions in recent years. A buyer holding one of two import channels into the world's largest agricultural market sits squarely on that chokepoint.
under Sinofert, and its product range explicitly includes phosphate fertilizers plus monocalcium and dicalcium phosphate. Phosphate rock is sourced internationally, including from Morocco — the single largest holder of world phosphate rock reserves, which makes origin concentration a live issue independent of price.
line, not merely an inferred process input. That is consistent with the phosphate business: sulfur is consumed as sulfuric acid to digest phosphate rock into finished phosphate fertilizer, and China is the world's largest sulfur importer for that reason. Here the exposure is both as a traded product and as the reagent underpinning the phosphate line above — the two are correlated, not independent.
Dropped from the sector default — all eleven. manganese, chromium, vanadium, niobium, tantalum, tin, cobalt, nickel, lithium, neodymium and dysprosium were the commodity-trading sector's generic metals, battery and permanent-magnet defaults. Sinochem Holdings is an agri-chemical and petrochemical group; no source describes it trading or producing any of them, and the original list contained none of the three minerals that actually drive its exposure.
Open leads, deliberately not listed. Two plausible exposures could not be confirmed this pass and are recorded as unverified rather than asserted: fluorspar, via the legacy ChemChina fluorochemicals business, and lithium or other battery materials. Neither is supported by a located source. Their absence here means "not established", not "checked and found to be zero".
Magnitude not disclosed. Sinochem Holdings is an unlisted central SOE and publishes no consolidated per-mineral segment breakdown, so no magnitude band is recorded for any of the three materials above.
Ranked by buyer-relative risk, highest first.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Potash | 🇨🇦 CA 31% refining | 58 | 50 | Elevated | — | — | none | 8 | ▲ rising |
| Phosphate | 🇨🇳 CN 38% refining | 32 | 59 | Low | — | — | none | 10 | ▲ rising |
| Sulfur | 🇨🇳 CN 23% mining | 20 | 34 | Low | — | — | hard | 3 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Potash | 4 | 2 | 3 | 5 | 3 | company input |
| Phosphate | 4 | 2 | 3 | 5 | 4 | company input |
| Sulfur | 3 | 2 | – | 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.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 3 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Potash — 🇨🇦 CA escalates potash controls to a full export-licensing / ban regime | 58 | 66 | +8 |
| Concentration | Potash — 🇨🇦 CA becomes the single source for potash — the second source is lost (full 31%+ monopoly) | 58 | 90 | +32 |
| Policy | Phosphate — 🇨🇳 CN escalates phosphate controls to a full export-licensing / ban regime | 32 | 34 | +2 |
| Concentration | Phosphate — 🇨🇳 CN becomes the single source for phosphate — the second source is lost (full 38%+ monopoly) | 32 | 42 | +10 |
| Policy | Sulfur — 🇨🇳 CN escalates sulfur controls to a full export-licensing / ban regime | 20 | 25 | +5 |
| Concentration | Sulfur — 🇨🇳 CN becomes the single source for sulfur — the second source is lost (full 23%+ monopoly) | 20 | 31 | +11 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold. The Art. 24(4) mitigation duty is not triggered on the factors we could score (1 of 15 inputs unrated across the materials bought). Absence of data is not evidence of low risk — an unrated factor enters the score as zero, not as an estimate, so this conclusion could change once those inputs are rated. The mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the materials this company buys. The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
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 ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Potash).
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | Yes — 3 scored SRMs on the input side (binding: Potash) |
| Manufactures a listed strategic technology | commodity-trading (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-07-24; 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 2026-10-06
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.