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1 critical material scored · binding chokepoint: Magnesium (🇨🇳 CN 86% of refining) · 2 restrictive government measures on record
Slovmag Lubeník produces 1 of the 1 scored material above (Magnesium). For those, a supply restriction by the controlling country is a tailwind, not a headwind — the exposure is to disruption of a market this company supplies, not to a chokepoint it depends on. Every scored material here sits on its output side, so the High · 75/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-07) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Magnesium — 🇨🇳 CN controls 86% of global refining. On this company's production footprint that scores 75/100 (adversarial chokepoint; global 63). The register holds 2 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Magnesium Slovmag Lubeník is the 15th-most-exposed of the 62 named companies we track on 🇨🇳 CN's Magnesium chokepoint; the most-exposed is Leonardo S.p.A. (75/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Slovmag Lubeník ranks 68th of 461 verified mining metals companies, tied with 8 others at 75.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 132 further mining metals 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 75/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 1 scored material. Buyer-relative (first-order): weighted by where the company produces (SK 100%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
> The exposure report this dossier powers is at > /intelligence/dossiers/slovmag-lubenik/report.
Slovmag a.s. is a refractories works (formerly also a magnesite mine, now suspended — see below) at Lubeník (Revúca district, Banská Bystrica region, Slovakia), with mining tradition dating to 1897 and the current joint-stock company registered in 1994. It historically mined magnesite ore (~42% MgO) and processed it on-site into sintered and fused magnesia and shaped/unshaped basic refractory products — used to line steelmaking furnaces, non-ferrous metallurgy vessels, cement rotary kilns and lime kilns, plus some use in electric storage heaters. As of late 2025 the on-site mine has suspended extraction (Ukraine-war export decline to Ukraine/Russia/Belarus plus higher energy and raw-material costs); the company filed a plan in June 2026 to flood and decommission the mine workings. Refractory production continues, now on externally-sourced magnesite; the workforce fell from ~450 (spring 2023) to over 260 (mid-2026). It is a small, loss-making producer: FinStat registry data shows revenue of €30.1M (2024, loss €3.3M) and €36.8M (2025, loss €0.56M).
Corrected 2026-09-09 — this section previously described the wrong owner. Slovmag was controlled by Russia's Magnezit Group (via a Luxembourg holding vehicle, MAG Holding) from January 2008, but that ended in March 2022: Slovakia's antimonopoly office (PMU SR) cleared INTOCAST Slovakia a.s. (part of INTOCAST AG, Bochum, Germany) acquiring exclusive control of Slovmag from Magnezit Group on 2022-03-03 (final 2022-03-07), reportedly a 99.62% stake. INTOCAST's own group site lists SLOVMAG as a subsidiary, and The Slovak Spectator (2025-04-30) independently describes Slovmag as "owned by German magnesite processor Intocast." The Magnezit Group OFAC (10-Jan-2025) and Ukraine NSDC (08-Aug-2025) sanctions listings are still real but no longer bear on Slovmag — they postdate its sale by roughly three years and concern the group's remaining Russian operations, not this subsidiary. Slovmag is a distinct company from SMZ Jelšava (Slovenské magnezitové závody), a separate Slovak magnesite producer — and, per INTOCAST's own 2022 regulatory filing, SMZ Jelšava is now INTOCAST's largest raw-magnesite supplier (see Sources).
magnesia, refractory products) sits in the magnesium value chain. Global magnesium metal production is ~91% concentrated in China (CRM Alliance), making any EU-based magnesium-chain capacity strategically scarce — but magnesite/magnesia itself is not currently on the EU Critical Raw Materials Act list; RHI Magnesita and Euromines have publicly lobbied the European Commission to add it, without success so far. Slovmag is therefore adjacent to, not directly inside, the CRMA's formal magnesium-metal scope.
Russian-ownership counterparty-risk signal (Magnezit Group). That ended in March 2022 when INTOCAST AG (Germany) bought Slovmag out of the Magnezit group — see Ownership above. No sanctions-relevant ownership signal applies to Slovmag today.
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.
PMU SR's 2022 concentration-clearance filing states SMZ Jelšava is the largest supplier of raw magnesite to INTOCAST (the group SLOVMAG is now part of) and that INTOCAST does not buy magnesite from SLOVMAG itself -- recorded at the INTOCAST group level since that is what the primary source states; SLOVMAG's own mine was still active at the time of this filing (suspended later, late 2025).
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.
Ranked by buyer-relative risk, highest first.
1 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Magnesium | 🇨🇳 CN 86% refining | 75 | 63 | High | EXCEEDS 86% | Med | none | 2 | ▲ 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 |
|---|---|---|---|---|---|---|
| Magnesium | 3 | 4 | 3 | 5 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Magnesium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Magnesium — 🇨🇳 CN escalates magnesium controls to a full export-licensing / ban regime | 75 | 90 | +15 |
| Concentration | Magnesium — 🇨🇳 CN becomes the single source for magnesium — the second source is lost (full 86%+ monopoly) | 75 | 85 | +10 |
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 on the input side — every scored material here is one Slovmag Lubeník produces, and Art. 24 addresses the use of a strategic raw material as an input. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Reported separately (not an Art. 24(4) trigger): Magnesium clears the same numeric bar but is a material Slovmag Lubeník produces. That is an output-market concentration — relevant to revenue and to counterparties who buy from this company — not an input dependency the company must mitigate under Art. 24(4).
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 0 materials this company buys (the 1 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one Slovmag Lubeník produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
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 | company input — all 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | mining-metals (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 2026-05-07; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-07
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.