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2 critical materials scored · binding chokepoint: Lithium (🇨🇳 CN 65% of refining) · 46 restrictive government measures on record
A verification pass re-checked this dossier's ownership/corporate-structure fields against their cited sources. It did not re-read the material_exposures claim the score, band and stress figures below are built on — treat those as not yet independently re-checked.
Sociedad Quimica y Minera de Chile SA produces 2 of the 2 scored materials above (Lithium, Potash). 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 Elevated · 59/100 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 Lithium — 🇨🇳 CN controls 65% of global refining. On this company's production footprint that scores 61/100 (neutral exposure; global 61). The register holds 46 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Lithium Sociedad Quimica y Minera de Chile SA is the 395th-most-exposed of the 488 named companies we track on 🇨🇳 CN's Lithium chokepoint; the most-exposed is Momentum Technologies (72/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Sociedad Quimica y Minera de Chile SA ranks 264th of 458 verified mining metals companies, tied with 15 others at 59.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 133 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 59/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 2 scored materials. Buyer-relative (first-order): weighted by where the company produces (CL 95% · AU 5%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
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/sociedad-quimica-y-minera-de-chile/report.
Sociedad Química y Minera de Chile S.A. (NYSE: SQM) is a Chilean chemicals and mining company headquartered in Santiago, reporting across five segments: Lithium and Derivatives, Iodine and Derivatives, Potassium, Specialty Plant Nutrition, and Industrial Chemicals. Its production centres are in northern Chile — brine extraction and evaporation ponds at the Salar de Atacama, lithium carbonate and hydroxide conversion at Salar del Carmen near Antofagasta, and caliche ore operations that yield iodine and nitrates. The business is overwhelmingly export-oriented: SQM's FY2025 20-F reports exports at 96.5% of net revenues, and identifies dependence on the Salar de Atacama as a principal risk, with products from that single deposit generating 50.1% of consolidated revenues.
Outside Chile, SQM holds 50% of Covalent Lithium, the joint venture with Wesfarmers that owns the Mt Holland mine and concentrator in Western Australia and the associated lithium hydroxide refinery at Kwinana; in July 2026 the partners took a final investment decision to roughly double nameplate spodumene concentrate capacity from ~380,000 t/y to ~760,000 t/y, with first expansion production expected in H1 2030. In Chile, SQM's future Salar de Atacama position runs through a joint venture with state copper producer Codelco: the partners signed in late 2025, merging Codelco's Minera Tarar into SQM Salar (renamed Nova Andino Litio), which gives the Chilean state a direct position in Salar de Atacama lithium output and extends the operating rights there through 2060, past SQM's previous 2030 lease expiry. That is the single fact that decides whether SQM's largest asset has a future beyond this decade, so it is recorded here rather than left to the merged-away duplicate file.
This is a producer dossier: the materials below are what SQM supplies to the market, not inputs it buys. Its exposure is therefore to measures aimed at producers and at its own operating jurisdiction, rather than to input chokepoints.
chemical producers, extracting lithium-bearing brine at the Salar de Atacama and converting it to battery-grade lithium carbonate and hydroxide at Salar del Carmen, with a second, hard-rock (spodumene) supply position in Western Australia through the 50%-held Covalent Lithium JV. The register's relevance here is jurisdictional as much as geological: Chilean lithium sits under a state-directed framework, and SQM's continued access to the Salar de Atacama runs through its Codelco joint venture rather than through an ordinary private concession.
Potassium segment produces potassium chloride and potassium sulfate from the Salar de Atacama brine, physically co-produced with the lithium stream rather than mined separately. This makes the potash position structurally tied to the lithium one — the same deposit, the same concession risk, the same evaporation-pond throughput constraint — which is why it is listed rather than treated as an unrelated fertiliser line.
Commercially dominant but not listable — iodine and nitrates. Iodine is arguably SQM's single most profitable product line, contributing roughly 42% of 2025 gross margin at record prices, and the company is one of the largest iodine producers globally. Neither iodine nor nitrates is in this register's SCORED_MATERIALS vocabulary (re-checked live against lib/minerals-supply-risk.ts on 2026-08-31), so they cannot be carried as scored exposures. Their absence below is a limit of our material vocabulary, not a judgement that the exposure is small — on revenue it is the opposite.
Not a parent/subsidiary relationship. Tianqi Lithium holds a large minority stake in SQM and Codelco is its Salar de Atacama JV counterparty, but neither controls the company, so no parent_slug is set and no ownership_country divergence is claimed.
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.
SQM and LGES signed a new long-term purchase contract (announced 2023-07-05) for LGES to buy over 100,000 t of battery-grade lithium carbonate/hydroxide during 2023-2029 (nearly tripling a prior 2020 deal for 36,000 t), explicitly 'to maximize benefits' under the US Inflation Reduction Act. SQM's own FY2023 Q2 6-K (SEC EDGAR, tmb-20230817x6k.htm) confirms the agreement was signed in Q2 2023 but does not disclose volume/duration; those terms come from contemporaneous trade press. Source describes SQM as operating mines in both Chile AND Australia without tying this volume to one site, and does not name a delivery country -- flow omitted; the IRA framing points toward LGES's North American cell plants (Arizona, Michigan), not its Seoul HQ.
SK On signed a 5-year deal (signing ceremony 2022-11-04, Seoul) to purchase up to 57,000 tons of battery-grade lithium hydroxide from SQM starting 2023, described as strengthening SK On's supply chain 'in coping with the U.S. Inflation Reduction Act (IRA)'. Source references SQM's IRMA-audited Atacama site in general terms but does not explicitly state this specific tonnage is Atacama-sourced, nor does it name a delivery country -- omitted flow accordingly; the IRA framing points toward SK On's US cell plants (Commerce, TN; Bartow County, GA), not its Seoul HQ.
Hyundai Motor Group brands Hyundai and Kia jointly signed a long-term lithium hydroxide supply agreement with SQM Salar S.A. (announced 2024-06-17), securing 'a portion of SQM's lithium hydroxide supply for electric vehicle production'. Source identifies SQM as a 'Chilean miner' but does not state a delivery country -- coverage speculates the deal supports a North American EV supply chain, not Hyundai's Korean HQ -- so flow is omitted. Volume and financial terms undisclosed.
Hyundai Motor Group brands Hyundai and Kia jointly signed a long-term lithium hydroxide supply agreement with SQM Salar S.A. (announced 2024-06-17), securing 'a portion of SQM's lithium hydroxide supply for electric vehicle production'. Source identifies SQM as a 'Chilean miner' but does not state a delivery country -- coverage speculates the deal supports a North American EV supply chain, not Kia's Korean HQ -- so flow is omitted. Volume and financial terms undisclosed.
SQM and Ford announced a long-term strategic agreement (2023-05-22) for SQM to supply 'battery-grade lithium products sustainably produced in Chile' for Ford's EV batteries; source states 'the origin of SQM's lithium should help Ford vehicles to qualify for the Inflation Reduction Act (IRA) consumer tax credit', tying the Chilean-origin material to US-market EV production. No volume disclosed. No 2024+ source pins a destination: SQM FY2025 20-F (sec.gov sqm-20251231.htm) does not name Ford and puts only 3% of lithium revenue in North America (95% Asia and Others), and Ford tolls lithium through cell makers whose plants the 2023 release does not name -- destination unstated.
Ronghui's ChiNext IPO inquiry response (Oct 2022, auditor BDO/立信): 'SQM 为公司卤水碳酸锂供应商。SQM 也委托公司将其提供的硫酸锂和卤水碳酸锂加工成电池级氢氧化锂和电池级碳酸锂' — SQM supplies Ronghui brine lithium carbonate and also tolls its lithium sulfate/brine carbonate into battery-grade LiOH/Li2CO3; '2022 年，公司与智利SQM签订合作协议…由智利SQM 提供硫酸锂，公司加工成电池级氢氧化锂后销售给智利SQM…每月的加工量为200-300 吨', rising to a 1,500-3,000 t/month target after Ronghui's new plant. Tolling revenue from SQM was RMB 41.6k (2020) and RMB 2.85mn (2021, 0.18% of Ronghui sales). Purchase volumes/values not disclosed. Chilean origin of the sulfate: SQM's FY2025 20-F states dry lithium sulfate from Salar del Carmen 'is currently sent to our refining plant and different tolling facilities in China'.
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.
0 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Lithium | 🇨🇳 CN 65% refining | 61 | 61 | Elevated | within 65% | High | some | 40 | ▲ rising |
| Potash | 🇨🇦 CA 31% refining | 50 | 50 | Moderate | — | Med | none | 8 | ▲ 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 |
|---|---|---|---|---|---|---|
| Lithium | 4 | 3 | 5 | 3 | 3 | company input |
| Potash | 4 | 2 | 3 | 5 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 31 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:
Under the 🇨🇳 CN shock, these disclosed plants carry the binding Lithium exposure:
Counterfactual: Indonesia extends the hilirisasi ore-ban template (2020 nickel → 2023 bauxite) to the next rung of battery-mineral exports — tightening upstream supply for cobalt intermediates, lithium feedstock and graphite alongside the existing nickel + aluminium regime. Direct-hit lines are basket issuers whose binding material is a battery-cell input (nickel, cobalt, lithium, graphite) — irrespective of controller, since the template-export is global supply-chain pressure not bilateral targeting.
The binding exposure this precedent lands on — Lithium — is a material Sociedad Quimica y Minera de Chile SA produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-07) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 6 restrictive actions on Lithium since 2021 — cadence accelerating (mean gap 339d → 306d), severity flat (3.3 → 2.7).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 1 of these 13 materials (Lithium) — your binding Lithium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 20.8 months apart across 4 distinct restriction dates since 2021 (n=3 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime | 61 | 67 | +6 |
| Concentration | Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly) | 61 | 81 | +20 |
| Policy | Potash — 🇨🇦 CA escalates potash controls to a full export-licensing / ban regime | 50 | 56 | +6 |
| Concentration | Potash — 🇨🇦 CA becomes the single source for potash — the second source is lost (full 31%+ monopoly) | 50 | 79 | +29 |
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 Sociedad Quimica y Minera de Chile SA 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.
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 2 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.
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.
Every scored material here is one Sociedad Quimica y Minera de Chile SA 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 2 scored SRMs here are ones 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 2026-08-06; 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
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