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

SSAB AB

6 critical materials scored · binding chokepoint: Manganese (🇨🇳 CN 90% of refining) · 62 restrictive government measures on record

Subject

ssab · 🇸🇪 SE

Sector

industrial

Materials scored

As of

2026-09-30

Risk Office verdict

High · 77/100Company supply-risk index

The binding exposure is Manganese — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 83/100 (adversarial chokepoint; global 69). The register holds 62 restrictive government measures touching this company's materials — each traced to its primary source below.

Peer rank · Manganese SSAB AB is the 153rd-most-exposed of the 446 named companies we track on 🇨🇳 CN's Manganese chokepoint; the most-exposed is Rivian Automotive, Inc. (83/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.

Competitor cohort · industrial

SSAB AB ranks 99th of 286 verified industrial companies, tied with 20 others at 77.

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
77🇸🇪 SSAB ABManganese

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 77/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 6 scored materials. Buyer-relative (first-order): weighted by where the company produces (SE 49% · FI 32% · US 19%, 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.

Executive summary

Swedish-Finnish flat-steel producer named directly in the EU steel safeguard successor regulation (April 2026) alongside ArcelorMittal, Thyssenkrupp, Salzgitter and Voestalpine — i.e. an EU policy-protected domestic steelmaker whose 2027-28 earnings carry a multi-year quota price umbrella. The strategic franchise is HYBRIT (hydrogen-DR fossil- free steel, Boden/Luleå/Oxelösund) — a CRMA-adjacent project whose execution risk depends on grid-electricity and hydrogen capex schedules in northern Sweden, not on critical-minerals access.

Binding thesis. Material-direct via the EU safeguard-defined slab/HRC quota system: SSAB's pricing power is contingent on the EU keeping the safeguard successor at or below the FY26 quota volumes. Secondary exposure to nickel/chromium policy (alloying), but not the dominant lever. The bigger non-mineral exposure is hydrogen + grid electricity policy for HYBRIT — those are not in the IPTM register but should be flagged.

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
Manganese	🇨🇳 CN 90% refining	83	69	High	EXCEEDS 90%	High	none	12	▲ rising
Silicon	🇨🇳 CN 80% refining	77	64	High	EXCEEDS 80%	High	limited	19	▲ rising
Vanadium	🇨🇳 CN 79% refining	75	64	High	—	Low	limited	3	▲ rising
Nickel	🇨🇳 CN 36% refining	64	55	Elevated	within 36%	Med	limited	29	▲ rising
Niobium	🇧🇷 BR 89% refining	61	61	Elevated	—	Low	some	5	▲ rising
Chromium	🇨🇳 CN 46% refining	49	42	Moderate	—	Med	hard	13	▲ 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
Manganese	4	4	1	5	3	company input
Silicon	4	4	1	4	4	company input
Vanadium	4	4	5	4	2	company input
Nickel	4	2	5	3	3	company input
Niobium	3	4	3	3	3	company input
Chromium	4	2	–	4	–	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

Manganese
- 4Geopolitical: 12 restrictive actions, peak severity 5, 6 in last 24mo
- 4Concentration: refining HHI 8134 (extreme); top CN 90%
- 5Substitutability: Graedel et al. 2013 PNAS Fig. 5: 96/100 (long-horizon, all major uses). Prior analyst short-run rating 0.92: USGS: no satisfactory substitute in its major steel applications
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)
Vanadium
- 4Geopolitical: 3 restrictive actions, peak severity 4, 3 in last 24mo
- 4Concentration: refining HHI 6497 (extreme); top CN 79%
- 5Price / market: price up, as of 2026-08-21
- 4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 63/100 (long-horizon, all major uses). Prior analyst short-run rating 0.60: niobium substitutes in some HSLA steel; VRFB has no substitute
Nickel
- 4Geopolitical: 29 restrictive actions, peak severity 5, 18 in last 24mo, less 4 liberalising actions
- 5Price / market: price up, as of 2026-09-01
Niobium
- 4Concentration: refining HHI 7990 (extreme); top BR 89%
Chromium
- 4Geopolitical: 13 restrictive actions, peak severity 5, 9 in last 24mo, less 2 liberalising actions
- 4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 76/100 (long-horizon, all major uses). Prior analyst short-run rating 0.95: USGS: no substitute in stainless steel or superalloys

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
2026-09-17filedUS OFAC SDN Designations: Cuban Nickel-Sector State Enterprises (CEDINIQ, CEPRONIQUEL, SERCONI, Pinares S.A.)
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
🇺🇸 US OFAC SDN Designations: Cuban Nickel-Sector State Enterprises (CEDINIQ, CEPRONIQUEL, SERCONI, Pinares S.A.)New since 2026-09-05
2026-09-17· sanction· severity 3· nickel
🇨🇳 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
🇺🇸 BIS DPAS Directive Allocation Order — 100% domestic-sale mandate for black mass and tungsten waste/scrap
2026-08-06· export-control· severity 4· lithium, cobalt, nickel, manganese
🇯🇵 Japan imposes provisional anti-dumping duty (3.6%-42.1%) on nickel-added cold-rolled stainless steel from China and Taiwan
2026-07-08· tariff· severity 3· nickel, steel
🇺🇸 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
🇨🇳 China Customs Tariff Commission — Zero-Tariff Treatment for All 53 African Diplomatic Partners (May 2026–April 2028)
2026-04-28· tariff· severity 3· cobalt, copper, bauxite, lithium
🇺🇸 US Commerce Preliminary Antidumping Determinations — Crystalline Silicon Photovoltaic Cells from India, Indonesia, and Laos
2026-04-23· tariff· severity 4· polysilicon
🇿🇼 Zimbabwe Cabinet approves Minerals Value Chain Framework
2026-04-15· industrial-policy· severity 2· lithium, chromite, platinum-group-metals, vanadium
🇹🇿 Tanzania Ministry of Minerals revokes 40 idle mineral exploration licences (188,163 ha; MBT reallocation)
2026-04-15· regulatory· severity 3· gold, nickel, graphite, rare-earths

+ 47 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).

Type	Scenario	Today	Stressed	Δ
Policy	Manganese — 🇨🇳 CN escalates manganese controls to a full export-licensing / ban regime	83	88	+5
Concentration	Manganese — 🇨🇳 CN becomes the single source for manganese — the second source is lost (full 90%+ monopoly)	83	88	+5
Policy	Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime	77	82	+5
Concentration	Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly)	77	89	+12
Policy	Vanadium — 🇨🇳 CN escalates vanadium controls to a full export-licensing / ban regime	75	84	+9
Concentration	Vanadium — 🇨🇳 CN becomes the single source for vanadium — the second source is lost (full 79%+ monopoly)	75	88	+13

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

This assessment identifies 1 significant vulnerability — Manganese — each a High/Critical exposure that is hard to substitute and already under at least one in-force restrictive measure. This engages the duty under Art. 24(4) to take mitigating efforts, including assessing diversification of the supply chain or substitution of the material (see Priority mitigations below).

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

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 Manganese
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)
- Manganese🇨🇳 today 83→88+5
🇳🇨 New Caledonia (France) — "renewed nickel doctrine" + nickel-industry recovery pact under the Bougival Accord
announced→low likelihood·flagged 83d ago · not yet law·matches Nickel
If passed — The 12 July 2025 Bougival Accord (13-page political agreement creating a "State of New Caledonia" within France, pending a 2026 referendum + French organic law) contains an economic-rebuilding pact that proposes a "renewed nickel doctrine" — reversing the long-standing New Caledonian export restriction that barred selling raw/unprocessed nickel ore, so as to *facilitate* raw-ore exports (incl. to Korean/Chinese offshore smelters) alongside a renewal of local processing capacity; paired with continued French state energy-price support for the territory's nickel plants (previously up to ~EUR 200m/yr). New Caledonia is a top-4 global nickel producer (SLN/Eramet, Prony Resources, KNS/Koniambo) and currently has 0 actions in the register, so this is a first-coverage chokepoint item. A doctrine that *loosens* raw-ore export controls is the mirror image of the African beneficiation/export-ban wave (Indonesia nickel, Zimbabwe lithium, Gabon manganese) — it would re-open Caledonian ore to the seaborne market and re-price the nickel supply chain. As of the latest reporting the nickel-specific "pacte nickel" is described as "in limbo," with France having set an end-March deadline for a nickel deal — so this is announced/negotiated, NOT yet enacted in a decree or organic law.
Caveat — NOT speculative — the renewed nickel doctrine is an explicit named component of the signed Bougival Accord and the ~EUR 200m/yr state energy support and end-March nickel-deal deadline are on-record — but the nickel-specific pact is unfinalised ("in limbo") and the accord as a whole is contingent on a 2026 referendum and a French organic law, so no enacted primary instrument exists to file yet. First NC action of any kind in the register (0 existing). Distinct from all filed nickel actions (Indonesia downstream mandates, Philippines ore-export debates) — this is a *liberalising* doctrine on a French-territory chokepoint. Watch the 2026 referendum timeline and Légifrance/gouv. nc for the implementing text.
https://www.mining.com/web/france-sets-end-march-deadline-for-new-caledonia-nickel-deal/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Nickel🇨🇳 today 64→71+7
🇹🇿 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 Nickel, Niobium
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)
- Nickel🇨🇳 today 64→71+7
- Niobium🇧🇷 today 61→71+10
🇰🇿 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 Chromium
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)
- Chromium🇨🇳 today 49→56+7
🇸🇦 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 Nickel
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)
- Nickel🇨🇳 today 64→71+7
🇮🇩 Indonesia NPI/Ferronickel/MHP Export Duty — ESDM Commitment, April 2026 Launch Postponed Indefinitely
announced→low likelihood·flagged 102d ago · not yet law·matches Nickel
If passed — Indonesia = ~50% global nickel mine supply and dominant producer of NPI/ferronickel/MHP; export duty on downstream nickel products (NPI, ferronickel, nickel matte, MHP) would add a material cost layer to ~$15B/yr Indonesian processed-nickel export chain; reprices stainless-steel and EV-battery Class 1 nickel supply for Chinese RKEF operators and global buyers; shifts relative competitiveness of Indonesian vs Filipino/Russian/Canadian nickel supply
Caveat — Government originally planned April 1, 2026 implementation; ESDM Minister Bahlil Lahadalia confirmed postponement in April 2026 pending resolution of unresolved questions about calculation mechanisms, price thresholds, and product-specific rates for NPI/ferronickel/nickel-matte/MHP; Nickel Miners Association and Indonesian Nickel Smelters Association both formally requested delay citing thin margins; no alternative implementation date set as of June 2026. Distinct from: filed 2025-04-11-indonesia-pp-19-tiered-minerba-royalty (royalty regime for extraction, not export duties on processed products); filed 2019/2023 nickel ore export bans (ore, not downstream); 2026-05-20-indonesia-dsi-sole-exporter (export-channel monopoly, not price levy). This is a new instrument type — first-ever export duty proposed on downstream/processed nickel products. Severity 3 expected if enacted.
https://www.mysteel.net/news/5117812-flash-indonesia-postpones-implementation-of-coal-and-nickel-export-duties
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Nickel🇨🇳 today 64→71+7
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Niobium, Manganese
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)
- Niobium🇧🇷 today 61→71+10
- Manganese🇨🇳 today 83→88+5
🇬🇦 Gabon — Government Announcement: Ban on Crude Manganese Ore Exports from January 1, 2029
announced→low likelihood·flagged 108d ago · not yet law·matches Manganese
If passed — Gabon = ~25% world manganese reserves, world's 2nd largest manganese ore exporter (~8 Mt/year via COMILOG/Eramet); ban on raw ore exports forces domestic processing investment (silicomanganese, EMD, battery-grade HPMSM) or cessation of shipments; reprices global manganese ore supply for steel alloy and NMC/LMFP battery cathode precursor markets; Eramet (dominant operator through COMILOG subsidiary and Setrag railway) confirmed impact; 3-year transition period gives industry until 2029
Caveat — Announced by President Brice Oligui Nguema (CTRI military transitional government, in power since August 2023 coup) in late May/June 2025; Eramet's June 2, 2025 official response at eramet. com confirms the government announcement; aligned with "Industrial Gabon 2035" strategy; no formal gazette decree text found as of June 2026. GA has 0 prior actions in IPTM register. Secondary source: https://www. eramet. com/en/news/eramets-response-to-the-gabonese-governments-an-nouncement-on-crude-manganese-export-ban-starting-in-2029/
https://www.africanews.com/2025/06/01/gabon-to-halt-manganese-exports-by-2029/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Manganese🇨🇳 today 83→88+5
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Manganese, Silicon, Nickel
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)
- Manganese🇨🇳 today 83→88+5
- Silicon🇨🇳 today 77→82+5
- Nickel🇨🇳 today 64→71+7
🇨🇩 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 Niobium
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)
- Niobium🇧🇷 today 61→71+10
🇳🇦 Namibia new Minerals Bill (Minerals Prospecting and Mining Act overhaul)
in-consultation→moderate likelihood·flagged 113d ago · not yet law·matches Manganese
If passed — 10% free-carried state equity in ALL new mining and energy projects (no-cost government stake via Epangelo Mining); consultations on 51% Namibian ownership in new mining ventures; maximum royalty rate rise from 5% to potentially 10% for strategic minerals; introduction of profit-based windfall-tax mechanism; tighter local-content and environmental obligations; affects Uranium One/NamCor (uranium), Osino Resources, B2Gold, and lithium juniors in Namibia
Caveat — Reforms the 1992 Minerals (Prospecting and Mining) Act — the foundational mining law since independence. MME announced that Government is also consulting on mechanisms to promote 51% Namibian ownership in new ventures (more aggressive than the 10% headline). The Extractor Magazine (July 17, 2025) and Veridicor (Sep 16, 2025) also confirm reform scope. Distinct from already-filed NA actions: 2023-06-06 Cabinet export ban on unprocessed critical minerals; 2024-12-04 National Upstream Petroleum Local Content Policy; 2025-09-23 Nuclear Industry Strategy. The 2025 Nuclear Strategy covers uranium value-chain capture but not the broader Minerals Act reform. Namibia is the 3rd-largest uranium producer globally (Rössing, Husab) and an emerging lithium jurisdiction.
https://www.cliffedekkerhofmeyr.com/en/news/publications/2025/Sectors/Mining-Minerals/mining-and-minerals-alert-2-september-developments-in-namibias-mining-law-underway
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Manganese🇨🇳 today 83→88+5
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Nickel, Manganese, Silicon, Niobium
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)
- Nickel🇨🇳 today 64→71+7
- Manganese🇨🇳 today 83→88+5
- Silicon🇨🇳 today 77→82+5
- Niobium🇧🇷 today 61→71+10
🇿🇦 South Africa DTIC Industrial Development Strategy 2026 — chrome export tax/quota + beneficiation licensing conditions
passed-committee→elevated likelihood·flagged 112d ago · not yet law·matches Chromium
If passed — If enacted, chrome ore export tax and/or quota would disrupt South Africa's ~2. 4 Mt/yr chrome ore export stream (≈45% of global seaborne supply); beneficiation licensing conditions attached to mineral rights allocations would require FTSE/JSE-listed chrome miners (Samancor/Merafe, Assore, Glencore) to build local ferrochrome and stainless-steel capacity before new rights are allocated; PGMs and other minerals may follow chrome as the test-case model, expanding scope to the full South African mining portfolio
Caveat — DMPR Director-General Jacob Mbele publicly described DTIC's beneficiation licensing proposal as outside DMPR's agreed jurisdiction ("a proposal, not agreed policy") — inter-departmental tension signals implementation risk; Minerals Council SA (90% of output by value) stated June 9, 2026 it will "engage" but expressed significant concern about policy uncertainty (TimesLive / Engineering News June 9, 2026). Cabinet approval makes this official government strategy direction; implementing instruments require separate legislative/regulatory action. Secondary: https://www. engineeringnews. co. za/article/minerals-council-to-engage-dtic-on-beneficiation-element-of-new-industrial-development-strategy-2026-06-09
https://www.thedtic.gov.za/south-africas-industrial-development-strategy-2026/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Chromium🇨🇳 today 49→56+7
🇮🇩 Indonesia PP 19/2025 Mining Royalty Rate Hike — Implementation Postponed Indefinitely (May 2026)
announced→low likelihood·flagged 111d ago · not yet law·matches Nickel
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)
- Nickel🇨🇳 today 64→71+7
🇬🇭 Ghana Minerals and Mining Act overhaul (Act 703 replacement) + new National Mining Policy
passed-committee→elevated likelihood·flagged 110d ago · not yet law·matches Manganese
If passed — Cabinet-cleared bill to replace the 2006 Minerals and Mining Act, Act 703: raises mining royalties from current 3–5% range to 9–12% (price-linked sliding scale), introduces a new medium-scale mining licence category bridging artisanal and large-scale operations, mandates district-level community and traditional-authority consultation before applications reach national regulators, scraps unlimited concession renewals (currently indefinitely renewable), and strengthens Ghanaian ownership provisions; National Mining Policy approved by Cabinet simultaneously; affects Newmont (Ahafo/Akyem), AngloGold Ashanti, Kinross (Chirano), Gold Fields (Tarkwa, post-Damang reversion), and Atlantic Lithium (Ewoyaa lithium project); royalty more than doubles at current gold prices — material cost increase for large-scale operators
Caveat — Distinct from all 6 filed GH actions: distinct from 2025-12-19-ghana-minerals-mining-royalty-regulations-2025 (those set sliding royalty under existing Act 703 — this bill replaces Act 703 entirely and raises the ceiling well beyond current regulations); distinct from 2026-03-13-ghana-growth-sustainability-levy-amendment (profit-based tax, not royalty); distinct from 2026-03-19-ghana-atlantic-lithium-ewoyaa-mining-lease and 2026-04-07-ghana-damang-engineers-planners-lease (specific lease grants, not legislation). The Green Minerals Policy (cabinet-approved July 2023, banning raw mineral exports) has not been separately enacted as of June 2026 — if the new Mining Act incorporates its provisions, that becomes the first statutory export restriction for Ghana's lithium and critical minerals. Filed upcoming 2026-06-17.
https://gna.org.gh/2026/06/govt-hints-scrapping-unlimited-years-of-mining-concession-renewals/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Manganese🇨🇳 today 83→88+5
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Nickel, Manganese
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)
- Nickel🇨🇳 today 64→71+7
- Manganese🇨🇳 today 83→88+5
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 109d ago · not yet law·matches Nickel
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)
- Nickel🇨🇳 today 64→71+7
CEMAC Common Mining Code — 6-member regional harmonisation (April 2026)
draft-published→moderate likelihood·flagged 107d ago · not yet law·matches Manganese
If passed — If adopted, creates a unified mining regulatory framework across Cameroon, CAR, Congo-Brazzaville, Gabon, Equatorial Guinea, and Chad — harmonising licensing regimes, fiscal terms, transparency obligations (EITI, KP, ICGLR), and environmental standards; would affect Eramet/Comilog manganese operations (Gabon), Sundance Resources iron ore (CAR), Chinese mining JVs (Congo-Brazzaville, CAR), and uranium projects across the region; if enacted, creates a regional investment-guarantee architecture that could facilitate cross-border mining finance and reduce individual-country treaty risk; structural precedent for pooled resource sovereignty in a region where individual states are renegotiating contracts (Gabon post-coup Décret 0276/2024 sovereign-equity mandate, CAR post-KP-readmission, Congo-Brazzaville mining-code review)
Caveat — Consultation meetings held April 2024 (Brazzaville), July 2024 (Riaba/Malabo), February 2025 (regional review workshop), April 2026 (Douala finalization session) — code still in draft form as of April-May 2026; CEMAC has a historically slow ratification track record (Tariff Union took ~15 years to operationalise); likelihood low until formal adoption at heads-of-state summit; DISTINCT from individually filed national mining code reforms: Gabon Décret 0276/2024 (sovereign substances regime), CAR Law 24-008 (new mining code). Filed upcoming 2026-06-20.
https://www.financialafrik.com/en/2026/04/24/cemac-a-common-mining-code-as-a-lever-for-regional-investment/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Manganese🇨🇳 today 83→88+5
🇹🇿 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 Nickel, Niobium
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)
- Nickel🇨🇳 today 64→71+7
- Niobium🇧🇷 today 61→71+10
🇹🇿 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 77→82+5
🇺🇸 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 Nickel, Manganese
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)
- Nickel🇨🇳 today 64→71+7
- Manganese🇨🇳 today 83→88+5
🇬🇦 Gabon — Government to Subscribe to Eramet €500M Capital Increase, Acquiring Equity Stake in French Parent Company
passed-vote→high likelihood·flagged 101d ago · not yet law·matches Manganese
If passed — Gabon (CTRI transitional government, President Oligui Nguema) announced at Africa Forward Summit in Nairobi (May 2026) its intention to subscribe to Eramet SA's €500M capital increase, giving the Gabonese state direct equity in the French-listed parent of COMILOG (its primary manganese mining subsidiary in Moanda). Gabon already holds 29% of COMILOG; a stake in Eramet SA itself would give Gabon leverage over the global operations of the parent group (smelting, nickel, lithium, manganese across France, Norway, Senegal, and Indonesia) and a seat at the Eramet Board. Eramet AGM (May 27, 2026) approved the capital raise resolution. Capital raise planned for H2 2026. Distinct from: filed 2025-05-30-gabon-raw-manganese-export-ban-2029 (the export ban forcing value-addition); filed 2024-07-02-gabon-decret-0276-regimes-des-substances-souveraines (35% state free-carry in new mines) — this is an equity purchase in the parent company, not a free-carry in a Gabonese concession; new vector of state resource-control
Caveat — Eramet capital raise planned for H2 2026; no decree number or gazette reference from Gabon available as of June 26, 2026. Gabon's National Strategic Investment Fund (FONSIG) or CTRI Council of Ministers would be the authorising body. Eramet SA (Euronext Paris: ERA) is ~37% owned by French state arm BPIFRANCE as at 2025 — a Gabon stake would create a two-sovereign ownership structure over the world's second-largest manganese ore exporter. Severity 3 expected if completed: creates direct state leverage over COMILOG's pricing, capex, and processing decisions, going beyond the 2029 ore export ban.
https://www.africanews.com/2026/05/13/gabon-move-to-acquire-stake-in-international-manganese-mining-company/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Manganese🇨🇳 today 83→88+5
🇮🇳 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 Manganese, Nickel
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)
- Manganese🇨🇳 today 83→88+5
- Nickel🇨🇳 today 64→71+7
🇲🇳 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 Manganese, Nickel
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)
- Manganese🇨🇳 today 83→88+5
- Nickel🇨🇳 today 64→71+7
🇯🇵 Japan METI/MOF Anti-Dumping Duty on Nickel-Added Cold-Rolled Stainless Steel Coil/Sheet/Strip from China and Taiwan
awaiting-signature→high likelihood·flagged 98d ago · not yet law·matches Nickel, Chromium
If passed — Japan's METI + MOF made an affirmative PRELIMINARY determination in an anti-dumping investigation (initiated 22 Jul 2025 on an application from Nippon Steel, Nippon Yakin Kogyo, NAS Stainless Steel Strip and Nippon Kinzoku) into nickel-added cold-rolled stainless steel coil, sheet and strip originating in the People's Republic of China and the separate customs territory of Taiwan (Penghu, Kinmen, Matsu); Trade Minister Ryosei Akazawa indicated provisional duties of ~45% on Chinese product and ~21% on Taiwanese product, expected to take effect as soon as July 2026. On 19 Jun 2026 METI/MOF EXTENDED the investigation period by four months to 21 Nov 2026 (final determination pending). IPTM relevance: (1) a RARE Japan-issuer trade remedy — JP has ZERO trade-remedy actions on the register and seldom uses AD, so a Japanese AD wall is a notable issuer + instrument-bloc gap; (2) China/Taiwan-target on nickel-added stainless steel, a nickel+chromium chokepoint-adjacent material; re-prices a China/TW->Japan stainless flow into a major downstream manufacturing base; (3) parallels the active 2025-26 Asian steel-AD wave the register is now capturing (Thailand DFT aluminium-extrusions, Indonesia KADI HRC, Malaysia MITI galvanised steel).
Caveat — As of 2026-06-29 only an affirmative PRELIMINARY determination exists; the provisional-duty cabinet order is not yet promulgated and the final determination is deferred to 21 Nov 2026 (investigation extended 19 Jun 2026) — hence awaiting-signature/upcoming, not enacted. Likelihood HIGH: preliminary affirmative + minister-stated rates + provisional duties imminent; the open question is final rate/scope, not whether duties happen. COMPANION lead for a future wake: METI/MOF separately INITIATED (1 Jun 2026) an AD investigation into cold-rolled steel coil/sheet/strip (carbon) from Korea, China and Taiwan (https://www. meti. go. jp/english/press/2026/0601_002. html) — earlier stage (initiation only), track separately. action_type=trade-remedy (sub: anti-dumping / preliminary-determination / stainless-steel / China / Taiwan); target_countries=[CN, TW]; sectors=[steel, trade-remedies, manufacturing]; materials=[stainless-steel, nickel, chromium]. Severity 2 expected.
https://www.meti.go.jp/english/press/2026/0619_002.html
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Nickel🇨🇳 today 64→71+7
- Chromium🇨🇳 today 49→56+7
🇪🇺 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 Nickel, Manganese
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)
- Nickel🇨🇳 today 64→71+7
- Manganese🇨🇳 today 83→88+5
🇲🇼 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 Niobium
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)
- Niobium🇧🇷 today 61→71+10
🇲🇬 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 Nickel
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)
- Nickel🇨🇳 today 64→71+7
🇨🇮 Côte d'Ivoire — Revision of the 2014 Code Minier (Loi n° 2014-138)
in-consultation→moderate likelihood·flagged 26d ago · not yet law·matches Manganese, Nickel
If passed — Minister of Mines, Petroleum and Energy Mamadou Sangafowa-Coulibaly formally launched the revision of Côte d'Ivoire's 2014 Mining Code on 13 June 2026, standing up an expert team drawn from his ministry, other state institutions and international bodies to rewrite Loi n° 2014-138 du 24 mars 2014. Stated goals: raise state revenue share, fix "disparate and sometimes poorly negotiated" mining conventions, and modernise the mining cadastre. No draft bill text published yet — this is a mandate/committee-formation stage, distinct from and earlier than the already-filed 2026-02-04 Assafou/Doropo gold-permit decrees and the 2025-12-03 PIRME minerals-energy policy (2025-2040), both of which operate under the CURRENT 2014 code rather than proposing to replace it. Chokepoint-relevant: register's only prior CI code-minier-lineage entries are the 2014 code itself and a 2022 local-content oil/gas law — no entry tracks this active rewrite.
Caveat — Dedup: checked action-index and both queues for "code minier"/"mining code" + CI — only hits are the already-filed 2014 code, the 2022 local-content petroleum law, and the 2024-12 gold-royalty finance law, none of which is this revision effort. Distinct from Senegal's and Morocco's already-queued mining-code amendments (different issuer/instrument).
https://www.energie.gouv.ci/actualite/sangafowa-coulibaly-veut-booster-lattractivite-du-code-minier
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Manganese🇨🇳 today 83→88+5
- Nickel🇨🇳 today 64→71+7
🇿🇼 Zimbabwe — ban on new mining licences for single-mineral ("isolated") operations; VP Chiwenga, Zimbabwe-China Business Forum
announced→low likelihood·flagged 1d ago · not yet law·matches Chromium
If passed — VP Constantino Chiwenga announced at the Zimbabwe-China Business Forum (Hangzhou) that Zimbabwe will no longer issue new mining licences for operations that extract only one mineral from a deposit — future licensees must demonstrate capacity to identify, separate and process the full mineral suite present, or be barred from operating. Framed as beneficiation policy, layered on Zimbabwe's Feb-2026 raw-mineral/lithium-concentrate export ban (filed). Raises the entry bar specifically for Great Dyke chrome/PGM claims, which are frequently single-mineral operations — a licensing-stage chokepoint action, distinct instrument type from the export-ban actions already in the register.
Caveat — Likelihood kept LOW per the discovery brief's calibration caution (a forum announcement with no SI number is exactly the channel that has previously stalled — e. g. the chrome-concentrate extension signalled since Feb-2026, entry below, remains unenacted 8 months on). Dedup: checked "chiwenga", "single mineral", "single-mineral", "zimbabwe chrome licence" across filing. md, upcoming. md, and action-index — zero hits; distinct from filed Zimbabwe lithium/chrome export-ban actions (different instrument: licensing bar on NEW operations, not export control on existing ones).
https://news.metal.com/newscontent/104134277-smm-chromium-flash-zimbabwes-new-ban-on-single-mineral-mining-licenses-could-reshape-its-chrome-sector
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Chromium🇨🇳 today 49→56+7
🇿🇼 Zimbabwe — signalled extension of the raw-mineral export ban to chrome CONCENTRATE (currently exempt)
announced→low likelihood·flagged 1d ago · not yet law·matches Chromium
If passed — Zimbabwean officials have signalled intent ("raw chrome exports obsolete") to expand the 25-Feb-2026 raw-mineral/lithium-concentrate export ban (filed) to cover chrome CONCENTRATE specifically — concentrate was exempt under the original order, which targeted raw ore only. This is the same ore/concentrate carve-out pattern that made Zimbabwe's 2022 SI 213 lithium ban a non-event (everyone exported the exempt concentrate instead). If the concentrate carve-out is closed, it would hit Zimbabwe's ~$1. 5-2bn/yr chrome sector feeding South African and Chinese ferrochrome smelters. No SI number, no date, no gazette found.
Caveat — Calibration caution per the discovery brief's instrument-vs-flow-fit lesson (this is Zimbabwe's own prior lithium-ban non-event, recurring): an ore ban that exempts concentrate is not a magnitude claim until the concentrate carve-out itself closes — kept likelihood LOW, not moderate. Dedup: checked "chrome concentrate", "zimbabwe concentrate" across filing. md, upcoming. md, and action-index — zero hits. Distinct from the licensing-ban entry above (new-operation licensing bar vs. scope-extension of an existing export ban) and from the filed Feb-2026 export ban itself (this flags a scope-extension TO that ban, not a restatement of it).
https://www.opis.com/blog/zimbabwe-to-expand-export-ban-to-chrome-concentrate/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Chromium🇨🇳 today 49→56+7

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.

Forthcoming events to watch — what could move the score

Named, datable events on the binding chokepoint and adjacent regimes — each linked to its primary government / multilateral source.

The events to watchShow

EU steel safeguard successor regulation — first review of tariff-rate-quotas (Reg 2026 successor to Reg 2025/612)
2026-Q4
Why it matters — Quota tightening at first review = direct margin tailwind; loosening = the regulatory thesis fails.
https://eur-lex.europa.eu/eli/reg/2025/612/oj
CBAM Phase-2 import-emissions cost pass-through — first full CBAM-covered import quarter
2026-Q1 reporting / 2026-Q2 settlement
Why it matters — CBAM tilts import economics against non-EU steel; the offset to safeguard easing.
https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en
HYBRIT Boden DR-pellet permitting + grid-connection schedule (SSAB + LKAB + Vattenfall JV)
2026-2027
Why it matters — If the Boden permit slips, the FY28-30 fossil-free volume guidance moves and the green-steel premium thesis with it.
https://www.ssab.com/en/news

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 (Manganese).

The mitigation optionsShow

Map your real exposure to Manganese. 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 Manganese is 🇿🇦 ZA (~5% 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.
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 — 6 scored SRMs on the input side (binding: Manganese)
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.

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