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3 critical materials scored · binding chokepoint: Chromium (🇨🇳 CN 46% of refining) · 18 restrictive government measures on record
Computed with 2 of 5 risk factors absent on the binding material (Chromium). Absence of data is not evidence of low risk — each absent factor enters the composite as zero, not as an estimate. The factor matrix below marks which cells are unscored.
Tharisa plc produces 3 of the 3 scored materials above (Chromium, Rhodium-iridium, Platinum-palladium). 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 Moderate · 40/100 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 2026-10-06) — 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 Chromium — 🇨🇳 CN controls 46% of global refining. On this company's production footprint that scores 42/100 (neutral exposure; global 42). The register holds 18 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Chromium Tharisa plc is the 447th-most-exposed of the 507 named companies we track on 🇨🇳 CN's Chromium chokepoint; the most-exposed is Patria Oyj (49/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Tharisa plc ranks 401st of 449 verified mining metals companies, tied with 14 others at 40.
Company supply-risk index 40/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 3 scored materials. Buyer-relative (first-order): weighted by where the company produces (ZA 100%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
> The exposure report this dossier powers is at > /intelligence/dossiers/tharisa/report.
Tharisa plc is a dual-listed (LSE, JSE) South African miner that operates the Tharisa Mine, an open-pit (transitioning to underground via the Apollo/Orion projects) operation on the western limb of the Bushveld Complex. Its defining feature is co-production: platinum-group-metal (PGM) concentrate and metallurgical/chemical-grade chrome concentrate are extracted from the same ore body, a dual-commodity model distinct from single-product PGM or chrome miners. FY2025 output was ~138,300 oz PGMs and 1.56Mt chrome concentrate; FY2026 guidance is 145,000-165,000 oz PGM and 1.5-1.65Mt chrome. Tharisa also holds 66.3% of the Karo Platinum project on Zimbabwe's Great Dyke (~2.6Moz PGM probable reserves), under development as of mid-2026.
PGM concentrate (part of a 6E basket: Pt, Pd, Rh, Ru, Ir, Au) is sold directly into the platinum/palladium market. South Africa supplies roughly 70% of mined platinum and, with Russia, ~80% of combined mined PGM supply (USGS) — a concentrated, largely non-substitutable chokepoint (catalytic converters, hydrogen electrolysis) that sits squarely under Tharisa's own mine.
concentrate. Rhodium is one of the most supply-concentrated traded metals; South Africa is the leading source of mined rhodium, and there is no industrial substitute for its role in autocatalysts. A production or export disruption at a South African PGM co-producer like Tharisa is a direct hit to global rhodium/iridium supply, not a diversifiable one.
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.
Tharisa's own Arxo Logistics page: 'The company manages the road transport of Tharisa Minerals' PGM concentrates to Northam and Sibanye-Stillwater.' Tharisa Minerals (western Bushveld, South Africa) is this dossier's operating subsidiary. Domestic ZA-ZA, no flow recorded; no volume/share disclosed.
Ranked by buyer-relative risk, highest first.
1 of 2 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 |
|---|---|---|---|---|---|---|---|---|---|
| Chromium | 🇨🇳 CN 46% refining | 42 | 42 | Moderate | — |
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 |
|---|---|---|---|---|---|---|
| Chromium | 4 | 2 | – |
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.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Chromium exposure:
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Tharisa plc 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 3 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.
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 Tharisa plc 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) |
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 3 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 2026-06-03; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-06
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 127 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.
concentrate, metallurgical and chemical grade). South Africa mines ~46% of world chromite and produces over half of global ferrochrome output; together with Kazakhstan and Turkey it accounts for >75% of primary chromite supply. Chromium is essential (and effectively irreplaceable) for stainless steel and superalloys.
vanadium were on the sector-derived default list but have no evidence of being produced or handled by Tharisa or Karo — dropped as unsupported.
Same source and quote as the Northam row above -- Arxo Logistics transports Tharisa Minerals' PGM concentrates to both Northam and Sibanye-Stillwater. Domestic ZA-ZA, no flow recorded; no volume/share disclosed.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
| High |
| hard |
| 13 |
| ▲ rising |
| Rhodium-iridium | 🇿🇦 ZA 83% mining | 37 | 71 | Low | EXCEEDS 83% | High | none | 10 | ▲ rising |
| Platinum-palladium | 🇿🇦 ZA 54% mining | 35 | 62 | Low | within 54% | High | limited | 12 | ▲ 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 ↗
| 4 |
| – |
| company input |
| Rhodium-iridium | 4 | 4 | 3 | 5 | 4 | company input |
| Platinum-palladium | 4 | 3 | 5 | 4 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
+ 3 more in the register.
| Type |
|---|
| Scenario |
|---|
| Today |
|---|
| Stressed |
|---|
| Δ |
|---|
| Policy | Chromium — 🇨🇳 CN escalates chromium controls to a full export-licensing / ban regime | 42 | 47 | +5 |
| Concentration | Chromium — 🇨🇳 CN becomes the single source for chromium — the second source is lost (full 46%+ monopoly) | 42 | 66 | +24 |
| Policy | Rhodium-iridium — 🇿🇦 ZA escalates rhodium-iridium controls to a full export-licensing / ban regime | 37 | 39 | +2 |
| Concentration | Rhodium-iridium — 🇿🇦 ZA becomes the single source for rhodium-iridium — the second source is lost (full 83%+ monopoly) | 37 | 41 | +4 |
| Policy | Platinum-palladium — 🇿🇦 ZA escalates platinum-palladium controls to a full export-licensing / ban regime | 35 | 37 | +2 |
| Concentration | Platinum-palladium — 🇿🇦 ZA becomes the single source for platinum-palladium — the second source is lost (full 54%+ monopoly) | 35 | 42 | +7 |
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.
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.
| 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.