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3 critical materials scored · binding chokepoint: Neodymium (🇨🇳 CN 85% of refining) · 64 restrictive government measures on record
PT Timah Tbk produces 3 of the 3 scored materials above (Neodymium, Praseodymium, Tin). For those, a supply restriction by the controlling country is a tailwind, not a headwind — the exposure is to disruption of a market this company supplies, not to a chokepoint it depends on. Every scored material here sits on its output side, so the High · 70/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-07) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Neodymium — 🇨🇳 CN controls 85% of global refining. On this company's production footprint that scores 72/100 (neutral exposure; global 72). The register holds 64 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Neodymium PT Timah Tbk is the 418th-most-exposed of the 519 named companies we track on 🇨🇳 CN's Neodymium chokepoint; the most-exposed is Alta Resource Technologies (86/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
PT Timah Tbk ranks 110th of 453 verified mining metals companies, tied with 7 others at 70.
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.
Company supply-risk index 70/100 — 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 (ID 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.
PT Timah Tbk (IDX: TINS) is Indonesia's state-owned (MIND ID group) integrated tin miner — exploration, onshore and offshore dredging (Bangka and Belitung islands, plus Kundur Island in the Riau Islands), smelting via TSL Ausmelt furnaces, and marketing of refined tin metal, solder, and tin chemicals. Indonesia is the world's largest tin exporter, and Timah is its dominant state producer. The company is currently under heavy scrutiny from a 2023-2024 corruption case over illegal mining on its concessions.
smelts, and exports cassiterite-derived tin metal at industrial scale; this is not an input dependency but its primary revenue-generating output. Tin is a scored critical mineral because Indonesia and China together dominate global supply, and it is essential (largely non-substitutable) as solder in electronics assembly.
exposure.** Bangka tin-mining tailings contain monazite/xenotime sands bearing light rare earths (cerium, lanthanum, neodymium, praseodymium) alongside radioactive thorium. Timah and parent MIND ID are revitalizing a pilot plant at Tanjung Ular, West Bangka, to convert this monazite by-product into mixed rare-earth carbonate, (groundbreaking date from VOI, not re-verified; Timah's 2025 annual report confirms an existing RE (OH) pilot plant at Tanjung Ular and names monazite/REE as a development option, without disclosing Nd/Pr volumes). This is real and company-specific but still pilot/pre-commercial — trace-scale by-product recovery, not yet a production line — so treat as a forward risk signal rather than a current material exposure at scale.
prosecutors found illegal tin mining routed through private smelter PT Refined Bangka Tin (via middleman Harvey Moeis) on Timah's own concessions, with state losses estimated around Rp 300 trillion (~$18-20bn), mostly environmental damage. Moeis was convicted in December 2024 and, on appeal in February 2025, had his sentence increased to the maximum 20 years — a material signal on concession-control and compliance risk at Timah itself, separate from the underlying commodity exposure.
ICDX commodity exchange (ITA, 2015 notice, effective 1 Aug 2015), with exporters verified by the Energy and Mineral Resources Ministry. Timah sells ~90 % of its refined tin abroad (FY2025: 16,634 t sold, 17,815 t produced; Laporan Tahunan 2025), so this licensing regime is a recurring chokepoint. Earlier claims here of a 2024 three-year licence and a March 2025 finance ministry decree were not supported by the cited ITA page and are dropped.
included.** These were carried over from the sector-default template but no evidence supports Timah producing or depending on them; dropped rather than asserted.
1. The Jakarta Post — Appellate court increases Harvey Moeis's sentence to maximum 20 years (2025-02-13): https://www.thejakartapost.com/indonesia/2025/02/13/appellate-court-increases-harvey-moeiss-sentence-to-maximum-20-years 2. International Tin Association — Further tightening of Indonesian export rules announced: https://www.internationaltin.org/further-tightening-of-indonesian-export-rules-announced/ 3. VOI — PT Timah Develops Pilot Plant For Rare Earth Metals In Bangka Belitung: https://voi.id/en/economy/478052 4. PT Timah — Tin mining business overview (primary): https://timah.com/blog/our-business/tin-mining
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.
Laporan Tahunan 2025, consolidated FS revenue note: 'Details of customers with revenue transactions that represent more than 10% of the total consolidated revenue are as follows: 2025 MIND ID Trading Limited 5.832.900; 2024 4.539.912' (Rp million) against total revenue Rp 11,552,733m (2025) / Rp 10,856,422m (2024), of which export sales Rp 10,346,545m (2025). Related-party note lists 'MIND ID Trading Limited | under common control | sale and purchase of tin ingots'; management report: Timah 'collaborates with MIND ID Trading as an affiliated (sister) company to support tin metal sales in Asia'. Trading intermediary of state holding MIND ID, so the end-buyer country is not disclosed.
US import BoL EGLV070400348146 (Evergreen, EVER MAX 1289E): Shipper 'Pt. Timah Tbk', Pangkalpinang, Bangka; Consignee 'To Order Of Indometal (London) Ltd', 326A City Rd, London; Shipment Origin Indonesia, place of receipt Singapore, lading Kaohsiung, unlading Baltimore MD; 25,025 kg, 25 bundles, HTS 8001.10.00.00 (unwrought tin, not alloyed). ImportGenius lists further Timah 'TIN INGOTS IN BUNDLE BANKA FOUR NINE' BoLs into Baltimore 2025-01-27 (consignee Indometal London, 50,050 kg) through 2026-05-03 (consignee masked). Tin smelted at Muntok (Bangka), ID. Indometal London is Timah's UK marketing arm, so the US end-user is not named; the BoL pins the route.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
2 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 |
|---|---|---|---|---|---|---|---|---|---|
| Neodymium | 🇨🇳 CN 85% refining | 72 | 72 | High | EXCEEDS 85% | — | some | 50 | ▲ rising |
| Praseodymium | 🇨🇳 CN 85% refining | 72 | 72 | High | EXCEEDS 85% | — | some | 48 | ▲ rising |
| Tin | 🇨🇳 CN 55% refining | 56 | 56 | Elevated | — | High | ready | 18 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Praseodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Tin | 4 | 2 | 5 | 2 | 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.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
Two independent lenses: USGS official puts China at 55% of global refining output (by tonnage); US filers' own disclosures independently name China for 28% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| China Tin Group Co., Ltd.CID1070 | China | 20 | SEC |
| PT Mitra Stania PrimaCID1453 | Indonesia | 18 | SEC |
| Gejiu Kai Meng Industry and Trade LLCCID942 | China | 18 | SEC |
| PT ATD Makmur Mandiri JayaCID2503 | Indonesia | 17 | SEC |
| PT Prima Timah UtamaCID1458 | Indonesia | 17 | SEC |
Source: US SEC Form SD / Conflict Minerals Report exhibits (EDGAR full-text search), aggregated from RMI smelter tables. “US filers naming it” = distinct US-listed companies whose most-recent CMR names that refiner — disclosure-derived presence, not verified throughput. Link opens the SEC exhibit.
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.
+ 49 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
The binding exposure this precedent lands on — Neodymium — is a material PT Timah Tbk produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-07) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 13 restrictive actions on Neodymium since 2024 — cadence accelerating (mean gap 103d → 29d), severity flat (3.8 → 3.4).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 2 of these 26 materials (Neodymium, Praseodymium) — your binding Neodymium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 4.7 months apart across 5 distinct restriction dates since 2024 (n=4 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime | 72 | 76 | +4 |
| Concentration | Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly) | 72 | 82 | +10 |
| Policy | Praseodymium — 🇨🇳 CN escalates praseodymium controls to a full export-licensing / ban regime | 72 | 76 | +4 |
| Concentration | Praseodymium — 🇨🇳 CN becomes the single source for praseodymium — the second source is lost (full 85%+ monopoly) | 72 | 82 | +10 |
| Policy | Tin — 🇨🇳 CN escalates tin controls to a full export-licensing / ban regime | 56 | 60 | +4 |
| Concentration | Tin — 🇨🇳 CN becomes the single source for tin — the second source is lost (full 55%+ monopoly) | 56 | 79 | +23 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one PT Timah Tbk 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.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one PT Timah Tbk produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 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 2026-09-30; 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 2026-10-07
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
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