3 critical materials scored · binding chokepoint: Silver (🇲🇽 MX 24% of mining) · 56 restrictive government measures on record
Subject
000630.SZ · 🇨🇳 CN
Sector
metals-refining
Materials scored
3
As of
2026-09-30
Risk Office verdict
Moderate · 41/100Company supply-risk index · consumer-side read
Role check · this company is a producer, not a buyer
Tongling Nonferrous Metals Group Co., Ltd. produces 3 of the 3 scored materials above (Silver, Copper, Tellurium). 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 · 41/100 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 Silver — 🇲🇽 MX controls 24% of global mining. On this company's production footprint that scores 43/100 (neutral exposure; global 43). The register holds 56 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · SilverTongling Nonferrous Metals Group Co., Ltd. is the 145th-most-exposed of the 340 named companies we track on 🇲🇽 MX's Silver chokepoint; the most-exposed is Omron Corporation (43/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Competitor cohort · metals refining
Tongling Nonferrous Metals Group Co., Ltd. ranks 86th of 98 verified metals refining companies.
Company supply-risk index 41/100 — 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 (CN 75% · EC 25%, 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.
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.
Tongling Nonferrous Metals Group Co., Ltd.
What they do
Tongling Nonferrous Metals Group is China's largest copper cathode producer, vertically integrated from mining and beneficiation through smelting, electrorefining, and downstream copper-foil/strip processing. Domestic smelting is centered in Tongling, Anhui province; overseas ore supply comes principally from a 70%-owned stake in the Mirador copper mine in Ecuador, whose Phase II expansion was commissioned in mid-2025. In 2024 the group produced 1.768 million tonnes of copper cathode, alongside byproducts including 5.36 million tonnes of sulfuric acid, 22.91 tonnes of gold, and 547.67 tonnes of silver recovered from the copper-smelting anode slime.
business, from Mirador ore through Anhui smelting to finished cathode and copper foil/strip. Exposure runs through both ends: Ecuadorian mining/ export policy on the supply side, and Chinese smelting capacity and power/environmental policy on the processing side.
Silver — trace byproduct. Recovered from the anode slime generated
during copper electrorefining (547.67 tonnes in 2024) — a real but secondary revenue stream riding on the copper business, not a standalone silver-mining operation.
Tellurium — trace byproduct. A 2025 government environmental-impact
disclosure for Tongling's anode-slime processing system upgrade states the existing facility already produces 43.84 tonnes/year of copper telluride alongside gold and silver ingots from the same anode-slime stream, with the expansion adding a dedicated selenium-recovery step; a genuine, disclosed byproduct exposure distinct from generic copper smelting.
Named counterparties — who actually buys and sells
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.
The full counterparty breakdownShowHide
Next mandatory disclosure — Q3-2026 quarterly, due 2026-10-31 (25 days) on SZSE (000630.SZ). rule ↗
What an A-share filer must publish is the top-5 concentration PERCENTAGE, not the customer names. Names reach us only where a disclosure trigger or the common-control merge rule forces them — so this lane guarantees a number for any listed producer and a name only sometimes.
The date is statutory; what this particular filing contains is not equally settled. The top-5 concentration clause we rely on sits in the content standard for the annual report, and nobody here has read the quarterly standard — so treat this deadline as a filing worth reading, not as a guaranteed refresh of the figures below.
Customers · FY2025
Disclosed top-5 25.36%of which related-party 0.00%arm's length 25.36% (derived)
Suppliers · FY2025
The exposure register
Ranked by buyer-relative risk, highest first.
0 of 1 of your scored CRMA-strategic material breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
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.
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.
2026-09-11amendedIndonesia 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.
The laws that threaten it
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:
Both stress-test scenariosShowHide
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).
Which of your plants carries the binding exposure
Under the 🇲🇽 MX shock, your disclosed plant carries the binding Silver exposure:
Disclosed plant-level detail matched to the binding material — descriptive, from the company's own disclosures; a plant not listed here is undisclosed, not unexposed. Country weights still drive the score above.
Type
Scenario
Today
Stressed
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Tongling Nonferrous Metals Group Co., Ltd. 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 — 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 threatsShowHide
🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)
passed-vote→high likelihood·flagged 56d ago · not yet law·matches Copper
If passed — On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
What to watch next
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The watch listShowHide
Silver is the line to war-game: 🇲🇽 MX already controls 24% of mining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Copper carries 52 restrictive measures on record (🇨🇳 CN 48% of refining) — a secondary escalation candidate.
Art. 24(4) · diversification & substitution
Priority mitigations
Every scored material here is one Tongling Nonferrous Metals Group Co., Ltd. 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.
The mitigation optionsShowHide
Track demand-side substitution against your own book. The buyer levers listed for consumers of Silver, Copper, Tellurium — qualifying alternative suppliers, designing the material out — are the demand risk to Tongling Nonferrous Metals Group Co., Ltd.'s revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by MX / CN on a material Tongling Nonferrous Metals Group Co., Ltd. produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The materials above are concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
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 crosswalkShowHide
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)
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 detailsShowHide
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
metals-refining (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.
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.
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.
41🇨🇳 Tongling Nonferrous Metals Group Co., Ltd.Silver
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 39 further metals refining 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.
Named counterparties
Tongling's FY2025 annual report (filed 2026-04-20) discloses its top-5 customer and top-5 supplier concentration tables — RMB 43.81bn (25.36% of sales) and RMB 50.88bn (35.30% of purchases) respectively — but both tables are fully coded (客户十一–十五 / 供应商一–五), with 0.00% related-party overlap on either side, so none of the top-5 constituents can be named from that table.
Three named entities do surface elsewhere in the same filing, in the mandatory daily-related-party-transaction disclosure (a separate table from the top-5 concentration table, disclosed against board-approved annual quotas rather than against total revenue):
Customers. Anhui Jiuhua New Materials Co., Ltd. (安徽九华新材料股份
有限公司) buys slag and anode copper from Tongling (RMB 152.9m, 0.09% of same-type sales). Zhongke Tongdu Powder New Materials Co., Ltd. (中科铜都 粉体新材料股份有限公司) buys silver ingots (RMB 1.009bn, 0.59% of same-type sales) — the only named counterparty found anywhere for the silver byproduct line.
Suppliers. Anhui Jiuhua New Materials also sells Tongling zinc ingot
and copper raw material (RMB 817.5m, 0.56% of same-type procurement, exceeding its RMB 500m board-approved cap) — i.e. the same entity is both a customer and a supplier on different product flows.
All three are 同受母公司控制 (under common control of the same parent — the Anhui state-asset system), not independent arm's-length counterparties; related_party: true is set accordingly and none should be read as an open-market buyer/seller discovery. No non-related-party named counterparty was found for copper, silver, or tellurium in this filing — the diffuse, anonymized top-5 customer/supplier base is the structural reason, not an access failure.
https://jjjskfq.tl.gov.cn/tlsjjjskfq/c00029/pc/content/content_1926072148369924096.html (Tongling Economic & Technological Development Zone EIA public disclosure, copper anode-slime processing system upgrade project, 2025-05-21; replaces dead matrixbcg.com citation)
https://disc.static.szse.cn/disc/disk03/finalpage/2026-04-20/9ce9a44c-195c-4f7c-a489-22ae9fd25950.PDF (Tongling Nonferrous Metals Group 2025 Annual Report, filed 2026-04-20; SZSE mirror — original cninfo static URL now returns 403)
</content>
Disclosed top-5 35.30%of which related-party 0.00%arm's length 35.30% (derived)
Top-5 customer and supplier tables are both fully coded (客户十一-十五 / 供应商一-五), 0% overlap with the top-5 disclosure — the three named rows above come from the separate daily-related-party-transaction table, not the top-5 table itself. source_url updated 2026-09-18: original cninfo static URL now returns 403; this is the same 2025 annual report filing (filed 2026-04-20) mirrored on SZSE's own static disclosure server.
Named suppliers (2)
安徽九华新材料股份有限公司 / Anhui Jiuhua New Materials Co., Ltd.0.56% of same-type procurement transactions · FY2025related partya-share-filingprimary-sourcesection filing ↗
Zinc ingot and copper raw material. Exceeded its RMB 500m board-approved related-party cap.
Glencore International AG · balance at 2024-12-31, per Tongling Nonferrous Metals Group Holdings 2024 annual report (audited)arm's lengthcompany-disclosureprimary-sourcesource ↗
Largest prepayment counterparty of the controlling shareholder (consolidating this company) at 31 Dec 2024: RMB 3,284,901,036.76, 34.33% of prepayments. Trader; the mine of origin is not named, so the corridor is open. Same note names MINERA ESCONDIDA LIMITADA (RMB 1,721.5m, recorded on the bhp dossier as CL>CN), IXM S.A. (RMB 1,673.3m), Transamine Trading (RMB 998.9m), Werco Trade (RMB 889.2m).
Named customers (2)
安徽九华新材料股份有限公司 / Anhui Jiuhua New Materials Co., Ltd.0.09% of same-type sales transactions · FY2025related partya-share-filingprimary-sourcesection filing ↗
Buys slag and anode copper from Tongling; same entity also sells Tongling zinc ingot/copper raw material as a supplier (separate row below).
中科铜都粉体新材料股份有限公司 / Zhongke Tongdu Powder New Materials Co., Ltd.0.59% of same-type sales transactions · FY2025related partya-share-filingprimary-sourcesection filing ↗
Buys silver ingots from Tongling — the only named counterparty found for the silver byproduct line.
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. · section source filing ↗
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 ↗
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
Silver
5Price / market: price up, as of 2026-10-05
Copper
4Geopolitical: 52 restrictive actions, peak severity 5, 33 in last 24mo, less 3 liberalising actions
5Price / market: price up, as of 2026-09-01
4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 70/100 (long-horizon, all major uses). Prior analyst short-run rating 0.50: USGS: aluminium substitutes in some electrical/heat-exchange uses
Tellurium
4Geopolitical: 2 restrictive actions, peak severity 4, 2 in last 24mo
4Concentration: refining HHI 6516 (extreme); top CN 80%
5Import reliance: Eurostat Comext 2025: 88% extra-EU imports, top partner CA 48% (partner HHI 3786)
Silver — 🇲🇽 MX escalates silver controls to a full export-licensing / ban regime
43
52
+9
Concentration
Silver — 🇲🇽 MX becomes the single source for silver — the second source is lost (full 24%+ monopoly)
43
73
+30
Policy
Copper — 🇨🇳 CN escalates copper controls to a full export-licensing / ban regime
40
42
+2
Concentration
Copper — 🇨🇳 CN becomes the single source for copper — the second source is lost (full 48%+ monopoly)
40
53
+13
Policy
Tellurium — 🇨🇳 CN escalates tellurium controls to a full export-licensing / ban regime
28
31
+3
Concentration
Tellurium — 🇨🇳 CN becomes the single source for tellurium — the second source is lost (full 80%+ monopoly)
28
32
+4
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.
Caveat — ENACTED / already in force (signed 29 June 2026, five independent Congolese/international outlets corroborate the ministers, date and substance) but parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. cd unreachable per prior wakes — same constraint noted on the DRC Strategic Mineral Reclassification, ARECOMS forfeiture, and 5% Worker Equity entries elsewhere in this file). DISTINCT from: 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (ARECOMS sectoral cobalt-hydroxide quota system, cobalt-only), 2025-12-19-drc-artisanal-copper-cobalt-processing-suspension (artisanal-sector only), the queued ARECOMS H1-2026 quota-forfeiture entry above (operationalises the ARECOMS quota, not this arrêté), 2026-04-10-drc-strategic-reserve-minerals-arecoms, and 2026-05-29-drc-strategic-mineral-expansion-decree. This arrêté is the FIRST instrument in the register banning concentrate exports for BOTH copper and cobalt jointly and replacing the 2023 commercialisation/export/nomenclature framework wholesale — a materially broader legal basis than any of the above. Re-check mines. gouv. cd and jocc.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 40→42+2
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 67d ago · not yet law·matches Copper
If passed — Minister of Finance, acting under s. 89 of the Customs and Excise Act, cut the copper-concentrate export duty to ZERO for tariff headings 2603. 00. 21 / 2603. 00. 22 / 2603. 00. 23 / 2603. 00. 29, capped at 271,742 t, effective 1 June 2026 with automatic lapse 30 September 2026, with per-entity tonnage caps and (per one secondary) a requirement that exempt shipments channel through Industrial Resources Limited. This is a SUPPLY-RELIEF (liberalising) action — a net EASING of a copper/cobalt chokepoint for ~4 months, explicitly to clear stockpiled unprocessed concentrate while Zambia's major smelters are down for extended maintenance. It is the "(No. 2)" successor instrument to the already-filed 2026-03-05-zambia-si-15-2026-copper-concentrates-export-duty-suspension (a distinct SI with its own number, tonnage cap and validity window). Severity ~2 expected.
Caveat — ENACTED / already in force per multiple independent secondary sources (all agree on SI number, exact citation title, s. org URL pattern that resolves for the parent SI 15/2026 (`/akn/zm/act/si/2026/43/eng@<date>`) across several plausible dates, all 404; zambialii's SI-list index page for 2026 also 404s directly. Parked here per the standing verify-or-don't-file convention (cf. DRC ARECOMS, Pakistan chloroform, China sulfuric-acid entries below) rather than filed on secondaries alone. Re-check zambialii.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 40→42+2
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 67d ago · not yet law·matches Copper
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.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 73d ago · not yet law·matches Copper
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 40→42+2
🇰🇿 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 99d ago · not yet law·matches Copper
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).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 40→42+2
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 100d ago · not yet law·matches Copper
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.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 109d ago · not yet law·matches Copper
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.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 40→42+2
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 114d ago · not yet law·matches Copper, Silver
If passed — Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mining concessions for first time in Peruvian law history, making concessions revocable by administrative authority; introduces higher annual fees and stronger production/investment requirements; threatens legal certainty for Peru's undeveloped copper and silver project pipeline — Peru = #2 copper, #4 silver, #1 lead, #2 zinc globally
Caveat — Approved by Energy and Mining Commission March 17, 2026 by 11 votes to 1 with 3 abstentions — driven by left-aligned Juntos por el Perú (JPP) and Podemos Peru majority. Bill also introduces "comuneros como accionistas" (community shareholders) in mining concessions — first legislative insertion of indigenous community equity rights. MINEM, SNMPE, ComexPerú, and Ingemmet publicly opposed; MINEM warns reform would incentivise illegal mining expansion. Full plenary debate pending as of June 2026. Distinct from all filed PE actions (all executive/regulatory decrees — no prior legislative amendment to Ley General de Minería in register). Also distinct from filed PE actions on REINFO extension (2025-12-26), illegal-mining criminalization (2026-01-20), and Tía María revocation (2026-03-19).
announced→low likelihood·flagged 112d ago · not yet law·matches Copper, Silver
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.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
Silver🇲🇽 today 43→52+9
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 111d ago · not yet law·matches Silver, Copper
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Silver🇲🇽 today 43→52+9
Copper🇨🇳 today 40→42+2
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 110d ago · not yet law·matches Copper
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 ↗
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Copper🇨🇳 today 40→42+2
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 110d ago · not yet law·matches Copper
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).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
🇹🇿 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 102d ago · not yet law·matches Copper
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.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 40→42+2
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 105d ago · not yet law·matches Copper
If passed — All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension; effectively forces equity restructuring across the entire DRC copper-cobalt belt; miners seeking moratorium as of June 18, 2026 — enforcement outcome by August 2026 will set the precedent
Caveat — Ministerial enforcement letter issued January 30, 2026 by Mines Minister Louis Watum Kabamba — activates dormant Art. 71 bis (5% employee equity in mining company capital) and Art. 144 bis (mechanics) of DRC Mining Code (Loi n° 18/001). Filed here (not filing. md) because DRC government websites (mines. gouv. cd, primature. gouv. cd) remain inaccessible per prior wakes — same constraint as the DRC Strategic Mineral Reclassification entry. Action IS already in effect and enforcement is underway (July 31, 2026 deadline); this is NOT speculative. DRC Chamber of Mines convened June 11, 2026 industry response meeting; companies arguing retroactive application is legally contested. Severity 3 expected if enforced. Distinct from: 2018-01-27-drc-mining-code-revision (underlying law), 2026-04-10-drc-strategic-reserve (ARECOMS mechanism), 2026-04-24-drc-tshisekedi-mining-export-revenue-audit.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 105d ago · not yet law·matches Copper
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 ↗
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Copper🇨🇳 today 40→42+2
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 102d ago · not yet law·matches Copper
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).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
🇲🇳 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 101d ago · not yet law·matches Copper
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.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Copper🇨🇳 today 40→42+2
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 101d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one of the world's largest undeveloped Cu-Au deposits (phase-1 ~200,000 t/yr copper concentrate + 250,000 oz/yr gold, first production targeted end-2028, ~USD 5. 5bn phase-1 capex). The stake would be purchased from the Pakistani state's half of the project (Pakistan federal SOEs + Balochistan hold 50%; Barrick Gold holds 50% and operates). This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) into a strategic copper chokepoint, paralleling Manara's Vale Base Metals 10% stake and IRH's Mopani (Zambia) acquisition; gives Saudi Arabia an equity claim on a major future non-China copper supply source.
Caveat — As of 2026-06-27 the deal is in negotiation — Pakistan's Petroleum Minister Musadik Malik said publicly he expected a deal "within the next six months," hence announced/upcoming not enacted. Distinct from filed 2025-09-08-pakistan-us-ussm-fwo-critical-minerals-mou (US EXIM/USSM financing angle on Reko Diq), filed 2025-03-14-pakistan-balochistan-mines-and-minerals-act (the provincial mining law), and filed 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake (Manara's Vale Base Metals deal). Severity 2-3 if completed.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 100d ago · not yet law·matches Copper
If passed — Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring the interest from the Government of Pakistan (Pakistan + Balochistan together own 50%; Barrick Gold holds the other 50% as operator). Reko Diq is one of the world's largest undeveloped copper-gold deposits (~$74bn projected free cash flow over a ~37-yr life). IPTM relevance: a GCC sovereign-capital upstream-mining-FDI entry (theme gcc-mining-upstream-fdi) into COPPER — a binding chokepoint material — extending the Saudi diversification-of-supply strategy beyond the filed 2024-03-01 Manara→Vale Base Metals 10% stake; would also be a Pakistan host-state instrument (federal divestment of part of its Reko Diq equity to a Gulf SWF, complementing the 2025-09-08 Pakistan–US USSM critical-minerals MoU already filed). Distinct GCC third-party capital base separate from Chinese-SOE capture and Western MSP/CRMA-aligned investment.
Caveat — As of mid-2025 the deal was reported by Pakistan's Petroleum Minister as expected "within six months" but NO binding SPA or primary gov instrument has surfaced as of 2026-06-28 — hence announced/moderate, not enacted. Dedup: only the 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake Manara action is filed; no Reko Diq/Manara slug in action-index; the filed Reko Diq item (2025-09-08 Pakistan–US USSM–FWO MoU) is a DIFFERENT instrument (US bilateral MoU, not a Saudi equity purchase). Severity 2-3.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 68d ago · not yet law·matches Copper
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").
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
Copper🇨🇳 today 40→42+2
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 54d ago · not yet law·matches Copper
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.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Copper🇨🇳 today 40→42+2
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 2d ago · not yet law·matches Copper
If passed — State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar's ambassador that it will resume the Jebel Ohier copper-gold project (Red Sea State) with an $800M commitment. Third GCC sovereign upstream-mining entry after Manara Minerals/Vale Base Metals 10% stake (2024-03-01, filed) and QIA/Ivanhoe Mines strategic placement (2025-09-17, filed) — extends the GCC-as-third-capital-base pattern (theme gcc-mining-upstream-fdi) to African copper, not just battery metals.
Caveat — gov. sd not independently reachable; QMSD's own project page does not yet mention the resumption) — parked here per the same convention used for the Malawi executive-order entry above (real/firm commitment, primary URL not yet locatable). Dedup: checked "qatar mining", "jebel ohier", "qmsd" across filing. md, upcoming. md, and action-index — zero hits. Likelihood=high reflects a confirmed government-to-government commitment, not a prediction of eventual gazettal.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Copper🇨🇳 today 40→42+2
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.
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.