2 critical materials scored · binding chokepoint: Silicon (🇨🇳 CN 80% of refining) · 21 restrictive government measures on record
Subject
toshiba-electronic-devices-storage · 🇯🇵 JP
Sector
semiconductor
Materials scored
2
As of
2026-09-22
Draft — not yet independently re-checked
This dossier's claims have not yet been independently re-checked against their cited sources. Treat every score, band and stress figure below as provisionalpending that re-check.
Risk Office verdict
Elevated · 69/100Not yet independently re-checkedCompany supply-risk index
The binding exposure is Silicon — 🇨🇳 CN controls 80% of global refining. On this company's production footprint that scores 77/100 (adversarial chokepoint; global 64). The register holds 21 restrictive government measures touching this company's materials — each traced to its primary source below.
Competitor cohort · semiconductor
Where the 72 verified semiconductor companies we track sit.
88🇬🇧 Filtronic plcGallium
86🇺🇸 MicroLink Devices, Inc.Gallium
86🇬🇧 CML Microsystems plcGallium
86🇸🇪 Norstel ABGraphite
86🇺🇸 Skyworks Solutions, Inc.Gallium
85🇦🇺 BluGlass LimitedGallium
84🇱🇹 Brolis SemiconductorsGallium
83🇦🇹 ams-OSRAM AGTerbium
83🇰🇷 DB HiTek Co., Ltd.Tungsten
83🇹🇼 Himax Technologies, Inc.Tungsten
Company supply-risk index 69/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 2 scored materials. Buyer-relative (first-order): weighted by where the company produces (JP 100%, HQ proxy), applied across all materials — it does not yet trace each input to its specific sourcing step.
Toshiba Electronic Devices & Storage Corporation is the wholly-owned Toshiba Corporation subsidiary that holds the group's semiconductor and hard-disk-drive businesses. Its own product listing covers two halves. The semiconductor half is discrete and analog rather than leading-edge logic: MOSFETs, IGBTs/IEGTs, bipolar transistors and diodes, microcontrollers, power-management and motor-driver ICs, linear ICs and logic devices, linear image sensors, and photocouplers/isolators — plus a wide-bandgap line of SiC MOSFETs and SiC Schottky barrier diodes. The storage half builds hard disk drives for data-centre/enterprise, consumer and specialty applications.
One boundary matters for anyone reading this file: it does not make NAND flash memory. Toshiba's memory business was separated as Toshiba Memory and is now Kioxia, an unrelated company. Nothing about NAND fabrication belongs in this dossier's exposure set.
Critical-material exposure
Silicon — bulk input, and the substrate the entire semiconductor half
is built on. Every product family Toshiba lists on this side — MOSFETs, IGBTs, bipolar transistors, diodes, microcontrollers, power-management and motor-driver ICs, linear and logic devices, image sensors, photocouplers — is a silicon-wafer device, and the wide-bandgap line is silicon , which is silicon-bearing as well. This is the plainest and highest-volume dependency in the file, though it is also a low-differentiation one: polysilicon and wafer supply is a chokepoint the whole industry shares rather than a Toshiba-specific concentration.
The exposure register
Ranked by buyer-relative risk, highest first.
1 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.
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).
Counterfactual: the 50%-ownership automatic extension of Entity List designations runs to its full perimeter (one-year suspension at 2025-11-10 lifted on schedule). Direct-hit lines are basket issuers in semiconductor / chip-equipment / AI-compute sectors — the perimeter where the rule's 50% controller-affiliate test compounds with existing Entity List names.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 77 → 82(+5) — a relative official policy-pressure magnitude, not a price drawdown.
Trace the precedent to its primary source via the link above ().
Art. 24(4) · mitigation trigger
Significant-vulnerability conclusion
No material crosses the significant-vulnerability threshold. 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 materials this company buys. The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed — not yet law
Upcoming regulatory threats
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet. Market-implied percentages are live external prediction-market prices (alternative/OSINT signal) — an independent read, not our model output and not merged into the official register or the stage-derived band; the gap between the market price and our stage assessment is itself the signal.
The upcoming threatsShowHide
🇹🇿 Tanzania Critical & Strategic Minerals Strategy + statutory critical/strategic minerals LIST (Ministry of Minerals, Mavunde) — beneficiation-mandate licensing instrument
in-consultation→moderate likelihood·flagged 98d ago · not yet law·matches Helium
If passed — Tanzania's Ministry of Minerals (Minister Anthony Mavunde) has FINALISED a Critical and Strategic Minerals Strategy that takes legal effect only once the Government formally approves and gazettes the official LIST of critical and strategic minerals — a distinct REGULATORY instrument (not the fiscal Finance Act). The strategy explicitly prioritises IN-COUNTRY BENEFICIATION for graphite, nickel, rare earths and lithium, and amends mineral-processing-licence conditions so that every processing licence now requires a domestic value-addition plan; it targets a 40-mineral beneficiation/local-processing scope plus technology-transfer partnership requirements. Once the list is gazetted, raw/unprocessed exports of the listed minerals (Tanzania = a structural graphite chokepoint via Faru/Lindi/Mahenge graphite, plus emerging niobium at Panda Hill and nickel at Kabanga) face value-addition-plan gating and likely export conditionality — re-pricing a major non-China graphite supply node and the Kabanga nickel/Panda Hill niobium projects.
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
Silicon is the line to war-game: 🇨🇳 CN already controls 80% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Art. 24(4) · diversification & substitution
Priority mitigations
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Silicon).
The mitigation optionsShowHide
Map your real exposure to Silicon. Trace it from the component back to the smelter/refiner and country of origin — most buyers discover the dependence is one tier deeper than their direct supplier.
Qualify a non-CN source. Identify and validate at least one supplier outside CN for the binding input before it is needed, even at a cost premium — optionality is the hedge.
Lead-time to re-source is ~9 months (6-12mo). The largest tracked non-CN producer of Silicon is 🇩🇪 DE (~7% of refining); scaling it into a replacement is roughly a 6-12mo ramp. A share-of-stage substitution heuristic derived from current production share, not a firm supplier quote.
Design for substitution where feasible. Silicon has at least partial substitutes; specify them into next-generation products to cut the dependence structurally.
Hold strategic inventory / contract forward. For materials with no substitute and active export controls, a buffer stock or long-dated offtake converts a shock into a managed cost.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.
Consider production localisation. Where the material is consumed inside the controlling country's perimeter, local sourcing/assembly can move you inside the chokepoint rather than across the export-control line.
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
Yes — 2 scored SRMs on the input side (binding: Silicon)
Manufactures a listed strategic technology
semiconductor (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 2026-09-22; 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.
82🇮🇹 LFoundry S.r.l.Tungsten
82🇺🇸 Qorvo, Inc.Gallium
82🇹🇼 Vanguard International Semiconductor Corporation (VIS)Gallium
81🇳🇴 Nordic Semiconductor ASATungsten
81🇬🇧 Pragmatic Semiconductor LtdGallium
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 10 further semiconductor 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.
carbide
Helium — *bulk input in the sealed sense, and the differentiating
exposure here. Toshiba's MG-series enterprise drives are helium-sealed*: the company's own storage product pages describe using "Toshiba precision laser welding technology to seal helium inside the disk mechanics", with the helium fill reducing aerodynamic drag to allow more platters and lower power. This is not a legacy detail — it runs across the current generations (MG07's 9-disk helium design through the 10-disk MG10F and MG11 at up to 24 TB), so the high-capacity data-centre line, the commercially important one, is structurally dependent on it. Helium is genuinely supply-concentrated: it is recovered as a byproduct of a small number of natural-gas fields, cannot be synthesised, and has repeatedly gone into global allocation during supply crunches. A helium disruption does not degrade this product line, it stops the sealed drives being buildable.
Dropped from the semiconductor sector default — tungsten, copper, tantalum, tin, indium, antimony, neodymium, niobium, silver and tellurium. No Toshiba document naming any of them as an input was located. Several are plausible on general semiconductor and HDD engineering grounds (copper interconnect and spindle-motor windings, tungsten contact plugs, tin solder, tantalum capacitors), but plausible-for-the-industry is what the sector default already was, and re-asserting it adds no information while claiming verification this file does not have. Tellurium and antimony in particular describe phase-change and compound-semiconductor processes this company's disclosed product set does not include.
Neodymium — dropped deliberately, and the one worth re-checking. HDD voice-coil actuators and spindle motors conventionally use NdFeB magnets, and if that holds here it would be a real rare-earth exposure in a policy-sensitive material. But no Toshiba-published document naming a magnet material was found this pass — a targeted search of Toshiba's own domains returned only third-party academic and patent literature on HDD magnet recycling in general. It is recorded here as an open lead rather than asserted. Note for the next pass: the parent dossier (toshiba-corporation.md) does list neodymium on exactly this HDD-actuator reasoning, and its own source list contains no Toshiba document supporting it either — so the two files disagree because the parent's claim is the weaker one, not because the subsidiary missed something. Resolve both together if a Toshiba magnet or responsible-minerals disclosure ever surfaces.
Not assessed — where the output is sold. Toshiba Electronic Devices & Storage is not separately listed and publishes no geographic revenue split of its own, so no sales_geography is recorded. For a company whose enterprise drives and power semiconductors ship into data-centre supply chains spanning the US, China and Europe, destination-side export-control exposure is a live question that this dossier cannot currently answer. Missing, not zero.
Sources
Toshiba Electronic Devices & Storage — company/product overview — MOSFETs, IGBTs/IEGTs, bipolar transistors, diodes, microcontrollers, power-management and motor-driver ICs, linear ICs, logic, linear image sensors, photocouplers/isolators, SiC MOSFETs and SiC Schottky barrier diodes, and the storage product lines
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
Silicon
4Geopolitical: 19 restrictive actions, peak severity 4, 14 in last 24mo
4Concentration: refining HHI 6498 (extreme); top CN 80%
4Substitutability: limited substitutes in electronics/electrical steel
4Import reliance: Eurostat Comext 2025: 63% extra-EU imports, top partner NO 47% (partner HHI 2698)
Helium
5Substitutability: no substitute in cryogenics/MRI and most lifting/leak-detection uses
🇨🇳 CN has issued 2 restrictive actions on Silicon since 2021, severity hardening (3.0 → 4.0).A descriptive trajectory of past official actions — not a forecast.
🇨🇳 CN's demonstrated restriction sequence — has restricted 2 materials since 2021, in this demonstrated order:
You hold exposure to 1 of these 2 materials (Silicon) — your binding Silicon exposure is one of them.
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
🇺🇸 US has historically countered a median of 3.9 months later (n=23 recorded episodes since 2024). Counter-move intensity: median severity 3/5 (3 of 23 via quantified basis).
🇮🇳 IN has historically countered a median of 9.9 months later (n=4 recorded episodes since 2025). Counter-move intensity: median severity 3.5/5 (0 of 4 via quantified basis).
Descriptive history of recorded counter-actions in our causal register — not a forecast; the gap is what the controller's past moves drew in response.
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
when 🇺🇸 US restricts your Helium, 🇪🇺 EU has historically countered (median 21 months later) — and those counter-moves have also restricted Silicon, which you also depend on (n=4 recorded episodes since 2023). Counter-move intensity: median severity 3.5/5, hardest 4/5 (0 of 4 via quantified basis).
Descriptive history of recorded counter-actions in our causal register, intersected with your dependency basket — not a forecast; it shows where a controller's past retaliations have landed across your materials.
The ordered history of what this controller has restricted, each step traced to /actions/{id} — a descriptive sequence, not a forecast.
Type
Scenario
Today
Stressed
Δ
Policy
Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime
77
82
+5
Concentration
Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly)
77
89
+12
Policy
Helium — 🇺🇸 US escalates helium controls to a full export-licensing / ban regime
38
47
+9
Concentration
Helium — 🇺🇸 US becomes the single source for helium — the second source is lost (full 43%+ monopoly)
38
55
+17
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 — 196 levy) — those are FISCAL provisions under the Finance Act; THIS is the regulatory beneficiation-LIST instrument under the Mining Act framework (the official critical/strategic minerals designation that triggers value-addition-plan licensing). Also distinct from filed 2024-11-05-tanzania-written-laws-no-4-2024-mining-act-critical-minerals (that introduced the critical-minerals legal category; this is the operative STRATEGY + LIST that activates the beneficiation-mandate machinery) and from filed 2026-04-15-tanzania-mavunde-40-mineral-licences-revocation. Still in consultation, list not yet gazetted → moderate likelihood; severity 3 expected if the list+value-addition mandate is enacted (export conditionality on graphite/REE/lithium/nickel), severity 2 if it lands as a non-binding strategy only.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Helium🇺🇸 today 38→47+9
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Silicon
If passed — Second wave of CRMA Art. 14 strategic projects (drawn from 160+ applications: 95 EU-domestic + 66 third-country including 40 from strategic-partnership countries) gains fast-track permitting (27-month EU cap, 15-month Member State cap), EIB/EBRD financing-hub priority, and off-taker certainty; 75 battery-value-chain projects + 21 REE-for-permanent-magnets in pool; widens the EU's 2030 extraction/processing benchmarks pipeline beyond the first 60 projects
Caveat — Second call for applications closed January 15, 2026 (September 2025 launch). Commission stated ~4-month assessment period → designation expected May–June 2026. As of 2026-06-15, no Commission press release or OJ publication confirmed. EUR-Lex CELEX 32026D0923 verified via web search to be an unrelated EU animal-disease implementing decision. Moved from filing. md 2026-06-15. Distinct from: 2025-03-25-eu-crma-strategic-projects-first-designation (60 projects, first round) and 2024-05-23-eu-crma-entry-into-force (base regulation). Severity 3 expected (same as first-round designation).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Silicon🇨🇳 today 77→82+5
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Silicon
If passed — Establishes the first legally binding "safe level" benchmark for EU strategic stocks of each of the 17 strategic raw materials listed in the CRMA Annex I; benchmarks used as reference by Member States, financial institutions, and industrial consumers to assess strategic supply risk; mandated every 2 years, so this is the first edition setting the baseline; informs CRMA Art. 23 monitoring obligations and is the evidential basis for Art. 24 corporate-reporting thresholds
Caveat — The May 24, 2026 deadline set by Parliament and Council in Reg. (EU) 2024/1252 has now passed. No OJ publication confirmed as of June 15, 2026 — Commission may have adopted quietly or is overdue. This is the first CRMA Art. 22 benchmark cycle and is legally distinct from: (1) the CRMA base regulation (filed 2024-05-23); (2) the Strategic Projects first designation (filed 2025-03-25); (3) the RESourceEU Amendment — CRMA revision (filed 2026-03-04). If confirmed adopted, severity=2 (establishes the measurement baseline for EU strategic material supply risk assessment and directly feeds corporate Art. 24 reporting obligations). Distinct from all filed EU-CRMA actions. Not in filing. md or upcoming. md.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Silicon🇨🇳 today 77→82+5
🇹🇼 Taiwan proposed comprehensive AI chip export controls on China — MOEA/ITA considering extending SHTC licensing requirements beyond blacklisted entities (Huawei, SMIC) to cover ALL Chinese customers for advanced AI chips and AI servers; would give Taiwanese regulators broader authority to block diversion of AI hardware (NVIDIA-powered servers, advanced AI chips) from Taiwan to China via third-country routing; MOEA stated June 9, 2026 "will continue strengthening oversight of strategic high-tech exports in line with global export-control trends"; discussions between Taiwan and US officials ongoing on controls for advanced chips
announced→low likelihood·flagged 112d ago · not yet law
If passed — If enacted, first Taiwan restriction covering all Chinese customers (not just blacklisted entities); would require Taiwanese OEMs (Foxconn, Pegatron, ASUS, Quanta, Wiwynn), server makers, and component suppliers to seek export licences before any AI hardware shipment to China — affects ~$15-20bn/yr of Taiwan-to-China AI server/component flows; raises costs for Taiwanese firms with significant China revenue
Caveat — Distinct from filed 2025-06-15-taiwan-moea-shtc-entity-list-expansion (Huawei/SMIC-specific, +599 entities) and 2025-11-18-taiwan-moea-ita-shtc-controlled-goods-list-expansion (quantum computers/3D printers). This is a proposed expansion to entity-neutral coverage. Low-to-elevated likelihood: confirmed that US lawmakers pressed Taiwan (2026 defence legislation); Taiwan-US synchronisation pattern well-established (aligned with US BIS controls on China); but MOEA has not publicly announced a formal rulemaking process.
🇹🇼 Taiwan ITA — Dual-Use Export Control List Revision: AI Chips and Advanced Semiconductors Targeting China (June 2026)
in-consultation→moderate likelihood·flagged 107d ago · not yet law
If passed — Taiwan ITA (International Trade Administration, MOEA) launched a 60-day public consultation on planned revisions to the SHTC (Sensitive High-Tech Commodity) controlled-goods export list to add AI chips and advanced semiconductor categories specifically targeting exports to China; if enacted, would extend Taiwan's existing sub-14nm chip / advanced packaging export controls (SHTC list 2025-11-18) to include AI-application chips sold for China use — the measure is designed to align Taiwan's export controls with US BIS advanced-chip restrictions and close the gap on AI server / Nvidia chip diversion from Taiwan to China; Bloomberg June 9, 2026 cites Taiwan authorities "considering much stricter export controls on AI chip sales to China to further align with US measures"; ITA confirmed a 60-day review period for planned revisions; if enacted, would add legal tools to address diversion of AI servers and Nvidia chips through Taiwan to China; affects global AI hardware supply chains and Taiwan-domiciled chip distributors, system integrators, and ODM/OEM assemblers
Caveat — Distinct from 2025-11-18-taiwan-moea-shtc-controlled-goods-expansion (that amendment added quantum computers and advanced semiconductor equipment to the SHTC list — this proposed revision targets AI application chips and AI server hardware for China specifically, different commodity scope and different policy driver); distinct from 2025-06-10-taiwan-moea-shtc-entity-list-huawei-smic (entity list addition, not commodity list revision). Timeline: 60-day review likely closes August 2026; if enacted, new SHTC amendment would take effect Q3/Q4 2026. Likelihood elevated: the ITA has formally initiated the review process and the stated policy driver (US BIS alignment) is official; Taiwan government has consistently tightened SHTC controls in line with US export control strategy since 2022. Filed upcoming 2026-06-20.
If passed — Requires US allies — primarily the Netherlands (ASML) and Japan (Tokyo Electron, Shin-Etsu) — to align their national export controls on advanced semiconductor manufacturing equipment with US BIS restrictions targeting China; strips DoC discretionary licensing authority for chipmaking tools; DUV immersion lithography machines (ASML TWINSCAN NXT series) would face mandatory licensing denial for China-bound sales/servicing; includes anti-circumvention provisions to block third-country re-export through Malaysia, Singapore, or UAE; if enacted, would overturn the bilateral US-Netherlands arrangement on DUV servicing and pressure Japan to expand its April 2023 / January 2024 semiconductor-equipment controls beyond current scope; diplomatic friction: NL Trade Minister Sjoerdsma was in Washington the same week opposing this bill while simultaneously signing Pax Silica
Caveat — Senate bill introduced April 8, 2026 (bipartisan: Risch R-ID, Ricketts R-NE, Kim D-NJ, Schumer D-NY); House companion H. R. 8170 introduced April 2, 2026 (Baumgartner R-WA); House Foreign Affairs Committee passed April 22, 2026 in what HFAC members described as "the largest significant export-control markup in the history of Congress" (20 bills advanced in single markup). Full House and Senate chamber votes still pending as of June 24, 2026. Key contested provision removed pre-committee: country-wide ban on cryogenic etching tool exports — DUV restrictions remain. Administration position unclear — DoC has been resistant to losing licensing discretion; USTR and State potentially prefer diplomatic alignment (Pax Silica model) over binding legislation. If enacted, directly targets ASML NL: estimated ~USD 3–5bn annual China DUV machine revenue at risk. Distinct from: filed 2025-01-15-netherlands-export-control-metrology-inspection-semiconductor (Dutch national expansion, not US law); filed 2024-09-07-netherlands-export-control-expansion-asml-duv-1970i-1980i (Dutch unilateral DUV controls — MATCH Act would mandate further alignment); filed 2025-12-12-us-pax-silica-initiative (non-binding multilateral cooperation — MATCH Act is the binding-legislation complement). If passed, would become the first US law explicitly requiring allied-country export-control harmonisation on semiconductor equipment. Severity 4 expected if enacted.
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 ↗
▲Bipartisan lead sponsors incl. Senate leadership (strong) — S.4281 introduced by Risch (R-ID, SFRC Chair), Ricketts (R-NE), Kim (D-NJ) and Schumer (D-NY, Minority Leader) — cross-party and leadership-level backing raises floor-time odds.source ↗
▲Bicameral — House companion exists (H.R.8170) (moderate) — Rep. Baumgartner (R-WA) introduced the House companion Apr 2, 2026; a live measure in both chambers is further along than a single-chamber bill.source ↗
🇹🇿 Tanzania Finance Bill 2026/27 — NEW raw-mineral EXPORT LEVY on quartz (HS 25.06) and feldspar (HS 2529.10.00) under the Export Tax Act, Cap. 196
awaiting-signature→high likelihood·flagged 99d ago · not yet law·matches Silicon
If passed — The same Finance Bill 2026/27 already tabled (Parliament-passed 23 June 2026, effective 1 July 2026) inserts a NEW export levy of "10% of the FOB value of the cargo OR TZS 200 per kilogram, whichever is higher" on exports of quartz minerals (HS 25. 06) and feldspar (HS 2529. 10. 00) via amendment to the Export Tax Act, Cap. 196 — a distinct beneficiation-forcing EXPORT-TAX instrument that pushes raw quartz/feldspar exporters toward in-country value-addition. 196), and neither existing entry mentions it; (2) material-relevant — quartz HS 25. 06 covers high-purity/silica quartz feeding the silicon→semiconductor/solar value chain, so a Tanzanian export tax re-prices a raw-silica supply node; the same "rocks to riches" beneficiation logic Tanzania applies elsewhere; (3) part of the wider African raw-mineral-export-tax wave (cf. Zimbabwe 10% lithium-concentrate levy, Namibia unprocessed-mineral ban, Guinea bauxite reference price).
Caveat — On enactment, fold into that one TZ Finance Act 2026 action with action_type capturing both the fiscal-incentive and the export-levy (export-control/tariff) provisions; do NOT double-file. Distinct from filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year — no quartz/feldspar export levy). Severity 2 (sectoral raw-mineral export tax, niche HS lines).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Silicon🇨🇳 today 77→82+5
🇨🇳 China unpublished 50% domestic-equipment local-content mandate for new/expanded semiconductor fabs
announced→low likelihood·flagged 93d ago · not yet law
If passed — Reuters (exclusive, multiple sources) reported 31 Dec 2025 that Chinese authorities have been requiring domestic chipmakers to source at least 50% of equipment spend from Chinese toolmakers when applying for approval to build or expand fab capacity — enforced administratively (approval rejected if the threshold isn't met) rather than via any published law or ministry order; strictest on mature-node lines, with temporary carve-outs for advanced-node lithography where local tools don't yet exist; officials reportedly want the floor higher over time, with a stated long-run goal of 100% domestic tooling. Directly squeezes foreign equipment suppliers (Lam Research, Applied Materials, Tokyo Electron, ASML) out of incremental Chinese fab capacity and is already lifting order books at domestic tool makers Naura Technology and AMEC (Naura H1 2025 revenue +30% YoY to RMB16bn; AMEC +44% YoY to RMB5bn). GTA logged this as a state act (state-act/95890) but provides no primary source; no MIIT/NDRC/MOFCOM document, gazette notice, or on-the-record government confirmation has surfaced in any outlet reviewed.
Caveat — Charter §6 verify-or-don't-file: GTA state-act/95890 provides zero primary source (page states only "reportedly mandated," no gov link, no gazette reference) and exhaustive web search (Reuters exclusive + 7 corroborating outlets: Modern Diplomacy, IBS Electronics, ExportComplianceDaily, Seeking Alpha, Stocktwits, Hawaii Tribune-Herald) confirms this is deliberately UNPUBLISHED administrative practice (enforced via approval-rejection, not a public instrument) rather than a not-yet-enacted proposal — it is arguably already in force but structurally opaque, so it does not fit filing. md's primary-source bar. Flagging as upcoming/announced rather than rejecting: multiple independent, well-sourced outlets corroborate a specific, falsifiable mechanism (50% threshold, mature-node-strict/advanced-node-exempt split, approval-rejection enforcement) with observable market effects (Naura/AMEC revenue growth) — this is credible policy, not speculation; likelihood HIGH reflects that the practice already appears to be in effect, with the open question being whether/when a public document ever surfaces to cross the register's verification bar. If no primary source ever emerges, this may need a standing "policy tracked, never promotable" annotation rather than eventual promotion — flag for a future strategy wake. Distinct from all filed CN semiconductor entries (export-control/entity-list actions on the inbound side); this is an outbound-directed, tooling-localisation industrial-policy instrument. Severity 3-4 expected if a primary document surfaces (broad fab-capex-shaping local-content rule); severity_basis would be quant (explicit 50% floor).
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.
▲Organized industry coalition support (weak) — AI Policy Network led a coalition letter backing the MATCH Act — organized outside support, though narrow.source ↗
▼Senate side still in committee (Banking) (moderate) — S.4281 was read twice and referred to Senate Banking, Housing & Urban Affairs; no Senate committee markup or floor calendaring reported as of Jul 2026.source ↗
▼Executive-branch resistance (Commerce) (moderate) — The bill strips DoC discretionary licensing authority; Commerce has been resistant to losing that discretion, and State/USTR may prefer diplomatic alignment (Pax Silica) over binding legislation.source ↗
Sourced OSINT observations, not a forecast — a qualitative second read beside the stage-derived band. We do not publish a passage probability of our own until the accrual record proves it is calibrated (never a fabricated %).