4 critical materials scored · binding chokepoint: Tungsten (🇨🇳 CN 90% of refining) · 78 restrictive government measures on record
Subject
TSM · 🇹🇼 TW
Sector
semiconductor-foundry
Materials scored
4
As of
2026-09-30
Risk Office verdict
High · 81/100Company supply-risk index
The binding exposure is Tungsten — 🇨🇳 CN controls 90% of global refining. On this company's production footprint that scores 87/100 (adversarial chokepoint; global 76). The register holds 78 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · TungstenTaiwan Semiconductor Manufacturing Company is the 237th-most-exposed of the 465 named companies we track on 🇨🇳 CN's Tungsten chokepoint; the most-exposed is Elbit Systems (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Company supply-risk index 81/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 4 scored materials. Buyer-relative (first-order): weighted by where the company produces (TW 88% · US 5% · JP 4% · CN 3%, 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.
Also listed in the dossier but not platform-scored: Photoresist, High-purity-quartz — no supply-risk series is tracked for these here.
Disclosed production sites
TW · Tainan Science Park (Fab 18) — leading-edge logic chip fabrication (3nm-class HVM, 8-phase gigafab, ~150k+ WPM by end-2025)
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.
Taiwan Semiconductor Manufacturing Company
What they do
TSMC is the world's largest dedicated semiconductor foundry, with the dominant share at every leading-edge logic node (N3 / N4 / N5 and the upcoming N2 / A16 / A14 generations) and a structurally profitable mature-node automotive / industrial franchise running at 12nm / 16nm / 22nm / 28nm. The business spans three franchises: (1) leading-edge wafer production — N3 family, N5 family, the N2 ramp from 2H-2025, and the A16 / A14 development roadmap through 2027–28; (2) advanced packaging — CoWoS (chip-on-wafer- on-substrate) and SoIC (system-on-integrated-chip), the bottleneck through which every NVIDIA H100 / H200 / B200 / B300 GPU, every AMD MI300X / MI325X / MI355X accelerator, and the lion's share of Apple, Broadcom, Marvell and AWS Trainium AI silicon must flow; (3) mature-node specialty — automotive-grade, industrial, IoT and RF processes increasingly dispersed across Kumamoto (JASM), Dresden (ESMC), Phoenix (TSMC Arizona), Singapore (VSMC JV with Sony / NXP) and Taiwan home fabs. Customer concentration runs through Apple (~25% of revenue), NVIDIA (~20% and rising), AMD, Broadcom, Qualcomm, MediaTek, Marvell, AWS, Intel-product (by foundry win), and a dense tail of fabless silicon vendors.
Material and trade exposures
TSMC's material exposure is structurally similar to ASML's (silicon, photoresist, helium, rare-earth permanent magnets and tungsten in fab construction and tool assemblies) but extends into wafer-scale chemistry that ASML does not consume directly:
Silicon (300mm and 200mm wafer-grade) — sourced from
Shin-Etsu Handotai, SUMCO, Siltronic, GlobalWafers and SK Siltron. Concentrated supply with limited Chinese alternative; the 2024 GlobalWafers-Siltronic merger rejection by Berlin and the subsequent GlobalWafers Arizona greenfield (Sherman, TX) are upstream of TSMC's wafer-input optionality.
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.
Joint NVIDIA/TSMC announcement of the first NVIDIA Blackwell wafer fabricated at TSMC Arizona, October 2025; NVIDIA's own blog describes a 'three decades' manufacturing partnership with TSMC. No dollar volume or revenue-share figure is disclosed in this release. TSMC's own 20-F discloses customer concentration only by anonymized letter (FY2025: largest customer 19%, second 17%, top-ten 78% of net revenue); analyst reporting (wccftech, CNBC) attributes named percentages to Apple and NVIDIA specifically, but both cited pages returned HTTP 403 to automated re-fetch this tick and were not independently confirmed, so no share_pct is recorded against this named row.
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.
The exposure register
Ranked by buyer-relative risk, highest first.
3 of 3 of your scored CRMA-strategic materials 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.
For the conflict-minerals metals among this company's exposures, the named chokepoint refiners that US-listed manufacturers disclose dependence on in their SEC Form SD / Conflict Minerals Reports. This is the peer-disclosed supply base for the material — drawn from 29 US filers' reports — not necessarily this company's own sourcing (which requires its Tier-1 supplier data under Art. 24(3)). It names the specific facilities behind the concentration number.
The named refinersShowHide
Tungsten
China = 54% of filer-disclosed refiner mentions · 291 named refiners
Two independent lenses: USGS official puts China at 90% of global refining output (by tonnage); US filers' own disclosures independently name China for 54% of their refiners (by facility count). Different metrics — both rank China first.
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.
Actions specifically flagged for Taiwan Semiconductor Manufacturing Company
An analyst traced these register actions to a specific, named effect on this company — date and severity below are read live from the register, not hand-typed.
86.5% TSMC ownership; Sony 6%, Denso 6%, Toyota 1.5%. METI funds ~half the construction cost of TSMC's first overseas mature-node fab. Strategic point: this is the template subsidy structure that JASM-Fab2 (Feb-2024) extended and that Czechia, India, Vietnam and Thailand later imitated as semi-state aid converged on the JASM model.
$52bn semis envelope. The direct $6.6bn TSMC Arizona allocation (announced 2024-04-08) plus the ITC was the operational vehicle for TSMC Arizona Phase 1 (N4, opened Dec-2024), Phase 2 (N3, 2H-2025) and the Phase 3 commitment to a 2nm / A16-class node by 2030. Without CHIPS, TSMC Arizona stays at one-fab Phase 1 and the US foundry-presence baseline is materially smaller.
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: 87 → 90(+3) — 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.
The upcoming threatsShowHide
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 66d ago · not yet law·matches Neodymium
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.
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
Tungsten is the line to war-game: 🇨🇳 CN already controls 90% of refining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Neodymium carries 50 restrictive measures on record (🇨🇳 CN 85% of refining) — a secondary escalation candidate.
Silicon carries 19 restrictive measures on record (🇨🇳 CN 80% of refining) — a secondary escalation candidate.
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 (Tungsten).
The mitigation optionsShowHide
Map your real exposure to Tungsten. 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 Tungsten is 🇦🇹 AT (~4% 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. Tungsten 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.
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 — 4 scored SRMs on the input side (binding: Tungsten)
Manufactures a listed strategic technology
semiconductor-foundry (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.
Photoresist — JSR, Tokyo Ohka Kogyo (TOK), Shin-Etsu
Chemical, Sumitomo Chemical, Fujifilm Electronic Materials. Concentration in Japan exposes TSMC to the JP-CN bilateral cycle (see PRC MOFCOM 2026-01-06 country-specific dual-use controls on Japan, action table below). EUV photoresist is a single-digit-supplier market dominated by JSR (Inpria) and TOK; substitution paths are R&D-capacity-limited.
Helium — DUV / EUV laser cooling and inerting consumable.
Same Hugoton / Amur / Ras Laffan concentration as ASML.
motors, vibration dampers and high-vacuum-pump magnetics throughout the toolset. China controls ≥85% of heavy-rare- earth refining; the 2025-10-09 PRC rare-earth extraterritorial control regime and the 2026-01-06 country- specific dual-use action against Japan sit directly upstream. Cross-reference: docs/minerals/materials/neodymium.md.
Tungsten — interconnect via, ALD-precursor and tool
structural use. Subject to the same PRC export-control architecture as the rare earths. Cross-reference: docs/minerals/materials/tungsten.md.
High-purity quartz / fused silica — quartzware for
diffusion furnaces, EUV mask blanks, and photomask substrates. Sub-bottleneck: Spruce Pine (NC) HPQ-3 grade quartz, where the 2024 Hurricane Helene flood disruption was a near-miss for the EUV mask-blank supply chain that hosts every TSMC leading-edge reticle.
*AI-compute exposure on the customer* side, not direct
inputs* — TSMC's compliance perimeter is now defined by what its customers* design. Under the BIS Foundry Due-Diligence IFR (action table below), TSMC has to certify, screen and document the design provenance of every 3A090.a tape-out as a condition of permission to manufacture. That is a material cost-of-doing-business novel to TSMC, not a material exposure in the traditional bill-of-materials sense.
Policy actions touching them (last 24 months)
Rendered live from the register below, driven by this dossier's action_relevance: frontmatter (migrated 2026-08-21, queue #128) — date, severity and severity_basis are read directly from each action's current frontmatter and can never drift from the hand-typed table this replaced.
Pending / discussed actions
Five ongoing processes carry asymmetric TSMC exposure:
BIS Affiliates Rule re-armament (Nov 2026). The one-year
suspension under the Busan understanding lapses by default. TSMC's customer-screening perimeter has to be re-armed on day one across the ≥50%-owned affiliate tree of every Entity-Listed parent.
FDD-IFR compliance deadline (Dec 2026). The extension above
is a one-time extension. The Dec-2026 deadline arrives in the middle of the Phase 2 (N3) Arizona ramp and the JASM-Fab2 qualification — i.e., TSMC has to operationalise foundry-side customer KYC at exactly the moment two new overseas fabs come online.
**Wassenaar 2025 round / EU Delegated Reg successor (late
2026)**. Successor to 2025/2003 expected to add High-NA EUV pellicle reticle masks, pattern-generator metrology, ALD precursors. TSMC's Dresden ESMC qualification window overlaps.
EU Chips Act 2.0 review (announced 2026). Demand-side
procurement mechanism + Strategic-Project status proposals. Material option on Dresden ESMC funding upsize.
Taipei outbound-screening secondary legislation. The
Executive Yuan implementing rules under Article 22 / 67-3 are to be issued by MOEA. Specifications of the "designated countries / regions" and "specific industries or technologies" triggers will determine the operational scope of Taipei's screening lever over TSMC's overseas capex.
Strategic alternatives
Five credible adjustment paths under further policy stress:
**Accelerate Arizona Phase 3–5 to leading edge (2nm / A16 /
A14)**. The Section 232 carve-out, the ART direct-investment pledge, and the CHIPS Act ITC together create a structural duty / tax preference for US-fabricated leading-edge dies bound for US hyperscalers. Pulls forward the 2030 schedule toward 2028 if the customer base agrees. Trade-off: pulls Hsinchu's bleeding-edge talent pool to Phoenix faster than Taipei's Article 10-2 retention ITC is designed to allow — a politically sensitive item.
Lean on JASM Kumamoto for automotive-grade mature-node.
Sony's CMOS image-sensor co-investment locks in a 12nm / 16nm demand floor at JASM-2 that is hard to replicate elsewhere. This is the strategic comfort node of the overseas portfolio even though the press attention is on bleeding-edge migration.
Dresden ESMC as the EU-dual-use-controlled outpost. ESMC
is designed for automotive / industrial nodes serving Bosch / Infineon / NXP first-party demand — i.e., a European demand floor analogous to JASM's Japanese one. The EU Chips Act 2.0 review may upsize the funding envelope; pending.
**Maintain Taipei-side R&D and leading-edge equipment
concentration**. Article 10-2's 25% R&D and 5% equipment ITC is the explicit retention instrument. TSMC's revealed preference (R&D centres in Hsinchu / Nanke; 1.4nm / 1nm pathfinder at Nanke Fab18 / Fab20) suggests the ITC is doing what it was designed to do.
Until 2024 all CoWoS happened in Taiwan; in 2025 TSMC announced CoWoS pilot lines at Arizona and JASM-2. Given the Section 232 carve-out, Arizona CoWoS for NVIDIA / AMD / AWS customers becomes structurally preferred. Trade-off: yield ramp in Phoenix at advanced packaging is harder than at wafer-fab — Arizona's CoWoS first-year yield will be the operational signal to watch.
The biggest open management decision is Arizona Phase 4 timing: whether to commit to a leading-edge (2nm / A16 / A14) Phase 4 ramp in 2028 vs the original 2030 schedule. The Section 232 carve-out, the ART direct-investment pledge, and the FDD-IFR's Phoenix- routing operational preference all argue for acceleration. The Article 22 / 67-3 outbound-screening regime in Taipei argues for caution — every outbound capex tranche has to be MOEA-approved, and MOEA has political reasons to slow the dispersal of leading- edge capacity even when the economic logic favours it. The revealed cadence of MOEA approvals on TSMC Arizona Phase 3 is the single highest-leverage signal of how aggressively the overseas portfolio can scale.
How this dossier is maintained
Refreshed quarterly by default, or on any of: (a) a new IPTM- registered action by US BIS, EU DG TRADE, Japan METI, Taiwan MOEA / Legislative Yuan or Korea MOTIE / Ministry of Trade with target_sectors including semiconductors, advanced-packaging or ai-compute; (b) a PRC MOFCOM rare-earth, tungsten or country-specific dual-use control update; (c) a TSMC capital- allocation or roadmap event (Arizona phase commitment, JASM-Fab3, Dresden ramp, 2nm / A16 / A14 cadence); (d) movement in the FDD-IFR / Affiliates Rule / Section 232 calendar; (e) any Executive Yuan implementing-rule publication under Article 22 / 67-3 outbound investment screening. Re-write triggers the last_refreshed field above and a new entry in the §Sources section below.
[docs/intelligence/dossiers/asml.md](./asml.md) — ASML Holding NV (the upstream litho-equipment counterpart; many actions above appear in both dossiers from different angles — ASML as the controlled-tool supplier, TSMC as the controlled-IC manufacturer)
Company disclosures (primary — to be cited inline as the dossier is extended; this v1 deliberately stays on policy actions as the spine):
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
Tungsten
4Geopolitical: 16 restrictive actions, peak severity 5, 10 in last 24mo, less 2 liberalising actions
4Concentration: refining HHI 8126 (extreme); top CN 90%
5Price / market: price up, as of 2026-09-01
Neodymium
4Geopolitical: 50 restrictive actions, peak severity 5, 35 in last 24mo, less 4 liberalising actions
4Concentration: refining HHI 7306 (extreme); top CN 85%
5Price / market: price up, as of 2026-10-05
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
The October-2022 BIS rule forces TSMC to refuse any tape-out from a Chinese-headquartered fabless customer at advanced nodes for AI-compute end uses, and to disclose 3A090 production to BIS. This is the architectural rule that makes TSMC's compliance perimeter a *legal* perimeter, not a *commercial* one.
25% R&D ITC + 5% advanced-process equipment ITC on Taiwan-resident spend. **Non-obvious read:** this is Taipei's *retention* lever — it structurally biases TSMC toward keeping the most-advanced-node R&D and the most-advanced-node equipment installation in Hsinchu / Nanke / Zhongke even as fab capacity disperses to Phoenix / Dresden / Kumamoto. The mature-node migrates abroad; the bleeding edge stays home.
Demand-side underwriter for the ESMC Dresden JV (TSMC 70%, Bosch / Infineon / NXP 10% each, fab opens 2027 at €10bn capex of which ~€5bn German state aid). Net read: turns TSMC's first-ever European fab from a single-customer JV into a state-co-financed strategic asset.
Second tranche covering JASM's Fab-2 (6nm / 7nm / 12nm / 16nm, opens 2027). **Non-obvious read on the JASM pair:** while bleeding-edge press attention concentrates on Phoenix and Dresden, JASM is the *mature-node automotive franchise* that quietly funds capex amortisation at trailing nodes Phoenix and Dresden don't address. Sony's CMOS image-sensor co-investment makes JASM the only TSMC overseas fab with a built-in 12nm-grade IDM-equivalent demand floor — every iPhone front and rear camera goes through this fab's reticles.
**The single most-under-read action on TSMC in the register.** Creates the "Authorized IC Designer" / "Approved IC Designer" regime, requires front-end-fabricator (i.e. TSMC) reporting on every 3A090.a IC produced for an authorised designer, and imposes a presumptive red-flag on any 3A090.a tape-out not on the approved list. This is *foundry-side* KYC at customer level — a compliance program TSMC had to stand up from scratch through 2025. The April-2026 extension (next row) is direct evidence that the program isn't fully operational yet.
The named-perpetrator counterpart to the FDD IFR above. Sophgo had taped out at TSMC the dies that allegedly ended up in Huawei Ascend 910B / 910C. The Entity List action is BIS putting the operational vehicle ("you have to identify these specific entities and refuse their tape-outs") next to the structural rule. **Reading the two 16-Jan-2025 actions as a unit** is the critical non-obvious surface for any TSMC investor model.
**Second highest-leverage non-obvious surface.** First-ever Taiwanese outbound-investment screening regime. MOEA prior-approval gate for outbound investment > NTD 1.5bn or into designated countries / sectors; NTD 50k–10m enforcement penalties under the new Art. 67-3. **For TSMC this is Taipei's lever over Arizona / Dresden / Kumamoto capex velocity** — every outbound capex deployment now requires MOEA sign-off. The sell-side narrative tracks the *inducement* side (CHIPS Act + JASM subsidies + EU Chips Act); almost nobody is modelling the *constraint* side at home.
GP10 declares that all ECCN 3A090 ICs designed by PRC-headquartered firms — Huawei Ascend 910B / 910C / 910D explicitly named — are presumptively EAR-violative, with use / transfer / financing / servicing *anywhere in the world* a presumptive GP10 violation. **Direct TSMC angle:** the Ascend 910B/C dies that triggered this rule were taped out at TSMC under the Sophgo shell — TechInsights' teardown matched the die to a TSMC-fabricated design ordered by Sophgo, TSMC halted shipments to Sophgo in Oct-2024, and the Commerce Department opened an export-control investigation into TSMC over the shipments (Reuters reported a potential penalty exceeding $1bn). *Correction (2026-08-24 verify): no "Commerce OIG record" naming TSMC could be located — that was this dossier's prior overstatement of a citation that doesn't exist; the accurate description is an open Commerce/BIS export-control investigation plus press reporting, not an Inspector General finding.* The rule is the legal architecture that makes TSMC's downstream-customer due-diligence a permanent perimeter rather than a one-off cleanup.
Taiwan's own Strategic High-Tech Commodities export-control list expanded to ~10,844 entities. **Why this matters for TSMC specifically:** the SHTC list is administered by MOEA-ITA at home, separate from BIS. For SHTC-listed items, TSMC needs *Taiwanese* export licences, not (just) US re-export licences. That gives Taipei direct unilateral leverage over what TSMC ships, separately from any US negotiation. The 18-Sep-2025 +279-entity expansion and the 18-Nov-2025 18-item commodity-list expansion extended the regime to advanced 3D printers, SME, electron microscopes and quantum-computing hardware — i.e., advanced-packaging-relevant categories.
Indirect for TSMC (TSMC's only Mainland fabs at Songjiang and Nanjing run mature nodes, not VEU-relevant). The structural read for TSMC is *bargaining-asymmetry*: the rule narrows non-Taiwanese advanced-node capacity in China, and the relative scarcity reinforces TSMC's leading-edge pricing power outside China.
Adds lithography systems, EUV pellicles / masks / reticles, ALD, epitaxial deposition, SEM, etch under EU dual-use control. Read for TSMC: Dresden ESMC will be operating inside the EU-dual-use perimeter from day one (fab opens 2027). Compliance burden front-loaded into the construction phase.
KYC perimeter for every TSMC customer expands materially. **One-year suspension via Busan understanding ends Nov-2026** — calendar event TSMC's compliance function has to be ready for.
The Japan-targeted vehicle threatens TSMC's photoresist supply line (JSR, TOK, Shin-Etsu, Sumitomo, Fujifilm), Nd / Dy / Sm permanent-magnet supply chain for tool stages, and any Japan-routed advanced-equipment second-source. If the same vehicle pivots to Taiwan (the obvious escalation path), TSMC's bill-of-materials exposure is direct.
Narrowly drawn to H200 / MI325X-tier devices. **Non-obvious operative provision:** the exemption for chips going into US data centres / US R&D / US repairs creates a *structural duty preference for TSMC Arizona output over TSMC Taiwan output* for any NVIDIA / AMD / Broadcom AI accelerator going into a US hyperscaler. This is a Phoenix-routing inducement disguised as a national-security tariff.
Competitor-baseline signal: Korea's per-fab subsidy intensity becomes the new comparator point for METI's next JASM upgrade, BIS's next 48D(c) extension, and EU Chips Act 2.0. Not direct for TSMC but moves the negotiation goalposts everywhere TSMC's overseas fabs operate.
**Locks in TSMC Arizona Phases 3–5.** The USD 250bn Taiwan-enterprise direct-investment pledge + USD 250bn Taiwan-government credit-guarantee pledge for US-side advanced-semis industrial parks is the headline financing vehicle for what becomes a TSMC Arizona mega-cluster (six fabs through 2030 per the 2024-04 commitment). The IEEPA reciprocal-tariff cut from 20% → 15% is favourable but secondary; the investment-pledge subclause is the binding structural change.
Pushes the FDD-IFR compliance deadline from 13 Apr 2026 → 31 Dec 2026 (with a subsequent 180-day authorisation runway). **The deadline extension is itself a TSMC-specific signal:** BIS doesn't extend a 15-month compliance window unless the regulated industry isn't ready. TSMC (the largest foundry under the rule) is the dominant determinant of "ready". Translation: the FDD-IFR compliance program at TSMC's customer-screening level is still being built.
🇨🇳 CN has issued 4 restrictive actions on Tungsten since 2025 — cadence accelerating (mean gap 264d → 103d), severity flat (4.0 → 4.0).A descriptive trajectory of past official actions — not a forecast.
🇨🇳 CN's demonstrated restriction sequence — has restricted 31 materials since 2021, in this demonstrated order:
You hold exposure to 3 of these 31 materials (Silicon, Neodymium, Tungsten) — your binding Tungsten exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 3.7 months apart across 8 distinct restriction dates since 2021 (n=7 intervals).
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 🇨🇳 CN restricts your Tungsten, 🇺🇸 US has historically countered (median 3.8 months later) — and those counter-moves have also restricted Neodymium, which you also depend on (n=16 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 of 16 via quantified basis).
when 🇨🇳 CN restricts your Neodymium, 🇺🇸 US has historically countered (median 2.6 months later) — and those counter-moves have also restricted Tungsten, which you also depend on (n=4 recorded episodes since 2025). Counter-move intensity: median severity 4/5, hardest 4/5 (1 of 4 via quantified basis).
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
Tungsten — 🇨🇳 CN escalates tungsten controls to a full export-licensing / ban regime
87
90
+3
Concentration
Tungsten — 🇨🇳 CN becomes the single source for tungsten — the second source is lost (full 90%+ monopoly)
87
91
+4
Policy
Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime
84
87
+3
Concentration
Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly)
84
91
+7
Policy
Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime
76
81
+5
Concentration
Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly)
76
88
+12
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 — 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)
Neodymium🇨🇳 today 84→87+3
🇹🇿 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 Neodymium, 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.
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)
Neodymium🇨🇳 today 84→87+3
Helium🇺🇸 today 38→47+9
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 98d ago · not yet law·matches Neodymium
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)
Neodymium🇨🇳 today 84→87+3
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 108d ago · not yet law·matches Neodymium
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)
Neodymium🇨🇳 today 84→87+3
🇪🇺 EU CRMA Strategic Projects — Second Designation Round
in-consultation→moderate likelihood·flagged 112d ago · not yet law·matches Neodymium, 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)
Neodymium🇨🇳 today 84→87+3
Silicon🇨🇳 today 76→81+5
🇨🇩 DRC Strategic Mineral Reclassification Decree — 6 new minerals (lithium, tantalum, niobium, tungsten, uranium, REEs) elevated to strategic tier, royalty 3.5%→10%
passed-vote→high likelihood·flagged 113d ago · not yet law·matches Tungsten, Neodymium
If passed — Royalty near-triples on Manono lithium project (Zijin Mining/La Cominière, DRC's first industrial lithium mine commissioning June 2026) and all DRC tantalum, niobium, tungsten, uranium, REE operators; reprices extraction economics across the entire DRC critical-mineral portfolio
Caveat — Council of Ministers adoption confirmed late May 2026 (Bloomberg May 31 2026: "Congo Triples Royalty Rate on Lithium With New Strategic Minerals Decree"; Zoom Eco June 1: "6 nouveaux minerais rejoignent la liste des substances stratégiques"; Jeune Afrique confirmed). Modifies décret n°18/042 of 24 November 2018. DRC gov websites unreachable as of 2026-06-14: mines. gouv. cd times out, gouvernement. cd times out, jocc. cd ENOTFOUND, primature. gouv. cd only shows 2020 content — formal text not yet accessible online. Moved from filing. md 2026-06-14. Secondary: https://africa. com/drc-moves-to-tax-lithium-as-a-strategic-mineral/
If passed & escalated to a full control regime — modelled impact (high likelihood)
Tungsten🇨🇳 today 87→90+3
Neodymium🇨🇳 today 84→87+3
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 114d ago · not yet law·matches Tungsten
If passed — Mandates 15% free-carried interest for Uganda National Mining Company (UNMC) in all new mining licences; introduces mandatory mineral buying centres; tightens local-content and value-addition obligations — changes joint-venture economics for all new Ugandan mining operations, raising effective cost-of-entry for foreign miners
Caveat — Amends the already-filed Uganda Mining and Minerals Act 2022 (UG action 1); expected to be enacted before end of 2025/26 parliamentary session per legal commentary; Bank of Uganda gold purchase programme and new mineral buying centres already being piloted — regulatory infrastructure being built ahead of formal enactment. Distinct from filed Uganda Gold Export Regulations 2024 (SI No. 30 of 2024).
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Tungsten🇨🇳 today 87→90+3
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Neodymium, Silicon, Tungsten
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.
awaiting-signature→high likelihood·flagged 112d ago · not yet law·matches Neodymium
If passed — Framework agreed "in principle" between Trump and Xi following June 5, 2026 call and subsequent negotiations; Trump stated June 11, 2026 "Our deal with China is done, subject to final approval with President Xi and me" — China to supply "full magnets, and any necessary rare earths, up front" to US; if formally enacted, would suspend or ease China's April 2025 rare earth export licensing regime (filed 2025-04-04-china-mofcom-rare-earth-export-licensing) for US-bound shipments; China's Vice Commerce Minister Li Chenggang confirmed "in principle" framework consensus from the June 5 Trump-Xi call; tariff framework: US 55% / China 10%; China April 2025 rare earth controls (heavy/medium REEs, including Dy/Tb NdFeB magnets, SmCo magnets) remain formally active — no MOFCOM suspension announcement found as of June 15, 2026; the deal is political but not yet implemented as a formal regulation or bilateral MOU
Caveat — Distinct from filed 2025-11-09-china-mofcom-announcement-72 (which suspended October 2025 US-targeted controls but left April 2025 REE licensing in place). Distinct from filed 2025-04-04-china-mofcom-rare-earth-export-licensing (April 2025 seven-REE licensing, which this deal may eventually suspend/amend). If formally enacted, this represents a structural easing of the most consequential REE supply-risk action in the register. Severity estimate: 3 if enacted (direct re-routing of ~$3–5bn/yr US rare earth magnet imports; reshapes REE concentration score for US/China interdependence axis).
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 84→87+3
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 109d ago · not yet law·matches Neodymium
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)
Neodymium🇨🇳 today 84→87+3
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 101d ago · not yet law·matches Neodymium
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)
Neodymium🇨🇳 today 84→87+3
🇹🇿 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 76→81+5
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 101d ago · not yet law·matches Neodymium
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)
Neodymium🇨🇳 today 84→87+3
🇪🇺 EU Permanent-Magnet Scrap & Waste Export Restriction
announced→low likelihood·flagged 100d ago · not yet law·matches Neodymium
If passed — Under the RESourceEU action plan (COM(2025) 945, adopted 3 Dec 2025 and already filed as 2025-12-03-eu-resourceeu-action-plan-com-2025-945), the European Commission committed to PROPOSE, by Q2 2026, restrictions on the export of scraps and waste of permanent magnets — an essential feedstock for European NdFeB recyclers that is increasingly shipped abroad (notably to China). Recycling could meet ~20% of the EU's ~20,000 t/yr permanent-magnet demand, so retaining end-of-life and pre-consumer magnet scrap in the EU is framed as a supply-security measure to reduce China dependence. Accompanying measures: a new EU-level Combined Nomenclature sub-code + European Waste Catalogue entry to identify/track permanent magnets and EoL products containing them, plus a targeted CRMA amendment on product-labelling and pre-consumer-waste recycling. If enacted as a binding export restriction this would be the EU's first outbound control on a critical-mineral waste stream — directly relevant to anyone in the EU/China REE-magnet recycling loop, and a mirror-image to China's REE/magnet export controls (re-prices intra-bloc vs ex-bloc scrap flows). The European recycling industry (BIR) has publicly warned the measure risks market distortion, so adoption/scope is contested.
Caveat — As of 2026-06-27 (end of Q2) no formal proposal or regulation has been located — still at the action-plan-commitment stage, hence axis-2/upcoming not filing. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella plan announcing the intent — this item tracks the specific export-restriction instrument that the plan promised), from filed 2026-03-04-eu-council-crma-general-approach-resourceeu (Council general approach on the CRMA amendment), and from the EU dual-use export-control regime (2021-821 / 2025-2003). Distinct from the US-China REE deal (line 78) and EU CRMA strategic-projects round (line 58). Severity 2-3 if enacted (first EU outbound control on an REE waste stream; re-prices the EU↔China magnet-scrap loop).
If passed & escalated to a full control regime — modelled impact (low likelihood)
Neodymium🇨🇳 today 84→87+3
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 100d ago · not yet law·matches Neodymium, Tungsten
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)
Neodymium🇨🇳 today 84→87+3
Tungsten🇨🇳 today 87→90+3
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 67d ago · not yet law·matches Neodymium, Tungsten
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)
Neodymium🇨🇳 today 84→87+3
Tungsten🇨🇳 today 87→90+3
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Neodymium
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)
Neodymium🇨🇳 today 84→87+3
🇲🇬 Madagascar — Council of Ministers lifts 16-year moratorium on new mining-permit issuance (except gold), effective ~29 Jan 2026
passed-vote→high likelihood·flagged 53d ago · not yet law·matches Neodymium
If passed — Madagascar's Council of Ministers approved resumption of mining-permit issuance on ~28-29 Jan 2026, ending a moratorium in place since 2010 (imposed during a political transition amid mining-title speculation). Roughly 1,650-3,000 pending permit applications accumulated during the freeze can now be processed — Mining Cadastre Bureau (BCMM) confirmed first-come-first-served processing with a maximum 3-month target for first issuances. Covers nickel, cobalt, graphite, rare earths, mineral sands/ilmenite, bauxite, sapphire, quartz and mica; GOLD remains explicitly excluded pending further review. Legal basis: implementation of the 2023 mining code (Loi n°2023-007, promulgated 27 Jul 2024) following mining-cadastre cleanup. SUPPLY-RELIEF — opens Madagascar's graphite (6 large projects, ~3% of global production / 8% of global reserves), nickel-cobalt (Ambatovy) and rare-earth potential to new entrants after a 16-year freeze; MG is currently one of the thinnest countries in the register (2 prior actions) despite this graphite/nickel relevance.
Caveat — ENACTED (Cabinet approved, permits already being processed per BCMM statements) but parked here rather than filing. primature. gov. mg returned a self-signed-certificate error on direct fetch, and app. primature. gov. mg's Conseil des Ministres listing did not surface a January 2026 session in the portion fetched. Same park-lot convention as the Malawi entry above and the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines earlier in this file. Dedup: action-index has only 2 Madagascar actions total, neither about the permit moratorium. Severity 3 expected — moratorium lift affects licensing for nickel/cobalt/graphite/REE projects nationwide.
If passed & escalated to a full control regime — modelled impact (high likelihood)
Neodymium🇨🇳 today 84→87+3
🇲🇦 Morocco Mining Code Amendment — National Commission for Strategic and Critical Minerals + strategic-minerals designation list
in-consultation→moderate likelihood·flagged 31d ago · not yet law·matches Neodymium
If passed — Draft law amending Morocco's 2015 Mining Code (led by the Ministry of Energy Transition and Sustainable Development, Minister Leila Benali), with public consultations reported open since ~Feb 2025. Three structural changes: (1) a National Commission for Strategic and Critical Minerals empowered to designate an official list of "strategic and critical minerals" — Morocco's first formal legal mechanism to do so, which would sit upstream of and interact directly with the phosphate chokepoint (Morocco holds ~70% of world phosphate-rock reserves via OCP); (2) the digital mining cadastre (governance/transparency layer — this component has ALREADY gone live, launched 2026-04-07, and is queued separately to filing. md as an enacted action); (3) sharply increased penalties for illegal mining/prospecting (unauthorised prospecting: MAD 100k-1m; illegal extraction/transport/sale: up to MAD 2m). Morocco is chokepoint-tier and thinly covered (only 4 prior MA actions: 2022 Investment Charter, an AfDB agriculture loan, the 2026 Loi de Finances, and a Feb-2026 mining-tender notice — none creates a minerals-designation regime).
Caveat — distinct from the already-filed 2026-04-07 digital-cadastre launch (enacted, queued to filing. Dedup: no MA action in the index covers a strategic-minerals designation commission or mining-code amendment; the 3 other MA entries (Investment Charter 2022, Loi de Finances 2026, Feb-2026 mining tender) are distinct instruments.
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
Neodymium🇨🇳 today 84→87+3
🇮🇳 India–Myanmar rare-earths cooperation — elevated to formal bilateral agenda at Modi–Min Aung Hlaing summit
announced→low likelihood·flagged 29d ago · not yet law·matches Neodymium
If passed — At Myanmar military-government head Min Aung Hlaing's early-June-2026 New Delhi visit (his first India visit since the 2021 coup), critical minerals and rare earths featured explicitly on the formal bilateral agenda for the first time — India's Foreign Secretary Vikram Misri confirmed both sides "agreed to stay in touch" on critical minerals/rare earths and "take cooperation forward. " This is India seeking an alternative heavy-rare-earth source (Kachin State/Wa State artisanal mining, currently ~all exported to China) amid China's 2025 rare-earth export controls. No formal supply contract, MOU, or binding mineral-cooperation instrument has been signed — this is government-to-government dialogue only, elevated from background technical talks to official summit-agenda status. Analysts place realistic commercial-scale sourcing in the 2028-2035 window, contingent on Kachin conflict resolution and connectivity infrastructure. Chokepoint-tier (MM heavy rare earths, only 4 prior MM actions in the index, all domestic Myanmar mining/export regulation — none touching an India bilateral angle).
Caveat — Dedup: no existing IN or MM action in filing. md/upcoming. md/action-index covers India-Myanmar rare-earth cooperation (checked "india. *myanmar" across all three — only hit was an unrelated DPIIT Press Note 2/2026 land-border-FDI action that separately still requires prior approval for Myanmar-domiciled investors). Distinct from the 3 filed Myanmar domestic actions (Wa State tin suspension/restart licensing, MOC Notification 93/2024, KIO rare-earth regulation) which are host-country supply-side instruments, not this demand-side sourcing-diversification angle. Severity 1-2 while at dialogue stage.
If passed & escalated to a full control regime — modelled impact (low likelihood)
Neodymium🇨🇳 today 84→87+3
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.