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2 critical materials scored · binding chokepoint: Magnesium (🇨🇳 CN 86% of refining) · 16 restrictive government measures on record
A verification pass re-checked this dossier's ownership/corporate-structure fields against their cited sources. It did not re-read the material_exposures claim the score, band and stress figures below are built on — treat those as not yet independently re-checked.
Ust-Kamenogorsk Titanium-Magnesium Plant JSC produces 1 of the 2 scored materials above (Titanium). For those, a supply restriction by the controlling country is a tailwind, not a headwind — the exposure is to disruption of a market this company supplies, not to a chokepoint it depends on. The remaining 1 (Magnesium) is genuine buyer dependencies and drive the mitigations below. The two sides are reported separately and never netted against each other.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-05) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Magnesium — 🇨🇳 CN controls 86% of global refining. On this company's production footprint that scores 63/100 (neutral exposure; global 63). The register holds 16 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Magnesium Ust-Kamenogorsk Titanium-Magnesium Plant JSC is the 53rd-most-exposed of the 63 named companies we track on 🇨🇳 CN's Magnesium chokepoint; the most-exposed is Leonardo S.p.A. (75/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Ust-Kamenogorsk Titanium-Magnesium Plant JSC ranks 56th of 98 verified metals refining companies, tied with 1 other at 62.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 39 further metals refining companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 62/100 — 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 (KZ 100%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
> The exposure report this dossier powers is at > /intelligence/dossiers/uktmp/report.
UKTMP JSC is Kazakhstan's sole titanium producer, operating a single vertically integrated titanium-magnesium complex at Öskemen (Ust-Kamenogorsk) in East Kazakhstan. Its output is titanium sponge, titanium ingots/slabs and alloys, and magnesium (grade Mg-90). It produced about 19,000 t of titanium sponge in 2024 (up from 16,000 t in 2023) and sold roughly 12,000 t of titanium products in 2025 on revenue of about 87 billion tenge (~US$179M).
Its customer list is the aerospace primes and the titanium mill-product majors — Boeing, Airbus, Safran, Rolls-Royce, TIMET, Howmet Aerospace, Dynamet, PCC and POSCO — with exports to Switzerland, France, Japan, the United Kingdom and the United States. Kazakhstan's prime minister has put Kazakh titanium at roughly 20% of the global aerospace titanium market; a separate industry figure gives UKTMP about 18% of world titanium sponge supply. A new sponge plant under UKTMP's investment programme is intended to add 10,000 t/y of capacity.
UKTMP is an upstream producer, so its exposure runs the opposite direction from most dossiers in this register: it is a source of these materials rather than a buyer facing input denial. Its risk sits on the supply, export-policy and feedstock side — the same framing the corpus applies to other upstream refiners (see chambishi-copper-smelter.md).
to produce titanium sponge and downstream ingot/slab/alloy, at roughly 19,000 t/y of sponge. This is a genuine global chokepoint position: aerospace-qualified titanium sponge has few producers, qualification of a new source takes years, and UKTMP supplies a double-digit share of it to Boeing, Airbus, Safran and Rolls-Royce. Concentration risk here is about the world's dependence on UKTMP, not UKTMP's dependence on the world.
UKTMP in two distinct ways, which is why the plant carries it in its name. It is the reductant consumed by the Kroll process — titanium sponge is made by reducing titanium tetrachloride with liquid magnesium — and it is also a sold product in its own right (grade Mg-90). The Kroll loop makes titanium output and magnesium handling physically inseparable, so a magnesium disruption is a titanium disruption. Note that global magnesium supply is itself heavily China-concentrated, making this the one exposure where UKTMP is genuinely on the buyer side of a chokepoint.
Dropped from the sector default: silver, copper, nickel, tin and antimony. These are the metals-refining sector template's generic assignment; no UKTMP or reputable third-party source located this pass attributes any of them to this plant, which is a titanium-magnesium operation rather than a polymetallic base-metal or precious-metal smelter. Dropped rather than guessed.
Not asserted (deliberately): aluminium and vanadium. UKTMP is sourced as producing titanium "ingots and alloys", and the dominant aerospace titanium alloy (Ti-6Al-4V) carries ~6% aluminium and ~4% vanadium — but no source located this pass names the specific alloy grades UKTMP melts, so recording those two would be an inference about grade mix dressed as a fact. Re-check if UKTMP publishes a product-grade catalogue.
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.
Panjiva free supplier page, sample US bill of lading dated 2025-09-23: shipper 'Ust Kamenogorsk Titanium And' (Titanium Magnesium Combine, Ust Kamenogorsk, Kazakhstan), consignee 'Rmi Titanium Company Llc', 1000 Warren Av (Niles, Ohio; Howmet Aerospace titanium mill), 34,200 kg in 120 drums, shipment origin Kazakhstan, HTS 8108.20 (unwrought titanium incl. sponge) and 8108.90, ocean carrier ONE, vessel CMA CGM Fidelio, lading Antwerp, unlading Newark, destination Port of Cleveland, BoL ONEYANRF22496601. Further RMI BoLs listed 2025-09-23 and 2025-09-18. UKTMP's only plant is Oskemen, Kazakhstan; RMI is Howmet's Niles OH titanium operation.
Panjiva free supplier page lists a US bill of lading dated 2025-09-18 with shipper Ust Kamenogorsk Titanium Magnesium Plant JSC and customer 'Timet' (product text masked; page top HTS codes 8108 titanium). Quantity and US port not shown on the free page. UKTMP's only plant is Oskemen, Kazakhstan; TIMET melts imported sponge at its US plants (Henderson NV, Morgantown PA, Toronto OH).
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
2 of 2 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Magnesium | 🇨🇳 CN 86% refining | 63 | 63 | Elevated | EXCEEDS 86% | Med | none | 2 | ▲ rising |
| Titanium | 🇨🇳 CN 70% refining | 59 | 59 | Elevated | EXCEEDS 70% | High | limited | 14 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Magnesium | 3 | 4 | 3 | 5 | 3 | company input |
| Titanium | 4 | 3 | 1 | 4 | 4 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 1 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Magnesium exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Magnesium — 🇨🇳 CN escalates magnesium controls to a full export-licensing / ban regime | 63 | 78 | +15 |
| Concentration | Magnesium — 🇨🇳 CN becomes the single source for magnesium — the second source is lost (full 86%+ monopoly) | 63 | 72 | +9 |
| Policy | Titanium — 🇨🇳 CN escalates titanium controls to a full export-licensing / ban regime | 59 | 63 | +4 |
| Concentration | Titanium — 🇨🇳 CN becomes the single source for titanium — the second source is lost (full 70%+ monopoly) | 59 | 75 | +16 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold. 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 1 material this company buys (the 1 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
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 (Magnesium). The 1 material Ust-Kamenogorsk Titanium-Magnesium Plant JSC produces (Titanium) is excluded from these buyer levers — see the role check in the verdict and the significant-vulnerability conclusion above.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | Yes — 1 scored SRM on the input side (binding: Magnesium); 1 further scored SRM produced, not consumed |
| Manufactures a listed strategic technology | metals-refining (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-05-07; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-05
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.