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6 critical materials scored · binding chokepoint: Dysprosium (🇨🇳 CN 99% of refining) · 55 restrictive government measures on record
USA Rare Earth, Inc. produces 5 of the 6 scored materials above (Dysprosium, Terbium, Gallium, Neodymium, Praseodymium). 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 (Boron) 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 Dysprosium — 🇨🇳 CN controls 99% of global refining. On this company's production footprint that scores 95/100 (adversarial chokepoint; global 88). The register holds 55 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Dysprosium USA Rare Earth, Inc. is the 30th-most-exposed of the 271 named companies we track on 🇨🇳 CN's Dysprosium chokepoint; the most-exposed is TdVib (95/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
USA Rare Earth, Inc. ranks 15th of 448 verified mining metals companies, tied with 2 others at 89.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 127 further mining metals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 89/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 6 scored materials. Buyer-relative (first-order): weighted by where the company produces (US 60% · GB 40%, 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/usa-rare-earth/report.
USA Rare Earth, Inc. (Nasdaq: USAR), headquartered in Stillwater, Oklahoma, describes itself as "building a fully integrated rare earth and permanent magnet supply chain across the United States, United Kingdom, and Europe" — a mine-to-magnet model rather than a mine alone. Its operating centre is a 310,000 sq ft magnet plant in Stillwater making sintered neodymium-iron-boron (NdFeB) permanent magnets; commissioning of production Line 1a (1,200 t/yr) began in Q1 2026, with full-scale capacity of roughly 3,600 t/yr and a stated ambition of 10,000 t/yr.
Upstream of the magnet plant it owns Less Common Metals Ltd (Ellesmere Port, UK), a manufacturer of specialised rare-earth metals and cast and strip-cast alloys — the metal-and-alloy step that sits between separated oxide and a finished magnet. It also controls the Round Top deposit near Sierra Blanca in Hudspeth County, Texas, a heavy-rare-earth and gallium resource, and in March 2026 agreed to acquire Texas Mineral Resources Corp in an all-stock deal to consolidate 100% economic ownership of Round Top under one operator. The company's about page additionally names a Brazilian asset (Pela Ema) and planned future operations in France.
Round Top is not in production. Commercial production is targeted for 2028 under the company's Accelerated Mining Plan, brought forward roughly two years on the strength of solvent-extraction pilot work. Everything Round Top contributes to this profile is a prospective supply position, not current output — and the Stillwater plant is itself still commissioning, so the group's only fully operating production asset today is the UK alloy business.
USAR is unusual in this register because its exposure runs in both directions at once, and the two directions have opposite signs. Today it is a buyer of separated rare-earth feedstock — precisely the Chinese-dominated input its investment case exists to displace. From 2028, if Round Top delivers, it becomes a producer of some of the same elements. The producer-tagged entries below therefore describe an output position that is largely prospective, not booked revenue.
is the mass constituent of every sintered NdFeB magnet the Stillwater plant makes and of the alloys Less Common Metals casts. This is the company's core material by tonnage in both roles; nothing about the business survives a sustained NdPr supply interruption. The chokepoint is separation and metallisation capacity, which remains heavily concentrated in China, and it binds on the purchasing side today regardless of what Round Top does later.
substitute*. Heavy rare earths added to NdFeB (increasingly by grain-boundary diffusion rather than bulk alloying) to hold coercivity at elevated temperature — the property that makes a magnet usable in a traction motor or a defence actuator. They are a few percent or less of magnet mass but there is no performance-equivalent substitute, and heavy-REE separation is more concentrated than light-REE separation. Round Top is a heavy-REE deposit, so these are also the elements where USAR's prospective mine position and its current purchasing exposure overlap most directly.
Named in the company's own SEC exhibit element list for Round Top. Gallium matters here because it is subject to active export-licensing control by China, which dominates primary production; a domestic gallium co-product stream is a large part of Round Top's strategic pitch. Recorded as a prospective supply position with a 2028 target, not as production.
boron is roughly one percent of magnet mass, but it is the element that forms the Nd₂Fe₁₄B tetragonal phase the whole magnet class depends on, so it cannot be designed out the way a coating or a binder could. Tagged consumer — USAR buys ferroboron as an input and has no boron production. Lower supply-risk salience than the rare earths, listed for completeness of the magnet bill-of-materials rather than as a chokepoint.
Not carried, and why. Third-party project databases report contained beryllium and lithium at Round Top from the 2019 resource estimate, and trade press has described it as the largest US beryllium source — but the company's own current element list for the deposit omits both, and its Accelerated Mining Plan is a heavy-REE-plus-gallium plan. Asserting Be and Li as exposures would credit USAR with product lines it is not itself currently claiming, so they are dropped pending the Round Top pre-feasibility study. Samarium is dropped as unsupported by any company source. Yttrium, gadolinium, hafnium, erbium, thulium, lutetium, ytterbium, holmium and zirconium are company-named at Round Top but are not scored materials on this platform (verified against the current SCORED_MATERIALS list this pass), so they cannot appear as scored exposures — their absence below reflects our coverage, not their absence from the deposit.
Ranked by buyer-relative risk, highest first.
5 of 6 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 |
|---|---|---|---|---|---|---|---|---|---|
| Dysprosium | 🇨🇳 CN 99% refining | 95 | 88 | Critical | EXCEEDS 99% | Low | none | 51 | ▲ rising |
| Terbium | 🇨🇳 CN 99% refining | 93 | 84 | Critical | EXCEEDS 99% | Low | limited | 51 | ▲ rising |
| Gallium | 🇨🇳 CN 98% refining | 88 | 74 | Critical | EXCEEDS 98% | Low | ready | 9 | ▲ rising |
| Neodymium | 🇨🇳 CN 85% refining | 86 | 72 | Critical | EXCEEDS 85% | High | some | 50 | ▲ rising |
| Praseodymium | 🇨🇳 CN 85% refining | 85 | 72 | Critical | EXCEEDS 85% | High | some | 48 | ▲ rising |
| Boron | 🇹🇷 TR 64% mining | 36 | 36 | Low | within 64% | Low | some | 1 | ▲ 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 |
|---|---|---|---|---|---|---|
| Dysprosium | 4 | 5 | 5 | 5 | 3 | company input |
| Terbium | 4 | 5 | 5 | 4 | 3 | company input |
| Gallium | 5 | 5 | 3 | 3 | 3 | company input |
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Praseodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Boron | 3 | 3 | – | 3 | – | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
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.
+ 40 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, these disclosed plants carry the binding Dysprosium exposure:
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
The binding exposure this precedent lands on — Dysprosium — is a material USA Rare Earth, Inc. produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-05) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 4 restrictive actions on Dysprosium since 2024 — cadence accelerating (mean gap 483d → 152d), severity flat (3.5 → 3.5).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 5 of these 28 materials (Gallium, Neodymium, Dysprosium, Praseodymium, Terbium) — your binding Dysprosium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 5.7 months apart across 8 distinct restriction dates since 2023 (n=7 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Dysprosium — 🇨🇳 CN escalates dysprosium controls to a full export-licensing / ban regime | 95 | 96 | +1 |
| Concentration | Dysprosium — 🇨🇳 CN becomes the single source for dysprosium — the second source is lost (full 99%+ monopoly) | 95 | 95 | 0 |
| Policy | Terbium — 🇨🇳 CN escalates terbium controls to a full export-licensing / ban regime | 93 | 94 | +1 |
| Concentration | Terbium — 🇨🇳 CN becomes the single source for terbium — the second source is lost (full 99%+ monopoly) | 93 | 93 | 0 |
| Policy | Gallium — 🇨🇳 CN escalates gallium controls to a full export-licensing / ban regime | 88 | 90 | +2 |
| Concentration | Gallium — 🇨🇳 CN becomes the single source for gallium — the second source is lost (full 98%+ monopoly) | 88 | 89 | +1 |
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 factors we could score (2 of 5 inputs unrated across the materials bought). Absence of data is not evidence of low risk — an unrated factor enters the score as zero, not as an estimate, so this conclusion could change once those inputs are rated. The mitigations below are precautionary.
Reported separately (not an Art. 24(4) trigger): Dysprosium clears the same numeric bar but is a material USA Rare Earth, Inc. produces. That is an output-market concentration — relevant to revenue and to counterparties who buy from this company — not an input dependency the company must mitigate under Art. 24(4).
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 5 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
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 (Boron). The 5 materials USA Rare Earth, Inc. produces (Dysprosium, Terbium, Gallium, Neodymium, Praseodymium) are 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: Boron); 5 further scored SRMs produced, not consumed |
| Manufactures a listed strategic technology | mining-metals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-30; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-06
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.