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2 critical materials scored · binding chokepoint: Graphite (🇨🇳 CN 85% of refining) · 28 restrictive government measures on record
The binding exposure is Graphite — 🇨🇳 CN controls 85% of global refining. On this company's production footprint that scores 88/100 (adversarial chokepoint; global 77). The register holds 28 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Graphite VisBlue is the 25th-most-exposed of the 207 named companies we track on 🇨🇳 CN's Graphite chokepoint; the most-exposed is Leading Edge Materials (Norra Kärr) (88/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
VisBlue ranks 2nd of 67 verified battery companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 8 further battery 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 85/100 — 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 (DK 60% · DE 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.
> The exposure report this dossier powers is at > /intelligence/dossiers/visblue/report.
VisBlue A/S is a Danish/Portuguese spinout from Aarhus University and the University of Porto (founded 2014 by Adelio Mendes, Anders Bentien, Morten Madsen and Søren Bødker), based in Aarhus, Denmark. It manufactures vanadium redox flow batteries (VRFBs) for long-duration, stationary renewable-energy storage — final system assembly and integration happens at the Aarhus HQ, with the electrochemical "stack" units (the core power-conversion component) supplied under a framework agreement by J. Schmalz GmbH of Glatten, Germany since 2020. VisBlue markets a "SMARTflow" control layer that schedules charge/discharge cycles against weather forecasts and grid prices. It is a small company (~12 employees) and is, per its own marketing, the only Danish battery producer specialising in vanadium redox flow technology.
mechanism is a vanadium-sulphate electrolyte cycled across four oxidation states (V2+/V3+/V4+/V5+) in two tanks — vanadium is not a minor input but the active energy-storage medium itself, so exposure is total rather than incidental. VisBlue's own materials page notes vanadium is sourced either as a byproduct of iron-ore slag processing or via direct chemical extraction — both routes are geographically concentrated (China, Russia, South Africa dominate primary vanadium supply), leaving a small assembler like VisBlue a price-taker with no vertical integration or long-term contracted supply disclosed.
graphite-polymer composite; graphite is subject to Chinese export-licensing controls on graphite-related items (in force since Dec-2023), and China dominates global natural and processed-graphite supply, so this is a genuine upstream concentration risk for the Schmalz-built stacks even though VisBlue itself does not import graphite directly.
copper, aluminium) have been removed: VRFB chemistry has no lithium-ion cell and none of these appear in VisBlue's or Schmalz's public materials disclosures for the stack/system.
/insight/vanadium-redox-flowbattery page cited previously now 404s at origin.2026-09-09 (Step 3.8 top-up): added one named counterparty, J. Schmalz GmbH (supplier of the electrochemical stack units), sourced to Schmalz's own account of the framework agreement. No other claims re-opened this pass — sourcing and production footprint were already re-checked on 2026-09-07.
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.
J. Schmalz GmbH (Glatten, Germany) supplies VisBlue's electrochemical stack units under an exclusive Scandinavia framework agreement since 2020; confirmed on Schmalz's own account of the deal and corroborated by Batteries News trade press.
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.
1 of 1 of your scored CRMA-strategic material 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 |
|---|---|---|---|---|---|---|---|---|---|
| Graphite | 🇨🇳 CN 85% refining | 88 | 77 | Critical | EXCEEDS 85% | Med | hard | 27 | ▲ rising |
| Vanadium | 🇨🇳 CN 79% refining | 75 | 64 | High | — | High | limited | 3 | ▲ 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 |
|---|---|---|---|---|---|---|
| Graphite | 4 | 4 | 5 | 4 | 4 | company input |
| Vanadium | 4 | 4 | 5 | 4 | 2 | 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.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 13 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:
Counterfactual: Indonesia extends the hilirisasi ore-ban template (2020 nickel → 2023 bauxite) to the next rung of battery-mineral exports — tightening upstream supply for cobalt intermediates, lithium feedstock and graphite alongside the existing nickel + aluminium regime. Direct-hit lines are basket issuers whose binding material is a battery-cell input (nickel, cobalt, lithium, graphite) — irrespective of controller, since the template-export is global supply-chain pressure not bilateral targeting.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 88 → 92 (+4) — a relative official policy-pressure magnitude, not a price drawdown.
🇨🇳 CN has issued 5 restrictive actions on Graphite since 2023 — cadence accelerating (mean gap 360d → 129d), severity flat (4.5 → 2.3).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 1 of these 7 materials (Graphite) — your binding Graphite exposure is one of them.
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 | Graphite — 🇨🇳 CN escalates graphite controls to a full export-licensing / ban regime | 88 | 92 | +4 |
| Concentration | Graphite — 🇨🇳 CN becomes the single source for graphite — the second source is lost (full 85%+ monopoly) | 88 | 94 | +6 |
| Policy | Vanadium — 🇨🇳 CN escalates vanadium controls to a full export-licensing / ban regime | 75 | 84 | +9 |
| Concentration | Vanadium — 🇨🇳 CN becomes the single source for vanadium — the second source is lost (full 79%+ monopoly) | 75 | 88 | +13 |
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.
This assessment identifies 1 significant vulnerability — Graphite — each a High/Critical exposure that is hard to substitute and already under at least one in-force restrictive measure. This engages the duty under Art. 24(4) to take mitigating efforts, including assessing diversification of the supply chain or substitution of the material (see Priority mitigations below).
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, 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 (Graphite).
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 — 2 scored SRMs on the input side (binding: Graphite) |
| Manufactures a listed strategic technology | battery (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 2026-08-06; 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.