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6 critical materials scored · binding chokepoint: Gallium (🇨🇳 CN 98% of refining) · 17 restrictive government measures on record
5N Plus Inc. produces 4 of the 6 scored materials above (Indium, Tellurium, Germanium, Bismuth). 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 2 (Gallium, Antimony) are 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 2026-10-07) — 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 Gallium — 🇨🇳 CN controls 98% of global refining. On this company's production footprint that scores 82/100 (adversarial chokepoint; global 74). The register holds 17 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Gallium 5N Plus Inc. is the 81st-most-exposed of the 113 named companies we track on 🇨🇳 CN's Gallium chokepoint; the most-exposed is Appia Rare Earths & Uranium Corp. (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 76/100 — 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 (DE 40% · US 25% · CA 15% · CN 12% · LA 8%, 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: Selenium, Cadmium-telluride — no supply-risk series is tracked for these here.
5N Plus is a Montréal-headquartered specialty-metals refiner and compound-semiconductor manufacturer. The group operates one of the very small set of Western integrated supply chains for the minor metals that sit at the heart of Case #1 (the Ga/Ge/Sb/Te/In retaliation architecture): germanium (4N–6N metal, GeO₂, GeCl₄, single-crystal Ge substrates for satellite solar cells and IR optics — the FY2024 AIF lists St. George UT for germanium, and does not list Trail BC or Saint-Genest-Lerpt FR), tellurium and cadmium-telluride (high-purity Te + CdTe sublimation feedstock for thin-film solar, with First Solar as the anchor customer under a multi-year supply agreement), antimony (purified Sb metal, antimony trioxide, antimony triselenide — used in IR detectors, defence munitions, and pharmaceutical flame retardants), bismuth (Bi metal, BiOCl, pharma-grade), indium (In metal, ITO precursor), selenium, and a smaller gallium line.
5N Plus is structurally the only North-American-domiciled pure-play public company simultaneously listed across all five MOFCOM-controlled minor-metals lines (Ge, Ga, Sb, Te, In). Heraeus (private, DE), Indium Corporation (private, US), and Vital Materials (private, CN) are the only peer-set comparators on commercial scale; the integrated Western multi-metal smelters (Aurubis, Glencore Nikkelverk, Boliden, Rio Tinto Kennecott) recover these minor metals as byproduct lines but do not segment them. The Electronic Materials segment (semiconductor wafers and high-purity compounds, including the AZUR SPACE solar-cell subsidiary — sold to Trinasolar/Canadian Solar/First Solar wafer programmes plus defence integrators in US, FR, IL) is the principal revenue concentrator; the Eco-Friendly Materials segment (pharma + animal-health bismuth + recycled tellurium) is the smaller but more margin-stable line.
The group's strategic positioning sits on the producer side of every Case #1 export-control vehicle since 2023-07 AND on the beneficiary side of every Western critical-minerals-stockpile vehicle since 2025-Q4. This is a structurally rare dual exposure.
| Date | Issuer | Type | Severity | Action | Why it touches 5N Plus |
|---|---|---|---|---|---|
| 2023-07-03 | CN | export-control | 4 | MOFCOM Ga/Ge export controls | Anchor of the Case-#1 minor-metals architecture. Routes the Western Ge/Ga supply chain through non-Chinese refiners — 5N Plus Trail BC + St-Genest-Lerpt are two of the shortlist of three commercial-scale producers. |
| 2024-08-15 | CN | export-control | 4 | China MOFCOM antimony export controls (effective Sept-15-2024 — pre-corpus event, not yet in register; see Caveats) | First antimony-targeted ECRA-style licensing regime by Beijing; immediate global Sb spot-price spike of ~75% inside two months. 5N Plus's Sb business line was the largest single beneficiary among listed peers. |
| 2024-10-19 | CN | export-control | 5 | China dual-use export-control regulations | Umbrella State Council regulations operationalising ECRA enforcement. Codifies the legal vehicle through which subsequent minor-metals controls (Dec-2024 country-targeted ban; Feb-2025 W/Te/Bi/Mo/In) are issued. |
| 2024-12-03 | CN | export-control | 5 | MOFCOM Ge/Ga/Sb export ban to US | The single most consequential action for 5N Plus in the corpus. Country-targeted ban (not licensing — outright denial of export licences for US end-use). Directly diverts every US-bound Ge / Ga / Sb order to non-Chinese refiners, of which 5N Plus is one of three. Concurrent with BIS HBM/SME package — see Case #1. |
| 2025-02-04 | CN | export-control | 4 | MOFCOM W/Te/Bi/Mo/In licensing | Extends the minor-metals architecture to 5 of 5N Plus's product lines in one announcement: tellurium (CdTe feedstock), bismuth (pharma), indium (ITO). Plus tungsten and molybdenum (not 5N Plus lines but provides architecture template). |
| 2025-03-20 | US | industrial-policy | 4 | US EO 14241 domestic-mineral-production DPA | Re-armament of DPA Title III for domestic mineral production. 5N Plus has historical DPA Title III germanium-recovery awards (publicly disclosed); this EO institutionalises the financial vehicle. |
| 2025-04-24 | US | industrial-policy | 4 | US EO 14285 offshore-critical-minerals | Companion order to EO 14241; expands the domestic-mineral processing scope. Implicit beneficiary set includes Canadian refiners exporting to US under USMCA. |
| 2025-04-24 | AU | industrial-policy | 4 | Australia critical-minerals strategic reserve | Establishes the strategic-reserve concept later mirrored by Canada (Oct-2025) and the US (Feb-2026). 5N Plus is implicitly a candidate non-domestic supplier to the AU reserve once procurement opens. |
| 2025-10-26 | CN | export-control | 4 | MOFCOM Announcement 68 — STE quota W/Sb/Ag | Hardens the legal vehicle from licensing to state-trading-enterprise quota — a step up the regulatory ladder. Tungsten and antimony move into a 2026-2027 quota framework that institutionalises 5N Plus's antimony economics for ≥24 months. |
| 2025-10-31 | CA | industrial-policy | 4 | Canada DPA critical-minerals stockpile | First Canadian DPA-equivalent stockpile vehicle. 5N Plus is the largest publicly-listed domestic candidate refiner for Ge/Sb/Te/Bi/In; under the Canadian Critical Minerals Strategy this is the structural offtake mechanism. |
| 2025-11-04 | CA | industrial-policy | 3 | Canada Budget 2025 CMETC expansion | Critical Mineral Exploration Tax Credit broadens to processing-stage tax credits — provides a flow-through-share advantage on minor-metals capex; benefits a small refiner like 5N Plus disproportionately versus integrated majors. |
| 2025-11-04 | CA | industrial-policy | 3 | Canada Budget 2025 First-Last Mile Fund | Capital pool for early-stage and late-stage processing infrastructure — exactly 5N Plus's mid-stream-refiner profile; CAD 1.5bn envelope. |
| 2025-11-06 | US | industrial-policy | 3 | US DOI USGS critical-minerals list 2025 | Updated USGS list explicitly names germanium, antimony, indium, tellurium, bismuth. Designation triggers downstream §45X / §232 / DPA Title III eligibility cascades. |
| 2025-12-03 | EU | industrial-policy | 5 | EU RESourceEU Action Plan COM(2025) 945 | Inbound feedstock-floor mechanism for 5N Plus's St-Genest-Lerpt FR plant via EU scrap-export-control regime; symmetric to the analysis surfaced in NDA.DE Aurubis dossier (RESourceEU Al-scrap regime). |
| 2026-01-14 | US | industrial-policy | 4 | US §232 critical-minerals proclamation | PCMDP supply-chain negotiations include germanium, antimony, tellurium, bismuth, indium. 5N Plus is an implicit US-content provider via Canadian USMCA-content qualification on inputs landed in the US. |
| 2026-02-02 | US | industrial-policy | 4 | US EXIM Project Vault strategic critical-minerals reserve | New EXIM-administered offtake-financing vehicle for critical-minerals projects with binding US-side offtake commitments. 5N Plus's Trail BC + Eco-Friendly Materials Montreal lines fit the candidate-project profile precisely. |
| 2026-02-04 | US | industrial-policy | 4 | US State Department FORGE critical-minerals launch | Multilateral co-financing facility (US + UK + JP + AU + KR + EU + CA) — 5N Plus as a Canadian domiciliary is the most-natural FORGE-eligible publicly-listed minor-metals refiner. |
| 2026-03-19 | US/JP | industrial-policy | 4 | US-Japan critical-minerals action plan | Trilateral with Canada implicitly. JOGMEC/JBIC offtake of Western minor-metals capacity is a candidate funding source for 5N Plus's North-American expansion. |
| 2026-04-24 | EU/US | industrial-policy | 4 | EU-US Critical Minerals Strategic Partnership | Bridges the EU CRMA + RESourceEU side to the US PCMDP / Project Vault / FORGE side. 5N Plus is uniquely positioned because it operates plants on BOTH sides (St-Genest-Lerpt FR + Trail BC + Montreal). The only listed peer with the same dual-jurisdiction footprint is Umicore. |
5N Plus is structurally not a candidate for the strategic-alternative analysis that drove the Eramet / Glencore / Rio dossiers — it is a small-cap pure-play with no obvious carve-out shape and no obvious large-asset optionality. The relevant strategic decisions are operational:
1. St-Genest-Lerpt FR capacity uplift versus Trail BC capacity uplift — the EU-US Critical Minerals Strategic Partnership creates an arbitrage on which side of the Atlantic to invest the next dollar of refining capex. The EU side benefits from RESourceEU scrap-export protections; the Canadian side benefits from First/Last Mile Fund and DPA Title III. The structural answer depends on whether the marginal customer is European (CdTe to First Solar India + ITO to Asian display) or North-American (DoD germanium awards + IR-detector primes). 2. Antimony-line capacity expansion ahead of MOFCOM Announcement-68 quota allocations — if Beijing's 2026 quota is at the lower end of analyst expectations, the global ex-China antimony spot premium widens further and 5N Plus's incremental Sb refining margin is gated only on input feed availability. The decision is essentially a feedstock-sourcing problem (recycled Sb from Western e-waste + new-mine offtake from Perpetua Resources Stibnite ID). 3. CdTe long-term-supply renegotiation with First Solar — First Solar's 2026-2028 capacity expansions in Ohio + Alabama + Louisiana + India tighten the supply window; the bargaining position of 5N Plus as the dominant non-China CdTe supplier should improve materially. The contract-renewal cycle is the watch event. 4. Compound-semiconductor wafer line as an integrated upgrade — 5N Plus produces single-crystal germanium substrates; an integrated wafer-finishing line would lift the company up the value chain into direct competition with IQE plc (UK). This is the most-leveraged but most-capital-intensive option.
The highest-leverage open management decision is whether to commit to a multi-year capex programme on St-Genest-Lerpt FR (~CAD 150-300m order of magnitude) before EU CRMA Strategic Projects round-2 designations are announced — early commitment maximises designation probability but pre-commits capital ahead of confirmation. Round-2 disclosure is the structural decision-window pivot.
Three structural reads the equity-research consensus has not priced as of 2026-05-24:
1. The 2024-12-03 country-targeted ban is more durably bullish than the equity narrative suggests. Sell-side has correctly identified that 5N Plus is a beneficiary of the Ga/Ge/Sb supply-chain rerouting, but treats the bullish thesis as having peaked with the initial 2023-07 Ga/Ge licensing and the 2024-12 country-targeted ban. The structural read is that the MOFCOM Announcement-68 STE quota regime (Oct-2025) institutionalises the architecture as a 2026-2027 multi-year arrangement rather than a one-off licensing tightening — quotas are explicitly state-trading-enterprise allocations published annually, which mechanically constrains supply at administrative levels rather than market-clearing prices. Combined with the Russia 2025-11-28 precious-metals-scrap export-ban extension closing the residual Russian byproduct route, the Western antimony/germanium supply floor is structurally elevated through at least 2028. The equity story treats this as a 2024-25 step-change; the structural read is that 2026-27 is the durable plateau, not the reversion phase.
2. 5N Plus is the only publicly-listed company in the corpus simultaneously eligible for the full North-American + European critical-minerals industrial-policy stack. Umicore is the only peer with comparable dual-jurisdiction footprint, but Umicore is structurally an automotive-catalysts business with critical-materials as a secondary line. 5N Plus is the only pure-play small-cap publicly-listed company that is simultaneously: (a) a candidate for the Canadian First/Last Mile Fund (CAD 1.5bn envelope), (b) a candidate for US EXIM Project Vault offtake-financing (2026-02-02 vehicle), (c) a candidate for State FORGE multilateral co-financing (2026-02-04 vehicle), (d) a candidate for EU CRMA Strategic Projects round-2 designation, (e) a candidate for the DPA Title III germanium / antimony / tellurium award cycle, and (f) a beneficiary of the IRA §45X CdTe production credit (passes through First Solar). No other listed company stacks all six. Equity-research models treat each policy vehicle independently; the structural read is that the company is a policy-stack arbitrage portfolio at small-cap scale, and the cumulative pull is non-additive (each new designation lowers the procedural friction for the next).
3. The First Solar / CdTe long-term-supply position is materially less commoditised than equity research models. Sell-side models treat 5N Plus's CdTe revenue as a unit-price × volume calculation against an assumed Te spot benchmark, with margin compression as the long-term operating risk. The structural read is that First Solar's IRA §45X tax-credit eligibility for thin-film modules requires demonstrably non-China-FEoC-tainted CdTe feedstock (per Treasury final regulations on §45X applicability published 2024-10-24), and 5N Plus is one of two scaled non-China CdTe suppliers globally — making the relationship effectively a regulatory-bound bilateral monopsony-monopoly pair within the US §45X eligibility envelope. The IRA §45X CdTe credit is USD 0.07/W of module capacity; this flows to First Solar but the bargaining structure around feedstock sourcing means 5N Plus captures a structurally negotiable share of the credit's economic surplus that is invisible in spot-Te modelling. The structural risk is asymmetric: as of this recheck (2026-08-24), First Solar's own public materials describe cadmium/tellurium separation and refining as still performed by a third party rather than in-house — no confirmed First Solar announcement of in-house Te-refining vertical integration was found on recheck (a prior version of this dossier cited a 2025-09-23 First Solar investor-materials announcement to that effect; that citation could not be verified and has been dropped). If First Solar does move Te-refining in-house, the bilateral structure would weaken; absent that, 5N Plus retains the pricing position through the IRA's full 10-year §45X window.
Refresh quarterly, or whenever a MOFCOM minor-metals announcement, a Canadian or US critical-minerals-policy vehicle, or a 5N Plus capacity-commitment announcement lands. Watch events for the next refresh: (a) MOFCOM Announcement-68 2026 quota allocation publication; (b) EU CRMA Strategic Projects round-2 designations; (c) 5N Plus St-Genest-Lerpt or Trail BC capex commitment; (d) First Solar Te-refining vertical-integration update at the next 10-Q.
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.
5N Plus press release (2025-08-05): CdTe deliveries to First Solar increase 33% for the 2025-2026 contract period versus initial levels, with a further 25% increase for 2027-2028, and 5N Plus begins supplying cadmium selenide (CdSe) to First Solar from 2026. The release credits semiconductor-compound production in Canada and Germany and does not say which First Solar plant (Ohio, Alabama, Malaysia, Vietnam, India) receives it, so the route is unstated. No revenue percentage or dollar figure is disclosed.
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 3 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 |
|---|---|---|---|---|---|---|---|---|---|
| Gallium | 🇨🇳 CN 98% refining | 82 | 74 | High | EXCEEDS 98% | — | ready | 9 | ▲ rising |
| Indium | 🇨🇳 CN 69% refining | 70 | 64 | High | — | Med | limited | 2 | ▲ rising |
| Tellurium | 🇨🇳 CN 80% refining | 68 | 62 | Elevated | — | High | ready | 2 | ▬ stable |
| Antimony | 🇨🇳 CN 78% refining | 66 | 60 | Elevated | — | Med | limited | 9 | ▲ rising |
| Germanium | 🇨🇳 CN 60% refining | 60 | 54 | Elevated | within 60% | High | some | 11 | ▲ rising |
| Bismuth | 🇨🇳 CN 88% refining | 59 | 54 | Elevated | EXCEEDS 88% | High | some | 2 | ▬ stable |
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 |
|---|---|---|---|---|---|---|
| Gallium | 4 | 5 | 3 | 3 | 3 | company input |
| Indium | 4 | 3 | 5 | 3 | 4 | company input |
| Tellurium | 4 | 4 | 3 | 3 | 5 | company input |
| Antimony | 4 | 3 | 1 | 3 | 4 | company input |
| Germanium | 4 | 3 | 1 | 3 | 4 | company input |
| Bismuth | 4 | 4 | 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.
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.
+ 2 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:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Gallium — 🇨🇳 CN escalates gallium controls to a full export-licensing / ban regime | 82 | 85 | +3 |
| Concentration | Gallium — 🇨🇳 CN becomes the single source for gallium — the second source is lost (full 98%+ monopoly) | 82 | 83 | +1 |
| Policy | Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime | 70 | 80 | +10 |
| Concentration | Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly) | 70 | 87 | +17 |
| Policy | Tellurium — 🇨🇳 CN escalates tellurium controls to a full export-licensing / ban regime | 68 | 78 | +10 |
| Concentration | Tellurium — 🇨🇳 CN becomes the single source for tellurium — the second source is lost (full 80%+ monopoly) | 68 | 82 | +14 |
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 2 materials this company buys (the 4 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 (Gallium). The 4 materials 5N Plus Inc. produces (Indium, Tellurium, Germanium, Bismuth) 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 — 2 scored SRMs on the input side (binding: Gallium); 4 further scored SRMs produced, not consumed |
| Manufactures a listed strategic technology | specialty-chemicals-and-materials (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 2026-06-29; 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 2026-10-07
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