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4 critical materials scored · binding chokepoint: Silicon (🇨🇳 CN 80% of refining) · 110 restrictive government measures on record
The binding exposure is Silicon — 🇨🇳 CN controls 80% of global refining. On this company's production footprint that scores 77/100 (adversarial chokepoint; global 64). The register holds 110 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Silicon Wallbox N.V. is the 303rd-most-exposed of the 839 named companies we track on 🇨🇳 CN's Silicon chokepoint; the most-exposed is aerodyn Engineering GmbH (77/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Wallbox N.V. ranks 58th of 181 verified electronics companies, tied with 8 others at 75.
Company supply-risk index 75/100 — 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 (ES 57% · US 35% · DE 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.
The exposure report this dossier powers is at /intelligence/dossiers/wallbox/report.
Wallbox N.V. (NYSE: WBX) is a Barcelona-headquartered manufacturer of electric-vehicle charging hardware and energy-management software. Its product line spans home/workplace AC chargers (Pulsar Plus, Commander 2, Copper), the Quasar and Quasar 2 bidirectional (V2H/V2G) DC home chargers, and the Supernova DC fast-charging line for commercial and fleet sites. It also co-offers a scalable Battery Energy Storage System (BESS) built on partner Pramac's battery packs, paired with its DC fast chargers. Per its FY2025 20-F, Wallbox manufactures chargers in Barcelona (Zona Franca, ~389k/yr capacity), Arlington, Texas (~241k/yr) and Lauf an der Pegnitz, Germany (~56k/yr), with component plants in Tangier, Morocco and Sant Boi de Llobregat (PCBs). Shanghai is an office.
The material rows below are sector inference: the FY2025 20-F does not name these materials.
through copper windings, high-current busbars, and heavy-copper PCB power planes; copper is the largest metal input by mass across the charger range.
bidirectional Quasar/Quasar 2 and the Supernova DC fast chargers rely on silicon and wide-bandgap (silicon-carbide/GaN) power semiconductors for the AC-DC and DC-DC inverter stages — foundry-dependent components with concentrated supply.
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.
Wallbox's Battery Energy Storage System (BESS) is a co-branded product built on Pramac battery packs; neither product page states the cell chemistry. Wallbox does not manufacture the cells itself.
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 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 |
|---|---|---|---|---|---|---|---|---|---|
| Silicon | 🇨🇳 CN 80% refining | 77 | 64 | High | EXCEEDS 80% |
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 |
|---|---|---|---|---|---|---|
| Silicon | 4 | 4 | 1 | 4 |
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.
Two independent lenses: USGS official puts China at 55% of global refining output (by tonnage); US filers' own disclosures independently name China for 28% of their refiners (by facility count). Different metrics — both rank China first.
| Refiner | Country | US filers naming it | Source |
|---|---|---|---|
| China Tin Group Co., Ltd.CID1070 | China | 20 | SEC |
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.
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: 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: 77 → 82 (+5) — a relative official policy-pressure magnitude, not a price drawdown.
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, 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.
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 (Silicon).
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) |
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 — 4 scored SRMs on the input side (binding: Silicon) |
| Manufactures a listed strategic technology | electronics (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.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 26 further electronics 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.
alloy) is used throughout the charger's control and power-electronics boards — small by mass but present in every unit.
partnered offering built on Pramac's battery packs (chemistry not stated), packs, not cells Wallbox manufactures itself; the lithium exposure sits in a co-branded storage product rather than Wallbox's core charger bill-of-materials.
| — |
| limited |
| 19 |
| ▲ rising |
| Lithium | 🇨🇳 CN 65% refining | 72 | 61 | High | within 65% | Low | some | 40 | ▲ rising |
| Copper | 🇨🇳 CN 48% refining | 68 | 59 | Elevated | within 48% | — | limited | 52 | ▲ rising |
| Tin | 🇨🇳 CN 55% refining | 66 | 56 | Elevated | — | — | ready | 18 | ▲ 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 ↗
| 4 |
| company input |
| Lithium | 4 | 3 | 5 | 3 | 3 | company input |
| Copper | 4 | 2 | 5 | 4 | 3 | company input |
| Tin | 4 | 2 | 5 | 2 | 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.
| PT Mitra Stania PrimaCID1453 | Indonesia | 18 | SEC |
| Gejiu Kai Meng Industry and Trade LLCCID942 | China | 18 | SEC |
| PT ATD Makmur Mandiri JayaCID2503 | Indonesia | 17 | SEC |
| PT Prima Timah UtamaCID1458 | Indonesia | 17 | SEC |
Source: US SEC Form SD / Conflict Minerals Report exhibits (EDGAR full-text search), aggregated from RMI smelter tables. “US filers naming it” = distinct US-listed companies whose most-recent CMR names that refiner — disclosure-derived presence, not verified throughput. Link opens the SEC exhibit.
+ 95 more in the register.
🇨🇳 CN has issued 2 restrictive actions on Silicon since 2021, severity hardening (3.0 → 4.0).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 3 of these 15 materials (Copper, Silicon, Lithium) — your binding Silicon exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 13.8 months apart across 7 distinct restriction dates since 2016 (n=6 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 | Silicon — 🇨🇳 CN escalates silicon controls to a full export-licensing / ban regime | 77 | 82 | +5 |
| Concentration | Silicon — 🇨🇳 CN becomes the single source for silicon — the second source is lost (full 80%+ monopoly) | 77 | 89 | +12 |
| Policy | Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime | 72 | 78 | +6 |
| Concentration | Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly) | 72 | 91 | +19 |
| Policy | Copper — 🇨🇳 CN escalates copper controls to a full export-licensing / ban regime | 68 | 74 | +6 |
| Concentration | Copper — 🇨🇳 CN becomes the single source for copper — the second source is lost (full 48%+ monopoly) | 68 | 93 | +25 |
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.
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 ↗
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — 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.
| 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.