Geopolitical Supply-Risk Report·EU CRMA Art. 20–25 assessment·MacroLens · CiconiaLabs

Yunnan Tin Company Limited

5 critical materials scored · binding chokepoint: Silver (🇲🇽 MX 24% of mining) · 69 restrictive government measures on record

Subject

000960.SZ · 🇨🇳 CN

Sector

metals-refining

Materials scored

As of

2026-09-30

Ownership re-checked · exposure claims not re-checked since fill

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.

Risk Office verdict

Low · 39/100Exposure claims not re-checked since fillCompany supply-risk index · consumer-side read

Role check · this company is a producer, not a buyer

Yunnan Tin Company Limited produces 5 of the 5 scored materials above (Silver, Indium, Copper, Tin, Zinc). 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. Every scored material here sits on its output side, so the Low · 39/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.

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 Silver — 🇲🇽 MX controls 24% of global mining. On this company's production footprint that scores 43/100 (neutral exposure; global 43). The register holds 69 restrictive government measures touching this company's materials — each traced to its primary source below.

Peer rank · Silver Yunnan Tin Company Limited is the 148th-most-exposed of the 331 named companies we track on 🇲🇽 MX's Silver chokepoint; the most-exposed is Omron Corporation (43/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.

Competitor cohort · metals refining

Yunnan Tin Company Limited ranks 94th of 98 verified metals refining companies, tied with 1 other at 39.

85🇨🇦 Neo Performance MaterialsDysprosium
84🇬🇧 Pensana PlcDysprosium
83🇬🇷 Sidenor Steel Industry SAManganese
82🇬🇧 FerroglobeManganese
82🇨🇿 Třinecké železárny, a.s.Manganese
82🇩🇪 Vital Pure Metal Solutions GmbHGallium
81🇸🇰 OFZManganese
80🇺🇸 Allegheny Technologies Incorporated (ATI)Tungsten
79🇰🇷 Korea Zinc Co., Ltd.Gallium
79🇨🇿 Nová Huť (formerly Liberty Ostrava a.s.)Manganese
78🇯🇵 Mitsubishi Steel Mfg. Co., Ltd. (Mitsubishi-lineage specialty steel and automotive springs)Manganese
78🇰🇷 POSCO Holdings Inc.Graphite
77🇺🇸 Carpenter Technology CorporationManganese
77🇺🇸 Cleveland-Cliffs Inc.Manganese
39🇨🇳 Yunnan Tin Company LimitedSilver

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 39/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 5 scored materials. Buyer-relative (first-order): weighted by where the company produces (CN 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

CN · Gejiu (Honghe), Yunnan — Dachun/Laochang/Kafang mines and tin, copper smelting — tin, copper and zinc concentrates; refined tin, cathode coppertincopperzincindium
CN · Wenshan, Yunnan — Dulong mine and zinc-indium smelter — zinc and indium smelting, die-cast zinc alloyzincindium
CN · Chenzhou, Hunan — tin smeltingtin

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.

Yunnan Tin Company Limited

The exposure report this dossier powers is at /intelligence/dossiers/yunnan-tin/report.

What they do

Yunnan Tin Company Limited (SZ: 000960) is the core listed smelting subsidiary of Yunnan Tin Group (YTC), headquartered in Gejiu, Yunnan province — a tin mining district worked since 1883. YTC is the world's largest refined-tin producer: it has held the top spot in global tin production and sales since 2005, and its ~80,100 tonnes of 2023 output represented roughly a quarter of China's tin supply and about half of the world's. The group runs the full chain from exploration, mining and ore dressing through smelting and downstream tin-chemical processing, and recovers several other metals as byproducts of its polymetallic tin/zinc/copper ore base.

Critical-material exposure

Tin (primary output, bulk producer) — YTC's core business and the

world's largest source of refined tin (~half of global supply). Tin is the standard solder metal for electronics and semiconductor packaging with no scale substitute, and China's smelting dominance (YTC alone accounts for a large share) concentrates a metal that's also seeing rising demand from EV power electronics and 5G infrastructure buildout.

Indium (major byproduct, not a trace credit) — YTC states its indium

reserves rank first in the world alongside tin. Indium is recovered from the same polymetallic ore refining stream and is essential for indium tin oxide (ITO) transparent electrodes used in displays, touchscreens, and thin-film photovoltaic cells; global indium refining is concentrated in a handful of Chinese smelters, of which YTC is one of the largest.

Copper (byproduct, standing product line) — cathode copper is a listed

YTC product recovered from its polymetallic ore, not a marginal credit. Global copper supply is more geographically diversified than tin or indium, so this is a lower-concentration exposure than the company's core tin/indium business, but it is a genuine production line.

Zinc (byproduct, standing product line) — zinc ingots are a standing

YTC output. Zinc supply is comparatively diversified globally, making this the lowest-risk exposure among YTC's refined metals.

Silver (byproduct, precious-metal credit) — silver ingots are a

disclosed byproduct output of YTC's polymetallic refining, smaller in scale than the tin/indium/copper/zinc lines but a genuine, recurring output rather than an incidental trace.

Named counterparties (added 2026-08-10)

Source for this entire section: Yunnan Tin Co., Ltd. (锡业股份) FY2025 annual report, filed with Shenzhen Stock Exchange via cninfo 2026-03-30 — static.cninfo.com.cn/finalpage/2026-03-30/1225043582.PDF (§(8) 主要销售客户和主要供应商情况, p.30; §十四重大关联交易, pp.70-71). Reporting period: FY2025 (year ended 2025-12-31). Confidence: primary-source (audited annual report). Do not present these as "current" — they are the FY2025 position.

The headline finding: no third-party counterparty is named

Yunnan Tin names only intra-group entities. Every arm's-length customer and supplier is anonymized as 客户2-5 / 供应商2-5 with amounts but no names. This is a real structural result, not an access failure — the world's largest refined-tin producer discloses zero third-party buyer names, so the tin/indium offtake chain is not reachable through this lane. It is reachable, if at all, only buyer-side (customs, importer jurisdiction) — see lane 2.

Because the single named counterparty on each side is the parent, the headline concentration ratios overstate arm's-length concentration by roughly half:

FY2025 metric	Reported	of which related-party	arm's-length residual
Top-5 customers, % of annual sales	32.80% (¥14.279bn)	16.29%	16.51%
Top-5 suppliers, % of annual procurement	42.98% (¥16.582bn)	29.33%	13.65%

The arm's-length residual column is arithmetic on the two disclosed figures, not a reported number — labelled as derived. On that basis Yunnan Tin's genuine third-party concentration is modest: no single outside customer exceeds 7.95% of sales, and no single outside supplier exceeds 6.65% of procurement.

Anonymized non-related-party ranks, verbatim:

Customers: #2 ¥3.461bn / 7.95%, #3 ¥1.872bn / 4.30%, #4 ¥999.6m / 2.30%, #5 ¥854.0m / 1.96%
Suppliers: #2 ¥2.566bn / 6.65%, #3 ¥1.029bn / 2.67%, #4 ¥848.7m / 2.20%, #5 ¥820.3m / 2.13%

Customers — named (all intra-group)

Rank 1 is 云南锡业集团（控股）有限责任公司 Yunnan Tin Group (Holding) Co., Ltd. ("Yuntin Holding", the controlling shareholder's parent) at ¥7,092,301,719.99 = 16.29% of FY2025 sales. The filing states this is an aggregate rolled up from commonly-controlled subsidiaries, and names the constituents. The related-party table breaks them out (原始单位万元 converted to ¥; "% of same-type transactions" is the filing's own 占同类交易金额的比例):

Named customer (Chinese legal name)	English rendering	FY2025 sales	% of same-type	Notes
云南锡业新材料有限公司	Yunnan Tin New Materials Co., Ltd.	¥4.071bn	11.11%	product sales
云南锡业锡化工材料有限责任公司	Yunnan Tin Tin-Chemical Materials Co., Ltd.	¥2.020bn	5.51%	product sales; exceeded its ¥1.700bn approved cap
云南锡业集团物流有限公司	Yunnan Tin Group Logistics Co., Ltd.	¥708.5m	1.93%	product sales
云南锡铟实验室有限公司	Yunnan Tin-Indium Laboratory Co., Ltd.	¥3.62m	0.01%	lease income only

These four sum to ¥6.80bn against the ¥7.092bn aggregate; the filing's own totals reconcile exactly (related-party sales 709,230.17万元 = ¥7.0923bn), which cross-validates that the rank-1 "customer" is the group roll-up and not a single operating buyer.

Suppliers — named (all intra-group)

Rank 1 is again Yuntin Holding at ¥11,317,222,438.31 = 29.33% of FY2025 procurement (reconciles exactly to the filing's related-party purchase total of 1,131,722.23万元). Constituents:

Named supplier (Chinese legal name)	English rendering	FY2025 purchases	% of same-type	What is supplied
云南锡业集团（控股）有限责任公司	Yunnan Tin Group (Holding) Co., Ltd.	¥6.176bn	14.07%	raw materials & fuel, spares, transferred water/power, repairs, leases; exceeded its ¥6.138bn approved cap
云锡澳大利亚TDK资源公司	Yuntin Australia TDK Resources Co.	¥2.434bn	5.55%	raw-material procurement (原料采购); exceeded its ¥2.090bn approved cap by ~16%
云南锡业集团物流有限公司	Yunnan Tin Group Logistics Co., Ltd.	¥1.984bn	4.52%	materials/fuel, equipment, spares, handling, freight, warehousing
云南锡业新材料有限公司	Yunnan Tin New Materials Co., Ltd.	¥220.7m	0.50%	raw-material procurement
云南锡业锡化工材料有限责任公司	Yunnan Tin Tin-Chemical Materials Co., Ltd.	¥176.9m	0.40%	raw-material procurement
云南锡业集团有限责任公司	Yunnan Tin Group Co., Ltd. (controlling shareholder)	¥188.7m	0.43%	raw materials & fuel, spares, utilities, repairs, leases
云南锡业建设集团有限公司	Yunnan Tin Construction Group Co., Ltd.	¥109.6m	0.25%	engineering construction & installation (not a material input)

The one genuinely chokepoint-relevant line here is 云锡澳大利亚TDK资源公司 — an Australia-domiciled group entity supplying ¥2.434bn of raw material into the Chinese smelter, 5.55% of total procurement, and the only named foreign-domiciled node in the entire disclosure. It ran ~16% over its board-approved related-party cap in FY2025, i.e. feedstock through the Australian channel grew faster than planned. The filing does not describe the underlying asset or the material, and this dossier does not infer one. Confidence: primary-source for the flow and the amount; the nature of the upstream asset is unverified.

Trading-book counterparties — disclosed but wholly anonymized

Trading revenue (贸易业务) exceeded 10% of FY2025 revenue, triggering a separate disclosure. Every name is withheld:

Top-5 trade customers: ¥3.966bn total (#1 ¥1.377bn, #2 ¥835.7m, #3 ¥609.5m, #4 ¥586.8m, #5 ¥557.6m)
Top-5 trade suppliers: ¥6.064bn total (#1 ¥3.323bn, #2 ¥1.292bn, #3 ¥628.1m, #4 ¥507.2m, #5 ¥312.7m)

Note the asymmetry: the trading book buys ¥6.06bn from its top five and sells ¥3.97bn to its top five — a materially more supplier-concentrated book (#1 trade supplier alone is larger than the entire top-5 trade customer #1-#3 combined).

Indium: a new JV vehicle, June 2025

The filing discloses a capital increase into 云南锡铟实验室有限公司 (Yunnan Tin-Indium Laboratory Co., Ltd.), approved at the 9th board's 3rd extraordinary meeting on 2025-06-12 and completed (including business-registration change) before period end: Yunnan Tin (000960) injected ¥120m cash, Yuntin Holding ¥30m, and Yunnan Tin New Materials ¥120m. Post-increase shareholding is Yuntin Holding 40% / Yunnan Tin 30% / New Materials 30%. Stated purpose is R&D coordination. Given this dossier's indium exposure (§Critical-material exposure), a dedicated capitalized tin-indium R&D vehicle is worth tracking. Confidence: primary-source; the filing does not state the vehicle's technical programme.

H1-2026 interim update (added 2026-08-20)

Format gap, distinct from CMOC's: this semi-annual report carries no sales-basis top-5 customer/supplier % table at all — a full-text search for 前五名客户/前五名供应商 and the 占...总额的比例 phrasing returned zero pages, out of 156. Unlike CMOC's FY2025 annual-report gap (a dual A+H disclosure-format choice), this is the ordinary PRC convention: the MD&A-style top-5 concentration table is an ANNUAL-report requirement and is routinely omitted from semi-annual reports, which disclose related-party transactions only. Practical effect: the FY2025 arm's-length-residual arithmetic above cannot be refreshed at the half-year mark — there is no H1-2026 top-5 aggregate to correct. The next point at which that table reappears is the FY2026 annual report (due ~March/April 2027).

What the filing DOES disclose — the same set of five customer and seven supplier related-party entities as the FY2025 annual report, now as absolute RMB flows against each entity's board-approved annual quota (not a share of total sales/procurement), with the H1-2025 comparative in the same table. Both tables reconcile exactly to their filing-stated totals (customers RMB 4,115,635,007.05; suppliers RMB 6,984,143,983.22) — see the structured frontmatter for the full per-entity breakdown, each carrying both the H1-2026 and H1-2025 figure as separate rows per R164.

Two related-party suppliers have already blown through their full-year quota at the half-year mark: 云南锡业集团物流有限公司 (Yunnan Tin Group Logistics) has purchased RMB 3.242bn against a RMB 1.900bn FY2026 cap (171% of the full-year allowance used in six months, up +317% YoY from H1-2025's RMB 777.4m), and 云南锡业新材料有限公司 (Yunnan Tin New Materials) has purchased RMB 148.2m against a RMB 136.0m cap (109%). The filing flags both with "是" (exceeded) in its own compliance column. Yuntin Holding, the largest related-party supplier by value (RMB 1.779bn, raw materials/fuel), remains within its much larger RMB 6.314bn cap. A quota breach at half-year means the board will need to either ratify a revised annual cap or the related-party procurement volume will need to slow materially in H2 — worth checking at the FY2026 annual report.

Governance note, not a counterparty: the filing discloses that Yuntin Group (云南锡业集团有限责任公司, the direct controlling shareholder) reduced its stake in Yunnan Tin from 32.98% to 31.76% during H1-2026 via on-market centralized-bidding and block trades (20,036,023 shares). This does not change control (ultimate controller remains the Yunnan provincial SASAC) but is a modest float increase worth tracking alongside the related-party transaction volumes above.

Access log — what was tried and what it returned

Sources

Yunnan Tin Co., Ltd. FY2025 annual report (cninfo, filed 2026-03-30) — customer/supplier concentration and related-party counterparties
Yunnan Tin Co., Ltd. H1-2026 semi-annual report (cninfo, filed 2026-08-20) — H1-2026 related-party transaction tables, H1-2025 comparatives, parent stake change
Yunnan Tin Group — Our Company
Yunnan Tin — Wikipedia
Tin Stocks: 10 Biggest Producers — Investing News Network

Named counterparties — who actually buys and sells

From the company’s own mandatory filings — the CSRC top-5 customer/supplier concentration disclosure and the related-party tables. 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.

The full counterparty breakdownShow

Next mandatory disclosure — Q3-2026 quarterly, due 2026-10-31 (24 days) on SZSE (000960.SZ). rule ↗

What an A-share filer must publish is the top-5 concentration PERCENTAGE, not the customer names. Names reach us only where a disclosure trigger or the common-control merge rule forces them — so this lane guarantees a number for any listed producer and a name only sometimes.

The date is statutory; what this particular filing contains is not equally settled. The top-5 concentration clause we rely on sits in the content standard for the annual report, and nobody here has read the quarterly standard — so treat this deadline as a filing worth reading, not as a guaranteed refresh of the figures below.

Customers · FY2025

Disclosed top-5 32.80%of which related-party 16.29%arm's length 16.51% (derived)

Suppliers · FY2025

Disclosed top-5 42.98%of which related-party 29.33%arm's length 13.65% (derived)

Read the arm's-length column, not the headline. Enough of the disclosed top-5 is intra-group that the company's genuine third-party customer concentration is 16.51%, not the 32.80% the filing reports. The arm's-length figure is arithmetic on the two disclosed numbers — derived, not reported.

Rank 1 on BOTH sides is the parent roll-up, so the headline ratios overstate arm's-length concentration by roughly half. Related-party shares are the filing's own disclosed figures, share-of-annual-sales / share-of-annual-procurement basis.

Named suppliers (9)

Direction NOT READABLE — 7 counterparties are disclosed across two filings, but none carries figures that can honestly be compared. This is a gap in what the filer published, not a finding that nothing moved.

Read from the filer's own disclosed shares across vintages — what the company did, not pressure applied to it. Separate from every score on this page. “Unchanged” means every comparable move is under 2.0 points — a stated, arbitrary band, not a fitted one.

云南锡业集团（控股）有限责任公司 / Yunnan Tin Group (Holding) Co., Ltd.H1-2025 — → FY2025 14.07% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 1,400,773,103.55.source ↗
FY2025 · Raw materials, fuel, spares, transferred water and power, repairs, leases. Exceeded its RMB 6.138bn approved cap.source ↗
H1-2026 · Purchases/services: RMB 1,778,801,659.54 against a RMB 6,314,400,000.00 board-approved FY2026 quota (not exceeded at half-year). H1-2025 comparative: RMB 1,400,773,103.55.source ↗
云锡澳大利亚TDK资源公司 / Yuntin Australia TDK Resources Co.H1-2025 — → FY2025 5.55% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 1,142,768,763.89.source ↗
FY2025 · The only named foreign-domiciled node in the whole disclosure — RMB 2.434bn of raw-material feed into the Chinese smelter, ~16 percent over its approved cap. The underlying asset is unverified.source ↗
H1-2026 · Raw-material procurement: RMB 1,599,474,731.04 against a RMB 2,100,000,000.00 FY2026 quota (not exceeded at half-year, unlike FY2025 full-year). H1-2025 comparative: RMB 1,142,768,763.89.source ↗
云南锡业新材料有限公司 / Yunnan Tin New Materials Co., Ltd.H1-2025 — → FY2025 0.50% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 123,599,408.79.source ↗
H1-2026 · Raw-material procurement: RMB 148,188,605.75 — already EXCEEDS the RMB 136,000,000.00 FY2026 board-approved quota at the half-year mark (109% of the full-year cap). H1-2025 comparative: RMB 123,599,408.79.source ↗
云南锡业锡化工材料有限责任公司 / Yunnan Tin Tin-Chemical Materials Co., Ltd.H1-2025 — → FY2025 0.40% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 111,078,009.37.source ↗
H1-2026 · Raw-material procurement: RMB 87,007,698.50 against a RMB 120,000,000.00 FY2026 quota. H1-2025 comparative: RMB 111,078,009.37.source ↗
云南锡业建设集团有限公司 / Yunnan Tin Construction Group Co., Ltd.H1-2025 — → FY2025 0.25% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 25,121,127.99.source ↗
FY2025 · Engineering construction and installation — not a material input.source ↗
H1-2026 · Purchases/services: RMB 49,756,599.25 against a RMB 210,000,000.00 FY2026 quota. H1-2025 comparative: RMB 25,121,127.99.source ↗
云南锡业集团有限责任公司 / Yunnan Tin Group Co., Ltd. (controlling shareholder)H1-2025 — → H1-2026 —not comparable · no share figure filedrelated party a-share-filing primary-source
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 83,788,733.96.source ↗
H1-2026 · Purchases/services: RMB 78,628,133.56 against a RMB 175,800,000.00 FY2026 quota. H1-2025 comparative: RMB 83,788,733.96.source ↗
云南锡业集团物流有限公司 / Yunnan Tin Group Logistics Co., Ltd.H1-2025 — → H1-2026 —not comparable · no share figure filedrelated party a-share-filing primary-source
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 777,378,965.86.source ↗
H1-2026 · Purchases/services: RMB 3,242,286,555.58 — already EXCEEDS the RMB 1,900,000,000.00 FY2026 board-approved quota at the half-year mark (171% of the full-year cap). H1-2025 comparative: RMB 777,378,965.86 (+317.1%).source ↗
云南锡业集团物流有限公司 / Yunnan Tin Group Logistics Co., Ltd. · FY2025 · both directionsrelated party a-share-filing primary-sourcesection filing ↗
Product sales out 1.93% of same-type; materials/fuel/freight/warehousing in 4.52% of same-type procurement.
云南锡业集团有限责任公司 / Yunnan Tin Group Co., Ltd.0.43% of same-type procurement · FY2025related party a-share-filing primary-sourcesection filing ↗
The controlling shareholder itself.

Named customers (7)

Direction NOT READABLE — 5 counterparties are disclosed across two filings, but none carries figures that can honestly be compared. This is a gap in what the filer published, not a finding that nothing moved.

云南锡业集团（控股）有限责任公司 / Yunnan Tin Group (Holding) Co., Ltd.H1-2025 — → FY2025 16.29% of annual sales → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 145,756,303.26.source ↗
FY2025 · Rank-1 customer, but an aggregate roll-up of commonly-controlled subsidiaries (RMB 7.092bn), not a single operating buyer.source ↗
H1-2026 · Sales of goods/services: RMB 312,337,816.86 (H1-2025 comparative: RMB 145,756,303.26, +114.3%).source ↗
云南锡业新材料有限公司 / Yunnan Tin New Materials Co., Ltd.H1-2025 — → FY2025 11.11% of same-type transactions → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 1,988,443,608.47.source ↗
H1-2026 · Sales of goods/services: RMB 1,514,186,751.15 (H1-2025 comparative: RMB 1,988,443,608.47, -23.9%).source ↗
云南锡业锡化工材料有限责任公司 / Yunnan Tin Tin-Chemical Materials Co., Ltd.H1-2025 — → FY2025 5.51% of same-type transactions → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 980,091,617.71.source ↗
FY2025 · Exceeded its RMB 1.700bn board-approved related-party cap.source ↗
H1-2026 · Sales of goods/services: RMB 1,155,947,744.95 (H1-2025 comparative: RMB 980,091,617.71, +17.9%).source ↗
云南锡业集团有限责任公司 / Yunnan Tin Group Co., Ltd. (controlling shareholder)H1-2025 — → H1-2026 —not comparable · no share figure filedrelated party a-share-filing primary-source
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 698,188.45.source ↗
H1-2026 · Sales of goods/services: RMB 714,491.24 (H1-2025 comparative: RMB 698,188.45).source ↗
云南锡业集团物流有限公司 / Yunnan Tin Group Logistics Co., Ltd.H1-2025 — → H1-2026 —not comparable · no share figure filedrelated party a-share-filing primary-source
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 287,266,352.98.source ↗
H1-2026 · Sales of goods/services: RMB 1,132,448,202.85 (H1-2025 comparative: RMB 287,266,352.98, +294.2%).source ↗
云南锡业集团物流有限公司 / Yunnan Tin Group Logistics Co., Ltd. · FY2025 · both directionsrelated party a-share-filing primary-sourcesection filing ↗
Product sales out 1.93% of same-type; materials/fuel/freight/warehousing in 4.52% of same-type procurement.
云南锡铟实验室有限公司 / Yunnan Tin-Indium Laboratory Co., Ltd.0.01% of same-type transactions · FY2025related party a-share-filing primary-sourcesection filing ↗
Lease income only. New JV capitalised June 2025 — Yuntin Holding 40 / Yunnan Tin 30 / New Materials 30.

Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: A-share issuers anonymise counterparties they are not required to name. · section source filing ↗

The exposure register

Ranked by buyer-relative risk, highest first.

0 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
Silver	🇲🇽 MX 24% mining	43	43	Moderate	—	—	some	5	▲ rising
Indium	🇨🇳 CN 69% refining	35	64	Low	—	—	limited	2	▲ rising
Copper	🇨🇳 CN 48% refining	34	59	Low	within 48%	—	limited	52	▲ rising
Tin	🇨🇳 CN 55% refining	30	56	Low	—	—	ready	18	▲ rising
Zinc	🇨🇳 CN 32% mining	19	37	Low	—	—	ready	7	▲ 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 ↗

Supply-risk factor analysis

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.

The factor-by-factor analysisShow

Material	Geopolitical	Concentration	Price / market	Substitutability	Import reliance	Logistics · ESG · Supplier
Silver	3	1	5	3	3	company input
Indium	4	3	5	3	4	company input
Copper	4	2	5	4	3	company input
Tin	4	2	5	2	3	company input
Zinc	4	2	3	3	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.

Material factors (scored 4–5) — evidence

Silver
- 5Price / market: price up, as of 2026-10-07
Indium
- 4Geopolitical: 2 restrictive actions, peak severity 4, 2 in last 24mo
- 5Price / market: price up, as of 2026-10-07
- 4Import reliance: Eurostat Comext 2025: 75% extra-EU imports, top partner BR 60% (partner HHI 4084)
Copper
- 4Geopolitical: 52 restrictive actions, peak severity 5, 33 in last 24mo, less 3 liberalising actions
- 5Price / market: price up, as of 2026-09-01
- 4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 70/100 (long-horizon, all major uses). Prior analyst short-run rating 0.50: USGS: aluminium substitutes in some electrical/heat-exchange uses
Tin
- 4Geopolitical: 18 restrictive actions, peak severity 4, 13 in last 24mo
- 5Price / market: price up, as of 2026-09-01
Zinc
- 4Geopolitical: 7 restrictive actions, peak severity 4, 3 in last 24mo

Named refiners in the supply base

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.

The named refinersShow

Tin

China = 28% of filer-disclosed refiner mentions · 879 named refiners

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
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.

Change log

last 30 days

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.

2026-09-30filedIndia Ministry of Mines launches first offshore mineral block auction (Andaman Sea)
2026-09-17filedUS Commerce Preliminary Affirmative Antidumping Determination: Tin Mill Products from China (September 2026)
2026-09-15filedUS Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)
2026-09-11amendedIndonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform— Kepmen ESDM No. 363.K/MB.01/MEM.B/2026 supersedes the Kepmen 144/2026 HPM formula for low-grade limonite: the nickel Correction Factor (CF) for 1.2%-Ni-or-lower ore is reset to 14% (falling 1pp per 0.1pp of grade below that), and the cobalt by-product coefficient is cut from 30% to 17%. Net effect on 1.2%-Ni ore: HPM falls ~45%, from USD 44.97/wmt to USD 24.89/wmt. The change targets the low-grade limonite/HPAL feedstock segment specifically — the 1.6%-grade CF set by 144/2026 is not disclosed as changed in available reporting.

The laws that threaten it

Restrictive government measures on this company's materials, newest first — each links to its primary government source.

The full list of lawsShow

🇮🇳 India Ministry of Mines launches first offshore mineral block auction (Andaman Sea)New since 2026-09-07
2026-09-30· industrial-policy· severity 2· cobalt, nickel, manganese, copper
🇺🇸 US Commerce Preliminary Affirmative Antidumping Determination: Tin Mill Products from China (September 2026)New since 2026-09-07
2026-09-17· tariff· severity 4· tin, steel
🇺🇸 US Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)New since 2026-09-07
2026-09-15· tariff· severity 4· tin, steel
🇵🇪 Peru DS 014-2026-EM — Mining exploration DIA fast-track platform threshold raised 40→60
2026-07-20· regulatory· severity 2· copper
🇺🇸 US USTR Section 301 Determination — Proposed 25% Tariff on All Brazilian Goods
2026-06-04· tariff· severity 3· niobium, copper, iron-ore
🇺🇸 US Proclamation 11032 — Further Adjusting Section 232 Tariff Regimes for Aluminum, Steel, and Copper
2026-06-01· tariff· severity 2· aluminum, steel, copper
🇨🇩 DRC Ministerial Suspension of All Mining in Mwenga and Shabunda (South Kivu)
2026-05-22· regulatory· severity 3· gold, coltan, cassiterite
🇺🇸 US OFAC April 30 2026 — designation of former DRC President Joseph Kabila under EO 13413/13671 for material support to M23 and Congo River Alliance (AFC)
2026-04-30· sanction· severity 3· cobalt, copper, coltan, tantalum
🇪🇬 Egypt PM Decree No. 1440/2026 — Executive Regulations of Mineral Resources Law 198/2014
2026-04-29· regulatory· severity 3· gold, phosphate, tantalum, copper
🇨🇳 China Customs Tariff Commission — Zero-Tariff Treatment for All 53 African Diplomatic Partners (May 2026–April 2028)
2026-04-28· tariff· severity 3· cobalt, copper, bauxite, lithium
🇪🇺 EU Myanmar Restrictive Measures Extended to April 2027 (Council Decision (CFSP) 2026/927)
2026-04-27· sanction· severity 2· heavy-rare-earths, tin
🇮🇩 Indonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform
2026-04-10· industrial-policy· severity 3· nickel, bauxite, cobalt, copper
🇺🇸 US Section 232 Strengthening Proclamation 11021 — Aluminum, Steel, Copper consolidation (50%/25%/10%/0% tier architecture)
2026-04-02· tariff· severity 2· steel, aluminum, copper
🇮🇩 Indonesia Permendag 5/2026 — fourth amendment to Permendag 23/2023: export licensing digitalisation, ilmenite/rutile IUP/IUPK restriction, tin ET elimination
2026-03-26· regulatory· severity 3· tin, ilmenite, rutile
🇿🇲 Zambia SI 17/2026 — Control of Goods (Prohibition of Export) (Sulphuric Acids) Order, 2026
2026-03-20· export-control· severity 2· copper, cobalt

+ 54 more in the register.

Art. 24(2)(c) · vulnerability to disruption

Stress test — two plausible scenarios

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:

Both stress-test scenariosShow

Policy shock — the controlling country escalates to a full export-licensing / ban regime.
Concentration shock — the supply structure collapses to a single source (second-source loss / full monopoly).

Type	Scenario	Today	Stressed	Δ
Policy	Silver — 🇲🇽 MX escalates silver controls to a full export-licensing / ban regime	43	52	+9
Concentration	Silver — 🇲🇽 MX becomes the single source for silver — the second source is lost (full 24%+ monopoly)	43	73	+30
Policy	Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime	35	38	+3
Concentration	Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly)	35	41	+6
Policy	Copper — 🇨🇳 CN escalates copper controls to a full export-licensing / ban regime	34	35	+1
Concentration	Copper — 🇨🇳 CN becomes the single source for copper — the second source is lost (full 48%+ monopoly)	34	43	+9

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.

Art. 24(4) · mitigation trigger

Significant-vulnerability conclusion

No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Yunnan Tin Company Limited produces, and Art. 24 addresses the use of a strategic raw material as an input. 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 0 materials 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 — not yet law

Upcoming regulatory threats

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.

The upcoming threatsShow

🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)
passed-vote→high likelihood·flagged 57d ago · not yet law·matches Copper
If passed — On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
Caveat — ENACTED / already in force (signed 29 June 2026, five independent Congolese/international outlets corroborate the ministers, date and substance) but parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. cd unreachable per prior wakes — same constraint noted on the DRC Strategic Mineral Reclassification, ARECOMS forfeiture, and 5% Worker Equity entries elsewhere in this file). DISTINCT from: 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (ARECOMS sectoral cobalt-hydroxide quota system, cobalt-only), 2025-12-19-drc-artisanal-copper-cobalt-processing-suspension (artisanal-sector only), the queued ARECOMS H1-2026 quota-forfeiture entry above (operationalises the ARECOMS quota, not this arrêté), 2026-04-10-drc-strategic-reserve-minerals-arecoms, and 2026-05-29-drc-strategic-mineral-expansion-decree. This arrêté is the FIRST instrument in the register banning concentrate exports for BOTH copper and cobalt jointly and replacing the 2023 commercialisation/export/nomenclature framework wholesale — a materially broader legal basis than any of the above. Re-check mines. gouv. cd and jocc.
https://actualite.cd/2026/08/06/rdc-kinshasa-interdit-lexportation-des-concentres-de-cuivre-et-de-cobalt-pour-encourager
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 68d ago · not yet law·matches Copper
If passed — Minister of Finance, acting under s. 89 of the Customs and Excise Act, cut the copper-concentrate export duty to ZERO for tariff headings 2603. 00. 21 / 2603. 00. 22 / 2603. 00. 23 / 2603. 00. 29, capped at 271,742 t, effective 1 June 2026 with automatic lapse 30 September 2026, with per-entity tonnage caps and (per one secondary) a requirement that exempt shipments channel through Industrial Resources Limited. This is a SUPPLY-RELIEF (liberalising) action — a net EASING of a copper/cobalt chokepoint for ~4 months, explicitly to clear stockpiled unprocessed concentrate while Zambia's major smelters are down for extended maintenance. It is the "(No. 2)" successor instrument to the already-filed 2026-03-05-zambia-si-15-2026-copper-concentrates-export-duty-suspension (a distinct SI with its own number, tonnage cap and validity window). Severity ~2 expected.
Caveat — ENACTED / already in force per multiple independent secondary sources (all agree on SI number, exact citation title, s. org URL pattern that resolves for the parent SI 15/2026 (`/akn/zm/act/si/2026/43/eng@<date>`) across several plausible dates, all 404; zambialii's SI-list index page for 2026 also 404s directly. Parked here per the standing verify-or-don't-file convention (cf. DRC ARECOMS, Pakistan chloroform, China sulfuric-acid entries below) rather than filed on secondaries alone. Re-check zambialii.
https://www.zambiamonitor.com/govt-suspends-export-duty-on-copper-concentrates/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 68d ago · not yet law·matches Copper
If passed — On 10 July 2026 the African Development Bank Group, with the African Union Commission, the AfCFTA Secretariat and UNECA, convened African ministers of mining/energy/industry in Abidjan for the "Ministerial Forum on Critical Minerals Value Chain and Beneficiation: Pathways for African Transformation". The stated ambition is continental: move the bloc off raw-ore exports toward regional value chains and in-country processing, with reporting of a push to HARMONISE African mining legislation by end-2026 around a ban on unprocessed ore exports, alongside a headline mobilisation figure of ~USD 63bn for critical-minerals value-chain investment. Why this matters as axis-2 early warning rather than noise: the register already holds a dense cluster of INDIVIDUAL national instruments moving in exactly this direction — Zimbabwe's 2026-02-25 indefinite raw-mineral/lithium-concentrate export suspension, Guinea's 2026-06-19 raw-gold export ban + domestic-refining mandate, Gabon's announced 2029 crude-manganese export ban, Nigeria's RMRDC 30% value-addition bill, Indonesia-style downstreaming copied across the continent, and CEMAC's regional Common Mining Code (all already filed or queued). A binding AU/AfCFTA-level harmonisation instrument would convert that scattered set into a coordinated continental supply shock across cobalt, copper, bauxite, manganese and lithium simultaneously — which is a materially different exposure event from any single-country ban, because it removes the substitute-jurisdiction escape route that currently absorbs each national ban.
Caveat — DELIBERATELY likelihood=low, not moderate. com) is low-quality and was NOT relied on. AU-level harmonisation instruments historically take years and frequently stall at the model-law stage (cf. the known ecb-spf 400 pattern) to establish whether a formal Abidjan Declaration text exists and what it actually commits signatories to.
https://www.afdb.org/en/documents/high-level-ministerial-forum-critical-minerals-value-chain-and-beneficiation-pathways-african-transformation
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 74d ago · not yet law·matches Copper
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
https://www.spglobal.com/energy/en/news-research/latest-news/metals/041526-chinas-sulfuric-acid-restrictions-set-to-squeeze-miners
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 100d ago · not yet law·matches Copper
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
https://senate.parlam.kz/en-US/news/details/14628
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 101d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in advanced negotiations to acquire a 15-20% equity stake (deal value ~USD 1. 5-2bn) in First Quantum Minerals' Zambian copper and nickel operations — i. e. the Kansanshi and Sentinel/Trident copper complex (Zambia's largest copper mines, ~0. 4-0. 5 Mt/yr combined) plus nickel. This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) directly into a binding African copper chokepoint, paralleling Manara's filed Vale Base Metals 10% stake (2024-03-01-sa-manara-minerals-vale-metals-10pct-stake) and its in-negotiation Reko Diq stake (queued below), and mirroring UAE IRH's Mopani (Zambia) acquisition. Gives Saudi Arabia an equity claim on a major non-China copper supply source and injects fresh capital into FQM as it recovers from the Cobre Panamá shutdown — a Gulf-capital re-pricing of Zambian copper supply risk that the exposure engine should track.
Caveat — As of 2026-06-28 this is in advanced negotiation, no signed SPA — hence announced/upcoming not enacted. DISTINCT from the Reko Diq (Pakistan) Manara stake queued below (different asset, different host country) and from the filed Vale Base Metals 10% stake. If completed, severity 2-3.
https://www.miningsee.eu/saudi-arabias-manara-minerals-eyes-stake-in-first-quantums-zambian-copper-and-nickel-assets/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 110d ago · not yet law·matches Copper
If passed — First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2447259
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 116d ago · not yet law·matches Tin
If passed — Mandates 15% free-carried interest for Uganda National Mining Company (UNMC) in all new mining licences; introduces mandatory mineral buying centres; tightens local-content and value-addition obligations — changes joint-venture economics for all new Ugandan mining operations, raising effective cost-of-entry for foreign miners
Caveat — Amends the already-filed Uganda Mining and Minerals Act 2022 (UG action 1); expected to be enacted before end of 2025/26 parliamentary session per legal commentary; Bank of Uganda gold purchase programme and new mineral buying centres already being piloted — regulatory infrastructure being built ahead of formal enactment. Distinct from filed Uganda Gold Export Regulations 2024 (SI No. 30 of 2024).
https://globallawexperts.com/uganda-mining-law-changes-2026/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Tin🇨🇳 today 30→31+1
🇮🇩 Indonesia Tin Export Ban — Downstreaming Initiative
announced→low likelihood·flagged 115d ago · not yet law·matches Tin
If passed — Indonesia = ~20% of global refined tin exports (Bangka Belitung); a ban on refined-tin exports would force downstream solder/semiconductor-packaging manufacturing domestically; disrupts global electronics and EV supply chains dependent on Indonesian tin solder and specialty alloys
Caveat — Minister of Energy and Mineral Resources Bahlil Lahadalia announced government "studying" tin export ban on February 13, 2026 at the Indonesia Economic Outlook, Jakarta; framed as replication of 2020 nickel ore ban which claimed 10x value-add uplift; key complication — Indonesia already exports refined tin (not raw ore), so a ban would require immediate creation of advanced downstream industries (solder, electronic-grade tin, semiconductor components) that don't yet exist at scale; Mining Weekly (Feb 13 2026) and BERNAMA (Feb 2026) confirm announcement; no Perpres, PP, or Kepmen issued as of June 14, 2026; government described as "studying" — not yet in formal regulatory drafting. Distinct from filed Indonesia nickel ore export bans (2019, 2023), filed bauxite export ban, and filed Permendag export-licensing amendments.
https://indonesiabusinesspost.com/6137/policy/indonesia-s-potential-tin-export-ban
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Tin🇨🇳 today 30→31+1
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 115d ago · not yet law·matches Tin, Zinc
If passed — Prohibits raw mineral exports unless 30% value-addition achieved domestically; affects Chinese mining companies (dominant in Nigerian critical minerals sector), Western offtake agreements, and all foreign-invested mining JVs; builds on existing eMC+ digital cadastre and mandatory value-addition plans introduced Nov 2024; could force processing-plant investment or suspension of raw mineral shipments from Africa's most populous economy; RMRDC = Raw Materials Research and Development Council (the sponsoring agency)
Caveat — Bill passed third reading in House of Representatives; multiple Nov 2025 sources confirm both chambers approved; as of 2026-06-14 presidential signature not yet confirmed. Distinct from filed Nigeria Tax Reform Acts 2025 (Loi n°1/19 tax restructuring) and Mining Cadastral licence revocations (2025-06-19). Applies to ALL raw materials, not minerals only — IPTM relevance is the mineral export provisions.
https://www.nationalaccordnewspaper.com/turning-point-for-nigeria-as-rmrdcs-30-value-addition-bill-nears-presidential-assent/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Tin🇨🇳 today 30→31+1
- Zinc🇨🇳 today 19→22+3
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 115d ago · not yet law·matches Copper, Silver, Zinc
If passed — Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mining concessions for first time in Peruvian law history, making concessions revocable by administrative authority; introduces higher annual fees and stronger production/investment requirements; threatens legal certainty for Peru's undeveloped copper and silver project pipeline — Peru = #2 copper, #4 silver, #1 lead, #2 zinc globally
Caveat — Approved by Energy and Mining Commission March 17, 2026 by 11 votes to 1 with 3 abstentions — driven by left-aligned Juntos por el Perú (JPP) and Podemos Peru majority. Bill also introduces "comuneros como accionistas" (community shareholders) in mining concessions — first legislative insertion of indigenous community equity rights. MINEM, SNMPE, ComexPerú, and Ingemmet publicly opposed; MINEM warns reform would incentivise illegal mining expansion. Full plenary debate pending as of June 2026. Distinct from all filed PE actions (all executive/regulatory decrees — no prior legislative amendment to Ley General de Minería in register). Also distinct from filed PE actions on REINFO extension (2025-12-26), illegal-mining criminalization (2026-01-20), and Tía María revocation (2026-03-19).
https://elcomercio.pe/economia/peru/comision-de-energia-aprueba-cambios-en-la-ley-de-mineria-y-reaviva-alertas-por-impacto-en-inversion-y-estabilidad-juridica-noticia/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 34→35+1
- Silver🇲🇽 today 43→52+9
- Zinc🇨🇳 today 19→22+3
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 114d ago · not yet law·matches Indium
If passed — Establishes the first legally binding "safe level" benchmark for EU strategic stocks of each of the 17 strategic raw materials listed in the CRMA Annex I; benchmarks used as reference by Member States, financial institutions, and industrial consumers to assess strategic supply risk; mandated every 2 years, so this is the first edition setting the baseline; informs CRMA Art. 23 monitoring obligations and is the evidential basis for Art. 24 corporate-reporting thresholds
Caveat — The May 24, 2026 deadline set by Parliament and Council in Reg. (EU) 2024/1252 has now passed. No OJ publication confirmed as of June 15, 2026 — Commission may have adopted quietly or is overdue. This is the first CRMA Art. 22 benchmark cycle and is legally distinct from: (1) the CRMA base regulation (filed 2024-05-23); (2) the Strategic Projects first designation (filed 2025-03-25); (3) the RESourceEU Amendment — CRMA revision (filed 2026-03-04). If confirmed adopted, severity=2 (establishes the measurement baseline for EU strategic material supply risk assessment and directly feeds corporate Art. 24 reporting obligations). Distinct from all filed EU-CRMA actions. Not in filing. md or upcoming. md.
https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Indium🇨🇳 today 35→38+3
🇮🇩 Indonesia PP 19/2025 Mining Royalty Rate Hike — Implementation Postponed Indefinitely (May 2026)
announced→low likelihood·flagged 113d ago · not yet law·matches Copper, Tin, Silver
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
https://en.antaranews.com/news/415656/indonesia-delays-mining-royalty-and-export-levy-plan
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
- Tin🇨🇳 today 30→31+1
- Silver🇲🇽 today 43→52+9
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 112d ago · not yet law·matches Tin, Silver, Zinc, Copper
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
https://www.mineria.gob.bo/index.php/nota_prensa/bolivia-activa-reforma-minera-integral-y-sale-a-captar-inversiones-con-respaldo-del-banco-mundial/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Tin🇨🇳 today 30→31+1
- Silver🇲🇽 today 43→52+9
- Zinc🇨🇳 today 19→22+3
- Copper🇨🇳 today 34→35+1
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 111d ago · not yet law·matches Copper
If passed — Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
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 ↗
https://ustr.gov/about/policy-offices/press-office/press-releases/2026/february/ustr-seeks-public-comment-design-plurilateral-agreement-trade-critical-minerals-and-policy-actions
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 34→35+1
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 111d ago · not yet law·matches Copper
If passed — Full replacement of the Mining Act 1992 with sweeping new statute: state acquires up to 30% equity in any new mining project (Kumul Minerals free-carry); special mining leases (SML) issued for initial 30-month periods with FID requirement to renew; mandatory landowner and community consultation before licence grant; Mining Development Authority (MDA) replaces current Mineral Resources Authority (MRA) as the sector regulator; CGT on extractive asset transfers now in force since the 2025 Income Tax Act (separate filed action); bill as drafted would reshape FDI terms for all existing and future mining permits including Wafi-Golpu (Newmont/Harmony 26 Moz Au, 4. 8 Mt Cu — SML long-delayed), Frieda River copper-gold (PanAust), and Ok Tedi expansion; PNG's 2023 Mining (New Porgera) Amendment Act handled Porgera separately
Caveat — The public-consultation-draft stage is already filed in the register as 2025-02-25-papua-new-guinea-mining-bill-2025 (filed action records the consultation launch). This upcoming entry tracks the NEXT stage: parliamentary enactment. Consultations closed April 4, 2025; minister aimed for September 2025 tabling but no confirmed passage found as of June 2026. Likelihood moderate — bill has broad government backing and a 15-year development history, but PNG legislative timelines are frequently extended; the May 2025 Marape cabinet reshuffle may have shifted ministerial priorities. Distinct from: 2023-10-13-papua-new-guinea-mining-new-porgera-amendment-act (single-mine statute); 2025-03-12-papua-new-guinea-national-petroleum-authority-act (petroleum, not mining); 2025-03-20-papua-new-guinea-income-tax-act-2025 (CGT on extractive transfers — already enacted separately).
https://www.businessadvantagepng.com/papua-new-guineas-draft-mining-bill-sweeping-reforms-to-overhaul-the-sector/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 103d ago · not yet law·matches Copper
If passed — TZ Finance Bill establishes the Mineral Research Fund capitalised at 10% of gross mineral revenue (~TZS 141 billion/yr at 2025 collection levels); amends the Income Tax Act to formally recognise tax exemptions granted under individual mining Framework Agreements and introduces standard operating procedures — reduces discretionary government risk for large mining investors (Panda Hill niobium, graphite juniors, Buzwagi gold); parallel VAT amendments give equivalent statutory certainty for VAT exemptions; taken together, the bill moves Tanzania from discretionary tax administration toward a rule-of-law-based investor regime for all critical-mineral projects; budget targets Tanzania for top-4 niobium producer status (Panda Hill DA already signed March 24, 2026) and 50% geophysical survey coverage by 2030
Caveat — Tanzania fiscal year starts July 1; the Finance Act signature typically occurs last week of June. Budget speech delivered June 11, 2026 by Finance Minister Khamis Mussa Omar; Parliament approved June 23. Mining provisions in §§ amending Income Tax Act (Cap. 332) and VAT Act (Cap. 148) and establishing the Mineral Research Fund. Distinct from: filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year), filed 2026-03-24-tanzania-panda-hill-niobium-ferroniobium-development-agreement (the specific project DA), and filed 2026-04-15-tanzania-ministry-of-minerals-revokes-40-idle-mineral-exploration-licences. Severity 2: institutional reform that de-risks the investor regime rather than a direct trade restriction.
https://www.tanzaniainvest.com/economy/budget-2026-2027-parliament-approved
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 106d ago · not yet law·matches Copper
If passed — All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension; effectively forces equity restructuring across the entire DRC copper-cobalt belt; miners seeking moratorium as of June 18, 2026 — enforcement outcome by August 2026 will set the precedent
Caveat — Ministerial enforcement letter issued January 30, 2026 by Mines Minister Louis Watum Kabamba — activates dormant Art. 71 bis (5% employee equity in mining company capital) and Art. 144 bis (mechanics) of DRC Mining Code (Loi n° 18/001). Filed here (not filing. md) because DRC government websites (mines. gouv. cd, primature. gouv. cd) remain inaccessible per prior wakes — same constraint as the DRC Strategic Mineral Reclassification entry. Action IS already in effect and enforcement is underway (July 31, 2026 deadline); this is NOT speculative. DRC Chamber of Mines convened June 11, 2026 industry response meeting; companies arguing retroactive application is legally contested. Severity 3 expected if enforced. Distinct from: 2018-01-27-drc-mining-code-revision (underlying law), 2026-04-10-drc-strategic-reserve (ARECOMS mechanism), 2026-04-24-drc-tshisekedi-mining-export-revenue-audit.
https://www.kitco.com/news/off-the-wire/2026-06-18/congo-miners-seek-delay-5-worker-equity-rule-july-deadline
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 106d ago · not yet law·matches Copper
If passed — Revises 30 CFR Part 580 to streamline 10 provisions governing prospecting, leasing, and operations for hard minerals (manganese nodules, cobalt-rich crusts, seafloor massive sulfides) on the US Outer Continental Shelf; eliminates environmental notification to adjacent state governors (§580. 31) and BOEM's own environmental review requirement (§580. 29); accelerates OCS hard mineral leasing pipeline in line with EOs 14285 and 14154 ("unleashing" OCS resources); comment period closed April 27, 2026; awaiting final rule
Caveat — First substantive revision of US OCS hard minerals regulatory framework in ~35 years; distinct from all filed US actions (no prior OCS hard minerals action in register). Severity 2: regulatory infrastructure that enables future OCS leasing rather than a direct production/export instrument; secondary-boem: https://www. boem. gov/newsroom/press-releases/boem-proposes-rule-changes-support-critical-mineral-exploration-and
Reference-class base rate
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 ↗
https://www.federalregister.gov/documents/2026/02/24/2026-03690/administrative-revisions-to-regulations-related-to-outer-continental-shelf-minerals-other-than-oil
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 34→35+1
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 103d ago · not yet law·matches Copper
If passed — Ministry of Mines issued operational guidelines for the Mining Sector Reforms component under Scheme for Special Assistance to States for Capital Investment (SASCI) FY2026-27, with total ₹5,000 crore (~USD 600M) incentive envelope to states; key components: (i) ₹250 crore one-time incentive to any state where ≥10% of pre-March-2026 auctioned major mineral blocks begin production+dispatch by end-2026; (ii) ₹100 crore baseline for systemic reforms (Unified Mining Portal integration, Pre-Auction Committees); (iii) ₹20 crore per block auctioned with pre-embedded forest and environmental clearances; scheme targets removing the "auction gap" — India has auctioned hundreds of mineral blocks since 2015 MMDR amendments but operationalisation lag remains a structural bottleneck; critical minerals relevance: India is running parallel programme of critical+strategic mineral auctions (7 tranches, 56 blocks auctioned by June 24, 2026) and this scheme incentivises states to bring those blocks into production faster; directly accelerates lithium (Rajasthan), REE (Andhra Pradesh, Tamil Nadu), graphite (Odisha), and nickel (Odisha, Jharkhand) pipelines
Caveat — Source is secondary (PolicyEdge news aggregator). To migrate to filing. md, filer must verify the primary notification on mines. gov. in or pib. gov. in (search "SASCI Mining 2026-27" on PIB search). India BHAVYA industrial parks scheme (₹33,660 crore, March 18, 2026) is separately filed — SASCI is a distinct scheme targeting state-level mining-sector governance reform. Distinct from filed India Union Budget 2026-27 Customs notifications and Semiconductor Mission 2. 0. Severity 2 (supply-side demand-unlock rather than export control or FDI gate).
https://www.policyedge.in/p/centre-launches-5000-crore-incentive-scheme-to-speed-up-mine-auctions-and-production
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 102d ago · not yet law·matches Copper
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
https://mono.mn/n/government_approves_draft
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 34→35+1
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 102d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one of the world's largest undeveloped Cu-Au deposits (phase-1 ~200,000 t/yr copper concentrate + 250,000 oz/yr gold, first production targeted end-2028, ~USD 5. 5bn phase-1 capex). The stake would be purchased from the Pakistani state's half of the project (Pakistan federal SOEs + Balochistan hold 50%; Barrick Gold holds 50% and operates). This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) into a strategic copper chokepoint, paralleling Manara's Vale Base Metals 10% stake and IRH's Mopani (Zambia) acquisition; gives Saudi Arabia an equity claim on a major future non-China copper supply source.
Caveat — As of 2026-06-27 the deal is in negotiation — Pakistan's Petroleum Minister Musadik Malik said publicly he expected a deal "within the next six months," hence announced/upcoming not enacted. Distinct from filed 2025-09-08-pakistan-us-ussm-fwo-critical-minerals-mou (US EXIM/USSM financing angle on Reko Diq), filed 2025-03-14-pakistan-balochistan-mines-and-minerals-act (the provincial mining law), and filed 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake (Manara's Vale Base Metals deal). Severity 2-3 if completed.
https://www.mining-technology.com/news/manara-minerals-acquire-20-stake-reko-diq-project/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 101d ago · not yet law·matches Copper
If passed — Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring the interest from the Government of Pakistan (Pakistan + Balochistan together own 50%; Barrick Gold holds the other 50% as operator). Reko Diq is one of the world's largest undeveloped copper-gold deposits (~$74bn projected free cash flow over a ~37-yr life). IPTM relevance: a GCC sovereign-capital upstream-mining-FDI entry (theme gcc-mining-upstream-fdi) into COPPER — a binding chokepoint material — extending the Saudi diversification-of-supply strategy beyond the filed 2024-03-01 Manara→Vale Base Metals 10% stake; would also be a Pakistan host-state instrument (federal divestment of part of its Reko Diq equity to a Gulf SWF, complementing the 2025-09-08 Pakistan–US USSM critical-minerals MoU already filed). Distinct GCC third-party capital base separate from Chinese-SOE capture and Western MSP/CRMA-aligned investment.
Caveat — As of mid-2025 the deal was reported by Pakistan's Petroleum Minister as expected "within six months" but NO binding SPA or primary gov instrument has surfaced as of 2026-06-28 — hence announced/moderate, not enacted. Dedup: only the 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake Manara action is filed; no Reko Diq/Manara slug in action-index; the filed Reko Diq item (2025-09-08 Pakistan–US USSM–FWO MoU) is a DIFFERENT instrument (US bilateral MoU, not a Saudi equity purchase). Severity 2-3.
https://www.dawn.com/news/1886746
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 69d ago · not yet law·matches Copper
If passed — RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 34→35+1
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 55d ago · not yet law·matches Copper
If passed — President Peter Mutharika signed an executive order (dated 23 Oct 2025, effective 21 Oct 2025, announced at Sanjika Palace during a cabinet swearing-in) prohibiting the export of raw/unprocessed minerals extracted in Malawi — uranium, rare earth elements, niobium, graphite, tantalum, bauxite, coal, limestone, gemstones, heavy mineral sands, vermiculite, phosphate, rutile, gold, diamonds, copper and others — with an exemption for minerals processed/refined/value-added domestically per Malawian mining law. Announced alongside a suspension of new mining-licence issuance and a review of mining laws (2026/27 State of the Nation Address), plus a planned sovereign wealth fund. Stated rationale: local beneficiation, targeting up to USD 500m/yr once the Kasiya rutile/graphite deposit (Lilongwe) and Kangankunde rare-earth project (Balaka, Mkango Resources — Africa's prospective first new REE mine since 2017, targeting late-2026 production) are fully developed. Violators face fines/penalties under Malawian law. MW is currently the THINNEST country in the register (1 prior action) despite this breadth of minerals covered. Export-ban/beneficiation-mandate, same instrument class as Zimbabwe's SI 213/2022 raw-mineral bans and Guinea's 2026 gold-export ban already in the register.
Caveat — ENACTED (signed order, in force since 21 Oct 2025) but parked here rather than filing. gov. mw directly (TLS cert mismatch: cert is issued for agriculture. gov. mw, not statehouse. gov. mw) and the malawiace. com implementation-analysis piece cites no gov URL either. Same park-lot convention as the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines above (real, already-enacted action; primary URL not independently locatable this wake). Dedup: action-index has only 1 Malawi action total, none overlapping (no prior MW export-ban or beneficiation-mandate action exists). Severity 3-4 expected given the breadth of minerals covered and MW's fast-growing REE/graphite production profile.
https://www.theeastafrican.co.ke/tea/business-tech/malawi-president-mutharika-bans-exports-of-raw-minerals-5247332
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 3d ago · not yet law·matches Copper
If passed — State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar's ambassador that it will resume the Jebel Ohier copper-gold project (Red Sea State) with an $800M commitment. Third GCC sovereign upstream-mining entry after Manara Minerals/Vale Base Metals 10% stake (2024-03-01, filed) and QIA/Ivanhoe Mines strategic placement (2025-09-17, filed) — extends the GCC-as-third-capital-base pattern (theme gcc-mining-upstream-fdi) to African copper, not just battery metals.
Caveat — gov. sd not independently reachable; QMSD's own project page does not yet mention the resumption) — parked here per the same convention used for the Malawi executive-order entry above (real/firm commitment, primary URL not yet locatable). Dedup: checked "qatar mining", "jebel ohier", "qmsd" across filing. md, upcoming. md, and action-index — zero hits. Likelihood=high reflects a confirmed government-to-government commitment, not a prediction of eventual gazettal.
https://sudantribune.com/article/313934
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1

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.

What to watch next

Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.

The watch listShow

Silver is the line to war-game: 🇲🇽 MX already controls 24% of mining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Copper carries 52 restrictive measures on record (🇨🇳 CN 48% of refining) — a secondary escalation candidate.
Tin carries 18 restrictive measures on record (🇨🇳 CN 55% of refining) — a secondary escalation candidate.

Art. 24(4) · diversification & substitution

Priority mitigations

Every scored material here is one Yunnan Tin Company Limited produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.

The mitigation optionsShow

Track demand-side substitution against your own book. The buyer levers listed for consumers of Silver, Indium, Copper, Tin, Zinc — qualifying alternative suppliers, designing the material out — are the demand risk to Yunnan Tin Company Limited's revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by MX / CN on a material Yunnan Tin Company Limited produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The materials above are concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.

Annex A · regulatory basis

CRMA Art. 24 compliance crosswalk

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)).

The full crosswalkShow

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.

Why this dependence is structural, not transitional. The EU's own external auditor — the European Court of Auditors, Special Report “Critical raw materials for the energy transition — Not a rock-solid policy” (Feb 2026) — judges the bloc's 2030 extraction, processing and recycling targets to be out of reach (recycling runs 1–5% for 7 of 26 materials, and diversification shows no measurable effect). A separate industry-analyst assessment (Adamas Intelligence & Tradium, EU CRMA report, Apr 2024 — an interested-party commercial view, not an independent verdict) reaches a compatible conclusion that the 2030 rare-earth targets will be missed without an expedited push. The chokepoint this report maps is therefore a durable constraint the Act has not yet closed, not a gap that resolves on its own.

Annex B · Art. 24(1) · Art. 2(29)

Scope & applicability

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.

Scope detailsShow

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	company input — all 5 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology	metals-refining (confirm against Annex)
Formally identified by a Member State authority	company input

Evidence & sources

Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.

All sourcesShow

Methodology

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 2026-10-07

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).

Refresh SLA

New government measures — polled hourly; a filed action can appear on this report within the hour it's picked up.
Dossier verification (this company's exposure list, sourced against its own disclosures) — the auto-onboarded backlog drains on a 30-minute cycle; a specific company's upgrade timing depends on queue position, not a fixed date.
Live-quoted materials (currently: neodymium, praseodymium, dysprosium, terbium, indium, tellurium — see the price row on each material's page) — refreshed daily.
Other material prices — hand-maintained; flagged STALE on the minerals index past 45 days without a fresh source, rather than left silently out of date.

This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.

← All companies

Geopolitical Supply-Risk Report·EU CRMA Art. 20–25 assessment·MacroLens · CiconiaLabs

Yunnan Tin Company Limited

5 critical materials scored · binding chokepoint: Silver (🇲🇽 MX 24% of mining) · 69 restrictive government measures on record

Subject

000960.SZ · 🇨🇳 CN

Sector

metals-refining

Materials scored

As of

2026-09-30

Ownership re-checked · exposure claims not re-checked since fill

Risk Office verdict

Low · 39/100Exposure claims not re-checked since fillCompany supply-risk index · consumer-side read

Role check · this company is a producer, not a buyer

Competitor cohort · metals refining

Yunnan Tin Company Limited ranks 94th of 98 verified metals refining companies, tied with 1 other at 39.

85🇨🇦 Neo Performance MaterialsDysprosium
84🇬🇧 Pensana PlcDysprosium
83🇬🇷 Sidenor Steel Industry SAManganese
82🇬🇧 FerroglobeManganese
82🇨🇿 Třinecké železárny, a.s.Manganese
82🇩🇪 Vital Pure Metal Solutions GmbHGallium
81🇸🇰 OFZManganese
80🇺🇸 Allegheny Technologies Incorporated (ATI)Tungsten
79🇰🇷 Korea Zinc Co., Ltd.Gallium
79🇨🇿 Nová Huť (formerly Liberty Ostrava a.s.)Manganese
78🇯🇵 Mitsubishi Steel Mfg. Co., Ltd. (Mitsubishi-lineage specialty steel and automotive springs)Manganese
78🇰🇷 POSCO Holdings Inc.Graphite
77🇺🇸 Carpenter Technology CorporationManganese
77🇺🇸 Cleveland-Cliffs Inc.Manganese
39🇨🇳 Yunnan Tin Company LimitedSilver

Disclosed production sites

CN · Gejiu (Honghe), Yunnan — Dachun/Laochang/Kafang mines and tin, copper smelting — tin, copper and zinc concentrates; refined tin, cathode coppertincopperzincindium
CN · Wenshan, Yunnan — Dulong mine and zinc-indium smelter — zinc and indium smelting, die-cast zinc alloyzincindium
CN · Chenzhou, Hunan — tin smeltingtin

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.

Yunnan Tin Company Limited

The exposure report this dossier powers is at /intelligence/dossiers/yunnan-tin/report.

What they do

Critical-material exposure

Tin (primary output, bulk producer) — YTC's core business and the

Indium (major byproduct, not a trace credit) — YTC states its indium

Copper (byproduct, standing product line) — cathode copper is a listed

Zinc (byproduct, standing product line) — zinc ingots are a standing

YTC output. Zinc supply is comparatively diversified globally, making this the lowest-risk exposure among YTC's refined metals.

Silver (byproduct, precious-metal credit) — silver ingots are a

disclosed byproduct output of YTC's polymetallic refining, smaller in scale than the tin/indium/copper/zinc lines but a genuine, recurring output rather than an incidental trace.

Named counterparties (added 2026-08-10)

The headline finding: no third-party counterparty is named

Because the single named counterparty on each side is the parent, the headline concentration ratios overstate arm's-length concentration by roughly half:

FY2025 metric	Reported	of which related-party	arm's-length residual
Top-5 customers, % of annual sales	32.80% (¥14.279bn)	16.29%	16.51%
Top-5 suppliers, % of annual procurement	42.98% (¥16.582bn)	29.33%	13.65%

Anonymized non-related-party ranks, verbatim:

Customers: #2 ¥3.461bn / 7.95%, #3 ¥1.872bn / 4.30%, #4 ¥999.6m / 2.30%, #5 ¥854.0m / 1.96%
Suppliers: #2 ¥2.566bn / 6.65%, #3 ¥1.029bn / 2.67%, #4 ¥848.7m / 2.20%, #5 ¥820.3m / 2.13%

Customers — named (all intra-group)

Named customer (Chinese legal name)	English rendering	FY2025 sales	% of same-type	Notes
云南锡业新材料有限公司	Yunnan Tin New Materials Co., Ltd.	¥4.071bn	11.11%	product sales
云南锡业锡化工材料有限责任公司	Yunnan Tin Tin-Chemical Materials Co., Ltd.	¥2.020bn	5.51%	product sales; exceeded its ¥1.700bn approved cap
云南锡业集团物流有限公司	Yunnan Tin Group Logistics Co., Ltd.	¥708.5m	1.93%	product sales
云南锡铟实验室有限公司	Yunnan Tin-Indium Laboratory Co., Ltd.	¥3.62m	0.01%	lease income only

Suppliers — named (all intra-group)

Rank 1 is again Yuntin Holding at ¥11,317,222,438.31 = 29.33% of FY2025 procurement (reconciles exactly to the filing's related-party purchase total of 1,131,722.23万元). Constituents:

Named supplier (Chinese legal name)	English rendering	FY2025 purchases	% of same-type	What is supplied
云南锡业集团（控股）有限责任公司	Yunnan Tin Group (Holding) Co., Ltd.	¥6.176bn	14.07%	raw materials & fuel, spares, transferred water/power, repairs, leases; exceeded its ¥6.138bn approved cap
云锡澳大利亚TDK资源公司	Yuntin Australia TDK Resources Co.	¥2.434bn	5.55%	raw-material procurement (原料采购); exceeded its ¥2.090bn approved cap by ~16%
云南锡业集团物流有限公司	Yunnan Tin Group Logistics Co., Ltd.	¥1.984bn	4.52%	materials/fuel, equipment, spares, handling, freight, warehousing
云南锡业新材料有限公司	Yunnan Tin New Materials Co., Ltd.	¥220.7m	0.50%	raw-material procurement
云南锡业锡化工材料有限责任公司	Yunnan Tin Tin-Chemical Materials Co., Ltd.	¥176.9m	0.40%	raw-material procurement
云南锡业集团有限责任公司	Yunnan Tin Group Co., Ltd. (controlling shareholder)	¥188.7m	0.43%	raw materials & fuel, spares, utilities, repairs, leases
云南锡业建设集团有限公司	Yunnan Tin Construction Group Co., Ltd.	¥109.6m	0.25%	engineering construction & installation (not a material input)

Trading-book counterparties — disclosed but wholly anonymized

Trading revenue (贸易业务) exceeded 10% of FY2025 revenue, triggering a separate disclosure. Every name is withheld:

Top-5 trade customers: ¥3.966bn total (#1 ¥1.377bn, #2 ¥835.7m, #3 ¥609.5m, #4 ¥586.8m, #5 ¥557.6m)
Top-5 trade suppliers: ¥6.064bn total (#1 ¥3.323bn, #2 ¥1.292bn, #3 ¥628.1m, #4 ¥507.2m, #5 ¥312.7m)

Indium: a new JV vehicle, June 2025

H1-2026 interim update (added 2026-08-20)

Access log — what was tried and what it returned

Sources

Yunnan Tin Co., Ltd. FY2025 annual report (cninfo, filed 2026-03-30) — customer/supplier concentration and related-party counterparties
Yunnan Tin Co., Ltd. H1-2026 semi-annual report (cninfo, filed 2026-08-20) — H1-2026 related-party transaction tables, H1-2025 comparatives, parent stake change
Yunnan Tin Group — Our Company
Yunnan Tin — Wikipedia
Tin Stocks: 10 Biggest Producers — Investing News Network

Named counterparties — who actually buys and sells

The full counterparty breakdownShow

Next mandatory disclosure — Q3-2026 quarterly, due 2026-10-31 (24 days) on SZSE (000960.SZ). rule ↗

Customers · FY2025

Disclosed top-5 32.80%of which related-party 16.29%arm's length 16.51% (derived)

Suppliers · FY2025

Disclosed top-5 42.98%of which related-party 29.33%arm's length 13.65% (derived)

Named suppliers (9)

云南锡业集团（控股）有限责任公司 / Yunnan Tin Group (Holding) Co., Ltd.H1-2025 — → FY2025 14.07% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 1,400,773,103.55.source ↗
FY2025 · Raw materials, fuel, spares, transferred water and power, repairs, leases. Exceeded its RMB 6.138bn approved cap.source ↗
H1-2026 · Purchases/services: RMB 1,778,801,659.54 against a RMB 6,314,400,000.00 board-approved FY2026 quota (not exceeded at half-year). H1-2025 comparative: RMB 1,400,773,103.55.source ↗
云锡澳大利亚TDK资源公司 / Yuntin Australia TDK Resources Co.H1-2025 — → FY2025 5.55% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 1,142,768,763.89.source ↗
FY2025 · The only named foreign-domiciled node in the whole disclosure — RMB 2.434bn of raw-material feed into the Chinese smelter, ~16 percent over its approved cap. The underlying asset is unverified.source ↗
H1-2026 · Raw-material procurement: RMB 1,599,474,731.04 against a RMB 2,100,000,000.00 FY2026 quota (not exceeded at half-year, unlike FY2025 full-year). H1-2025 comparative: RMB 1,142,768,763.89.source ↗
云南锡业新材料有限公司 / Yunnan Tin New Materials Co., Ltd.H1-2025 — → FY2025 0.50% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 123,599,408.79.source ↗
H1-2026 · Raw-material procurement: RMB 148,188,605.75 — already EXCEEDS the RMB 136,000,000.00 FY2026 board-approved quota at the half-year mark (109% of the full-year cap). H1-2025 comparative: RMB 123,599,408.79.source ↗
云南锡业锡化工材料有限责任公司 / Yunnan Tin Tin-Chemical Materials Co., Ltd.H1-2025 — → FY2025 0.40% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 111,078,009.37.source ↗
H1-2026 · Raw-material procurement: RMB 87,007,698.50 against a RMB 120,000,000.00 FY2026 quota. H1-2025 comparative: RMB 111,078,009.37.source ↗
云南锡业建设集团有限公司 / Yunnan Tin Construction Group Co., Ltd.H1-2025 — → FY2025 0.25% of same-type procurement → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 25,121,127.99.source ↗
FY2025 · Engineering construction and installation — not a material input.source ↗
H1-2026 · Purchases/services: RMB 49,756,599.25 against a RMB 210,000,000.00 FY2026 quota. H1-2025 comparative: RMB 25,121,127.99.source ↗
云南锡业集团有限责任公司 / Yunnan Tin Group Co., Ltd. (controlling shareholder)H1-2025 — → H1-2026 —not comparable · no share figure filedrelated party a-share-filing primary-source
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 83,788,733.96.source ↗
H1-2026 · Purchases/services: RMB 78,628,133.56 against a RMB 175,800,000.00 FY2026 quota. H1-2025 comparative: RMB 83,788,733.96.source ↗
云南锡业集团物流有限公司 / Yunnan Tin Group Logistics Co., Ltd.H1-2025 — → H1-2026 —not comparable · no share figure filedrelated party a-share-filing primary-source
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 777,378,965.86.source ↗
H1-2026 · Purchases/services: RMB 3,242,286,555.58 — already EXCEEDS the RMB 1,900,000,000.00 FY2026 board-approved quota at the half-year mark (171% of the full-year cap). H1-2025 comparative: RMB 777,378,965.86 (+317.1%).source ↗
云南锡业集团物流有限公司 / Yunnan Tin Group Logistics Co., Ltd. · FY2025 · both directionsrelated party a-share-filing primary-sourcesection filing ↗
Product sales out 1.93% of same-type; materials/fuel/freight/warehousing in 4.52% of same-type procurement.
云南锡业集团有限责任公司 / Yunnan Tin Group Co., Ltd.0.43% of same-type procurement · FY2025related party a-share-filing primary-sourcesection filing ↗
The controlling shareholder itself.

Named customers (7)

云南锡业集团（控股）有限责任公司 / Yunnan Tin Group (Holding) Co., Ltd.H1-2025 — → FY2025 16.29% of annual sales → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 145,756,303.26.source ↗
FY2025 · Rank-1 customer, but an aggregate roll-up of commonly-controlled subsidiaries (RMB 7.092bn), not a single operating buyer.source ↗
H1-2026 · Sales of goods/services: RMB 312,337,816.86 (H1-2025 comparative: RMB 145,756,303.26, +114.3%).source ↗
云南锡业新材料有限公司 / Yunnan Tin New Materials Co., Ltd.H1-2025 — → FY2025 11.11% of same-type transactions → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 1,988,443,608.47.source ↗
H1-2026 · Sales of goods/services: RMB 1,514,186,751.15 (H1-2025 comparative: RMB 1,988,443,608.47, -23.9%).source ↗
云南锡业锡化工材料有限责任公司 / Yunnan Tin Tin-Chemical Materials Co., Ltd.H1-2025 — → FY2025 5.51% of same-type transactions → H1-2026 —not comparable · shares of different basesrelated party a-share-filing primary-source
Denominator changed between vintages — these are shares of different bases, so no change is computed. Subtracting them would manufacture a number.
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 980,091,617.71.source ↗
FY2025 · Exceeded its RMB 1.700bn board-approved related-party cap.source ↗
H1-2026 · Sales of goods/services: RMB 1,155,947,744.95 (H1-2025 comparative: RMB 980,091,617.71, +17.9%).source ↗
云南锡业集团有限责任公司 / Yunnan Tin Group Co., Ltd. (controlling shareholder)H1-2025 — → H1-2026 —not comparable · no share figure filedrelated party a-share-filing primary-source
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 698,188.45.source ↗
H1-2026 · Sales of goods/services: RMB 714,491.24 (H1-2025 comparative: RMB 698,188.45).source ↗
云南锡业集团物流有限公司 / Yunnan Tin Group Logistics Co., Ltd.H1-2025 — → H1-2026 —not comparable · no share figure filedrelated party a-share-filing primary-source
H1-2025 · H1-2025 comparative from the H1-2026 filing: RMB 287,266,352.98.source ↗
H1-2026 · Sales of goods/services: RMB 1,132,448,202.85 (H1-2025 comparative: RMB 287,266,352.98, +294.2%).source ↗
云南锡业集团物流有限公司 / Yunnan Tin Group Logistics Co., Ltd. · FY2025 · both directionsrelated party a-share-filing primary-sourcesection filing ↗
Product sales out 1.93% of same-type; materials/fuel/freight/warehousing in 4.52% of same-type procurement.
云南锡铟实验室有限公司 / Yunnan Tin-Indium Laboratory Co., Ltd.0.01% of same-type transactions · FY2025related party a-share-filing primary-sourcesection filing ↗
Lease income only. New JV capitalised June 2025 — Yuntin Holding 40 / Yunnan Tin 30 / New Materials 30.

The exposure register

Ranked by buyer-relative risk, highest first.

0 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
Silver	🇲🇽 MX 24% mining	43	43	Moderate	—	—	some	5	▲ rising
Indium	🇨🇳 CN 69% refining	35	64	Low	—	—	limited	2	▲ rising
Copper	🇨🇳 CN 48% refining	34	59	Low	within 48%	—	limited	52	▲ rising
Tin	🇨🇳 CN 55% refining	30	56	Low	—	—	ready	18	▲ rising
Zinc	🇨🇳 CN 32% mining	19	37	Low	—	—	ready	7	▲ rising

Supply-risk factor analysis

The factor-by-factor analysisShow

Material	Geopolitical	Concentration	Price / market	Substitutability	Import reliance	Logistics · ESG · Supplier
Silver	3	1	5	3	3	company input
Indium	4	3	5	3	4	company input
Copper	4	2	5	4	3	company input
Tin	4	2	5	2	3	company input
Zinc	4	2	3	3	2	company input

Material factors (scored 4–5) — evidence

Silver
- 5Price / market: price up, as of 2026-10-07
Indium
- 4Geopolitical: 2 restrictive actions, peak severity 4, 2 in last 24mo
- 5Price / market: price up, as of 2026-10-07
- 4Import reliance: Eurostat Comext 2025: 75% extra-EU imports, top partner BR 60% (partner HHI 4084)
Copper
- 4Geopolitical: 52 restrictive actions, peak severity 5, 33 in last 24mo, less 3 liberalising actions
- 5Price / market: price up, as of 2026-09-01
- 4Substitutability: Graedel et al. 2013 PNAS Fig. 5: 70/100 (long-horizon, all major uses). Prior analyst short-run rating 0.50: USGS: aluminium substitutes in some electrical/heat-exchange uses
Tin
- 4Geopolitical: 18 restrictive actions, peak severity 4, 13 in last 24mo
- 5Price / market: price up, as of 2026-09-01
Zinc
- 4Geopolitical: 7 restrictive actions, peak severity 4, 3 in last 24mo

Named refiners in the supply base

The named refinersShow

Tin

China = 28% of filer-disclosed refiner mentions · 879 named refiners

Refiner	Country	US filers naming it	Source
China Tin Group Co., Ltd.CID1070	China	20	SEC
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

Change log

last 30 days

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.

2026-09-30filedIndia Ministry of Mines launches first offshore mineral block auction (Andaman Sea)
2026-09-17filedUS Commerce Preliminary Affirmative Antidumping Determination: Tin Mill Products from China (September 2026)
2026-09-15filedUS Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)
2026-09-11amendedIndonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform— Kepmen ESDM No. 363.K/MB.01/MEM.B/2026 supersedes the Kepmen 144/2026 HPM formula for low-grade limonite: the nickel Correction Factor (CF) for 1.2%-Ni-or-lower ore is reset to 14% (falling 1pp per 0.1pp of grade below that), and the cobalt by-product coefficient is cut from 30% to 17%. Net effect on 1.2%-Ni ore: HPM falls ~45%, from USD 44.97/wmt to USD 24.89/wmt. The change targets the low-grade limonite/HPAL feedstock segment specifically — the 1.6%-grade CF set by 144/2026 is not disclosed as changed in available reporting.

The laws that threaten it

Restrictive government measures on this company's materials, newest first — each links to its primary government source.

The full list of lawsShow

🇮🇳 India Ministry of Mines launches first offshore mineral block auction (Andaman Sea)New since 2026-09-07
2026-09-30· industrial-policy· severity 2· cobalt, nickel, manganese, copper
🇺🇸 US Commerce Preliminary Affirmative Antidumping Determination: Tin Mill Products from China (September 2026)New since 2026-09-07
2026-09-17· tariff· severity 4· tin, steel
🇺🇸 US Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)New since 2026-09-07
2026-09-15· tariff· severity 4· tin, steel
🇵🇪 Peru DS 014-2026-EM — Mining exploration DIA fast-track platform threshold raised 40→60
2026-07-20· regulatory· severity 2· copper
🇺🇸 US USTR Section 301 Determination — Proposed 25% Tariff on All Brazilian Goods
2026-06-04· tariff· severity 3· niobium, copper, iron-ore
🇺🇸 US Proclamation 11032 — Further Adjusting Section 232 Tariff Regimes for Aluminum, Steel, and Copper
2026-06-01· tariff· severity 2· aluminum, steel, copper
🇨🇩 DRC Ministerial Suspension of All Mining in Mwenga and Shabunda (South Kivu)
2026-05-22· regulatory· severity 3· gold, coltan, cassiterite
🇺🇸 US OFAC April 30 2026 — designation of former DRC President Joseph Kabila under EO 13413/13671 for material support to M23 and Congo River Alliance (AFC)
2026-04-30· sanction· severity 3· cobalt, copper, coltan, tantalum
🇪🇬 Egypt PM Decree No. 1440/2026 — Executive Regulations of Mineral Resources Law 198/2014
2026-04-29· regulatory· severity 3· gold, phosphate, tantalum, copper
🇨🇳 China Customs Tariff Commission — Zero-Tariff Treatment for All 53 African Diplomatic Partners (May 2026–April 2028)
2026-04-28· tariff· severity 3· cobalt, copper, bauxite, lithium
🇪🇺 EU Myanmar Restrictive Measures Extended to April 2027 (Council Decision (CFSP) 2026/927)
2026-04-27· sanction· severity 2· heavy-rare-earths, tin
🇮🇩 Indonesia Kepmen ESDM No. 144.K/MB.01/MEM.B/2026 — Nickel Ore Multi-Element HPM Benchmark Price Reform
2026-04-10· industrial-policy· severity 3· nickel, bauxite, cobalt, copper
🇺🇸 US Section 232 Strengthening Proclamation 11021 — Aluminum, Steel, Copper consolidation (50%/25%/10%/0% tier architecture)
2026-04-02· tariff· severity 2· steel, aluminum, copper
🇮🇩 Indonesia Permendag 5/2026 — fourth amendment to Permendag 23/2023: export licensing digitalisation, ilmenite/rutile IUP/IUPK restriction, tin ET elimination
2026-03-26· regulatory· severity 3· tin, ilmenite, rutile
🇿🇲 Zambia SI 17/2026 — Control of Goods (Prohibition of Export) (Sulphuric Acids) Order, 2026
2026-03-20· export-control· severity 2· copper, cobalt

+ 54 more in the register.

Art. 24(2)(c) · vulnerability to disruption

Stress test — two plausible scenarios

Both stress-test scenariosShow

Policy shock — the controlling country escalates to a full export-licensing / ban regime.
Concentration shock — the supply structure collapses to a single source (second-source loss / full monopoly).

Type	Scenario	Today	Stressed	Δ
Policy	Silver — 🇲🇽 MX escalates silver controls to a full export-licensing / ban regime	43	52	+9
Concentration	Silver — 🇲🇽 MX becomes the single source for silver — the second source is lost (full 24%+ monopoly)	43	73	+30
Policy	Indium — 🇨🇳 CN escalates indium controls to a full export-licensing / ban regime	35	38	+3
Concentration	Indium — 🇨🇳 CN becomes the single source for indium — the second source is lost (full 69%+ monopoly)	35	41	+6
Policy	Copper — 🇨🇳 CN escalates copper controls to a full export-licensing / ban regime	34	35	+1
Concentration	Copper — 🇨🇳 CN becomes the single source for copper — the second source is lost (full 48%+ monopoly)	34	43	+9

Art. 24(4) · mitigation trigger

Significant-vulnerability conclusion

Proposed — not yet law

Upcoming regulatory threats

The upcoming threatsShow

🇨🇩 DRC — Interministerial Arrêté Banning Export of Unprocessed Copper and Cobalt Concentrates (29 June 2026, replaces 4 August 2023 framework)
passed-vote→high likelihood·flagged 57d ago · not yet law·matches Copper
If passed — On 29 June 2026 DRC's Vice-Prime Minister for the National Economy (Daniel Mukoko Samba), Minister of Mines (Louis Watum Kabamba) and Minister of Foreign Trade (Julien Paluku Kahongya) jointly signed an arrêté interministériel regulating the commercialisation, export and nomenclature of marketable mining products, which for the first time BANS the export of unprocessed copper and cobalt concentrates outright — replacing the entire framework adopted 4 August 2023. Mining-rights holders, processing entities and buying counters (comptoirs) may seek a ministerial derogation to export less-elaborated products for up to one year, assessed against national mining policy and the technical/economic constraints of each mineral. A new tax regime for economically significant mining byproducts is introduced with a 3-month transition period. This is broader and more foundational than the existing filed/queued DRC cobalt-specific instruments — it is a national concentrate EXPORT BAN (not a quota or hydroxide-specific measure) covering BOTH copper and cobalt, issued under joint Economy/Mines/Trade authority rather than ARECOMS sectoral rulemaking. DRC = priority-tier chokepoint (cobalt, copper, tantalum). Severity 4 expected (national ban, dual-metal, replaces a 3-year-old framework).
Caveat — ENACTED / already in force (signed 29 June 2026, five independent Congolese/international outlets corroborate the ministers, date and substance) but parked here per the standing DRC convention (mines. gouv. cd / primature. gouv. cd / jocc. cd unreachable per prior wakes — same constraint noted on the DRC Strategic Mineral Reclassification, ARECOMS forfeiture, and 5% Worker Equity entries elsewhere in this file). DISTINCT from: 2025-02-22-drc-arecoms-cobalt-export-ban-quota-system (ARECOMS sectoral cobalt-hydroxide quota system, cobalt-only), 2025-12-19-drc-artisanal-copper-cobalt-processing-suspension (artisanal-sector only), the queued ARECOMS H1-2026 quota-forfeiture entry above (operationalises the ARECOMS quota, not this arrêté), 2026-04-10-drc-strategic-reserve-minerals-arecoms, and 2026-05-29-drc-strategic-mineral-expansion-decree. This arrêté is the FIRST instrument in the register banning concentrate exports for BOTH copper and cobalt jointly and replacing the 2023 commercialisation/export/nomenclature framework wholesale — a materially broader legal basis than any of the above. Re-check mines. gouv. cd and jocc.
https://actualite.cd/2026/08/06/rdc-kinshasa-interdit-lexportation-des-concentres-de-cuivre-et-de-cobalt-pour-encourager
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇿🇲 Zambia SI No. 43 of 2026 — Customs and Excise (Suspension) (Copper Concentrates) (No. 2) Regulations, 2026
passed-vote→high likelihood·flagged 68d ago · not yet law·matches Copper
If passed — Minister of Finance, acting under s. 89 of the Customs and Excise Act, cut the copper-concentrate export duty to ZERO for tariff headings 2603. 00. 21 / 2603. 00. 22 / 2603. 00. 23 / 2603. 00. 29, capped at 271,742 t, effective 1 June 2026 with automatic lapse 30 September 2026, with per-entity tonnage caps and (per one secondary) a requirement that exempt shipments channel through Industrial Resources Limited. This is a SUPPLY-RELIEF (liberalising) action — a net EASING of a copper/cobalt chokepoint for ~4 months, explicitly to clear stockpiled unprocessed concentrate while Zambia's major smelters are down for extended maintenance. It is the "(No. 2)" successor instrument to the already-filed 2026-03-05-zambia-si-15-2026-copper-concentrates-export-duty-suspension (a distinct SI with its own number, tonnage cap and validity window). Severity ~2 expected.
Caveat — ENACTED / already in force per multiple independent secondary sources (all agree on SI number, exact citation title, s. org URL pattern that resolves for the parent SI 15/2026 (`/akn/zm/act/si/2026/43/eng@<date>`) across several plausible dates, all 404; zambialii's SI-list index page for 2026 also 404s directly. Parked here per the standing verify-or-don't-file convention (cf. DRC ARECOMS, Pakistan chloroform, China sulfuric-acid entries below) rather than filed on secondaries alone. Re-check zambialii.
https://www.zambiamonitor.com/govt-suspends-export-duty-on-copper-concentrates/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
African Union — African Union / AfDB — continental harmonisation of mining legislation toward a ban on unprocessed critical-mineral ore exports (Abidjan Ministerial Forum outcome)
announced→low likelihood·flagged 68d ago · not yet law·matches Copper
If passed — On 10 July 2026 the African Development Bank Group, with the African Union Commission, the AfCFTA Secretariat and UNECA, convened African ministers of mining/energy/industry in Abidjan for the "Ministerial Forum on Critical Minerals Value Chain and Beneficiation: Pathways for African Transformation". The stated ambition is continental: move the bloc off raw-ore exports toward regional value chains and in-country processing, with reporting of a push to HARMONISE African mining legislation by end-2026 around a ban on unprocessed ore exports, alongside a headline mobilisation figure of ~USD 63bn for critical-minerals value-chain investment. Why this matters as axis-2 early warning rather than noise: the register already holds a dense cluster of INDIVIDUAL national instruments moving in exactly this direction — Zimbabwe's 2026-02-25 indefinite raw-mineral/lithium-concentrate export suspension, Guinea's 2026-06-19 raw-gold export ban + domestic-refining mandate, Gabon's announced 2029 crude-manganese export ban, Nigeria's RMRDC 30% value-addition bill, Indonesia-style downstreaming copied across the continent, and CEMAC's regional Common Mining Code (all already filed or queued). A binding AU/AfCFTA-level harmonisation instrument would convert that scattered set into a coordinated continental supply shock across cobalt, copper, bauxite, manganese and lithium simultaneously — which is a materially different exposure event from any single-country ban, because it removes the substitute-jurisdiction escape route that currently absorbs each national ban.
Caveat — DELIBERATELY likelihood=low, not moderate. com) is low-quality and was NOT relied on. AU-level harmonisation instruments historically take years and frequently stall at the model-law stage (cf. the known ecb-spf 400 pattern) to establish whether a formal Abidjan Declaration text exists and what it actually commits signatories to.
https://www.afdb.org/en/documents/high-level-ministerial-forum-critical-minerals-value-chain-and-beneficiation-pathways-african-transformation
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇨🇳 China — MOFCOM/GACC suspension of ordinary industrial & smelter-byproduct sulfuric acid exports (in force from 1 May 2026)
passed-vote→high likelihood·flagged 74d ago · not yet law·matches Copper
If passed — Effective 1 May 2026 China suspended exports of all ordinary industrial sulfuric acid — including the acid co-produced from copper/zinc smelting — with only electronic-grade high-purity acid still exportable under special approval; reporting attributes the measure to a joint Ministry of Commerce (MOFCOM) + General Administration of Customs (GACC) notice, expected to run through end-2026. Sulfuric acid is the indispensable leach/process input for copper hydrometallurgy (SX-EW), phosphate-fertilizer production, and battery-metal (nickel HPAL, lithium) processing, so a China export halt tightens a systemic upstream chokepoint hitting seaborne-acid buyers (Chile/Peru copper, Morocco/India phosphate, Indonesia nickel). This is a DISTINCT instrument from the already-filed 2025-12-12-china-ndrc-phosphate-fertilizer-export-suspension (finished-fertilizer export control) and 2026-03-31-russia-decree-350-sulphur-export-ban-extension (elemental sulphur, different country/product) — it controls the acid itself.
Caveat — ENACTED / in force per multiple independent secondary sources (S&P Global, SCMP, MINING. the parked H200 window-guidance item). Parked here per the standing verify-or-don't-file convention rather than filed. Re-check mofcom. gov. md as a distinct export-control action.
https://www.spglobal.com/energy/en/news-research/latest-news/metals/041526-chinas-sulfuric-acid-restrictions-set-to-squeeze-miners
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇰🇿 Kazakhstan Subsoil Code 2026 amendments — domestic-content rise to 70% (incl. uranium), geological-data digitisation, e-auctions, strategic-investor priority right
passed-vote→high likelihood·flagged 100d ago · not yet law·matches Copper
If passed — Senate-approved package of amendments to Kazakhstan's Code on Subsoil and Subsoil Use (No. 125-VI ZRK): (1) raises the mandatory local (domestic) content share in works and services from 50% to 70% during exploration and extraction of solid minerals INCLUDING URANIUM — a material new in-country-value obligation on the world's #1 uranium producer (Kazatomprom) and its JV partners (Cameco, Orano, CGN/CNNC, Uranium One); (2) digitises geological data and expands electronic auctions for granting subsoil-use rights; (3) grants strategic investors implementing large industrial/innovation projects (>14. 5M MCI) a priority right to explore and extract solid minerals. Re-prices the cost base and access regime for Kazakh uranium, copper, chromium and the country's emerging rare-earth deposits.
Caveat — DISTINCT from filed 2025-12-26 Subsoil Code amendment (that one granted Kazatomprom statutory PRIORITY over uranium blocks specifically); this 2026 package is the broader 50%→70% local-content + digitisation + e-auction + strategic-investor-priority reform — different provisions, same Code. Also distinct from filed 2025-07-18 Tax Code No. 214-VIII (uranium MET restructure + solid-mineral royalty). Senate passage = awaiting presidential signature; high likelihood. Severity 2-3 (raises operating cost + tightens access for a global uranium chokepoint).
https://senate.parlam.kz/en-US/news/details/14628
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 15-20% stake acquisition in First Quantum Minerals' Zambian copper-nickel assets
announced→low likelihood·flagged 101d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in advanced negotiations to acquire a 15-20% equity stake (deal value ~USD 1. 5-2bn) in First Quantum Minerals' Zambian copper and nickel operations — i. e. the Kansanshi and Sentinel/Trident copper complex (Zambia's largest copper mines, ~0. 4-0. 5 Mt/yr combined) plus nickel. This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) directly into a binding African copper chokepoint, paralleling Manara's filed Vale Base Metals 10% stake (2024-03-01-sa-manara-minerals-vale-metals-10pct-stake) and its in-negotiation Reko Diq stake (queued below), and mirroring UAE IRH's Mopani (Zambia) acquisition. Gives Saudi Arabia an equity claim on a major non-China copper supply source and injects fresh capital into FQM as it recovers from the Cobre Panamá shutdown — a Gulf-capital re-pricing of Zambian copper supply risk that the exposure engine should track.
Caveat — As of 2026-06-28 this is in advanced negotiation, no signed SPA — hence announced/upcoming not enacted. DISTINCT from the Reko Diq (Pakistan) Manara stake queued below (different asset, different host country) and from the filed Vale Base Metals 10% stake. If completed, severity 2-3.
https://www.miningsee.eu/saudi-arabias-manara-minerals-eyes-stake-in-first-quantums-zambian-copper-and-nickel-assets/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇧🇷 Brazil PNMCE — Política Nacional de Minerais Críticos e Estratégicos (PL 2780/2024)
passed-vote→high likelihood·flagged 110d ago · not yet law·matches Copper
If passed — First federal statutory framework for critical and strategic minerals; establishes CMCE oversight committee, R$2B Mineral Activity Guarantee Fund (0. 2% gross revenue levy on critical-mineral companies), mandatory 0. 3% gross revenue R&D investment, 20% tax credits for domestic mineral transformation projects; limits raw-mineral exports where domestic processing capacity exists; covers niobium explicitly (CBMM/CMOC supply ~85% of global niobium — Brazil is a structural chokepoint); Chamber passed 343-97 on 7 May 2026, Senate review pending
Caveat — Consolidates 14 prior legislative proposals. Key contested provision: CMCE review/veto power over exports — mining lobby opposed, may resurface in Senate. Distinct from filed 2024-01-22-brazil-nova-industria-brasil-nib, 2024-09-11-brazil-brasil-semicon-program, 2024-08-02-brazil-lei-14948-low-carbon-hydrogen-framework, 2025-04-11-brazil-lei-15122-economic-reciprocity-law. First action to explicitly frame niobium as a strategic supply-chain anchor.
https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2447259
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇺🇬 Uganda Mining and Minerals (Amendment) Bill 2026
in-consultation→moderate likelihood·flagged 116d ago · not yet law·matches Tin
If passed — Mandates 15% free-carried interest for Uganda National Mining Company (UNMC) in all new mining licences; introduces mandatory mineral buying centres; tightens local-content and value-addition obligations — changes joint-venture economics for all new Ugandan mining operations, raising effective cost-of-entry for foreign miners
Caveat — Amends the already-filed Uganda Mining and Minerals Act 2022 (UG action 1); expected to be enacted before end of 2025/26 parliamentary session per legal commentary; Bank of Uganda gold purchase programme and new mineral buying centres already being piloted — regulatory infrastructure being built ahead of formal enactment. Distinct from filed Uganda Gold Export Regulations 2024 (SI No. 30 of 2024).
https://globallawexperts.com/uganda-mining-law-changes-2026/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Tin🇨🇳 today 30→31+1
🇮🇩 Indonesia Tin Export Ban — Downstreaming Initiative
announced→low likelihood·flagged 115d ago · not yet law·matches Tin
If passed — Indonesia = ~20% of global refined tin exports (Bangka Belitung); a ban on refined-tin exports would force downstream solder/semiconductor-packaging manufacturing domestically; disrupts global electronics and EV supply chains dependent on Indonesian tin solder and specialty alloys
Caveat — Minister of Energy and Mineral Resources Bahlil Lahadalia announced government "studying" tin export ban on February 13, 2026 at the Indonesia Economic Outlook, Jakarta; framed as replication of 2020 nickel ore ban which claimed 10x value-add uplift; key complication — Indonesia already exports refined tin (not raw ore), so a ban would require immediate creation of advanced downstream industries (solder, electronic-grade tin, semiconductor components) that don't yet exist at scale; Mining Weekly (Feb 13 2026) and BERNAMA (Feb 2026) confirm announcement; no Perpres, PP, or Kepmen issued as of June 14, 2026; government described as "studying" — not yet in formal regulatory drafting. Distinct from filed Indonesia nickel ore export bans (2019, 2023), filed bauxite export ban, and filed Permendag export-licensing amendments.
https://indonesiabusinesspost.com/6137/policy/indonesia-s-potential-tin-export-ban
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Tin🇨🇳 today 30→31+1
🇳🇬 Nigeria RMRDC 30% Value Addition Bill — mandatory 30% local processing of ALL raw materials before export
awaiting-signature→high likelihood·flagged 115d ago · not yet law·matches Tin, Zinc
If passed — Prohibits raw mineral exports unless 30% value-addition achieved domestically; affects Chinese mining companies (dominant in Nigerian critical minerals sector), Western offtake agreements, and all foreign-invested mining JVs; builds on existing eMC+ digital cadastre and mandatory value-addition plans introduced Nov 2024; could force processing-plant investment or suspension of raw mineral shipments from Africa's most populous economy; RMRDC = Raw Materials Research and Development Council (the sponsoring agency)
Caveat — Bill passed third reading in House of Representatives; multiple Nov 2025 sources confirm both chambers approved; as of 2026-06-14 presidential signature not yet confirmed. Distinct from filed Nigeria Tax Reform Acts 2025 (Loi n°1/19 tax restructuring) and Mining Cadastral licence revocations (2025-06-19). Applies to ALL raw materials, not minerals only — IPTM relevance is the mineral export provisions.
https://www.nationalaccordnewspaper.com/turning-point-for-nigeria-as-rmrdcs-30-value-addition-bill-nears-presidential-assent/
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Tin🇨🇳 today 30→31+1
- Zinc🇨🇳 today 19→22+3
🇵🇪 Peru Ley General de Minería Amendment — Mining Concession Regime Reform
passed-committee→elevated likelihood·flagged 115d ago · not yet law·matches Copper, Silver, Zinc
If passed — Reduces maximum idle-concession period from 30 to 15 years (initial production deadline unchanged at 10 yr; penalty extension cut from 20 yr to just 5 yr); eliminates irrevocable legal status of mining concessions for first time in Peruvian law history, making concessions revocable by administrative authority; introduces higher annual fees and stronger production/investment requirements; threatens legal certainty for Peru's undeveloped copper and silver project pipeline — Peru = #2 copper, #4 silver, #1 lead, #2 zinc globally
Caveat — Approved by Energy and Mining Commission March 17, 2026 by 11 votes to 1 with 3 abstentions — driven by left-aligned Juntos por el Perú (JPP) and Podemos Peru majority. Bill also introduces "comuneros como accionistas" (community shareholders) in mining concessions — first legislative insertion of indigenous community equity rights. MINEM, SNMPE, ComexPerú, and Ingemmet publicly opposed; MINEM warns reform would incentivise illegal mining expansion. Full plenary debate pending as of June 2026. Distinct from all filed PE actions (all executive/regulatory decrees — no prior legislative amendment to Ley General de Minería in register). Also distinct from filed PE actions on REINFO extension (2025-12-26), illegal-mining criminalization (2026-01-20), and Tía María revocation (2026-03-19).
https://elcomercio.pe/economia/peru/comision-de-energia-aprueba-cambios-en-la-ley-de-mineria-y-reaviva-alertas-por-impacto-en-inversion-y-estabilidad-juridica-noticia/
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 34→35+1
- Silver🇲🇽 today 43→52+9
- Zinc🇨🇳 today 19→22+3
🇪🇺 EU CRMA Art. 22 Commission Implementing Decision — Strategic Raw Material Stock Benchmarks
awaiting-signature→high likelihood·flagged 114d ago · not yet law·matches Indium
If passed — Establishes the first legally binding "safe level" benchmark for EU strategic stocks of each of the 17 strategic raw materials listed in the CRMA Annex I; benchmarks used as reference by Member States, financial institutions, and industrial consumers to assess strategic supply risk; mandated every 2 years, so this is the first edition setting the baseline; informs CRMA Art. 23 monitoring obligations and is the evidential basis for Art. 24 corporate-reporting thresholds
Caveat — The May 24, 2026 deadline set by Parliament and Council in Reg. (EU) 2024/1252 has now passed. No OJ publication confirmed as of June 15, 2026 — Commission may have adopted quietly or is overdue. This is the first CRMA Art. 22 benchmark cycle and is legally distinct from: (1) the CRMA base regulation (filed 2024-05-23); (2) the Strategic Projects first designation (filed 2025-03-25); (3) the RESourceEU Amendment — CRMA revision (filed 2026-03-04). If confirmed adopted, severity=2 (establishes the measurement baseline for EU strategic material supply risk assessment and directly feeds corporate Art. 24 reporting obligations). Distinct from all filed EU-CRMA actions. Not in filing. md or upcoming. md.
https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Indium🇨🇳 today 35→38+3
🇮🇩 Indonesia PP 19/2025 Mining Royalty Rate Hike — Implementation Postponed Indefinitely (May 2026)
announced→low likelihood·flagged 113d ago · not yet law·matches Copper, Tin, Silver
If passed — The Energy and Mineral Resources Ministry (ESDM) and Ministry of Finance announced May 11, 2026 that the implementation of higher tiered royalty rates under Government Regulation (PP) 19/2025 — covering copper, tin, nickel, gold, and silver — is postponed indefinitely pending development of a "mutually beneficial formulation"; the already-filed PP 19/2025 (2025-04-11) established a tiered royalty regime that would have raised effective royalty burdens for large-volume miners; the postponement relieves immediate cost pressure on Freeport McMoRan (copper/gold — Grasberg), Vale Indonesia (nickel), PT Timah (tin), and other major operators; the delay also signals continued investor-consultation sensitivity in Indonesian mining fiscal policy following industry pushback
Caveat — This is an amendment-trigger candidate: the formal revision to PP 19/2025 does not yet exist; only a minister's public announcement through the state news agency. Not yet a Government Regulation. Severity of the underlying PP 19/2025 was 3; this postponement reduces near-term supply-chain fiscal pressure on Indonesian nickel/copper miners but signals policy instability. Public hearing held May 8, 2026 with no final decisions (Mysteel, May 12, 2026). Distinct from all 25 filed Indonesia actions. Filed upcoming 2026-06-16.
https://en.antaranews.com/news/415656/indonesia-delays-mining-royalty-and-export-levy-plan
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
- Tin🇨🇳 today 30→31+1
- Silver🇲🇽 today 43→52+9
🇧🇴 Bolivia nueva Ley de Minería — comprehensive replacement of the 2014 Ley 535 de Minería y Metalurgia
draft-published→moderate likelihood·flagged 112d ago · not yet law·matches Tin, Silver, Zinc, Copper
If passed — New general mining law (distinct from PL-157 lithium/evaporites bill already in index): 20-year tax stability regime for mining projects; eliminates the 12. 5% impuesto adicional IUE-RM on extraordinary commodity-price gains; retains 25% company profits tax (IUE) and 5% royalty; streamlines licensing from current 9–15 years to international norms; enables association contracts between private companies and cooperatives; coordinated with a forthcoming general investment law incorporating fiscal and non-fiscal incentives; framed around reversing 15+ years of investment drought; backing from World Bank; bill to be presented to Asamblea Legislativa Plurinacional after Mining Summit (May 18–20, 2026); target: executive submission late July 2026
Caveat — Distinct from 2026-02-01-bolivia-pl-157-recursos-evaporiticos (lithium-only evaporitícos bill; this is the general mining law replacing Ley 535 for ALL mineral sectors) and 2025-12-17-bolivia-ds-5503-economic-emergency (fuel subsidies/fiscal package). Bolivia = world's 7th-largest tin producer and holds the world's largest known lithium resources; the Paz government reform is the most significant pro-investment mining signal since the 2014 Ley 535. Likelihood moderate — new government with World Bank backing but legislative timeline uncertain; Bolivia protests history (2026 protests wiki) creates social-risk overlay. Filed upcoming 2026-06-17.
https://www.mineria.gob.bo/index.php/nota_prensa/bolivia-activa-reforma-minera-integral-y-sale-a-captar-inversiones-con-respaldo-del-banco-mundial/
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Tin🇨🇳 today 30→31+1
- Silver🇲🇽 today 43→52+9
- Zinc🇨🇳 today 19→22+3
- Copper🇨🇳 today 34→35+1
🇺🇸 USTR Plurilateral Agreement on Trade in Critical Minerals
in-consultation→moderate likelihood·flagged 111d ago · not yet law·matches Copper
If passed — Binding plurilateral trade agreement among like-minded partners (US, EU, Japan and FORGE coalition members) establishing coordinated trade measures for critical mineral supply chains — including border-adjusted price floors, standards-based market access conditions, price-gap subsidies, and off-take agreement frameworks — to counter non-market pricing from state-backed producers and reduce concentrated supply-chain dependency; would create the first binding multilateral trade-law instrument specifically governing critical minerals flows, operating parallel to and distinct from the WTO goods schedule
Caveat — Distinct from FORGE (Forum on Resource Geostrategic Engagement, already filed as 2026-02-04-us-forge-critical-minerals-coalition — a diplomatic coordination platform, not a binding trade instrument); distinct from the filed bilateral action plans (US-Mexico 2026-02-04, US-Japan 2026-03-19, US-EU 2026-04-24 — these are bilateral work programmes, not the binding multilateral trade agreement being designed). Public comment period launched February 5, 2026; partners in scope include FORGE member states + EU. If finalised, this would be the highest-severity IPTM action in the register — creates a binding legal framework reshaping the economics of critical mineral trade globally. Context: companion to the US-EU-Japan joint statement of February 4, 2026 which directed the three parties to "develop Action Plans and explore a plurilateral trade initiative with like-minded partners on trade in critical minerals, which could include exploring the development of coordinated trade policies and mechanisms, such as border-adjusted price floors. "
Reference-class base rate
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 ↗
https://ustr.gov/about/policy-offices/press-office/press-releases/2026/february/ustr-seeks-public-comment-design-plurilateral-agreement-trade-critical-minerals-and-policy-actions
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 34→35+1
🇵🇬 Papua New Guinea Mining Bill 2025 — parliamentary enactment (replacement of Mining Act 1992)
announced→low likelihood·flagged 111d ago · not yet law·matches Copper
If passed — Full replacement of the Mining Act 1992 with sweeping new statute: state acquires up to 30% equity in any new mining project (Kumul Minerals free-carry); special mining leases (SML) issued for initial 30-month periods with FID requirement to renew; mandatory landowner and community consultation before licence grant; Mining Development Authority (MDA) replaces current Mineral Resources Authority (MRA) as the sector regulator; CGT on extractive asset transfers now in force since the 2025 Income Tax Act (separate filed action); bill as drafted would reshape FDI terms for all existing and future mining permits including Wafi-Golpu (Newmont/Harmony 26 Moz Au, 4. 8 Mt Cu — SML long-delayed), Frieda River copper-gold (PanAust), and Ok Tedi expansion; PNG's 2023 Mining (New Porgera) Amendment Act handled Porgera separately
Caveat — The public-consultation-draft stage is already filed in the register as 2025-02-25-papua-new-guinea-mining-bill-2025 (filed action records the consultation launch). This upcoming entry tracks the NEXT stage: parliamentary enactment. Consultations closed April 4, 2025; minister aimed for September 2025 tabling but no confirmed passage found as of June 2026. Likelihood moderate — bill has broad government backing and a 15-year development history, but PNG legislative timelines are frequently extended; the May 2025 Marape cabinet reshuffle may have shifted ministerial priorities. Distinct from: 2023-10-13-papua-new-guinea-mining-new-porgera-amendment-act (single-mine statute); 2025-03-12-papua-new-guinea-national-petroleum-authority-act (petroleum, not mining); 2025-03-20-papua-new-guinea-income-tax-act-2025 (CGT on extractive transfers — already enacted separately).
https://www.businessadvantagepng.com/papua-new-guineas-draft-mining-bill-sweeping-reforms-to-overhaul-the-sector/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇹🇿 Tanzania Finance Bill 2026/27 — Parliament-passed June 23, 2026; mining: Mineral Research Fund (10% gross mineral revenue), Income Tax Act & VAT Framework Agreement exemptions
awaiting-signature→high likelihood·flagged 103d ago · not yet law·matches Copper
If passed — TZ Finance Bill establishes the Mineral Research Fund capitalised at 10% of gross mineral revenue (~TZS 141 billion/yr at 2025 collection levels); amends the Income Tax Act to formally recognise tax exemptions granted under individual mining Framework Agreements and introduces standard operating procedures — reduces discretionary government risk for large mining investors (Panda Hill niobium, graphite juniors, Buzwagi gold); parallel VAT amendments give equivalent statutory certainty for VAT exemptions; taken together, the bill moves Tanzania from discretionary tax administration toward a rule-of-law-based investor regime for all critical-mineral projects; budget targets Tanzania for top-4 niobium producer status (Panda Hill DA already signed March 24, 2026) and 50% geophysical survey coverage by 2030
Caveat — Tanzania fiscal year starts July 1; the Finance Act signature typically occurs last week of June. Budget speech delivered June 11, 2026 by Finance Minister Khamis Mussa Omar; Parliament approved June 23. Mining provisions in §§ amending Income Tax Act (Cap. 332) and VAT Act (Cap. 148) and establishing the Mineral Research Fund. Distinct from: filed 2025-06-30-tanzania-finance-act-11-of-2025 (prior year), filed 2026-03-24-tanzania-panda-hill-niobium-ferroniobium-development-agreement (the specific project DA), and filed 2026-04-15-tanzania-ministry-of-minerals-revokes-40-idle-mineral-exploration-licences. Severity 2: institutional reform that de-risks the investor regime rather than a direct trade restriction.
https://www.tanzaniainvest.com/economy/budget-2026-2027-parliament-approved
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇨🇩 DRC Mines Minister Circular — 5% Worker Equity Enforcement (Articles 71 bis + 144 bis), January 30 2026
announced→low likelihood·flagged 106d ago · not yet law·matches Copper
If passed — All DRC mining operators (Glencore, CMOC, Ivanhoe Mines, Eurasian Resources Group, and 50+ others) must transfer 5% of share capital to Congolese employees by July 31, 2026 or face permit suspension; effectively forces equity restructuring across the entire DRC copper-cobalt belt; miners seeking moratorium as of June 18, 2026 — enforcement outcome by August 2026 will set the precedent
Caveat — Ministerial enforcement letter issued January 30, 2026 by Mines Minister Louis Watum Kabamba — activates dormant Art. 71 bis (5% employee equity in mining company capital) and Art. 144 bis (mechanics) of DRC Mining Code (Loi n° 18/001). Filed here (not filing. md) because DRC government websites (mines. gouv. cd, primature. gouv. cd) remain inaccessible per prior wakes — same constraint as the DRC Strategic Mineral Reclassification entry. Action IS already in effect and enforcement is underway (July 31, 2026 deadline); this is NOT speculative. DRC Chamber of Mines convened June 11, 2026 industry response meeting; companies arguing retroactive application is legally contested. Severity 3 expected if enforced. Distinct from: 2018-01-27-drc-mining-code-revision (underlying law), 2026-04-10-drc-strategic-reserve (ARECOMS mechanism), 2026-04-24-drc-tshisekedi-mining-export-revenue-audit.
https://www.kitco.com/news/off-the-wire/2026-06-18/congo-miners-seek-delay-5-worker-equity-rule-july-deadline
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇺🇸 US BOEM Proposed Rule — Administrative Revisions to OCS Hard Minerals Regulations (FR Doc. 2026-03690)
passed-committee→elevated likelihood·flagged 106d ago · not yet law·matches Copper
If passed — Revises 30 CFR Part 580 to streamline 10 provisions governing prospecting, leasing, and operations for hard minerals (manganese nodules, cobalt-rich crusts, seafloor massive sulfides) on the US Outer Continental Shelf; eliminates environmental notification to adjacent state governors (§580. 31) and BOEM's own environmental review requirement (§580. 29); accelerates OCS hard mineral leasing pipeline in line with EOs 14285 and 14154 ("unleashing" OCS resources); comment period closed April 27, 2026; awaiting final rule
Caveat — First substantive revision of US OCS hard minerals regulatory framework in ~35 years; distinct from all filed US actions (no prior OCS hard minerals action in register). Severity 2: regulatory infrastructure that enables future OCS leasing rather than a direct production/export instrument; secondary-boem: https://www. boem. gov/newsroom/press-releases/boem-proposes-rule-changes-support-critical-mineral-exploration-and
Reference-class base rate
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 ↗
https://www.federalregister.gov/documents/2026/02/24/2026-03690/administrative-revisions-to-regulations-related-to-outer-continental-shelf-minerals-other-than-oil
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 34→35+1
🇮🇳 India SASCI Mining Sector Reforms Component FY2026-27 — ₹5,000 crore incentive scheme to accelerate mine auction-to-production pipeline
announced→low likelihood·flagged 103d ago · not yet law·matches Copper
If passed — Ministry of Mines issued operational guidelines for the Mining Sector Reforms component under Scheme for Special Assistance to States for Capital Investment (SASCI) FY2026-27, with total ₹5,000 crore (~USD 600M) incentive envelope to states; key components: (i) ₹250 crore one-time incentive to any state where ≥10% of pre-March-2026 auctioned major mineral blocks begin production+dispatch by end-2026; (ii) ₹100 crore baseline for systemic reforms (Unified Mining Portal integration, Pre-Auction Committees); (iii) ₹20 crore per block auctioned with pre-embedded forest and environmental clearances; scheme targets removing the "auction gap" — India has auctioned hundreds of mineral blocks since 2015 MMDR amendments but operationalisation lag remains a structural bottleneck; critical minerals relevance: India is running parallel programme of critical+strategic mineral auctions (7 tranches, 56 blocks auctioned by June 24, 2026) and this scheme incentivises states to bring those blocks into production faster; directly accelerates lithium (Rajasthan), REE (Andhra Pradesh, Tamil Nadu), graphite (Odisha), and nickel (Odisha, Jharkhand) pipelines
Caveat — Source is secondary (PolicyEdge news aggregator). To migrate to filing. md, filer must verify the primary notification on mines. gov. in or pib. gov. in (search "SASCI Mining 2026-27" on PIB search). India BHAVYA industrial parks scheme (₹33,660 crore, March 18, 2026) is separately filed — SASCI is a distinct scheme targeting state-level mining-sector governance reform. Distinct from filed India Union Budget 2026-27 Customs notifications and Semiconductor Mission 2. 0. Severity 2 (supply-side demand-unlock rather than export control or FDI gate).
https://www.policyedge.in/p/centre-launches-5000-crore-incentive-scheme-to-speed-up-mine-auctions-and-production
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇲🇳 Mongolia Minerals Law Comprehensive Amendment 2026 — ~40% of 2006 law revised; exploration-licence term cut, statutory critical-minerals definition, downstream-beneficiation licensing
draft-published→moderate likelihood·flagged 102d ago · not yet law·matches Copper
If passed — Mongolia's cabinet approved and submitted to the State Great Khural a draft amending ~40% of the 2006 Minerals Law: (i) cuts the maximum exploration-licence duration from 12 to 6 years while raising holding fees (to curb speculative licence-trading/flipping); (ii) introduces a STATUTORY definition of "critical minerals" (aligned to Mongolia's 11-mineral list: molybdenum, manganese, nickel, copper, fluorspar, graphite, REEs, cobalt, lithium, PGMs, tungsten) and a SEPARATE licensing regime for downstream beneficiation plants; (iii) mandates mine-closure plans + financial bonding once a mine reaches 75% of its life; aims to accelerate licence issuance and expand the resource base. Mongolia is a structural China/Russia-flanked chokepoint pursuing Western REE/copper partnerships (US FORGE, JP, KR), so a domestic critical-minerals statutory regime + downstream-processing licensing reprices the entry terms for any foreign developer of Mongolian copper/REE/fluorspar (Oyu Tolgoi-adjacent, Erdenes critical-minerals SOE pipeline).
Caveat — As of 2026-06-27 the bill is cabinet-approved and submitted to Parliament — NOT yet passed, hence axis-2/upcoming. Likelihood moderate: ruling-party majority favours passage but Mongolian minerals-law amendments are politically contested and frequently amended in committee. Distinct from filed 2024-04-19-mongolia-sovereign-wealth-fund-law (SWF + 34% strategic-deposit state-stake amendments), filed 2025-01-15-mongolia-critical-minerals-support-law (the separate critical-minerals PROJECT-support draft law), and filed 2025-09-05-mongolia-mpe-royalty-calculation-shift (royalty base shift to the Mining Product Exchange). Severity 3 expected if enacted.
https://mono.mn/n/government_approves_draft
If passed & escalated to a full control regime — modelled impact (moderate likelihood)
- Copper🇨🇳 today 34→35+1
🇸🇦 Manara Minerals (Saudi PIF / Ma'aden JV) — 10-20% stake acquisition in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 102d ago · not yet law·matches Copper
If passed — Saudi sovereign mining vehicle Manara Minerals (PIF + Ma'aden JV) is in negotiation to buy a 10-20% stake (deal value ~USD 500m-1bn) in the Reko Diq copper-gold project in Balochistan, Pakistan — one of the world's largest undeveloped Cu-Au deposits (phase-1 ~200,000 t/yr copper concentrate + 250,000 oz/yr gold, first production targeted end-2028, ~USD 5. 5bn phase-1 capex). The stake would be purchased from the Pakistani state's half of the project (Pakistan federal SOEs + Balochistan hold 50%; Barrick Gold holds 50% and operates). This extends the Gulf-SWF upstream-mining capital base (theme gcc-mining-upstream-fdi) into a strategic copper chokepoint, paralleling Manara's Vale Base Metals 10% stake and IRH's Mopani (Zambia) acquisition; gives Saudi Arabia an equity claim on a major future non-China copper supply source.
Caveat — As of 2026-06-27 the deal is in negotiation — Pakistan's Petroleum Minister Musadik Malik said publicly he expected a deal "within the next six months," hence announced/upcoming not enacted. Distinct from filed 2025-09-08-pakistan-us-ussm-fwo-critical-minerals-mou (US EXIM/USSM financing angle on Reko Diq), filed 2025-03-14-pakistan-balochistan-mines-and-minerals-act (the provincial mining law), and filed 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake (Manara's Vale Base Metals deal). Severity 2-3 if completed.
https://www.mining-technology.com/news/manara-minerals-acquire-20-stake-reko-diq-project/
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇸🇦 Manara Minerals (Saudi PIF/Ma'aden JV) — 10–20% stake in Pakistan's Reko Diq copper-gold project
announced→low likelihood·flagged 101d ago · not yet law·matches Copper
If passed — Saudi state mining-investment vehicle Manara Minerals (the PIF/Ma'aden JV) is negotiating to buy a 10–20% stake in the Reko Diq copper-gold project (Balochistan, Pakistan) for ~$500M–$1bn, acquiring the interest from the Government of Pakistan (Pakistan + Balochistan together own 50%; Barrick Gold holds the other 50% as operator). Reko Diq is one of the world's largest undeveloped copper-gold deposits (~$74bn projected free cash flow over a ~37-yr life). IPTM relevance: a GCC sovereign-capital upstream-mining-FDI entry (theme gcc-mining-upstream-fdi) into COPPER — a binding chokepoint material — extending the Saudi diversification-of-supply strategy beyond the filed 2024-03-01 Manara→Vale Base Metals 10% stake; would also be a Pakistan host-state instrument (federal divestment of part of its Reko Diq equity to a Gulf SWF, complementing the 2025-09-08 Pakistan–US USSM critical-minerals MoU already filed). Distinct GCC third-party capital base separate from Chinese-SOE capture and Western MSP/CRMA-aligned investment.
Caveat — As of mid-2025 the deal was reported by Pakistan's Petroleum Minister as expected "within six months" but NO binding SPA or primary gov instrument has surfaced as of 2026-06-28 — hence announced/moderate, not enacted. Dedup: only the 2024-03-01-sa-manara-minerals-vale-metals-10pct-stake Manara action is filed; no Reko Diq/Manara slug in action-index; the filed Reko Diq item (2025-09-08 Pakistan–US USSM–FWO MoU) is a DIFFERENT instrument (US bilateral MoU, not a Saudi equity purchase). Severity 2-3.
https://www.dawn.com/news/1886746
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1
🇪🇺 EU European Critical Raw Materials (CRM) Centre — establishing instrument
consultation-closed (pre-proposal; CFE + OPC both closed 2026-07-29)→elevated likelihood·flagged 69d ago · not yet law·matches Copper
If passed — RESourceEU (COM(2025) 945, 3 Dec 2025) commits the Commission to establish a **European Critical Raw Materials Centre** in early 2026 with four functions: (a) generate **systemic market intelligence on CRM value chains**; (b) steer and de-risk finance into strategic projects with public and private partners; (c) support **strategic stockpiling**; and (d) run **joint purchasing** by pooling company orders and matchmaking demand with supply (a "raw materials platform" pooling orders and creating joint stocks, with an EU-coordinated stockpiling pilot to become operational in the following year). A **call for evidence + public consultation opened 19 May 2026**, and the Commission announced a **legislative proposal for Q2 2026**. Supply-relief on the material axis (EU-side aggregation, stockpiles and de-risking finance directly loosen chokepoint exposure for EU industrial buyers), but it also creates a new EU purchasing/allocation gatekeeper whose membership and priority rules will be contested. If it carries reporting or data-submission duties on participating companies, it becomes a second corporate-facing CRM information obligation alongside CRMA Art. 24.
Caveat — europa. eu/info/law/better-regulation/brpapi/groupInitiatives/14832) serves the registry entry directly. Verified: initiative **id 14832**, ref **Ares(2025)6918424**, planning ref **PLAN/2025/1815**, lead **DG GROW**, **isMajor: true**, foreseen act **PROP_REG**; the Commission's own dossier summary names the four pillars as **joint purchasing, stockpiling, investments, and raw materials intelligence**. (1) The **19 May 2026 launch IS confirmed** — both consultation publications carry publishedDate 2026/05/19; the call for evidence (CFE_IMPACT_ASSESS, titled "Legislative proposal for a Regulation of the European Parliament and of the Council establishing the EU Critical Raw Materials Centre") and the open public consultation (OPC_LAUNCHED) each ran a 10-week window that **CLOSED 2026-07-29 23:59:59**, drawing **138** and **72** submissions respectively. (2) The **Q2-2026 slip is confirmed, not a fetch artefact** — the PROP_REG publication still carries plannedPeriod "Q-2026-2" (2026-04-01 → 2026-06-30) with initiativeStatus **UPCOMING**, and a EUR-Lex check on 2026-07-31 finds no COM(2026) text establishing the Centre: ~31 days overdue by the Commission's own planning record, neither folded into another instrument nor silently adopted. **Legal form now known: a Regulation of the EP and Council** → full ordinary legislative procedure after the proposal lands, so an operational Centre is a 2027+ event. Cheapest future check: re-poll the same API endpoint and watch for the PROP_REG publication flipping to published. Distinct from filed 2025-12-03-eu-resourceeu-action-plan-com-2025-945 (the umbrella action plan announcing the intent — this item tracks the specific instrument establishing the Centre), from the CRMA base regulation (filed 2024-05-23), from the CRMA Art. 22 strategic-stock benchmarks item (line 103 above — that is a benchmark-setting implementing measure, this is an institution-creating instrument), and from the permanent-magnet scrap export restriction (line 141 above). ALSO a competitive-positioning item, not only a register item: a publicly-funded EU body with a statutory CRM market-intelligence remit is the most credible free substitute for our minerals intelligence layer — see the 2026-07-30 entry in docs/strategy/mandate_triggers_watch. md ("Demand-narrative signals").
https://single-market-economy.ec.europa.eu/document/download/01c448d6-dc93-40d7-9afe-4c2af448d00c_en
If passed & escalated to a full control regime — modelled impact (elevated likelihood)
- Copper🇨🇳 today 34→35+1
🇲🇼 Malawi — Presidential Executive Order banning export of all raw/unprocessed minerals (effective 21 Oct 2025)
passed-vote→high likelihood·flagged 55d ago · not yet law·matches Copper
If passed — President Peter Mutharika signed an executive order (dated 23 Oct 2025, effective 21 Oct 2025, announced at Sanjika Palace during a cabinet swearing-in) prohibiting the export of raw/unprocessed minerals extracted in Malawi — uranium, rare earth elements, niobium, graphite, tantalum, bauxite, coal, limestone, gemstones, heavy mineral sands, vermiculite, phosphate, rutile, gold, diamonds, copper and others — with an exemption for minerals processed/refined/value-added domestically per Malawian mining law. Announced alongside a suspension of new mining-licence issuance and a review of mining laws (2026/27 State of the Nation Address), plus a planned sovereign wealth fund. Stated rationale: local beneficiation, targeting up to USD 500m/yr once the Kasiya rutile/graphite deposit (Lilongwe) and Kangankunde rare-earth project (Balaka, Mkango Resources — Africa's prospective first new REE mine since 2017, targeting late-2026 production) are fully developed. Violators face fines/penalties under Malawian law. MW is currently the THINNEST country in the register (1 prior action) despite this breadth of minerals covered. Export-ban/beneficiation-mandate, same instrument class as Zimbabwe's SI 213/2022 raw-mineral bans and Guinea's 2026 gold-export ban already in the register.
Caveat — ENACTED (signed order, in force since 21 Oct 2025) but parked here rather than filing. gov. mw directly (TLS cert mismatch: cert is issued for agriculture. gov. mw, not statehouse. gov. mw) and the malawiace. com implementation-analysis piece cites no gov URL either. Same park-lot convention as the DRC ARECOMS / Sudan / Egypt / Morocco / Brazil / India lines above (real, already-enacted action; primary URL not independently locatable this wake). Dedup: action-index has only 1 Malawi action total, none overlapping (no prior MW export-ban or beneficiation-mandate action exists). Severity 3-4 expected given the breadth of minerals covered and MW's fast-growing REE/graphite production profile.
https://www.theeastafrican.co.ke/tea/business-tech/malawi-president-mutharika-bans-exports-of-raw-minerals-5247332
If passed & escalated to a full control regime — modelled impact (high likelihood)
- Copper🇨🇳 today 34→35+1
🇶🇦 Qatar Mining Company (QMSD) recommits US$800M to resume Jebel Ohier copper-gold project, Sudan
announced→low likelihood·flagged 3d ago · not yet law·matches Copper
If passed — State-owned QMSD (Qatar Mining Company subsidiary), paused since Sudan's 2023 civil war, confirmed at a 13 May 2026 Port Sudan meeting between Sudan's Minister of Minerals Nour al-Daim Taha and Qatar's ambassador that it will resume the Jebel Ohier copper-gold project (Red Sea State) with an $800M commitment. Third GCC sovereign upstream-mining entry after Manara Minerals/Vale Base Metals 10% stake (2024-03-01, filed) and QIA/Ivanhoe Mines strategic placement (2025-09-17, filed) — extends the GCC-as-third-capital-base pattern (theme gcc-mining-upstream-fdi) to African copper, not just battery metals.
Caveat — gov. sd not independently reachable; QMSD's own project page does not yet mention the resumption) — parked here per the same convention used for the Malawi executive-order entry above (real/firm commitment, primary URL not yet locatable). Dedup: checked "qatar mining", "jebel ohier", "qmsd" across filing. md, upcoming. md, and action-index — zero hits. Likelihood=high reflects a confirmed government-to-government commitment, not a prediction of eventual gazettal.
https://sudantribune.com/article/313934
If passed & escalated to a full control regime — modelled impact (low likelihood)
- Copper🇨🇳 today 34→35+1

What to watch next

Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.

The watch listShow

Silver is the line to war-game: 🇲🇽 MX already controls 24% of mining, and the policy lever is active. A single new licensing or export-control action on this material moves the binding score materially.
Copper carries 52 restrictive measures on record (🇨🇳 CN 48% of refining) — a secondary escalation candidate.
Tin carries 18 restrictive measures on record (🇨🇳 CN 55% of refining) — a secondary escalation candidate.

Art. 24(4) · diversification & substitution

Priority mitigations

The mitigation optionsShow

Track demand-side substitution against your own book. The buyer levers listed for consumers of Silver, Indium, Copper, Tin, Zinc — qualifying alternative suppliers, designing the material out — are the demand risk to Yunnan Tin Company Limited's revenue. The substitutability factors on each material above are the same numbers read from the other side.
Watch the controlling jurisdiction's measures as price/volume events, not supply risk. A restriction by MX / CN on a material Yunnan Tin Company Limited produces tightens the market it sells into. The register below is the same monitor; only the sign of the read changes.
Concentration of the output market cuts both ways. The materials above are concentrated by construction — that is the pricing power, and it is also the counterparty and offtake concentration a board should see stated next to it.
Run a live policy tripwire. Monitor MOFCOM, EU CRMA and the exporting jurisdictions for new measures on your materials, with a pre-agreed escalation if a licensing regime tightens — this register is that monitor.

Annex A · regulatory basis

CRMA Art. 24 compliance crosswalk

The full crosswalkShow

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

Annex B · Art. 24(1) · Art. 2(29)

Scope & applicability

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.

Scope detailsShow

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	company input — all 5 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment
Manufactures a listed strategic technology	metals-refining (confirm against Annex)
Formally identified by a Member State authority	company input

Evidence & sources

Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.

All sourcesShow

Methodology

MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-07

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).

Refresh SLA

New government measures — polled hourly; a filed action can appear on this report within the hour it's picked up.
Dossier verification (this company's exposure list, sourced against its own disclosures) — the auto-onboarded backlog drains on a 30-minute cycle; a specific company's upgrade timing depends on queue position, not a fixed date.
Live-quoted materials (currently: neodymium, praseodymium, dysprosium, terbium, indium, tellurium — see the price row on each material's page) — refreshed daily.
Other material prices — hand-maintained; flagged STALE on the minerals index past 45 days without a fresh source, rather than left silently out of date.

This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.