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4 critical materials scored · binding chokepoint: Cobalt (🇨🇳 CN 78% of refining) · 94 restrictive government measures on record
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.
Zijin Mining Group Co., Ltd. produces 4 of the 4 scored materials above (Cobalt, Lithium, Copper, Silver). 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 Elevated · 58/100 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 2026-10-06) — 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 Cobalt — 🇨🇳 CN controls 78% of global refining. On this company's production footprint that scores 62/100 (neutral exposure; global 62). The register holds 94 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Cobalt Zijin Mining Group Co., Ltd. is the 521st-most-exposed of the 603 named companies we track on 🇨🇳 CN's Cobalt chokepoint; the most-exposed is Less Common Metals (75/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Zijin Mining Group Co., Ltd. ranks 275th of 448 verified mining metals companies, tied with 4 others at 58.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 127 further mining metals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 58/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 4 scored materials. Buyer-relative (first-order): weighted by where the company produces (CN 34% · CD 21% · RS 16% · PG 6% · TJ 5% · KG 4% · GH 4% · GY 4% · AR 2% · AU 3%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
The exposure report this dossier powers is at /intelligence/dossiers/zijin-mining/report.
Zijin Mining Group is a Fujian-headquartered, partly state-owned mining conglomerate and one of the world's largest producers of copper and gold, with a fast-growing lithium and zinc business layered on top. Its flagship copper assets are Julong (Xizang/Tibet, China's largest copper deposit, still ramping), Kamoa-Kakula and the COMMUS copper-cobalt mine (both DRC), and the Serbia cluster (Zijin Bor Copper — Bor smelter/mine, Majdanpek, and the Timok/Čukaru Peki copper-gold project). Since 2025 it has also become a lithium producer, bringing three projects into production in the same year: the Lakkor Tso salt-lake brine operation in Xizang, the Tres Quebradas ("3Q") salar in Argentina, and the Xiangyuan hard-rock spodumene mine in Hunan — 25,500 t of lithium carbonate equivalent (LCE) in 2025, guided to 120,000 t in 2026 and a 250,000-300,000 t/yr target by 2028 (top-3-5 global LCE producer). It is listed on both the Shanghai (601899.SS) and Hong Kong exchanges.
COMMUS (DRC), and Bor/Majdanpek/Timok (Serbia) are all copper mines or copper-gold mines with copper concentrate/cathode output. Copper is not substitutable in the grid/EV buildout Zijin is positioning around, and its own growth strategy (target: top-3 global copper producer by 2028) makes the company itself a large marginal supplier as much as a consumer of concentrator/smelter inputs.
Kolwezi, DRC (67%-owned by Zijin); DRC accounts for the large majority of global mined cobalt, so Zijin's cobalt stream carries the same DRC concentration/governance risk as the rest of the industry.
separate projects (Xizang brine, Argentina brine, Hunan hard-rock) reached production in the same year, and management's stated 2028 target would put Zijin among the top handful of global LCE producers. This is a real, disclosed pivot rather than sector-typical boilerplate.
refining across the copper/gold portfolio (~223,559 kg mined + ~277,451 kg refinery-byproduct in the most recent disclosed period per company reporting).
niobium, vanadium — no evidence Zijin produces or is materially exposed to any of these; they were generic mining-metals sector defaults, not company-specific. Zinc, molybdenum and gold are also part of Zijin's actual product mix but are not on the platform's scored critical-mineral list, so they are omitted here rather than mapped to an adjacent slug.
Source for this entire section: 紫金矿业集团股份有限公司 (Zijin Mining Group Co., Ltd.) 2025 annual report, filed with the Shanghai Stock Exchange via cninfo 2026-03-21 — static.cninfo.com.cn/finalpage/2026-03-21/1225023658.PDF (MD&A §4④ "主要销售客户及主要供应商情况", p.47; financial-statement notes 十二.5(A) 关联方商品和劳务交易, pp.196-197; note 十二.5(C)(2) guarantee table, p.301). Reporting period: FY2025 (year ended 2025-12-31), with FY2024 comparatives from the same filing. Confidence: primary-source (audited annual report).
Top-5 customers: RMB 138.77bn (13,877,099万元), 39.75% of annual sales; of that, related-party sales = 0%. Top-5 suppliers: RMB 57.54bn (5,754,271万元), 22.81% of annual purchases; related-party = 0%. The filing names, in prose only (no individual amounts or ranks): "主要客户包括 上海黄金交易所、托克等" (major customers include the Shanghai Gold Exchange, Trafigura, and others) and "主要供应商包括上海黄金交易所、金川集团等" (major suppliers include the Shanghai Gold Exchange, Jinchuan Group, and others). Trafigura's presence as a named example customer is notable — one of the world's largest independent commodity traders buying directly from Zijin — but with no share_pct disclosed it cannot be written as a quantified row; it is recorded here as narrative evidence only.
Source: 紫金矿业集团股份有限公司2026年半年度报告 (2026 semi-annual report), filed with the Shanghai Stock Exchange via cninfo 2026-08-22 — static.cninfo.com.cn/finalpage/2026-08-22/1225493590.PDF (其他重要事项 §1 分部报告, "主要客户信息", p.208; financial highlights p.5). Reporting period: H1-2026 (six months ended 2026-06-30), with an H1-2025 comparative from the same filing. Confidence: primary-source.
The interim report does not repeat the annual report's top-5 customer/supplier MD&A table — that disclosure item is annual-report-only under the CSRC format guidelines, so counterparty_concentration above stays at its FY2025 vintage until the next annual report. But the entity-wide major-customer note (required whenever a single external customer clears 10% of consolidated revenue) does quantify the Shanghai Gold Exchange for the first time in this dossier: RMB 45,311,670,887 of RMB 194,178,458,630 total H1-2026 revenue (23.34%), against an H1-2025 comparative of RMB 52,464,687,342 of RMB 167,710,853,231 (31.28%) — the SGE-settled share of revenue fell 7.94 points even as the Group's total revenue grew 15.78% year-on-year, i.e. SGE-settled sales grew markedly slower than the rest of the business. SGE is China's national physical-gold trading and settlement exchange, not a corporate offtaker — a sale "to" SGE means gold sold through the exchange's settlement system, not a bilateral commercial buyer relationship, so this is not read as ordinary single-customer concentration risk. related_party: false — no evidence SGE is under common control with Zijin.
Separately, a credit-risk note (十、1(1) financial-instrument risk, p.169) discloses a different concentration metric not written as a named_counterparties row: top-5 customers' accounts-receivable balance share was 21.73% at 2026-06-30 vs 15.90% at 2025-12-31. This is a balance- sheet (receivables) concentration, not the revenue-based top-5 metric that counterparty_concentration.customers_top5_pct tracks — the two are not comparable and are kept separate here to avoid conflating them.
The MD&A table's "0% related-party" claim looks at odds with a separate note (十二.5(A)) that discloses named related-party trade in the billions of RMB — the reconciliation is that every individual related-party line here, even the largest (Kamoa concentrate purchases at RMB 11.4bn), sits below the implied per-entity top-5 threshold (~RMB 11.5bn average across the top 5 suppliers), so the two disclosures are consistent, not contradictory.
| Named counterparty | Relationship | Flow | FY2025 (RMB) | FY2024 (RMB) | Δ |
|---|---|---|---|---|---|
| Kamoa Holding and subsidiaries (卡莫阿及其子公司) | Group JV (合营企业) | Zijin buys copper concentrate | 11,396,472,842 | 10,028,058,500 | +13.6% |
| Kamoa Holding and subsidiaries | Group JV | Zijin sells materials/mine construction | 663,834,730 | 776,864,667 | -14.5% |
| Zisen (Xiamen) Supply Chain and subsidiaries (紫森(厦门)及其子公司) | Group associate (联营企业) | Zijin buys raw materials | 580,306,937 | 1,282,137,925 | -54.7% |
| Zisen (Xiamen) Supply Chain and subsidiaries | Group associate | Zijin sells zinc concentrate + cathode copper | 516,224,858 | 723,473,406 | -28.6% |
| Southwest Zijin Gold, Guizhou (西南紫金黄金) | Group associate | Zijin buys doré gold | 245,549,111 | 364,904,877 | -32.7% |
| Lualaba, DRC (卢阿拉巴) | Group associate | Zijin sells spare parts | 180,849,028 | 182,075,249 | -0.7% |
| Xianglong Mining, Tibet (翔龙矿业) | Group associate | Zijin sells mine-construction services | 296,457,256 | 40,752,265 | +627% |
| Wengfu Zijin (瓮福紫金) | unconfirmed (see note) | Zijin sells sulfuric acid | 154,521,582 | 76,698,004 | +101% |
Kamoa Holding is the vehicle carrying Zijin's ~39.6% joint-control stake in Kamoa-Kakula (DRC) — already in this dossier's production_footprint — so the copper-concentrate purchase line is the JV mine's own output flowing into Zijin's group smelting capacity: captive intra-group supply, not arm's-length procurement, and by far the largest single related-party line in the filing. The reciprocal sales line (Zijin → Kamoa, materials and mine construction) is Zijin supplying its own JV's build-out.
Zisen (Xiamen) is a genuine bidirectional trading relationship touching Zijin's own refined product: Zijin buys raw materials from it and sells it zinc concentrate and cathode copper — i.e. Zisen sits downstream of Zijin's own copper cathode output as well as upstream as a raw-material supplier.
Lualaba (DRC) and Xianglong Mining (Tibet) are both confirmed Group associates via notes elsewhere in the same filing (a financing note for Lualaba: two Zijin subsidiaries have carried USD shareholder loans to it since 2019, extended to 2028; a bank-guarantee note for Xianglong: Zijin guaranteed a RMB 1.02bn bank facility for it, 2025-2037, both explicitly tagged 联营企业/associate). Both are equipment/construction-services flows rather than material flows, but both sit in copper-producing jurisdictions already central to this dossier (DRC, Tibet) — plausibly satellite entities around the Kamoa/COMMUS and Julong operations respectively, though their precise corporate function is not stated in the pages read.
Wengfu Zijin's relationship subtype was not confirmed in the associate/JV list extracted from p.302 of the filing (that list may be incomplete — the extraction started mid-section) — it is included here because it appears inside the 关联方交易 (related-party transactions) note itself, which by Chinese accounting standard (企业会计准则第36号) only lists confirmed related parties. The sulfuric-acid sale is Zijin monetizing a copper-smelting byproduct; the counterparty's name (a Wengfu Group + Zijin compound) is consistent with a JV between Zijin and Wengfu Group, a major Chinese phosphate-fertiliser producer that consumes sulfuric acid as a fertiliser input — a plausible but unconfirmed inference, stated as such.
GLEIF has an LEI on file for the parent company (529900ABI5CBFXD01Q05, legal name "Zijin Mining Group Co. Ltd.", jurisdiction CN) but the record's registry status is DUPLICATE and it reports no parent/relationship data — not usable as the primary ownership source, so this falls back to manual research per Step 3's fallback path. Zijin is large/well-known enough that a controlling shareholder would be public knowledge, so "no parent reported" was not treated as evidence of independence.
Largest shareholder, per Zijin's own FY2025 annual report (same cninfo filing already cited above for named_counterparties/counterparty_concentration, shareholder-structure section): 闽西兴杭国有资产投资经营有限公司 / Minxi Xinghang State-owned Assets Investment & Operation Co., Ltd., holding 6,083,517,704 shares (22.88%) as of 2025-12-31. Minxi Xinghang is 100%-owned by the Shanghang County (Fujian) government finance bureau, making Shanghang County state assets Zijin's actual controller (实际控制人) — consistent with, and now sourced to a specific stake/date for, this dossier's pre-existing "partly state-owned" framing in ## What they do. Corroborated by a secondary aggregation of the same filing (eastmoney.com) and by Wikipedia ("Shanghang Minxi Xinghang State-Owned Property Investment Company... controlled by the government of Shanghang County"). Second-largest holder is HKSCC Nominees (~22.48%) — the aggregated Hong Kong-exchange free float, not a controlling entity. No parent_slug set: Minxi Xinghang is a county-government investment vehicle, not a corporate parent with its own dossier in this corpus.
From the company’s own filings and dated disclosures — top-5 concentration and related-party tables where the filer’s regime compels them, named supply and offtake agreements where it does not. This is a disclosure, not a netting: a named supplier concentration is shown beside the exposure score and never adjusts it. Figures are the fiscal years labelled, not a current snapshot.
Standard MD&A top-5 table gives only the aggregate share, not individual names or per-entity percentages. The filing separately names, in prose, two customer examples (Shanghai Gold Exchange, Trafigura) and two supplier examples (Shanghai Gold Exchange, Jinchuan Group) with no share_pct — recorded below as null-share named_counterparties rows (2026-08-30) rather than omitted, since a named relationship is worth having even unquantified. Every OTHER row here comes from the separate related-party-transactions note, whose individual amounts (largest: RMB 11.4bn) are each below the top-5 threshold — consistent with 0% related-party share of top-5 being literally true even though named related-party trade is large in absolute terms.
FY2024 · FY2024 comparative from the same FY2025 filing: RMB 10,028,058,500 in copper concentrate purchases from Kamoa and subsidiaries (+13.6% to FY2025).source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 6,401,171,672 in anode copper etc. purchased from the Kamoa JV (交易内容 购买阳极铜等, market price). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2025 · Disclosed as the Group's joint venture (合营企业) and subsidiaries. Purchases of copper concentrate, market price: RMB 11,396,472,842 in FY2025 — the single largest related-party line in the filing. Kamoa Holding is the joint vehicle through which Zijin holds its ~39.6% stake in Kamoa-Kakula (DRC), already carried in this dossier's production_footprint — this transaction is the JV mine's concentrate flowing to Zijin's own smelting capacity, i.e. captive intra-group supply, not arm's-length procurement.source ↗
2025-2028 (three-year term from smelter start-up) · Ivanhoe Q1 2025 results: 'CITIC Metal (HK) Limited and Gold Mountains International Mining Company Limited, a subsidiary of Zijin Mining, have each signed an offtake agreement with Kamoa Copper for a combined 80% of the smelter's anode production' (three-year term); Gold Mountains 'provided an advance payment facility of $250 million' received January 2025 (1-month SOFR + 3.75%). Copper anodes, not concentrate — distinct from the A-share related-party concentrate lines above. Receiving smelter/country not stated.source ↗
H1-2026 · RMB 4,777,434,875 in anode copper etc. purchased from the Kamoa JV (交易内容 购买阳极铜等, market price); H1-2025 comparative RMB 6,401,171,672 (-25.4%). Kamoa is the Group's joint venture (合营企业) per the note's relationship table. Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2024 · FY2024 comparative: RMB 1,282,137,925 in raw-material purchases from Zisen (Xiamen) and subsidiaries.source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 650,041,193 in copper and zinc concentrate purchases (购买铜精矿与锌精矿, market price). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2025 · Disclosed as the Group's associate (联营企业) and subsidiaries. Purchases of raw materials, market price: RMB 580,306,937 in FY2025 (down from RMB 1,282,137,925 in FY2024, -54.7%).source ↗
H1-2026 · RMB 337,519,792 in copper and zinc concentrate purchases (购买铜精矿与锌精矿, market price); H1-2025 comparative RMB 650,041,193 (-48.1%). Zisen is an associate (联营企业) per the relationship table. Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2024 · FY2024 comparative: RMB 364,904,877 in doré-gold purchases from Southwest Zijin Gold.source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 196,447,100 in doré gold purchases (购买合质金, market price). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2025 · Disclosed as the Group's associate (联营企业). Purchases of doré gold (合质金), market price: RMB 245,549,111 in FY2025 (down from RMB 364,904,877 in FY2024, -32.7%). Gold is not on this platform's scored critical-mineral list (per this dossier's own material_exposures note), so this row is disclosure context, not a scored exposure.source ↗
H1-2026 · RMB 120,531,347 in doré gold purchases (购买合质金, market price); H1-2025 comparative RMB 196,447,100 (-38.6%). Associate (联营企业). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
福建紫金锂元材料科技有限公司紫金矿业固态电池锂电新材料建设工程 EIA report (Fujian provincial 生态环境厅, 公示本, page 54): 'the project's main raw material is lithium chloride... externally-purchased anhydrous lithium chloride is mainly sourced from Anhui Tiantie Lithium Battery New Energy Co. (incl. its Jiangsu Changjili plant), Sichuan Ausheng New Materials Co., and Jiangxi Ganfeng Lithium Co. Ltd, among other suppliers' — Ganfeng verbatim-quoted and live-verified on this VPS 2026-09-10 (PDF fetched fresh, not recalled from memory). No share_pct disclosed — EIA reports name suppliers, never volumes or percentages. This is the supplier-side counterpart to Ganfeng's own dossier (002460), which carries no reciprocal customer row for Zijin — EIA filings are one-directional disclosure (name the supplier, not the buyer).
Same EIA report, page 54, same anhydrous-lithium-chloride supplier list as the Ganfeng row above (incl. its Jiangsu Changjili production base). No dossier exists for this company in the corpus — recorded for disclosure completeness; does not resolve to a MACRO∩MICRO pair.
Same EIA report, page 54, same anhydrous-lithium-chloride supplier list as the Ganfeng row above. No dossier exists for this company in the corpus — recorded for disclosure completeness; does not resolve to a MACRO∩MICRO pair.
UNQUANTIFIED — named only as a prose example in the FY2025 annual report's MD&A ('主要供应商包括上海黄金交易所、金川集团等'), not in the top-5 table or the related-party note. Backfilled 2026-08-30, same rationale as the Trafigura row above. Jinchuan Group is itself tracked in this corpus (jinchuan-group-international) as China's largest primary nickel producer.
FY2024 · FY2024 comparative: RMB 776,864,667 in materials/mine-construction sales to Kamoa and subsidiaries (-14.5% to FY2025).source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 315,653,806 in materials and mine-construction sales to the Kamoa JV (销售物资、矿山建设, market price). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2025 · Reciprocal flow: Zijin sells materials and mine-construction services to the Kamoa JV, market price. RMB 663,834,730 in FY2025 — Zijin supplying its own JV's build-out, not a separate commercial customer relationship.source ↗
H1-2026 · RMB 168,007,456 in materials and mine-construction sales to the Kamoa JV (销售物资、矿山建设, market price); H1-2025 comparative RMB 315,653,806 (-46.8%). Reciprocal build-out flow to the Group's own JV. Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2024 · FY2024 comparative: RMB 723,473,406 in zinc concentrate / cathode copper sales to Zisen (Xiamen) and subsidiaries.source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 620,308,481 in zinc concentrate and cathode copper sales (销售锌精矿与阴极铜, market price). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2025 · Reciprocal flow: sale of zinc concentrate and cathode copper, market price. RMB 516,224,858 in FY2025 (down from RMB 723,473,406 in FY2024, -28.6%) — directly copper-chain-relevant (cathode copper is Zijin's refined product).source ↗
H1-2026 · RMB 250,192,822 in zinc concentrate and cathode copper sales (销售锌精矿与阴极铜, market price); H1-2025 comparative RMB 620,308,481 (-59.7%). Zisen is an associate (联营企业). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2024 · FY2024 comparative: RMB 182,075,249 in spare-parts sales to Lualaba.source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 72,673,033 in spare-parts sales (销售备品备件, market price). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2025 · Confirmed the Group's associate (联营公司) in a separate financing note (十二.5(D) note 5: Zijin subsidiaries Zijin International Capital and Jinshan Hong Kong have provided USD shareholder loans to Lualaba since 2019, extended to 2028-09-01). Sale of spare parts, market price: RMB 180,849,028 in FY2025 (down from RMB 182,075,249 in FY2024, roughly flat). DRC-domiciled — same jurisdiction as the Kamoa-Kakula and COMMUS copper-cobalt operations in this dossier's production_footprint; full corporate identity (Lualaba is likely a copper smelter/refinery JV given the province name and the equipment/spare-parts trade) not resolved from the pages read.source ↗
H1-2026 · RMB 141,519,572 in spare-parts sales (销售备品备件, market price); H1-2025 comparative RMB 72,673,033 (+94.7%). Short name as printed in the note; relationship not itemized in the H1-2026 relationship table. Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2024 · FY2024 comparative: RMB 40,752,265 in mine-construction sales to Xianglong Mining.source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 54,777,141 in mine-construction services (矿山建设, market price). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2025 · Relationship confirmed as the Group's associate (联营企业) in the bank-guarantee note (page 301: 紫金矿业 provided a RMB 1,022,791,278 joint-liability guarantee to 西藏翔龙矿业有限公司, 2025-05-06 to 2037-05-05, 关联关系: 联营企业). Sale of mine-construction services, market price: RMB 296,457,256 in FY2025 (up from RMB 40,752,265 in FY2024, +627%). Tibet (Xizang)-domiciled — same province as Zijin's flagship Julong copper mine; the specific project this construction spend supports is not stated in the pages read.source ↗
H1-2026 · RMB 197,583,755 in mine-construction services (矿山建设, market price); H1-2025 comparative RMB 54,777,141 (+260.7%). Also a guaranteed borrower in the same note (RMB 2.30bn guarantee at 2026-06-30 vs 1.02bn at FY-end). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2024 · FY2024 comparative: RMB 76,698,004 in sulfuric-acid sales to Wengfu Zijin.source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 81,476,581 in sulfuric acid sales (销售硫酸, market price). Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
FY2025 · Sale of sulfuric acid, market price: RMB 154,521,582 in FY2025 (up from RMB 76,698,004 in FY2024, +101%). Sulfuric acid is a byproduct of Zijin's copper smelting; the counterparty name pattern (Wengfu Group, a major Chinese phosphate-fertiliser producer, + Zijin) is consistent with a fertiliser JV consuming smelter-byproduct acid, but the exact corporate relationship subtype was not confirmed in the associate/JV list captured from page 302 — flagged as inferred, not textually confirmed.source ↗
H1-2026 · RMB 41,624,836 in sulfuric acid sales (销售硫酸, market price); H1-2025 comparative RMB 81,476,581 (-48.9%). Short name as printed. Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 52,464,687,342 of RMB 167,710,853,231 total H1-2025 revenue (-13.6% absolute, -7.94 pts of revenue share vs H1-2026 — SGE-settled sales grew slower than the Group's 15.78% overall H1-2026 revenue growth).source ↗
H1-2026 · Entity-wide major-customer disclosure (>=10% of consolidated revenue), first time this counterparty is quantified in this dossier — the FY2025 annual report named it only in unquantified prose (see counterparty_concentration note above). Revenue from SGE: RMB 45,311,670,887 of RMB 194,178,458,630 total H1-2026 revenue. SGE is China's national physical-gold trading/settlement exchange, not an end-consumer — sales 'to' SGE are exchange-settled bullion sales, structurally different from a corporate offtake customer; do not read this as a single buyer concentration risk in the ordinary sense.source ↗
H1-2025 · H1-2025 comparative from the same H1-2026 filing: RMB 1,269,194 in silver ingot sales (销售银锭, market price) — the silver line of the related-party sales table. Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
H1-2026 · RMB 135,588,708 in silver ingot sales (销售银锭, market price) — the silver line of the related-party sales table; H1-2025 comparative RMB 1,269,194 (+10583.1%). Short name as printed; relationship not itemized in the H1-2026 relationship table. Source: 财务报表附注 十二.5(A) 关联方商品和劳务交易 (interim financial-statement note; the interim carries no top-5 table, so no share_pct).source ↗
UNQUANTIFIED — named only as a prose example in the FY2025 annual report's MD&A ('主要客户包括上海黄金交易所、托克等'), not in the top-5 table or the related-party note, so no share_pct exists to record. `share_pct` deliberately OMITTED rather than set to null: lib/intelligence.ts's parser only validates the field when the key is present at all, so an explicit `null` value fails validation while an absent key parses cleanly to the same internal null. Backfilled 2026-08-30 (previously left as prose-only per this dossier's own counterparty_concentration note) because a named relationship to a top-3 global metals trader is worth recording even unquantified — absence of a percentage is not absence of the fact.
RMB 115,374,274 of refined-gold sales (销售精炼金, market price) in H1-2026; the H1-2025 column is blank ('-'), so this is a new line with no comparative. Associate (联营企业) per the relationship table. Source: 财务报表附注 十二.5(A).
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all. · section source filing ↗
Ranked by buyer-relative risk, highest first.
1 of 3 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Cobalt | 🇨🇳 CN 78% refining | 62 | 62 | Elevated | EXCEEDS 78% | Med | some | 37 | ▲ rising |
| Lithium | 🇨🇳 CN 65% refining | 61 | 61 | Elevated | within 65% | Med | some | 40 | ▲ rising |
| Copper | 🇨🇳 CN 48% refining | 48 | 59 | Moderate | within 48% | High | limited | 52 | ▲ rising |
| Silver | 🇲🇽 MX 24% mining | 40 | 43 | Moderate | — | Low | some | 5 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Cobalt | 4 | 3 | 3 | 3 | 3 | company input |
| Lithium | 4 | 3 | 5 | 3 | 3 | company input |
| Copper | 4 | 2 | 5 | 4 | 3 | company input |
| Silver | 3 | 1 | 5 | 3 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 79 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇨🇳 CN shock, your disclosed plant carries the binding Cobalt exposure:
Counterfactual: Indonesia extends the hilirisasi ore-ban template (2020 nickel → 2023 bauxite) to the next rung of battery-mineral exports — tightening upstream supply for cobalt intermediates, lithium feedstock and graphite alongside the existing nickel + aluminium regime. Direct-hit lines are basket issuers whose binding material is a battery-cell input (nickel, cobalt, lithium, graphite) — irrespective of controller, since the template-export is global supply-chain pressure not bilateral targeting.
The binding exposure this precedent lands on — Cobalt — is a material Zijin Mining Group Co., Ltd. produces, so this is an output-market event for this company, not a supply vulnerability. No modelled stressed delta is shown: the buyer-relative stress models a rising cost of an input, which is the wrong direction for a supplier of the material, and we would rather show no number than a wrong-signed one. It is never netted against the consumer-side levers in §6.4 — those are reported separately.
role: tag or the producer-sector classifier (one classifier on disk, generated 2026-10-06) — for this company the basis is a disclosed dossier tag. It enters no score.🇨🇳 CN has issued 2 restrictive actions on Cobalt since 2016, severity flat (5.0 → 3.0).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 4 of these 17 materials (Cobalt, Copper, Lithium, Silver) — your binding Cobalt exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 12.1 months apart across 7 distinct restriction dates since 2016 (n=6 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Cobalt — 🇨🇳 CN escalates cobalt controls to a full export-licensing / ban regime | 62 | 67 | +5 |
| Concentration | Cobalt — 🇨🇳 CN becomes the single source for cobalt — the second source is lost (full 78%+ monopoly) | 62 | 76 | +14 |
| Policy | Lithium — 🇨🇳 CN escalates lithium controls to a full export-licensing / ban regime | 61 | 66 | +5 |
| Concentration | Lithium — 🇨🇳 CN becomes the single source for lithium — the second source is lost (full 65%+ monopoly) | 61 | 80 | +19 |
| Policy | Copper — 🇨🇳 CN escalates copper controls to a full export-licensing / ban regime | 48 | 51 | +3 |
| Concentration | Copper — 🇨🇳 CN becomes the single source for copper — the second source is lost (full 48%+ monopoly) | 48 | 66 | +18 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Zijin Mining Group Co., Ltd. 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 4 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Bills at out of committee in US historically become law ~21% of the time (n=1,687, GovTrack — 117th Congress (2021–2023)) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one Zijin Mining Group Co., Ltd. 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.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 4 scored SRMs here are ones this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | mining-metals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-30; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-06
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.