Businesses can assess exposure by tracing each critical material through the components, suppliers, processing stages and countries that stand between the company and usable input, then testing how specific disruptions would affect operations. A useful assessment combines supply concentration, import dependence, governance and geopolitical conditions, trade restrictions, recycling and substitution options, traceability confidence, and the time and cost of a business interruption. The result should be a ranked risk register with scenarios, mitigation actions, accountable owners and review dates.
This is a management method, not a single universal score. The European Commission’s 3 December 2025 proposal describes a similar assessment for identified large companies in the Union that use strategic raw materials, but it is proposal text. Its provisions should not be described as current obligations until adoption and the final law are confirmed.
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What a credible raw-material exposure assessment must show
The assessment should answer five practical questions for every material or material-containing component:
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- Which suppliers, traders, logistics routes and facilities control each stage?
- How concentrated or vulnerable is supply at each stage, rather than only at the mine?
- What would a disruption do to production, service delivery, revenue, safety, contracts and regulatory obligations?
- Which actions could reduce the exposure, by when, at what cost and with what owner?
Keep physical-supply resilience separate from responsible-sourcing due diligence. A country or supplier may present human-rights or environmental concerns without an imminent shortage, while a commercially reliable source may still be exposed to a processing bottleneck or export restriction.
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Step 1: define scope and business criticality
Start with products, processes and components
List products, production lines, services and infrastructure whose interruption would materially affect the business. Include bought-in finished components, spare parts, packaging, catalysts, coatings, batteries, electronics and other indirect materials. A company can miss its greatest exposure when it looks only at raw materials purchased under its own name.
For each item, record the material used, annual volume and spend, supplier part number, inventory on hand, normal replenishment lead time, minimum order quantity, qualified alternatives and the consequence of a shortage. Note whether the material is essential to performance, safety, certification, warranty terms or a customer contract.
Use a transparent criticality test
Classify an item as high, medium or low business criticality using explicit criteria. High-criticality examples include a component that stops an entire line, a material with a long qualification process, or an input with no technically approved substitute. Do not treat a low purchase price as low risk: a small quantity of a specialized material can have a very large operational impact.
The cited Commission proposal establishes the need to map components containing strategic raw materials, but neither it nor the other sources prescribes a universal company scoring formula. Document the thresholds your management team chooses.
Step 2: map the supply chain and the confidence of each fact
Map more than the direct supplier
Connect the bill of materials to the direct supplier and then, as far upstream as information is available, to processors, refiners, smelters, recyclers, traders and extraction sites. Record the countries and facilities involved at each stage, transport or trading points, ownership where known, and the route by which material changes custody or form.
The International Energy Agency defines traceability as following origin, movement, custody and transformation. That distinction matters: a supplier’s country declaration is not the same as verified end-to-end provenance.
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Label data quality instead of hiding uncertainty
For every data point, record its source and date and mark whether it is verified, supplier-reported, inferred or unknown. Add the percentage of volume covered and the number of visible tiers. An unknown mine, refinery or trading route should remain an explicit uncertainty in the risk register; it should not automatically receive a low-risk score.
IEA reporting in 2026 on a joint IEA-OECD survey of more than 80 companies found that two-thirds had some traceability system: 30% reported full coverage and 40% covered selected minerals or supply chains. Coverage commonly falls beyond direct suppliers. Those figures indicate the state of practice among respondents, not a benchmark that every company can assume it meets.
Step 3: score exposure on decision-relevant axes
Use separate likelihood and impact scores. A simple five-point scale can be useful if definitions are written down, but the weights and thresholds are management choices. The following dimensions keep the analysis focused on decisions:
| Dimension | What to examine | Evidence to record |
|---|---|---|
| Supply concentration | Number and share of suppliers, countries and processing facilities at extraction, refining and recycling stages | Supplier and facility shares, alternate capacity, single points of failure |
| Geopolitical and governance exposure | Political instability, governance concerns, sanctions, export controls, trade restrictions and chokepoints | Applicable restrictions, affected routes, credible time horizons and dependencies |
| Import dependence | Reliance on imported material or processing and the ability to source domestically or regionally | Import share, customs routes, border and logistics dependencies |
| Substitutability | Technical substitutes, redesign options, qualification time, performance limits and customer approvals | Approved alternatives, test results, qualification schedule and cost |
| Circularity | Availability of secondary material, recovery rates and the company’s ability to use recycled input | Recycled-content capacity, collection or recovery constraints and quality requirements |
| Operational consequence | Time to interruption, inventory buffer, recovery time, financial loss, customer and safety effects | Days of coverage, affected output, contractual exposure and recovery assumptions |
| Traceability confidence | Share of volume with known origin and processing, visible tiers, verification quality and data age | Coverage percentage, audit or corroboration status and last update |
Concentration must be measured at every important stage. A material can come from several mines but still depend on one country’s refining capacity. Conversely, several suppliers may draw from the same processor, so counting supplier names alone can overstate diversification.
Step 4: convert exposure into disruption scenarios
Scenario analysis translates a supply-chain map into a business decision. Build a small set of plausible events and trace each one to affected components, processes and customers.
Useful scenarios to test
- Loss of a major source country because of conflict, political instability or a policy change.
- Export controls or another trade restriction that limits availability or extends delivery times.
- A fire, outage, contamination event or bankruptcy at a dominant processor or refiner.
- A port closure, shipping interruption, sanctions issue or other logistics chokepoint.
- Failure of a direct supplier while upstream capacity remains available but unqualified.
- A sudden loss of recycled feedstock or a reduction in recovery yield.
For each scenario, estimate the time until production is affected, the volume that cannot be made, the period required to qualify an alternative, incremental procurement and logistics cost, customer or contractual effects, and safety or compliance consequences. State assumptions clearly. The sources do not establish universal probability estimates, so avoid presenting a management scenario as a forecast.
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Keep likelihood and impact distinct
A rare event with catastrophic consequences may deserve earlier action than a frequent event with an easily absorbed effect. Present a matrix or risk register showing both dimensions, the affected material and component, the confidence of the underlying data, and the decision required.
Step 5: prioritise mitigation that can actually reduce exposure
Prioritise materials that combine high operational consequence with concentrated or fragile supply, poor traceability and limited substitutes. Mitigation should address the identified failure mechanism rather than simply adding another supplier name.
Diversify supply intelligently
Qualify suppliers in different geographic areas and, where possible, use sources that do not share the same processor, transport corridor or political dependency. A second supplier drawing from the same refinery does not remove concentration risk. Contracts, safety stock or capacity reservations may help when the cost is justified by the interruption consequence.
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Increase secondary-material use
Assess whether recycled or secondary material can meet technical and quality requirements, whether sufficient feedstock exists, and whether recovery can be secured through supplier or product-design changes. The Commission proposal identifies secondary raw materials as one possible response to significant vulnerabilities.
Substitute or redesign
Test alternative materials, component architectures or product specifications. Include engineering validation, customer approval, certification, warranty, performance and responsible-sourcing implications in the business case. Substitution is not a risk reduction if it moves the bottleneck to an equally concentrated material.
Improve traceability where it changes a decision
Request standardized upstream information, require suppliers to identify processors and source countries, reconcile declarations with transaction and mass-balance records, and set update intervals. Prioritise deeper tracing for high-consequence materials instead of demanding identical data depth for every low-risk input.
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Step 6: govern, report and refresh the assessment
Assign an owner for each material risk and mitigation action. The owner should have a due date, measurable completion condition, required budget or decision, and an escalation path if information cannot be obtained. Preserve the assumptions and source dates so a later review can distinguish changed conditions from changed data quality.
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Board-level metrics that support decisions
- Percentage of critical-material volume with origin and processing locations confirmed.
- Percentage dependent on one country, processor, supplier or route.
- Days of inventory coverage under normal and stressed demand.
- Number of critical components without a qualified substitute.
- Time and cost to qualify an alternative source or material.
- Mitigation actions overdue, funded, completed or blocked by missing data.
What the EU frameworks do—and do not—require
December 2025 Commission proposal
COM(2025) 946, dated 3 December 2025, proposes amendments to Regulation (EU) 2024/1252. It describes identified large companies operating in the Union that use strategic raw materials for specified sectors mapping component chains and where materials are extracted, processed or recycled, assessing factors affecting supply and vulnerabilities, and mitigating significant vulnerabilities. The text is a proposal, so its scope, wording and legal effect must be checked against the adopted final measure.
Existing 3TG due-diligence regulation
Regulation (EU) 2017/821 creates risk-management duties for covered Union importers of tin, tantalum, tungsten and gold originating from conflict-affected and high-risk areas. Its purpose is responsible sourcing and adverse-impact due diligence, not a general physical-shortage assessment for every business and every mineral. Applicability depends on the importer and regulatory criteria; obtain qualified legal advice for a specific determination.
The European Commission’s “Due diligence ready!” portal provides OECD-based guidance and tools that can help small and medium-sized businesses and other companies build responsible-sourcing processes. Those tools complement, but do not replace, the operational disruption analysis described here.
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How EU-wide trends should inform, not replace, company analysis
The European Environment Agency’s indicator, based on the Joint Research Centre Critical Raw Materials Dashboard, compares EU supply risk for 66 materials between 2011 and 2023. It reports that supply risk increased for 36 materials, remained steady for five and decreased for 25. The assessment is repeated every three years. These are EU-level trend counts, not a forecast and not a measurement of any individual company’s exposure. Use them as context for prioritisation, then test the actual suppliers, processing stages and business consequences in your own chain.
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A practical implementation sequence
- Weeks 1–2: appoint an executive sponsor and working team from procurement, engineering, operations, finance, legal, sustainability and risk. Agree definitions of “critical,” “known,” “verified” and “disruption.”
- Weeks 3–6: build the product and component inventory, collect material quantities and inventory coverage, and identify direct suppliers and current alternatives.
- Weeks 7–10: request upstream extraction, processing and recycling information; map countries and facilities; label every data point by confidence and date.
- Weeks 11–12: score concentration, trade and geopolitical exposure, import dependence, substitutability, circularity, consequence and traceability confidence. Run the disruption scenarios.
- After the first review: approve owners, budgets and dates for diversification, inventory, redesign, secondary-material or data-improvement actions. Set triggers for an interim refresh.
The output should be a living register connecting each material to its components, suppliers, upstream stages, scenarios, consequences, mitigation and accountable owner. That connection is what turns traceability data into resilience decisions.
Frequently Asked Questions
Does a small business need to map all the way to a mine?
Not always. Start with materials and components whose interruption would materially affect the business, then extend upstream as far as information and risk justify. Record where the chain remains unknown and treat that uncertainty explicitly.
Is supplier diversification enough to remove raw-material risk?
No. Suppliers may share the same processor, country, route or feedstock. Diversification reduces exposure only when the alternate source is genuinely independent and technically qualified.
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Refresh it after material changes in sourcing, trade policy, supplier structure, product design or market conditions. The Commission’s December 2025 proposal describes at least a three-year cycle for companies in its proposed scope, but that proposal is not automatically a current legal deadline.
What is the difference between traceability and due diligence?
Traceability follows origin, movement, custody and transformation. Due diligence evaluates and responds to responsible-sourcing risks such as adverse impacts. They support each other but answer different management questions.
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