Strategic Dependencies: Governments Map Them, Companies Should Too

Brussels published its first real answer to the question in May 2021. The European Commission's Strategic Dependencies and Capacities review screened the EU's import book for products where the bloc had no realistic substitute, no diversified sourcing, and no domestic fallback, and it found 137 of them.[^1] That exercise still exists, still gets updated, and is available to read for free. Most companies with a supply chain running through the same geography have never built their own version of it.

TL;DR: The EU and US governments have spent five years publicly mapping the products, materials and sectors their economies cannot easily source outside a handful of countries. That work is free, well documented, and the wrong resolution to manage a single company's exposure, because it measures dependency at the level of a product code, not a supplier relationship.

Key takeaways:

• The European Commission's 2021 review identified 137 products in sensitive ecosystems with high non-EU import dependency, of which 34 were judged more vulnerable due to limited diversification options.[^1]
• China supplied roughly 52 percent of the import value of the EU's most import-dependent products in that same review.[^1]
• The EU's Critical Raw Materials Act has approved 47 Strategic Projects since March 2025 and set 2030 capacity benchmarks of 10 percent extraction, 40 percent processing and 25 percent recycling for critical raw materials domestically.[^2]
• Executive Order 14017 gave US federal agencies 100 days to review four sectors and a further year to review six more, running from February 2021.[^3]
• A national dependency map is built at the level of an HS product code or an entire ecosystem; a company's actual exposure sits inside one supplier's one factory, which the national map cannot see.

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Two Governments Already Ran the Exercise

Neither Brussels nor Washington waited for a crisis to start counting dependencies, and neither treats the count as finished.

• The original EU screen. The Commission's 2021 staff working document scored products across six industrial ecosystems on import concentration, substitutability and stockpiling feasibility, isolating 137 products where the EU had thin alternatives and 34 where the exposure was judged acute.[^1]
• The raw materials follow-through. The Critical Raw Materials Act translated that screen into targets: by 2030, the EU wants 10 percent of its critical raw material demand met by domestic extraction, 40 percent by domestic processing and 25 percent by recycling, an admission that full independence was never the plan.[^2]
• The 2025 acceleration. The Commission selected 47 Strategic Projects across 13 member states and 14 raw materials in March 2025, then adopted the RESourceEU action plan on 3 December 2025 to mobilise up to 3 billion euros of EU funding within 12 months for projects that can diversify supply faster than the Strategic Projects pipeline alone.[^2][^4]
• The US parallel track. Executive Order 14017, signed 24 February 2021, ordered 100-day reviews of semiconductors, large-capacity batteries, critical minerals and pharmaceutical ingredients, followed by one-year reviews of the defense industrial base, public health and biopreparedness, ICT, energy, transportation and agriculture.[^3]

Both governments built these maps the same way: pick a list of goods the economy cannot function without, trace where they actually come from, and flag the ones with too few alternative sources. That is the same question a corporate supply chain team is supposed to answer for its own bill of materials. The difference is that the national exercise is public, repeated, and already several years into refinement, and most companies with comparable geopolitical risk in their supplier base have not built an equivalent for themselves.

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The Limits of a National Strategic Dependencies Map

A government dependency map is built at the level of a product category or an entire economic ecosystem, because that is the level at which trade and customs data exist. The EU's 137 products are HS-code aggregates covering every importer in the bloc. That resolution is exactly wrong for a single company trying to find its own exposure.

Two products can share the same HS code, the same country-of-origin concentration, and the same "high dependency" flag in the national review, and still carry completely different risk for two different buyers. One buyer has three qualified suppliers spread across two countries; the other has one supplier, in one country, under one long-term contract. The national map scores them identically because it cannot see below the product level. A company's actual strategic dependency lives in the specific factory, the specific contract renewal date and the specific alternate qualification lead time, none of which appear in a Commission staff working document or a CISA sector review.

The timing mismatch compounds the resolution problem. The EU's original dependency review is now more than four years old, refreshed through follow-on exercises like the Critical Raw Materials Act and RESourceEU rather than a full re-screen. A company's supplier base changes on the timeline of contract cycles and plant investment decisions, which move faster than a multi-year government reassessment. Treating a national dependency list as a current picture of your own exposure, rather than as a starting vocabulary and a cross-check, is the mistake. The lists tell a company which categories deserve scrutiny. They do not tell it where its own single point of failure actually sits, and that gap is where geopolitical risk to an individual firm hides even when the aggregate national number looks manageable.

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Building the Corporate Version

The government exercises are still useful, just not as a finished answer. They hand a company three things for free: a vetted list of categories worth checking first, a defensible external reference for why a category matters, and, in the EU's case, a rough sense of where public money will chase supply diversification over the next several years, which is itself a signal about where prices and availability may shift.

A corporate concentration-risk map borrows that starting list, then does the part governments structurally cannot. It runs the same logic down to the supplier and site level: for every input on the national dependency list that appears anywhere in the company's own bill of materials, identify the actual qualified suppliers, their actual plant locations, and how many of them sit inside the same country or the same chokepoint. It time-stamps the exposure against contract renewal and requalification lead times, not against a Commission publication schedule. And it treats the national lists as inputs to update the map against, not a substitute for building one.

None of this requires the scale of a government agency. It requires taking the categories Brussels and Washington have already flagged and asking, supplier by supplier, whether the company's own answer looks as concentrated as the national average, or worse. It is the same discipline behind mapping supply chain exposure past the first tier of suppliers, and the same gap that leaves pharmaceutical supply chains blind two tiers back even when the finished product looks fully sourced. Companies without an internal team to run this exercise can start the conversation at Fortius Intel's brief.

Fortius Intel note: A company that has read the EU and US dependency reports but never mapped its own suppliers against them has done the reading without doing the assignment. The public lists are the syllabus, not the homework.

Methodology note: this analysis draws on the European Commission's Strategic Dependencies and Capacities staff working document (May 2021), the Critical Raw Materials Act's Strategic Projects list and RESourceEU action plan documentation, and the text and implementing reviews of US Executive Order 14017.

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