In-Country Off-take Study — NEOM

Sharia-Structured Instrument Ijarah + Musharakah. NEOM Company is both the CSA counterparty and the primary off-take buyer — a single-entity bilateral structure unique in the KSA programme. Option A-IC in-country premium participation is an additive election. Formal Sharia Board review recommended prior to CSA execution.

All buyer status: CANDIDATE — no LOI at registry lock. WARN-05 applies.

NEOM is unique in the programme: NEOM Company (PIF Direct) is simultaneously the CSA authority, the Manufacturing Site Deed counterparty, and the primary off-take buyer. This is not an arm's-length negotiation. OXAGON's closed-loop procurement of Carbon Fiber Precursor, Graphene Oxide, Pozzolanic SCM, and advanced materials from ACM converts NEOM's construction and industrial waste into the manufactured inputs that NEOM's own advanced manufacturing city requires — at zero Authority capital and a supply chain security premium on every output category.

The NEOM Authority-Buyer Structure — Unique in the Programme

NEOM Company (PIF Direct) = CSA Counterparty = Site Agreement Counterparty = Primary Off-take Buyer. No RCJY. No MODON. No SIRC. One entity on all three sides of the value chain. This is structurally different from every other region in the programme.

In every other KSA region, the CSA counterparty (SIRC) is separate from the Manufacturing Site Deed counterparty (RCJY or MODON), and the ICO buyers are independent institutions. In NEOM:

CSA: NEOM Company — PIF Direct subsidiary
Site agreement: NEOM Company — same entity
Primary buyer: NEOM Company — through OXAGON industrial procurement office

The same sovereign entity that authorizes the CSA, allocates the site, and processes the waste is also the manufacturing customer for the output. The off-take negotiation is an internal NEOM procurement decision — not an arm's-length commercial engagement with an independent institution. This compresses the ICO confirmation timeline significantly relative to all other regions.

RevCon™ Output Baseline

NEOM's construction-dominated feedstock profile (C&D fluff 220 TPD at full programme — highest in the KSA programme) drives a Pozzolanic SCM output profile. Carbon streams from ASR and commercial waste produce CFP and GO. RC3 baseline, 350 operating days.

Phase Initial Output (100 TPD, 35,000 tpy)

Product	RevCon	Annual tpy ESTIMATED	Export Ref. $/ton	NEOM Buyer (CANDIDATE)
Carbon Fiber Precursor CRB-009	RC4	875	$15,000–$22,000	OXAGON — advanced manufacturing
Graphene Oxide CRB-010	RC4	175	$60,000–$100,000	OXAGON — energy storage + composites
Pozzolanic SCM MIN-002	RC2	1,400	$80–$140	NEOM construction programme
Mineral Aggregate MIN-001	RC1	4,200	$30–$80	NEOM on-site construction supply
High-Purity Graphite CRB-008	RC3	1,068	$6,000–$10,000	OXAGON battery and industrial materials
Carbon Black CRB-007	RC2-RC3	2,188	$800–$1,500	OXAGON polymer and rubber inputs
Aromatics (BTX)	RC3	3,589	$900–$2,000	OXAGON chemical processing

Full programme (3 modules, 105,000 tpy) scales all figures by 3×. C&D fluff scaling at full programme (220 TPD) produces proportionally higher Pozzolanic SCM — aligned with NEOM's sustained construction programme through the 2030s.

Buyer 1 — OXAGON: Carbon Fiber Precursor + Graphene Oxide + Advanced Materials

Status: CANDIDATE — No LOI at registry lock. WARN-05 applies.

OXAGON is NEOM Company's industrial procurement entity — the same principal as the CSA authority. Off-take engagement is an internal NEOM decision.

OXAGON — NEOM's advanced industrial and manufacturing city on the Red Sea — is mandated to supply advanced manufactured materials to its industrial tenants. OXAGON's procurement requirements align precisely with ACM's highest-value outputs:

Carbon Fiber Precursor (RC4, CRB-009)

OXAGON's aerospace, automotive, and lightweight structural manufacturing tenants require Carbon Fiber Precursor as a base input for carbon fiber production
Saudi Arabia currently imports 100% of its CFP requirements — primarily from Japan (Toray, Teijin) and US (Hexcel, Solvay)
875 tpy Phase Initial; 2,625 tpy full programme — relevant procurement volume for OXAGON's industrial scale
OXAGON's mandate to localize industrial supply chains makes domestic CFP procurement a policy priority, not merely a cost optimization

Graphene Oxide (RC4, CRB-010)

OXAGON's energy storage, filtration, and advanced composites manufacturing require GO as a functional material
175 tpy Phase Initial; 525 tpy full programme from ASR stream
Zero domestic GO production currently — complete import dependency
OXAGON's semiconductor and photonics tenants require GO for GaN substrate applications

High-Purity Graphite (RC3, CRB-008)

OXAGON's battery manufacturing and industrial electrode programmes require HP Graphite as an anode material precursor
Saudi Arabia's Vision 2030 EV supply chain localization target makes domestic HP Graphite a strategic procurement item
China controls 60%+ of global natural graphite supply — OXAGON's procurement policy prioritizes supply chain security

Buyer 2 — NEOM Construction Programme: Pozzolanic SCM + Mineral Aggregate

Status: CANDIDATE — No LOI at registry lock. WARN-05 applies.

NEOM's construction programme — spanning THE LINE, SINDALAH, AQABA, TROJENA, and OXAGON itself — is one of the largest sustained construction programmes globally. C&D waste from this construction is ACM's primary feedstock; the processed output feeds directly back into the same construction programme.

Pozzolanic SCM (RC2): Supplementary cementitious material from sludge and C&D processing reduces Portland cement consumption. NEOM's construction programme has public sustainability commitments — Pozzolanic SCM from ACM provides documented circular cement reduction with provenance audit trail.
Mineral Aggregate (RC1): 4,200 tpy Phase Initial; 12,600 tpy full programme. On-site construction supply — minimum logistics cost, no external supply chain.
Circular provenance: NEOM construction generates C&D waste → ACM processes → Pozzolanic SCM and Aggregate → NEOM construction uses output. Full circular loop within NEOM Company's own programme.
Samsung C&T JV alignment: Samsung C&T's construction JV within NEOM generates significant C&D and ASR waste. ACM provides Samsung C&T with a certified waste disposition that supports NEOM's sustainability commitments.

Buyer 3 — SINDALAH: Marine + Composite Materials

Status: CANDIDATE — No LOI at registry lock. WARN-05 applies.

SINDALAH — NEOM's luxury maritime destination — generates marine waste and requires composite materials for yacht and maritime infrastructure maintenance and construction.

Carbon Fiber Precursor: Marine composite structures (hull repair, dock infrastructure, equipment housings) require CFP. SINDALAH's maritime operations create structural ongoing demand for composite materials precursors.
Graphene Oxide: Marine corrosion inhibition coatings — GO-enhanced epoxy coatings provide superior salt-water resistance for SINDALAH's marine infrastructure. OXAGON composite manufacturing tenants supply these coatings.
Marine waste stream: SINDALAH's marine operations generate waste (bilge, hull maintenance, dockside commercial) that ACM processes — converting SINDALAH's own operational waste into the composite materials inputs it requires.

In-Country Premium Rationale

NEOM's in-country premium is structurally different from all other regions: NEOM Company is the buyer. The premium is not a negotiated commercial premium — it is NEOM's internal procurement valuation of import substitution, supply chain security, and circular economy closed-loop credentials. These are NEOM's own policy objectives, not external market factors.

Product	NEOM procurement driver	Est. premium ESTIMATED — WARN-04
Carbon Fiber Precursor RC4	Zero domestic production; OXAGON supply chain localization mandate; sustainability certification	+15–22%
Graphene Oxide RC4	Zero domestic production; OXAGON advanced materials mandate; supply chain security (China 95% supply)	+15–22%
Pozzolanic SCM RC2	Circular provenance premium — NEOM construction sustainability commitment; cement carbon reduction documentation	+10–18%
High-Purity Graphite RC3	Battery supply chain localization; OXAGON EV programme; zero domestic HP Graphite	+12–18%

NEOM has the highest FWDC in the programme (SAR 320/ton — remote location, no incumbent processor). The in-country premium on ACM's highest-value outputs, combined with the highest gross cost displacement in the programme, makes NEOM's A-IC economics the most favorable per-unit in the KSA portfolio. All premiums ESTIMATED — WARN-04.

Confirmation Pathway

NEOM's off-take confirmation requires no external institutional engagement. NEOM Company signs the CSA, allocates the site, and directs OXAGON procurement. The confirmation pathway is an internal NEOM decision — not a multi-party commercial negotiation.

OXAGON industrial procurement office: Initiate at CSA execution. OXAGON's procurement mandate aligns with all ACM outputs. Specification review → preferred supplier agreement. Estimated timeline: 3–9 months (internal process, no external approval chain).
NEOM construction materials procurement: Initiate at T0. Pozzolanic SCM and Aggregate — supply sustainability documentation. Timeline: 6–12 months.
SINDALAH marine procurement: Initiate at Phase Medium — SINDALAH operational volumes scale with NEOM buildout. Timeline: 12–24 months from T0.

Minimum Viable Off-take Package

OXAGON preferred supplier agreement covering CFP + GO: satisfies minimum off-take package unilaterally
No external LOI required — NEOM Company internal procurement decision
No critical minerals engineering confirmation required — NEOM ICO is entirely carbon and organics

Risk & Sensitivity

#	Risk	Mitigation
1	NEOM construction programme timeline slips — reduces C&D feedstock volume	ACM design basis is P90 surge — operates efficiently at below-surge volumes. Commercial and ASR streams provide baseline regardless of construction pace.
2	OXAGON procurement specification requirements more demanding than standard RC4 grade	Sample protocol at T0. ACM output specification sheet to OXAGON procurement before preferred supplier agreement. OXAGON's own materials validation timeline is the gating item.
3	NEOM budget reallocation reduces OXAGON procurement volume	ACM revenue does not depend solely on OXAGON — Riyadh and Jeddah programme ICO buyers provide alternative off-take for CFP and GO at programme scale. NEOM A-IC is highest value but not exclusive.
4	SINDALAH completion delayed	SINDALAH is a medium-term buyer. Phase Initial does not require SINDALAH LOI. Marine procurement track activates at Phase Medium COD.