ASM Conditions Index: Artisanal Mining Along the Corridor

1. The ASM Landscape

Artisanal and small-scale mining is not an aberration in the Lobito Corridor's mineral supply chain. It is a foundational component. Before any industrial mine was sunk in Katanga, before Union Minière du Haut-Katanga arrived in 1906, before Gécamines inherited the colonial infrastructure, people dug minerals from the earth by hand. They still do. Over two million of them in the DRC alone, and an additional 250,000 or more in Zambia's Copperbelt and Northwestern Provinces. They mine cobalt, copper, gold, tin, tantalum, and tungsten. They do it with shovels, chisels, bare hands, and a knowledge of the local geology that no engineering degree provides. They are called creuseurs — diggers — and they are the invisible workforce of the energy transition.

The geography of ASM in the corridor zone maps directly onto the richest mineral deposits in Central Africa. Lualaba Province, with its capital Kolwezi, is the epicentre of artisanal cobalt mining. The heterogenite-bearing oxide ores that outcrop across the Kolwezi area are amenable to hand mining in a way that deeper sulphide deposits are not. A creuseur with a shovel and a sack can extract cobalt-bearing ore from surface deposits or shallow pits without machinery. In Haut-Katanga Province, artisanal copper mining supplements industrial production around Likasi, Kipushi, and the greater Lubumbashi area. Across the border in Zambia, informal copper mining operations dot the Copperbelt Province and the Northwestern Province around Solwezi, though at a smaller scale than the DRC.

Gold ASM operations extend further. Artisanal gold mining occurs across Haut-Lomami, Tanganyika, and South Kivu provinces, and increasingly in Lualaba itself as miners diversify beyond cobalt. The 3TG minerals — tin (cassiterite), tantalum (coltan), and tungsten (wolframite) — are mined artisanally in eastern DRC provinces that feed into the broader corridor supply chain through trading networks that converge on Lubumbashi and, increasingly, on the Lobito Corridor rail route.

The Scale of ASM Production

ASM cobalt production in the DRC accounts for an estimated 15–30% of the country's total cobalt output, depending on the year and the methodology used to calculate it. In absolute terms, this means between 15,000 and 40,000 tonnes of cobalt per year are produced by hand mining. At current cobalt prices of roughly $25,000–35,000 per tonne of contained metal, ASM cobalt production represents a mine-gate value of $375 million to $1.4 billion annually. That value is generated by miners earning between $1.50 and $4.00 per day. The arithmetic of exploitation is not subtle.

ASM copper production is harder to quantify because artisanal copper is more readily absorbed into informal smelting and local markets without export documentation. Estimates range from 50,000 to 100,000 tonnes annually across the DRC and Zambia. Artisanal gold production in the DRC is estimated at 15–25 tonnes per year, though the gold trade is notoriously opaque and smuggling rates are high. Much artisanal gold leaves the DRC through Uganda, Burundi, and Tanzania without appearing in official export statistics.

The Creuseur System

Understanding ASM conditions requires understanding the social organisation of artisanal mining in the DRC. The system is hierarchical, exploitative, and deeply embedded in local power structures.

At the bottom are the creuseurs themselves — the diggers. These are overwhelmingly young men, aged 15 to 40, though children as young as six participate in surface collection and washing operations as documented in our Child Labour Monitor. Creuseurs work in teams of two to ten, typically organised around kinship or neighbourhood ties. They dig, carry, wash, and sort ore. They own nothing except their labour. The tools they use — shovels, chisels, headlamps, sacks — are often borrowed or rented from intermediaries who charge daily fees that reduce the miner's already minimal earnings.

Above the creuseurs are the négociants — small-scale buyers who purchase ore at the mine face or at roadside depots. Négociants provide the link between the mine and the formal market. They buy from dozens of creuseurs, aggregate the ore, and sell to larger buyers. Négociants set prices locally, and the information asymmetry is total: a creuseur has no access to international commodity prices and no leverage to negotiate. A négociant who tells a miner that cobalt is worth $3 per kilogram when the international price implies $8 per kilogram at the mine gate is not negotiating. He is extracting rent from desperation.

Above the négociants are the comptoirs — licensed trading houses that hold government permits to purchase and export minerals. Comptoirs in Kolwezi and Lubumbashi aggregate material from dozens of négociants, blend ASM ore with industrial-grade material, and sell into the international market through trading houses in Lubumbashi, Dar es Salaam, Durban, and increasingly through the Port of Lobito. It is at the comptoir level that ASM material enters the formal supply chain and its artisanal origins become invisible. A comptoir's export documentation does not distinguish between cobalt dug by a twelve-year-old in a collapsing tunnel in Kasulo and cobalt produced by a mechanised cooperative at a formalised ZEA site. Both become "Congolese cobalt, Grade A" on the shipping manifest.

Above the comptoirs sit the international trading houses, smelters, and ultimately the battery manufacturers and automotive companies whose products contain corridor-origin minerals. The supply chain is long, opaque, and designed — whether by intent or indifference — to obscure the conditions under which minerals were extracted.

2. ASM Site Conditions Index

This is the core of this page: a site-by-site assessment of conditions at major artisanal mining zones across the Lobito Corridor supply area. Data is compiled from IPIS mine-site mapping, Better Mining site-level monitoring, SAEMAPE (Service d'Assistance et d'Encadrement du Small-Scale Mining) registration records, field reports from our community-based monitors, civil society partner documentation, and satellite imagery analysis. Each site is assessed on depth of operations, tunnel support infrastructure, ventilation, water management, child labour presence, and an overall safety score.

The safety score is our composite assessment on a scale of 1 (extreme danger, no safety measures) to 10 (formalised operation with basic safety infrastructure). No artisanal site in the corridor zone scores above 6. The median score is 2.

3. The Formalisation Experiment

Formalisation — the process of bringing artisanal mining within regulatory, legal, and commercial frameworks — is the dominant policy response to ASM's problems. In theory, formalised ASM means registered miners working at designated sites under government oversight, selling their production through licensed channels at fair prices, with safety standards, environmental controls, and prohibitions on child labour. In practice, formalisation in the DRC is an incomplete, contested, and often co-opted process that has reached a small fraction of the sector.

EGC: Entreprise Générale du Cobalt

The EGC, established in 2019 as a subsidiary of the state mining company Gécamines, was granted a legal monopoly on the purchase and marketing of artisanal cobalt in the DRC. Every artisanal cobalt cooperative is, in law, required to sell its production to EGC. EGC, in turn, is supposed to ensure traceability, enforce labour standards, and market artisanal cobalt internationally at prices that return fair value to miners.

What EGC promises is transformative: a state-managed buying monopoly that eliminates the exploitative négociant layer, guarantees minimum prices to cooperatives, and provides the traceability that downstream buyers demand. What EGC delivers is less clear. Its buying stations cover a fraction of the ASM sites in Lualaba and Haut-Katanga. The prices it offers have been criticised as below what miners can obtain from informal négociants, creating a perverse incentive to sell informally. Corruption allegations have accompanied EGC since inception, including reports of officials demanding payments from cooperatives for registration and of EGC-stamped documentation being applied to non-EGC ore. The EGC's first internationally documented cobalt shipment through the Lobito Corridor occurred in early 2026, but the volume represented a tiny fraction of DRC's artisanal cobalt output.

The Mutoshi Model Mine

The Mutoshi pilot, initially developed by Chemaf with Trafigura as the commercial partner, remains the most frequently cited example of what ASM formalisation could look like. Miners at Mutoshi work within a designated area under cooperative management. They receive higher prices than the informal market average. Basic safety measures are in place: some tunnel support, protective equipment distribution, and a monitoring system. Child labour screening occurs at the site entrance. The pilot has received endorsement from the OECD, NGOs, and industry bodies as a proof of concept.

The pilot's limitations are equally important. Mutoshi covers approximately 3,000–5,000 miners. The DRC has over two million artisanal miners. Scaling the Mutoshi model across the ASM sector would require investment, institutional capacity, and political will that do not currently exist. Trafigura's involvement has been questioned by NGOs who note that Trafigura's broader commodity trading business includes relationships with entities whose ASM practices do not meet the Mutoshi standard. The pilot demonstrates possibility. It does not demonstrate scalability.

SAEMAPE Cooperatives

SAEMAPE — the DRC government agency responsible for supervising artisanal mining — registers cooperatives and issues artisanal mining permits. Registration is the first step in formalisation. But registration without ongoing oversight is bureaucratic theatre. SAEMAPE's field capacity is minimal. Inspectors are few, underpaid, and lack transport to reach remote sites. A cooperative can be registered with SAEMAPE and continue operating with no safety infrastructure, child labour, and no government oversight between the date of registration and the next inspection, which may never come.

As of our most recent data, approximately 1,200 cooperatives are registered with SAEMAPE across Lualaba and Haut-Katanga provinces. An estimated 40–60% of these are paper entities — cooperatives in name that function as vehicles for concession access rather than genuine collective mining organisations. The gap between registered cooperatives and functioning cooperatives with actual governance, shared equipment, safety protocols, and transparent revenue distribution is vast.

Zones d'Exploitation Artisanale (ZEAs)

The DRC Mining Code provides for designated artisanal mining zones — ZEAs — where artisanal mining is legally authorised. In theory, ZEAs channel artisanal mining into defined areas where the government can provide oversight, safety infrastructure, and environmental management. In practice, the number of designated ZEAs is a fraction of the number of areas where artisanal mining actually occurs. Many ZEAs exist on paper but have received no investment in infrastructure. Miners operating outside designated ZEAs — which is to say, the majority of artisanal miners — are technically illegal, which makes them more vulnerable to exploitation by intermediaries and less likely to seek government protection when their rights are violated.

4. Safety and Mortality

Artisanal miners in the DRC die at rates that would be unacceptable in any regulated industry anywhere in the world. They die from tunnel collapses, drowning in flooded pits, suffocation in unventilated underground workings, rockfall, and equipment accidents. No comprehensive mortality statistics exist because no institution counts ASM deaths systematically. Our estimate of 200+ annual deaths is conservative and is based on aggregated community reports, hospital admissions data from Kolwezi and Likasi, NGO documentation, and media reports. The actual number is almost certainly higher. Some researchers have estimated 300–500 annual fatalities across the DRC's ASM sector, but the data quality does not support precision.

Tunnel Collapse: The Primary Killer

Hand-dug tunnels in the DRC's ASM sector are the most dangerous working environment in global mining. Tunnels are dug without engineering assessment, without understanding of the overburden geology, without support structures, and without escape routes. A typical ASM tunnel in Kolwezi is 0.6 to 1.0 metres in diameter — barely wide enough for a person to crawl through — and extends 10 to 35 metres horizontally or vertically into heterogenite-bearing strata. The tunnel walls are unsupported earth and soft rock. When they collapse, they collapse without warning, burying miners alive in a space too narrow for effective rescue.

Drowning and Flooding

Underground ASM workings in the DRC have no water management infrastructure. When rain saturates the surface, water infiltrates underground tunnels through permeable overburden. In the rainy season (October to April), flooded workings are the second leading cause of ASM death after tunnel collapse. Miners working underground may have minutes of warning — the sound of water entering the tunnel system — or none at all. The tunnel dimensions preclude rapid escape. Drowning in an underground tunnel 20 metres below the surface, in darkness, in a space too narrow to turn around, is among the worst deaths imaginable.

Open-pit ASM operations face flooding from accumulated rainwater. Pits fill during heavy rain, and miners who enter partially flooded pits to recover ore from submerged workings face drowning risk from unstable pit walls that collapse into the water, trapping miners below the surface. No ASM site in the corridor zone has pumping equipment adequate to manage water ingress during the rainy season.

No Rescue Capacity

When a tunnel collapses at an industrial mine, a trained mine rescue team with specialised equipment responds within minutes. When a tunnel collapses at an ASM site in Kolwezi, the response is other artisanal miners digging with shovels. There is no mine rescue team for the ASM sector. There is no emergency telephone number. There are no ambulances stationed at or near ASM sites. The nearest hospital may be an hour away by motorbike, and it may lack the capacity to treat crush injuries or perform emergency surgery. The DRC's ASM sector has no emergency response infrastructure. Every collapse, every flood, every rockfall is a potential mass casualty event with no institutional response.

5. Mercury and Chemical Exposure

Mercury is the silent killer of artisanal mining. While tunnel collapses generate headlines, mercury poisoning kills slowly, invisibly, and across generations. Artisanal gold processing in the DRC and across sub-Saharan Africa relies on mercury amalgamation — a method in which liquid mercury is mixed with gold-bearing ore to capture fine gold particles. The mercury-gold amalgam is then heated, typically over an open flame, to evaporate the mercury and recover the gold. The mercury vapour is released directly into the atmosphere, where it is inhaled by the processor, bystanders, and the surrounding community.

Scale of Mercury Use

An estimated 14 or more tonnes of mercury are used annually in artisanal gold mining across the DRC corridor supply zone, encompassing operations in Haut-Katanga, Tanganyika, Haut-Lomami, and Lualaba provinces. Globally, artisanal gold mining is the single largest source of anthropogenic mercury emissions, responsible for approximately 38% of total global mercury releases according to the United Nations Environment Programme. The DRC is among the top mercury-emitting countries from ASM gold processing.

Mercury enters the ASM supply chain through informal trading networks. Despite international restrictions under the Minamata Convention on Mercury, to which the DRC is a party, mercury is readily available in markets across the Copperbelt. It is sold in small bottles at prices of $30–50 per kilogram by traders who source it from industrial suppliers, recycled products, and smuggling networks that originate in China, India, and Latin America. No effective enforcement mechanism exists to restrict mercury sales to artisanal miners.

Health Effects

Mercury poisoning from artisanal gold processing produces devastating health effects that are well documented in the medical literature but systematically ignored in the policy response to ASM. Acute mercury vapour inhalation during amalgam burning causes respiratory damage, neurological symptoms including tremors, memory loss, and cognitive impairment, and kidney damage. Chronic low-level exposure — which affects not just miners but entire communities living near processing sites — causes progressive neurological damage, developmental delays in children, reproductive harm including increased rates of miscarriage and birth defects, and cardiovascular disease.

The most devastating effects are intergenerational. Methylmercury, the organic form produced when mercury enters waterways and is converted by aquatic bacteria, bioaccumulates through the food chain and is a potent neurotoxin. Pregnant women exposed to methylmercury through contaminated fish or water transmit it to their developing foetuses. The result is developmental damage that manifests as reduced cognitive capacity, motor impairment, and learning disabilities in children who were poisoned before they were born. Studies from artisanal gold mining communities in other African countries have documented urinary mercury levels in children 50 to 100 times above WHO safety thresholds.

Acid Leaching in Cobalt Processing

Mercury is primarily a gold processing issue. Cobalt processing at the artisanal level involves different but equally hazardous chemical exposures. Artisanal cobalt processors use acid leaching — dissolving cobalt-bearing ore in sulphuric acid to extract cobalt in solution — in rudimentary processing facilities that lack containment, ventilation, or protective equipment. Sulphuric acid is handled without gloves. Acid fumes are inhaled without respiratory protection. Acid solutions are discharged into the ground and nearby waterways without treatment. Chemical burns to skin and eyes are common. Chronic respiratory damage from acid fume inhalation is endemic among cobalt processors.

The acid itself is sourced from industrial mining operations. Used acid from industrial hydrometallurgical plants is sold or given to artisanal processors, creating a link between the industrial and artisanal sectors that is rarely acknowledged in corporate supply chain disclosures. An industrial mining company that provides used acid to artisanal processors is facilitating a processing method that causes chemical injury. This is not captured by any existing due diligence framework.

Minamata Convention Compliance

The DRC ratified the Minamata Convention on Mercury in 2019, committing to develop a National Action Plan to reduce mercury use in artisanal gold mining. At the February 2026 review point, the DRC has not finalised or published its National Action Plan. No mercury-free processing alternatives have been deployed at scale in the DRC's artisanal gold sector. No enforcement actions have been taken against mercury traders. The Minamata Convention's implementation in the DRC exists on paper. On the ground, mercury use continues unabated.

6. The Supply Chain Connection

Understanding how ASM material enters the formal supply chain is essential to understanding why conditions remain as they are. The supply chain is not a neutral conduit. It is the mechanism through which conditions at the mine face are either reinforced or challenged by commercial actors downstream.

From Mine Face to Smelter

The journey of ASM cobalt from a creuseur's sack to a cathode in your electric vehicle battery involves five to seven intermediary steps, each of which reduces traceability and increases the distance between the mine-face conditions and the downstream buyer's awareness of them.

The creuseur sells ore at the mine face or at a roadside depot to a négociant for $2–5 per kilogram of heterogenite. The négociant transports the ore by bicycle, motorbike, or truck to a comptoir in Kolwezi or Lubumbashi, selling at $4–8 per kilogram. The comptoir aggregates ore from dozens of négociants, blends it for grade consistency, and sells to a licensed exporter or directly to a smelter at $8–15 per kilogram. The exporter ships the ore — via truck to Durban or Dar es Salaam, or increasingly via the Benguela Railway to Lobito — to smelters in China, Finland, Belgium, or Zambia. The smelter produces cobalt metal or cobalt sulphate, which is sold to cathode manufacturers, who sell to battery cell makers, who sell to automotive OEMs, who sell to consumers.

At each step, the material becomes more aggregated, more documented, and more distant from its origin. By the time cobalt reaches a smelter, it has been mixed with material from dozens of sources. By the time it reaches a battery, the question of whether a child dug it from beneath a house in Kasulo is statistically irrecoverable.

Mixing at Buying Houses

The critical point of traceability failure is the comptoir. Buying houses in Kolwezi and Lubumbashi receive ore from multiple négociants representing multiple mine sites with varying conditions. The ore is physically mixed for grade consistency before export. A comptoir that buys from 50 négociants representing 200 mine sites cannot trace individual bags of ore to specific mine faces. It can document that it bought a certain tonnage from registered négociants. It cannot document the conditions under which every kilogram was mined. This is where ASM cobalt from the worst sites — from Kasulo's urban tunnels, from Shabara's unshored pits — becomes indistinguishable from ASM cobalt mined at safer, better-managed sites.

Due Diligence Under OECD Guidance

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provides the international reference standard for mineral supply chain due diligence. Annex II of the Guidance identifies the worst abuses that companies must identify and respond to, including child labour, forced labour, direct or indirect support to non-state armed groups, and serious human rights abuses. The Guidance establishes a five-step due diligence framework: establish strong company management systems; identify and assess risks in the supply chain; design and implement a strategy to respond to identified risks; carry out independent third-party audit of supply chain due diligence; and report on supply chain due diligence.

The OECD Guidance is incorporated by reference into the EU Conflict Minerals Regulation, the EU Battery Regulation, and the EU Corporate Sustainability Due Diligence Directive. It is the normative baseline for corporate due diligence across the cobalt supply chain. Its implementation, however, remains uneven. Companies that adopt the Guidance at the policy level do not always implement its requirements at the operational level. The gap between due diligence policy and due diligence practice is where ASM conditions persist unchanged despite the proliferation of corporate sustainability commitments.

7. Economic Analysis

The economics of artisanal mining explain why two million people endure the conditions documented in this index. They also explain why those conditions persist. The ASM value chain is structured to extract maximum value from the miner and transfer it upward through a chain of intermediaries, each of whom captures a share without bearing any of the physical risk.

Income Distribution

A creuseur mining cobalt in Kolwezi earns $1.50 to $4.00 per day, depending on the quality of ore found, the price offered by the négociant, and the miner's bargaining position (which is effectively zero). This income supports not just the miner but typically a household of five to eight people. Per capita income for a creuseur's household ranges from $0.20 to $0.80 per day — deep below the World Bank extreme poverty line of $2.15 per person per day.

Meanwhile, the cobalt the miner extracts generates value at every subsequent stage of the supply chain. A kilogram of heterogenite sold by a creuseur for $3 contains approximately 100–200 grams of cobalt metal equivalent. At an international cobalt price of $30 per kilogram of contained metal, that kilogram of ore represents $3–6 in metal value. By the time it reaches a battery cathode manufacturer, processing, refining, and transport have increased the value. The miner captures 15–25% of the mine-gate metal value. The négociant captures 20–30%. The comptoir captures 15–25%. The exporter, smelter, and downstream processors capture the remainder. Risk flows downward. Value flows upward.

Price Manipulation at Buying Points

The creuseur's inability to capture fair value is not a market failure. It is a market design. Négociants at buying points set prices without reference to any transparent market mechanism. A creuseur has no access to real-time cobalt prices on the London Metal Exchange. He has no weighing equipment to verify the weight of his ore. He has no assay capability to verify the grade. He sells to the négociant who is present, at the price the négociant offers, because the alternative is to carry his sack of ore to another buying point that may be kilometres away and may offer the same price or less.

Deliberate under-grading is standard practice. Négociants routinely assess ore at lower grades than its actual cobalt content, paying $2 per kilogram for material worth $5. Under-weighing is equally common. A négociant whose scale reads 8 kilograms when the actual weight is 10 kilograms captures a 20% margin through fraud alone. These practices are so pervasive that they are not even perceived as fraud by participants. They are the terms of trade. The information asymmetry between a miner with no instruments and a buyer with a scale, a phone, and connections to the international market is the mechanism through which poverty is maintained at the mine face.

Comparison With Industrial Mining

An underground miner at Glencore's Kamoto Copper Company in Kolwezi earns approximately $300–600 per month — $10–20 per day. This is five to ten times the daily income of an artisanal miner extracting the same mineral from the same geological formation, sometimes within sight of the industrial mine's perimeter fence. The industrial miner works with safety equipment, tunnel support, ventilation, emergency response systems, and health insurance. The artisanal miner works with a shovel and a headlamp. The wage differential reflects the value of formalisation, safety infrastructure, and collective bargaining that industrial miners possess and artisanal miners do not.

This comparison is not an argument for industrial mining to replace artisanal mining. Industrial mining in the DRC has its own human rights problems, documented in our Displacement Tracker and ESG scorecards. But the wage comparison illustrates what artisanal miners lose by operating outside formal employment structures: not just safety, but income. Formalisation that brings ASM miners even partway toward industrial wage levels would transform the economics of poverty that drive the sector's worst conditions.

8. Legal Framework

The legal architecture governing artisanal mining across the Lobito Corridor supply zone is layered across national, regional, and international instruments. The framework is comprehensive on paper. Its enforcement is negligible on the ground.

DRC Mining Code: Chapter on ASM

The DRC Mining Code 2018, as amended, dedicates Title IV to artisanal mining. Key provisions include: the definition of artisanal mining as manual extraction without mechanised equipment; the requirement for artisanal miners to hold valid cards (cartes d'exploitant artisanal) issued by the provincial mining authority; the restriction of artisanal mining to designated ZEAs; the prohibition of artisanal mining within industrial concession perimeters without the concession holder's authorisation; and the requirement for artisanal miners to organise into cooperatives registered with SAEMAPE. The Mining Code establishes the legal basis for SAEMAPE's supervisory role and for the creation of ZEAs by provincial governors.

The 2018 revision strengthened several ASM provisions. It increased the community development fund contribution from 0.3% to 0.3% of revenue (unchanged but with stronger enforcement language). It introduced provisions for environmental rehabilitation obligations for ASM operators, though these are effectively unenforceable against individual artisanal miners. It strengthened the language around child labour prohibition in mining. And it created the legal basis for EGC's monopoly on artisanal cobalt purchasing.

ZEA Regulations

The designation of Zones d'Exploitation Artisanale is governed by ministerial decree and implemented by provincial governors. The regulatory framework for ZEAs specifies that designated zones must be geologically assessed for artisanal mining suitability, must not overlap with valid industrial mining concessions (though this is routinely violated in practice), and must be equipped with basic infrastructure for ASM management. The regulations are aspirational. Most designated ZEAs lack geological assessment, infrastructure, and active management. The gap between the ZEA regulations and their implementation is one of the widest in the DRC's mining governance framework.

Cooperative Law

The DRC's cooperative law (Law No. 002/2002) provides the legal framework for artisanal mining cooperatives. Cooperatives must be registered, must have governance structures including elected leadership, and must distribute revenues transparently among members. In practice, many ASM cooperatives are controlled by politically connected individuals who use the cooperative structure to secure concession access and extract rents from miners who are members in name but labourers in fact. The gap between cooperative law and cooperative practice is a governance problem that undermines every formalisation effort.

EGC Monopoly Legal Basis

EGC's monopoly on artisanal cobalt purchasing was established by government decree in 2019 and confirmed by subsequent legislation. The legal basis rests on the state's authority under the Mining Code to regulate the marketing of artisanal minerals. The monopoly has been challenged by informal market participants and some international observers as anti-competitive and contrary to the interests of artisanal miners who may obtain better prices from private buyers. The legal question — whether a state monopoly that promises fair prices but delivers below-market rates actually serves miners' interests — has not been tested in DRC courts.

Zambia ASM Provisions

Zambia's Mines and Minerals Development Act 2015 provides for artisanal mining licences issued by the Director of Mines. The Zambian framework is more coherent than the DRC's: licences are issued for defined areas, licence holders must comply with safety and environmental conditions, and enforcement capacity, while limited, is greater than in the DRC. Zambia's artisanal mining sector is also significantly smaller, making regulatory coverage more feasible. The Zambia Mining Environmental Remediation and Improvement Fund provides a mechanism for environmental rehabilitation of ASM sites, though funding is insufficient for the scale of the problem.

9. What Needs to Happen

The following recommendations are specific, actionable, and directed at the actors with the capacity to change conditions in the ASM sector. They are drawn from the evidence documented in this index and informed by two decades of ASM policy experience across Africa.

To DFIs and International Partners

Development finance institutions financing the Lobito Corridor — the US DFC, the AfDB, the EIB, and the World Bank/IFC — should condition corridor financing on parallel investment in ASM formalisation. The corridor exists to move minerals. The conditions under which those minerals are mined are not an externality to the corridor's purpose. They are central to it. DFIs that finance logistics infrastructure without investing in the social conditions at the origin end of the supply chain are building a pipeline from exploitation to market.

To Mining Companies

Industrial mining companies operating in the corridor zone should stop treating ASM as somebody else's problem. ASM miners dig on the periphery of industrial concessions, sell to the same supply chains, and mine the same geological formations. Industrial companies have the technical expertise, financial resources, and institutional capacity to support ASM formalisation in their concession zones. Some companies — Ivanhoe Mines at Kamoa-Kakula, CMOC at Tenke Fungurume — have begun engagement. Most have not. The EU CSDDD will soon require this engagement as a legal obligation, not a voluntary choice. Companies that begin now will be ahead of the regulatory curve. Companies that wait will be caught by it.

To the DRC Government

The DRC government should invest its mining revenue in the mining communities that generate it. The 0.3% community development fund under the Mining Code is insufficient and poorly administered. Royalty revenue from industrial mining should fund ASM formalisation, safety infrastructure, mercury elimination, and SAEMAPE capacity building. The DRC receives billions of dollars annually in mining revenue. Allocating 1–2% of that revenue to ASM conditions would transform the sector. The political will to make that allocation is the binding constraint, not the financial capacity.

To Downstream Buyers

Companies buying cobalt, copper, and gold from the DRC supply chain should stop pretending that due diligence paperwork in Geneva, London, or Tokyo substitutes for conditions at the mine face in Kolwezi. Due diligence must include physical verification at the point of extraction. Companies that source ASM material should invest in the sites from which they source — funding safety improvements, formalisation support, and mercury elimination at the specific sites in their supply chain. Companies that refuse to engage with ASM should acknowledge publicly that their avoidance strategy does not reduce child labour, improve safety, or eliminate mercury exposure. It merely transfers the problem to less scrupulous supply chains.

Related Database Pages

• Cobalt
• Copper
• Kolwezi
• Entreprise Générale du Cobalt (EGC)
• Child Labour Monitor
• Displacement Tracker
• Artisanal Mining and the Corridor
• OECD Due Diligence Guidance
• EU CSDDD
• DRC Mining Code 2018

This index reflects Lobito Corridor's independent assessment based on IPIS mine-site mapping, Better Mining site-level monitoring, SAEMAPE registration data, field reports from community-based monitors, civil society partner documentation, satellite imagery analysis, UNEP mercury emissions data, academic research, and corporate disclosures. Data is triangulated but inherently uncertain. Estimates of miner numbers, mortality rates, and mercury use are based on the best available methodologies but cannot capture the full extent of the ASM sector, which operates largely outside formal documentation systems. Site-level safety scores are our composite assessment and may not reflect conditions on any specific day. Companies, government agencies, and civil society organisations that wish to provide corrections, additional data, or alternative assessments are invited to contact asm@lobitocorridor.com. All corrections are published transparently. This index does not constitute legal advice. For information about legal obligations under the DRC Mining Code, Minamata Convention, EU CSDDD, or other frameworks, consult qualified legal counsel.