27 February 2026
The Zimbabwe Environmental Law Organisation (ZELO) views Government’s recent ban on the export of Lithium concentrate as a development which will help plug mineral leakages. Having identified the risks and vulnerabilities in the lithium sector in our recent Mine to Market Situational Report for critical minerals which tracked Zimbabwe’s Lithium supply and value chains, we take comfort in knowing that some recommendations in the situational report are aligned with Government’s position at this moment.
Announcing the ban, Mines and Mining Development Minister Polite Kambamura said the suspension would remain in force until further notice as authorities work to tighten export controls, promote local beneficiation and ensure greater accountability in the country’s strategic minerals sector.
This announcement by the minister validates observations in the 2025 ZELO Mine to Market situational report for critical minerals which highlighted a porous lithium value chain which is prone to illicit trade and revenue leakages. In the Report, our focus was to ensure that Zimbabwe derives maximum economic benefits from the lithium sector and attracts more investments.
Our report revealed that in response to the growing global demand for lithium, the Government of Zimbabwe has introduced a range of policy and legislative instruments aimed at promoting beneficiation and value addition of lithium and other base minerals within the country.
Key among these legal instruments is the Base Minerals Export Control (Unbeneficiated Base Mineral Ores) (Amendment) Order, 2023 (Statutory Instrument 57 of 2023). This legislative direction underscores government’s commitment to ensuring that the extraction of strategic minerals contributes meaningfully to domestic industrialization and inclusive economic growth.
However, the report noted that the implementation of this legal framework needs to be improved as mineral leakages were still reported at borders, including export of raw lithium passed off as concentrates even if it did not meet prescribed value addition thresholds in the regulations. This was observed to be attributable to technical and procedural factors such as compromised boarder control and export monitoring.
“The Minerals Marketing Corporation of Zimbabwe (MMCZ) currently lacks presence at border posts, leading to weak oversight. The Zimbabwe Revenue Authority (ZIMRA) also lacks the technical capacity to verify mineral content independently, creating delays and risks of mineral leakage,” reads the report. However, commendably, MMCZ has since responded and positively addressed this problem by stationing its officers at borders.
“If effectively implemented, Zimbabwe stands to realize substantial benefits from lithium mining and processing, including job creation, the growth of new towns, infrastructure development, increased tax revenue and improved livelihoods for rural communities. However, to fully optimize these benefits, there is an urgent need for the government to strengthen its policy and legal frameworks governing the transitional minerals sector.”
“This includes ensuring investment security, fostering fair competition in the mining industry, promoting responsible and sustainable mining standards, and implementing progressive fiscal policies that enable the lithium sector to drive long-term economic growth and help the country avoid the resource curse,” explained ZELO in the report.
Based on such operational, administrative, policy, legal and practice-based recommendations, the ban on lithium concentrate export was an expected development.
To ensure that the intended benefits of the ban are realized, ZELO reiterates recommendations made in the Mines to Market report, which would complement the policy:
- Strengthen Compliance and Export Monitoring of lithium: Government agencies, particularly the Ministry of Mines and Mining Development and MMCZ, must ensure strict enforcement of export regulations, including the ban of unbeneficiated lithium. Improved inspection, monitoring, and data transparency systems are essential to curb illicit trade and revenue leakages.
- Ensure consistent enforcement of export regulations: Government should strictly enforce the ban on unprocessed lithium exports as provided under SI 213 of 2022 and ensure compliance with the concentrate thresholds stipulated in SI 57 of 2023 and SI 5 of 2023. Effective enforcement will strengthen local beneficiation, promote domestic value addition, and reduce risks of illicit trade and leakages along the lithium value chain
- Strengthen Public-Private Partnerships (PPPs): The government should encourage joint ventures and PPPs between local and international actors across the lithium value chain actors. Such partnerships should prioritize the establishment of Approved Processing Plants (APPs), energy hubs and skills development programmes to promote technology transfer and local capacity building.
- Establish Special Economic Zones (SEZs) for Beneficiation: Create Special Economic Zones dedicated to lithium and critical mineral beneficiation into high value products such as lithium metal oxide cathode material, graphite anode material, lithium-ion batteries, turbines and solar panels. These SEZs can serve as catalysts for industrialisation and investment aligned with Vision 2030 and the National Industrial Development Policy.
- Develop national strategies aimed at reducing reliance on a single export market, particularly China: This can be achieved by exploring new global trade partners, expanding market outreach, and aligning domestic production with international demand trends. Market diversification will enhance resilience, improve competitiveness, and strengthen Zimbabwe’s bargaining power.
- Encourage competition and broaden investor participation in the lithium sector: This can be achieved by engaging additional investor countries through trade fairs, diplomatic missions, and international partnerships. Government should leverage regional trade agreements such as AfCFTA, SADC, and COMESA to attract diversified investment portfolios and enhance Zimbabwe’s integration into regional and global value chains.