Mining Indaba 2026 Speaker Notes: Changed Dynamics in Zimbabwe’s ASM Lithium Sector, and Integration of ASM into Formal Markets and Supply Chains

ZELO Approach to Markets, Critical Minerals

At ZELO we use legal and policy research to provide technical assistance and capacity building for Government departments and agencies to create a conducive investment and trade environment for responsible investments in the mining and natural resources sector for the benefit of local communities and the economy. We also provide support to companies to develop and implement environmental, social and governance (ESG) policies and strategies that are responsive to community needs and trigger economic growth.  We encourage Government to apply international best practices in responsible mining that helps in attracting investments in the critical minerals sector.   

Question 1: Artisanal and small-scale mining is prominent in Zimbabwe, with into Artisanal and Small-Scale mining (ASM) operations extracting resources ranging from gold to chromium and lithium. How has the ASM sector in Zimbabwe changed in the last decade under the influence of dynamics related to increased demand driven by the energy transition and defense sector? What have been the social, economic and political implications?

Response Notes: Changed dynamics

• An increased number of people are venturing into Artisanal and Small-Scale mining of mostly gold, chrome, and lithium. Thus, ASM is a source of livelihood for many unemployed youths with the number Artisanal and Small-Scale miners (ASMers) estimated at between 500 thousand – 1.5 million.
• Following government intervention, including an export ban on unprocessed lithium and the removal of miners from some sites, activity in the lithium value chain has fallen from its 2022-2023 peak, though some small-scale mining continues.
• The ban resulted in the registration of Approved Processing Plants (APPs) operated by medium and large-scale companies. This resulted in the channeling of ASM lithium into the formal market.
• The registration of Approved Processing Plants increased after the ban was instituted, which restricted lithium exports to licensed APPs. The ZELO Mine to Market Study notes there are now more than 17 such plants.
• These APP’s/Companies are buying material from ASMERs.
• The relationship between ASMers and mineral processing companies or large-scale miners is evident in the Gold, Chrome and Lithium Sectors, however, different revenue or mineral sharing arrangements exist in these different mineral value chains.
• Many Chinese companies in the lithium sector established licenced Approved Processing Plants around the country with some buying lithium ore from artisanal and small-scale miners.
• Such arrangements make it cheaper for companies to access minerals from mining sites that are not commercially viable, than investing in production.
• In most cases, the relationship between ASMers and APP or mining companies are not in terms of any specific legislative requirements, although others allow ASMers to work on their claims under Tribute Agreements that are legally recognized in the Mines and Minerals Act. These agreements are based on mutually agreed terms. Most do not however, include elaborate provision on mineral traceability, responsible sourcing or Environmental, Social and Governance (ESG) standards.
• While Zimbabwe’s law does not recognize artisanal mining as a special category, it enables registered individuals over 18 to apply for a mining licence. Furthermore, a practical formalization is occurring, as companies and Approved Processing Plants (APPs) regularly purchase lithium, chrome, and gold from artisanal miners. This de facto system has emerged in the absence of specific legislation, even as the process to reform the Mines and Mineral Bill continues to face delays.
• However, ASM and large-scale mining companies have been affected by low lithium prices. Some ASMers have abandoned their mining sites while some bigger companies also scaled down operations.

Response notes: Social, economic and political implications

• Political: There are Geopolitical implications, especially as Chinese investments dominate the sector.
• Political: A comparative view of regional investment trends, including Zambia, DRC and Angola, reveals that neighboring countries are actively securing strategic partnerships and infrastructure projects with major global economies such as the US, EU, China, EU Global Gateway and Lobito corridor. This stands in contrast to the current investment pattern within Zimbabwe, which remains disproportionately reliant on a single source (China). Economic diversification, achieved by attracting competitive investment from a broader range of international partners, is widely considered crucial for maximizing the development potential of the nation’s resources.

• Zimbabwe has now adopted an investor re-engagement strategy: This strategy underpins the “Zimbabwe is open for business” mantra, ease of doing business measures and no-questions asked for ASMers in gold sector policy.
• Economic impact: The mining sector is a primary contributor to foreign exchange earnings. A significant portion of this activity involves artisanal and small-scale mining (ASM), which supports numerous miners and local communities.

Environmental and Social Impacts: Key challenges identified in a recent ZELO Mine to Market study include strained access to water, significant environmental damage, and violations of workers’ rights.

Question 2: To follow-up on that, could you also reflect on some of the changes in debates or policies related to responsible sourcing, both in the context of increased mineral demand, but also policy developments.

Response Notes:

• Zimbabwe largely views itself as Open for Business and treats the Lithium, Platinum, Chrome, Coal and Iron Ore sectors as crucial in promoting economic growth, especially through value addition.
• Zimbabwe is implementing a Responsible Mining Audit (RMA) which involves the assessment of Small Scale and Large-Scale miners’ compliance with legislation on labour, immigration, environment, community benefits, mining taxation, mine management, safety and health standards, etc. This programme, commissioned in 2023 and 2024, is being recalibrated through ZELO’s support to carry out mine inspections and compliance visits in partnership with the Ministry of Mines and Mining Development. Thus, having influenced its adoption, ZELO is supporting the RMA programme.
• Legal reforms: The Mines and Minerals Ammendment Bill includes provisions on responsible mining and ESG, including recognition of Artisanal and Small Scale Mining. However, difficulties around defining Artisanal Miners persist.
• State companies striving to adopt ESG standards: ZELO has partnered with state institutions such as ZIDA, MMCZ, and Fidelity Printers to assist them with adopting ESG standards.
• Ongoing efforts to develop a Critical Minerals Strategy Zimbabwe: The Ministry of Mines and Mining Development is working on a draft and asked ZELO to assist.

Question 3: As we strive for a better integration of responsible ASM operations in formal mineral supply chains, what do you think are the two biggest opportunities for the ASM sector in this time of increased demand and what are its two biggest challenges that need to be overcome to realize market integration?

Response Notes:

• Opportunity 1: There is an emerging practice of establishing market/buying arrangements between ASMers and large-scale companies or processing centres or external buyers, this presents an opportunity to formalise these relations, including the signing of Tribute Agreements.  
• Opportunity 2: Ongoing efforts to reform policy and legal frameworks that promote responsible mining and sourcing standards and open Zimbabwe for business as well as efforts to improve the ease of doing business in Zimbabwe can also help ASM sector formalisation. The country is ripe for Investments.
• Bonus Opportunity 3: Demand for critical minerals should result in more support to ASMers for enhanced profitability, market linkages, access to mining claims, mining rights and mining equipment. This requires private sector investments and even support of ASM targeted projects by programmes such as the European Partnership for Responsible Minerals (EPRM). As such, EPRM is supporting ZELO to promote responsible mining practices in the lithium value chain.

• Challenge 1: Market access for ASMers is always a challenge including the low prices given to ASMers who do not own (Approved) Processing Plants and cannot export on their own. This is coupled with the low prices that affect ASMers leading to abandonment of mining sites.
• Challenge 2: There is limited access to capital and equipment including proper and safe mining technologies for ASMers.