Traceability and Risk in Africa’s Critical Minerals
Written by Elisa Garbil – 29.12.2025
Critical minerals have become the strategic linchpin of the global energy transition. Electrification, battery manufacturing, and digital infrastructure all depend on a steady flow of minerals such as cobalt, lithium, manganese, rare earth elements, and platinum-group metals. As industrialised economies push toward decarbonisation and technological expansion, they are discovering that the foundations of these ambitions lie in supply chains marked by fragility, opacity, and uneven governance. Nowhere is this tension more visible than in Africa, a continent rich in the very resources that global industry requires, yet operating within historical patterns of extraction, limited beneficiation, and persistent governance challenges.
In this context, mineral traceability has shifted from a niche sustainability aspiration into a core instrument of geopolitical and economic strategy. European policy frameworks including the Critical Raw Materials Act, and global norms anchored in OECD due diligence processes, position traceability as central to securing supply chains, managing regulatory exposure, and ensuring that minerals entering global markets meet basic standards of legality and responsibility. Beyond compliance, governments increasingly view traceability as necessary for understanding the flow of resources that underpin national security, industrial competitiveness, and political autonomy.
But while the logic of traceability appears compelling, its implementation in African mineral sectors exposes a complex interplay of risk, structural constraint, and competing ambitions. Traceability promises order and accountability, yet it must operate in environments shaped by informality, weak institutions, artisanal and small-scale mining, and contested political authority. Without careful design, traceability risks reinforcing existing asymmetries: it can become another requirement imposed from abroad, narrowing African policy space while entrenching raw-material dependency. Yet, if embedded within broader governance and industrial strategies, traceability could help African States strengthen oversight, capture more value, and negotiate from a position of greater sovereignty.
Traceability as a Strategic Imperative
Modern mineral supply chains are exceptionally vulnerable to disruption. Concentrated production, particularly in the case of cobalt and rare earth minerals, amplifies the impact of political instability, regulatory shifts, logistical bottlenecks, or conflict. The growing centrality of these minerals to industrial policy means that supply risk translates directly into economic and strategic vulnerability. For Europe, diversifying sources of critical minerals is now integral to industrial resilience, and traceability is the mechanism that enables diversification to be pursued responsibly and credibly.
Traceability systems address a fundamental blind spot in mineral markets. Namely, the lack of reliable information about the origin and movement of materials.
By creating verifiable chains of custody, they help identify points of vulnerability, prevent the laundering of illicit minerals, and ensure that materials entering essential industries are not linked to environmental degradation, forced labour, or conflict financing. This is not simply a matter of ethics or corporate responsibility. In a world where industrial competitiveness hinges on access to secure mineral inputs, traceability becomes a hard instrument of strategic management.
At the same time, traceability strengthens regulatory coherence. European institutions rely on it to enforce sustainability standards under the Critical Raw Materials Act and ensure compliance with due diligence requirements. The logic is straightforward: without traceability, regulation is unenforceable. Without enforceable regulation, responsible sourcing collapses into voluntary signaling. Traceability therefore forms the backbone of both regulatory credibility and strategic autonomy.
What Traceability Requires
Effective traceability rests on three pillars:
- Data collection must begin at the point of extraction, identifying the mine of origin, recording volumes and grades, tracking custody transfers, and documenting transformations along the value chain. The tools used to generate this data vary, such as digital tags, blockchain-based systems, and geochemical fingerprinting, each contribute to traceability. However, no technology can overcome institutional weakness. The validity of data depends on the integrity of the systems that gather and manage it.
- Institutional oversight forms the second pillar. Traceability requires coherent regulatory frameworks, interoperable data systems, and agencies capable of monitoring compliance. In the absence of strong oversight, sophisticated technology merely digitises unreliability. Fragmented or politicised institutions can distort records, overlook discrepancies, or fail to sanction infractions, undermining the entire apparatus.
- Verification completes the system. Third-party auditors, independent from both state and corporate influence, must validate data integrity. Their role is not to replace public authority but to reinforce it with a layer of credibility that global markets rely on. Without such verification, traceability cannot deliver the assurance required for responsible sourcing or strategic planning.
For these reasons, traceability is not a technocratic add-on. It is a governance system that must be embedded in broader political and institutional structures. Where those structures are strong, traceability enhances transparency and accountability. Where they are weak, traceability risks becoming superficial or corrupted.
The Structural Realities of African Mineral Production
Africa’s critical-mineral landscape is shaped by a paradox: vast geological potential coexists with constrained institutional capacity and limited local value addition. This structural duality shapes every aspect of traceability implementation.
A defining feature of African mineral extraction is the prominence of artisanal and small-scale mining. ASM supports millions of livelihoods, especially in countries such as the Democratic Republic of Congo, Ghana, and Tanzania. Its informal nature, however, makes it difficult to integrate into formal governance systems. Mine sites shift rapidly, teams are fluid, and record-keeping is minimal. Many miners lack digital tools, literacy, or the financial margins required to comply with complex traceability procedures. In these conditions, conventional traceability systems risk excluding ASM producers or driving them into illicit markets.
The significance of this challenge cannot be overstated. ASM is not a marginal activity, as it is central to African mineral economies and central to household incomes. A traceability system that fails to accommodate ASM realities would undermine both economic livelihoods and security objectives by incentivising cross-border smuggling and reinforcing the influence of informal power brokers.
Institutional capacity poses a parallel constraint. Regulatory authorities in many African states struggle with limited resources, incomplete data systems, and overlapping mandates. Cadastres, customs agencies, environmental regulators, and revenue authorities often operate in silos, complicating data integration and oversight. Political interference or corruption can further erode credibility. In such contexts, traceability cannot succeed by layering technology onto weak foundations. It must be paired with institutional reform, training, and long-term governance strengthening.
The final structural dimension is economic. African mineral economies remain largely export-oriented, with limited domestic processing. This creates an asymmetry where traceability improves visibility into extraction but does not alter the underlying pattern in which the highest-value segments of mineral value chains remain outside the continent. Implemented without an industrial strategy, traceability risks consolidating Africa’s role as a compliant raw-material supplier in a value chain governed elsewhere. This is one of the core structural risks facing African states in the global shift toward critical minerals.
The Cost–Benefit Imbalance
The implementation of traceability carries real costs. Governments must invest in regulatory infrastructure, digital systems, training, and auditing. Producers must adapt operations, manage new reporting requirements, and potentially reorganise logistics. For many African states and mining communities, these costs are proportionally higher than for the industrialised customers who ultimately benefit from supply-chain security.
This creates a risk of economic imbalance, where the producers most in need of development gains may bear a disproportionate share of compliance costs. Without offsetting benefits, think of improved bargaining power, premium pricing, or enhanced investment, traceability becomes a form of regulatory burden rather than a development tool.
There is also the risk of market exclusion. If traceability becomes a prerequisite for accessing international markets but remains financially or technically inaccessible for small-scale or under-resourced producers, African exporters could lose market share. Entire segments of ASM activity may be driven underground, reinforcing informality and undermining governance objectives.
However, the economic risks are not destiny. Traceability can form part of a strategy to shift African states out of the raw-export trap. When paired with beneficiation policies, it creates the foundation for processing industries that require robust data on inputs. When integrated into investment frameworks, it can attract climate-aligned financing tied to governance improvements. And when used to authenticate responsibly sourced materials, it can differentiate African minerals in global markets increasingly concerned with provenance. The risk is not inherent in traceability but in deploying it without attention to economic strategy.
Traceability in Fragile Contexts
The role of traceability in conflict-affected regions highlights both its necessity and its limits. In areas such as the eastern DRC, mineral extraction intersects with armed group financing, cross-border smuggling, and fragmented political authority. Traceability offers mechanisms to sever these links, but its effectiveness depends on the system’s ability to function in environments where the state itself may have limited reach.
The risk in these contexts is straightforward, if traceability is implemented superficially, it can be manipulated to legitimise illicit minerals rather than exclude them. Labels can be forged, data falsified, and paperwork laundered through neighbouring countries. The appearance of traceability can therefore mask the continuation of conflict-linked trade.
Yet if implemented rigorously, traceability can reshape incentives.
By tying market access to verifiable origin and responsible production, it reduces the profitability of smuggling and strengthens the bargaining position of legitimate operators. But to achieve this, traceability must be accompanied by formalisation pathways for ASM, credible cross-border cooperation, and regulatory systems that minimise opportunities for manipulation. Otherwise, it may simply shift illicit activities rather than reduce them.
Policy Space, Sovereignty, and the Future of EU-Africa Engagement
Traceability introduces a new dimension to negotiations between African states and external partners. It is a tool that can either expand or constrain policy space, depending on how it is designed and governed.
Externally driven traceability frameworks, if poorly aligned with African development priorities, may pressure governments to prioritise compliance over strategy.
This can narrow options for industrial policy, particularly if standards are rigid or tied to market access conditions. African governments are acutely aware of this risk. Many now seek partnerships that combine traceability with support for processing industries, skills development, and infrastructure investment, ensuring that governance improvements translate into economic opportunity.
European policy is evolving in ways that make such alignment possible. Recent initiatives emphasise long-term partnerships, local value creation, and cooperation on regulatory frameworks. But whether this potential materialises depends on how traceability is embedded in broader EU–Africa cooperation. If traceability is treated as a unilateral requirement, cooperation will remain transactional. If it is treated as a jointly governed system that supports industrial development and strengthens state capacity, it can become a platform for shared strategic benefit.
Traceability as a Foundation for Shared Prosperity
Traceability in Africa’s critical-mineral supply chains embodies a dual promise. It offers a way to secure global supply chains, improve governance, and prevent the circulation of illicit or conflict-linked minerals. Simultaneously, it offers African states a potential instrument for asserting sovereignty, capturing more value, and building industrial capabilities suited to a rapidly changing global economy.
But realising this promise requires confronting the risks directly. Traceability cannot succeed if it excludes artisanal miners, rests on weak institutions, or operates in isolation from industrial policy. Nor can it succeed if external partners impose its frameworks without co-developing the capacity and economic structures necessary for its sustainability. A traceability system that reproduces historical patterns of extraction will only deepen dependency; one that supports governance, economic diversification, and equitable partnerships can instead anchor a more just global resource order.
Africa’s critical minerals sit at the center of global transformation. Traceability will help determine whether this moment becomes another cycle of extraction or a turning point toward shared prosperity.
