Where do the aluminium, cobalt, copper, gold, graphite, and tin in your phone, or if you’re lucky, your electric vehicle, come from? How was it produced? Who handled it? Did any of the material come from Africa, and if so, where and who had oversight of its production?
Africa does not have a homogeneous mining sector. There is no single route from ore body to manufacturer or consumer for the myriad minerals and metals that emanate from the continent. The spectrum of actors involved in production includes global corporate mining giants, junior exploration outfits, traders, exchanges, smelters and processors, middlemen, logistics firms, state and private finance and operators, communities, illegal miners and trades, and at least 10 million artisanal producers across the continent.
Many industrial mining operations share an ore body with artisanal and small-scale mine (ASM) producers from local communities, seeking to benefit from their resource endowments.
Out of this complexity, global political leaders are seeking two clear outcomes: the increase and geographical diversification of critical minerals production, and the use of this increase in production to drive development and meet the economic aspirations of African citizens.

When launching the UN critical minerals panel, Secretary General Antonio Guterres said, “…critical minerals are a critical opportunity – to create jobs, diversify economies, and dramatically boost revenues. But only if they are managed properly. The race to net zero cannot trample over the poor. The renewables revolution is happening – but we must guide it towards justice.”
These sentiments have been echoed by the EU, the UK, and other consumer nations. In 2024, the EU Development Committee commissioned a study on the pathways to implementing traceability for critical raw materials ahead of their visit to eastern DRC this year.
Delivering on these aspirations requires significantly improved knowledge on who is producing material, who are the custodial entities over the material as it moves through the supply chain and, most significantly, under what conditions and to what responsibility standards are mined products extracted and traded, and how abuse is mitigated.
Ethical concerns for responsible sourcing and international legislation around sourcing specific metals from conflict-affected and high-risk areas – including the US Dodd Frank Act and EU Conflict Minerals Act – have necessitated the creation of mechanisms to support transparent and traceable mineral supply chains.
Traceability is essentially the ability to identify and trace the history, distribution, location, and application of products, parts, and materials. This can be done with paper trails, digital logs – including the application of blockchain as a digital ledger of product movement – or even the chemical analysis of material to ascertain where it came from.

However, a critical question for consumers and regulators is: Where does traceability begin? In some cases, agents at mine sites verify and tag bags of mined product to show their source, often using a digital tag that creates a parallel digital supply chain following the batch through real-world handlers. Or it can begin at the smelter – a “choke point” where a small number of custodians handle large amounts of material.
For industrial producers, traceability can verify responsible sourcing claims and provide vital information for supply chain due diligence or mitigation of supply chain risks. While seemingly simple on paper, the implementation of traceability has generated scepticism when interacting with the practicalities of production, particularly ASM production.
ASM constitutes an estimated 90% of global mining employment and accounts for 25 % and 26 % of the global supply of tin and tantalum, respectively. International pressures to delink production of 3TG (Tin, Tantalum, Tungsten and Gold) in DRC were instrumental in the foundation of several regional initiatives, including the state-centric Regional Certification Mechanism of the International Conference on the Great Lakes Region, and the International Tin Supply Chain Initiative (ITSCI).
Structural fragilities of these schemes have been well-documented, showcasing the corruptibility of the agents responsible for inputting data and the informal availability of tags meant to segregate ethical production. Beyond validity issues, the fragmented and highly complex nature of artisanal supply chains, with lower production levels assembled from dispersed, sometimes remote sites, and routinely blended at various stages, poses fundamental challenges to workable traceability enforcement.

A proliferation of frontier traceability innovations has attempted to fix this. The bet was placed on digitisation, automation, blockchain technology, and sometimes geo-chemical fingerprinting, as tamper-proof solutions to reduce the risks of fraud, bribery, and supply chain contamination in the distant spaces where governance is contested.
However, high-tech traceability systems, because of their cost intensity, risk strengthening the bias towards industrial mining. Traceability requirements effectively heighten barriers to entry to an ethical supply chain for low-tech, labour-intensive workers without external support. Participating in traceability schemes can entail having access to mobile phones or digital services, the infrastructure for which is often lacking in remote mining areas or would be costly.
To compete with industrial production, ASM has often had to absorb the costs associated with due diligence requirements and cannot capitalise on the economies of scale available to industrial production. Shifting the cost of traceability onto small-scale producers is not a sustainable approach.
If narrowly enforced, traceability risks culminating in a two-speed system, further disadvantaging artisanal mining while reinforcing their dependence on alternative, illicit chains.
International regulators, traceability schemes and mining initiatives are aware of this bias. Emerging solutions can provide ASM producers with access to supply chains. Many provide training and equipment to workers, as well as an above-market price guarantee, simplifying the connection between artisanal miners and global markets. Price guarantees, access to finance, offtake agreements, support for market access, and administrative help to local cooperatives are the conditions that accompany successful traceable ASM in Africa.
However, the inclusion of communities and ASM producers into traceability mechanisms still carries a financial cost, and for them to be sustainable, this cost cannot be borne by these producers. The challenge remains to scale up these solutions where infrastructure is lacking and structural governance issues prevail. Governmental buy-in is necessary for traceability to be harmonised with national formalisation efforts instead of creating unnecessary duplication.

