The Democratic Republic of Congo’s artisanal and small-scale mining sector represents one of the most consequential governance failures in the global critical minerals landscape. Despite more than a decade of international attention, hundreds of millions of dollars in development spending, and increasingly sophisticated corporate due diligence programs, the fundamental structure of artisanal cobalt extraction in Lualaba and Haut-Katanga provinces has changed remarkably little.
An estimated 150,000 to 200,000 artisanal miners — known locally as creuseurs — continue to extract cobalt-bearing heterogenite ore from hand-dug pits across the Copperbelt, often on concessions formally held by industrial operators or the state mining company Gécamines. Their output, which fluctuates between 10% and 20% of the DRC’s total cobalt production depending on price cycles and enforcement intensity, enters a labyrinthine trading network that effectively launders the material’s provenance before it reaches Chinese-owned processing facilities in Lubumbashi and Likasi.
The Architecture of Informality
Understanding why formalization has failed requires examining the political economy that sustains artisanal mining in its current form. The standard narrative — that ASM persists because of poverty and lack of alternatives — is accurate but incomplete. Artisanal mining in Katanga is not merely a livelihood of last resort. It is a deeply embedded economic system with its own hierarchy of beneficiaries, from provincial politicians and military officers who control site access, to négociants (intermediary traders) who advance credit and set prices, to the creuseurs themselves who bear the physical risk for the smallest share of value.
This system generates enormous rents for its gatekeepers. A 2024 study by the International Peace Information Service (IPIS) estimated that informal taxation and protection payments at ASM sites in Lualaba province alone exceeded $45 million annually — revenue that flows to local chiefs, military units, police commanders, and mining cooperative officials who have every incentive to maintain the status quo.
Formalization, as conceived by international frameworks like the OECD Due Diligence Guidance and implemented through programs such as the Fair Cobalt Alliance and the Responsible Minerals Initiative, threatens this architecture of extraction. When formalization succeeds, it redirects revenue from informal gatekeepers to formal state structures. When it is perceived as threatening established interests, it encounters resistance — not through dramatic confrontation, but through bureaucratic obstruction, selective enforcement, and the quiet reassertion of customary authority over formal institutional mandates.
The Cooperative Conundrum
The DRC mining code requires artisanal miners to organize into cooperatives and operate only within designated Zones d’Exploitation Artisanale (ZEAs). In theory, cooperatives provide organizational structure, negotiate collectively with buyers, ensure compliance with safety standards, and facilitate traceability. In practice, the cooperative system has been captured by political entrepreneurs who use the cooperative structure as a vehicle for rent extraction.
Research published by the University of Lubumbashi’s Centre de Recherche en Géosciences documented that of the 287 registered mining cooperatives in Lualaba province as of mid-2025, fewer than 40 maintained functional governance structures with elected leadership and transparent financial records. The remainder were effectively controlled by individual présidents who paid nominal registration fees to the provincial mining authority and used the cooperative license to control site access, set ore purchase prices below market rates, and extract membership fees from miners who had no meaningful voice in the cooperative’s operations.
The Entreprise Générale du Cobalt (EGC), established in 2019 as a state-backed monopoly buyer of artisanal cobalt, was designed to solve this problem by creating a single transparent purchasing channel. Its early partnership with Trafigura was intended to provide international market access and credibility. But EGC has struggled with fundamental operational challenges: insufficient working capital to purchase at competitive prices, limited collection infrastructure in remote mining areas, and the difficulty of competing with an established network of Chinese and Congolese négociants who offer immediate cash payment at the pit head.
By late 2025, EGC was purchasing less than 8% of estimated ASM cobalt output. The remainder continued to flow through informal channels, reaching Chinese-owned dépôts in Kolwezi and Lubumbashi where it was blended with industrial-grade material, processed into cobalt hydroxide, and exported — often with documentation that obscured its artisanal origin.
Corporate Due Diligence: Performance Theater
The major cobalt consumers — Apple, Samsung SDI, CATL, LG Energy Solution, Tesla — have invested substantially in supply chain due diligence programs. These programs, which typically involve third-party audits, chain-of-custody tracking systems, and grievance mechanisms, have produced real improvements at the industrial mining level. Glencore’s Kamoto Copper Company, for instance, has implemented perimeter security, geological monitoring, and community engagement programs that have measurably reduced unauthorized artisanal intrusion onto its concessions.
But the broader claim that corporate due diligence has addressed the systemic risks of artisanal cobalt is not supported by the evidence. The fundamental challenge is structural: due diligence programs can verify what happens within audited supply chains, but they cannot account for material that enters the system before the first point of documented custody. The cobalt hydroxide exported from Lubumbashi’s processing facilities is a chemical commodity — once ore from multiple sources is blended and processed, its origin is indistinguishable.
This creates what supply chain researchers call the “traceability paradox.” The more sophisticated traceability systems become at tracking material from refiner to end product, the greater the incentive to introduce undocumented material at the refinery level, where it can benefit from the clean provenance of the already-traced industrial supply. Several Chinese-owned processors in the DRC have been documented purchasing from both formal industrial sources and informal ASM channels simultaneously, with limited segregation of material flows.
The EU Battery Regulation, which entered full force in 2025, mandates supply chain due diligence for cobalt and other battery raw materials. Its impact on ASM formalization remains uncertain. European automakers have responded primarily by shifting procurement toward refining jurisdictions with lower perceived risk — notably Finland (Umicore Kokkola), Canada, and Australia — rather than investing in the harder work of formalizing DRC artisanal supply chains.
The Child Labor Question
No discussion of artisanal cobalt mining in the DRC can avoid the issue of child labor, which has been the single most potent driver of international attention to the sector since Amnesty International’s landmark 2016 report “This Is What We Die For.”
The current picture is more nuanced than the original reporting suggested. Large-scale child labor at major ASM sites like Kasulo and Shabara has been significantly reduced, partly through corporate-funded programs and partly through increased monitoring by organizations such as PACT and Good Shepherd International Foundation. Site-level surveys by IPIS in 2025 found children present at approximately 12% of monitored sites in Lualaba province, compared with over 30% in 2016.
However, the definition of “child labor” in the mining context remains contested. Children are frequently present at ASM sites not because they are working in pits, but because the sites function as informal economic zones where families live, trade, and socialize. Distinguishing between children performing hazardous underground work, children washing ore, children carrying water for household use, and children simply present at a site where a parent is working requires granular monitoring that few programs can sustain.
Moreover, as enforcement has increased at high-profile sites that are subject to international monitoring, there is evidence of displacement rather than elimination. Artisanal mining activity has shifted to more remote sites in rural Lualaba and western Haut-Katanga where monitoring coverage is thin and children’s participation is less visible to auditors and journalists.
The LFP Displacement and Its Consequences
The rapid adoption of lithium iron phosphate (LFP) battery chemistry — which contains no cobalt — by Chinese and increasingly Western automakers has introduced a new dynamic. LFP’s market share in global EV battery production rose from approximately 28% in 2023 to over 41% in 2025, driven by BYD, CATL, and Tesla’s decision to use LFP in its standard-range vehicles.
This shift has complex implications for artisanal mining. In the near term, reduced cobalt demand growth has depressed prices, squeezing the margins of ASM operations and making artisanal mining less economically attractive relative to other livelihoods. The cobalt price decline from its 2022 peak of over $80,000 per tonne to the $25,000–$30,000 range in 2025–2026 has already pushed some marginal ASM sites into inactivity.
But the longer-term picture is less straightforward. Even as LFP captures the standard-range segment, high-nickel NMC chemistries (811 and beyond) remain the preferred choice for premium EVs requiring maximum energy density. These chemistries still require cobalt, and the absolute volume of cobalt demand is projected to grow even as its share of the battery market declines. Moreover, cobalt’s critical role in aerospace, superalloys, and other non-battery applications provides a demand floor that ensures continued extraction.
The risk is that LFP’s growth reduces the economic incentive for corporate investment in ASM formalization. If cobalt becomes a smaller and less visible component of the battery supply chain, the reputational pressure that has driven due diligence investment may diminish — even as the underlying governance challenges in the DRC persist unchanged.
What Would Real Formalization Require?
Genuine formalization of artisanal cobalt mining would require a level of institutional reform and political commitment that has not been forthcoming. The essential elements are well understood:
Functional ZEAs with geological assessment — Artisanal mining zones need to be established on geologically assessed land where commercially viable deposits exist, rather than on marginal areas where miners cannot earn a living wage.
Cooperative reform — The cooperative system needs external governance oversight, mandatory financial audits, and mechanisms for miners to exercise genuine democratic control over cooperative leadership.
Competitive purchasing — ASM purchasing programs must offer prices that compete with informal channels. This requires access to working capital at scale and payment infrastructure that can reach remote sites.
Revenue redistribution — Provincial and local authorities need to see direct fiscal benefits from formalization to overcome their incentive to maintain informal taxation systems.
Security sector reform — Military and police involvement in ASM site management must be curtailed through credible enforcement of existing regulations prohibiting security force participation in mining.
None of these elements can be delivered by corporate supply chain programs alone. They require sustained engagement from the DRC government, international development partners, and mining companies acting collectively rather than in isolated corporate responsibility silos.
The cobalt supply chain is not going to reform itself. The question for the EV industry is whether the current approach — which amounts to managing reputational risk through due diligence documentation while leaving the structural drivers of informality intact — is sustainable in the face of tightening regulation and growing scrutiny. The evidence from Katanga suggests it is not.