A three-month export suspension rests on stockpile claims that buyers, lenders and auditors can only partly test.

By Kanisa Magazine · June 2025

On 21 June 2025 the Regulatory Authority for Strategic Mineral Substances Markets, known as ARECOMS, extended the DRC’s cobalt export suspension by three months, one day before the first four-month period lapsed. The stated reason was the continued accumulation of significant market stockpiles.

For anyone who buys, finances or audits Congolese cobalt, the decision is the rule that now governs the market, and the stockpile statement is the evidence behind it. A rule is only as enforceable as the information it rests on, and the information available in late June is partial. The regulator has given a conclusion, not a dataset.

The distinction matters commercially. A supply contract, a letter of credit or a stockpile valuation can be priced on a decision. It can only be defended against an auditor or a counterparty on documents, and those documents differ in dates, grades and quotation sources.

What the regulator has actually decided

The suspension covers every producer, and the regulator has said it will decide again before it ends.

According to a Xinhua report on the decision, the suspension applies to cobalt from industrial, semi-industrial, small-scale and artisanal operations alike, and takes effect from 21 June for three months. ARECOMS said a new decision would be issued before the suspension period ends, which may modify, extend or lift the ban. Agence Ecofin adds that export quotas have been discussed as an alternative to a complete embargo.

That leaves the rule with an explicit expiry and an explicit review. The regulator has announced the decision point, which is itself useful information. Contracts signed in July will run across it, and counterparties should expect that the next communiqué changes pricing.

The evidence the BCC can and cannot supply

Output is measured, stockpiles are asserted, and the data stops in March.

The Banque Centrale du Congo publishes regular official statistics on the sector. Its weekly digest of 18 June records 41,721 tonnes of cobalt produced in the first quarter of 2025, against 198,777 tonnes for the whole of 2024, an average of 49,694 tonnes a quarter. Copper output was 785,841 tonnes in the quarter, close to the 2024 quarterly average of 775,059 tonnes. The cobalt shortfall is about 16 per cent.

Two cautions apply. The production table is provisional and cumulates only to March, so it says nothing about April to June. And it counts output, not shipments or inventory. If mines kept producing after the February suspension at anything like the 2024 pace, tonnes would have piled up at sites, ports and processors, which is consistent with the regulator’s claim but does not prove it. No public series in the digest shows the size of that inventory, and the regulator’s wording, as Xinhua reports it, refers to inventories in both domestic and international markets.

The price evidence has the same problem. The same digest lists two cobalt series. London cathode at 99.80 per cent purity is quoted at US$33,335 a tonne in the most recent column, and the Boursorama series for 99.30 per cent LME material at US$33,011. The Ecofin report quotes the London price at US$30,200 a tonne, up from US$20,900 at the end of February, an increase of about 45 per cent. The BCC’s own series reads US$21,171 on 28 February.

There are two explanations, and a reader should assume both apply. Cobalt is a thinly traded, assessed market, so grade, location and quotation date matter. The BCC’s cathode series also moves in steps: it jumped from US$26,578 at the end of March to US$33,652 at the end of April, then sat within a US$550 band for six weeks. A series that flat is an indicative quote, not a transaction record. A lender valuing collateral or an auditor testing inventory should state which benchmark, which date and which grade.

How the rule moves money

Exporters hold inventory they cannot ship, buyers pay for scarcity, and copper keeps the reserve line rising.

The mechanism runs through three parties. Miners that keep producing under the suspension cannot sell abroad, so their working capital sits in unshipped metal. Refiners and battery makers outside Congo draw down their own stocks, and the price signal, the roughly 45 per cent rise over four months, tells them how scarce the material has become. The state may gain pricing power, and it may lose receipts that depend on shipments.

The central bank’s reserve table did not register the squeeze by mid-June: net reserves rose from US$6,132 million at the end of December to US$6,741 million on 13 June, with copper at US$9,637 a tonne against US$8,789. Copper is carrying the external account while cobalt is held back, and an analyst who reads only the cobalt headline will overstate the damage to the country and understate the damage to individual cobalt producers.

A second rulebook arrives

The Washington agreement adds mineral-sector commitments that are still only text.

On 27 June the DRC and Rwanda signed a peace agreement in Washington. Actualite.cd reported that President Donald Trump said at the White House that the United States was getting a very large share of mining rights in Congo. That is a claim by one party, made before the signing, and the text of the agreement and its economic annexes need to be read before anyone assumes any right has changed hands.

The practical point is the same as for cobalt. Rules are being written quickly, from several directions, with the supporting data trailing behind. A due-diligence file should now carry a dated register of each instrument: its issuer, its legal form, its start date, its review date and whether its evidence is public.

What to do before the September decision

Treat the review date as a contract event and the evidence gap as a risk line.

Buyers should write the ARECOMS review into contracts as a named trigger, covering price, quantity and delivery dates, rather than hide it inside a general force majeure clause. Lenders secured on cobalt inventory should require a stated benchmark price and a dated source, and test valuations against at least two series.

Producers face the more immediate task: document every tonne held. A plant manager who can show output, location, grade and storage conditions by week will be the one best placed to negotiate under a quota system if the regulator turns to one. The next dated fact is the ARECOMS decision before late September, and the businesses that have built their evidence file by then will be the ones that can act on it first.