Three documents, none of them a price, changed what a careful buyer of Congolese cobalt has to prove.

By Kanisa Magazine · May 2025

The most consequential cobalt documents of 2025 are not price sheets. They are a four-month export decree issued by the board of ARECOMS on 22 February, a market report published by the Cobalt Institute in May, and a certificate awarded in April to two Glencore mines in Katanga. Between them they changed what a buyer, a lender or an insurer must hold on file to say that Congolese cobalt has been sourced properly.

Prices tell the same story from another angle. The Banque Centrale du Congo’s digest to 16 May records London cobalt cathode at US$33,602 a tonne, against US$24,050 at the end of 2024, a gain of about 40 per cent. A price is a signal, though, and a rulebook is a condition: the first moves with sentiment, the second decides who is allowed to sell and who is allowed to buy.

This is a story about three layers of evidence that now sit in a cobalt buyer’s file, how they interact, and where each is thin.

A decree that rewrote the supply chain

ARECOMS covered every producer and made the state’s artisanal channel the only lawful route for hand-dug cobalt.

According to ACP’s account of the decision, ARECOMS suspended all cobalt exports from Congo for four months from 22 February, covering industrial, semi-industrial, small-scale and artisanal mining. The stated purpose was to stabilise the market against oversupply on the international market. The decision provides for a review within three months, after which the authorities may modify or end the suspension, and it names no quota.

It also set rules on origin. Cobalt from artisanal and semi-industrial production must be sourced and exported through the Entreprise Générale du Cobalt, mixing certified and non-certified supply is prohibited, and OECD compliance standards and workplace-safety rules apply. The Cobalt Institute’s reading is that the measures reiterate the EGC’s exclusive right to buy and export hand-dug cobalt and adopt its responsible-sourcing standard as national policy.

The evidence buyers actually read

The Cobalt Institute’s report put numbers on the problem the decree was written to solve.

The Cobalt Market Report 2024, published in May and resting on estimates by Benchmark Mineral Intelligence, counts 254,000 tonnes of cobalt mined in 2024, up 22 per cent, with Congo supplying 76 per cent. CMOC alone produced 114,000 tonnes from Tenke Fungurume and Kisanfu, 31 per cent above its stated capacity of 87,000 tonnes. Demand passed 200,000 tonnes for the first time, but supply grew faster for a third year. Hydroxide fell 15 per cent and metal 22 per cent during 2024, ending at historic lows.

The same report records what the decree did. Benchmark assessed metal prices in Europe up 41 per cent between 19 February and 19 March and Chinese sulphate up 92 per cent between 19 February and 26 March. It judges that part of the jump was speculation by traders caught short, and that prices began to moderate. It also says global stocks covered the four months but not a much longer ban, and that the government has indicated quotas or an extension without giving specifics. This is an industry body’s compilation, not an audit, and its figures are estimates.

One of its estimates matters for the rules. Artisanal output is put at under 2 per cent of Congolese production in 2024, against roughly 10 per cent in 2018. The EGC channel therefore governs a small share of tonnes. Its importance is to the reputation of the other 98 per cent.

The private rulebook: certification

A Copper Mark for two mines is becoming a purchasing condition rather than a courtesy.

On 14 April Glencore announced that Kamoto Copper Company and Mutanda Mining had received the Copper Mark, the first African mines assessed against version 3.0 of its Risk Readiness Assessment. The process measured performance against 33 criteria, used independent assessors and included interviews with more than 200 workers and stakeholders. Mark Davis, chief executive of Glencore Copper Africa, said it helped the company “gain better understanding of gaps in our social and environmental processes”.

The Cobalt Institute adds the buyer’s side. It reports that 82 per cent of refined cobalt was assessed under the Responsible Minerals Initiative in 2024, that Benchmark estimates 77 per cent of mine supply meets RMI criteria at least at one stage of processing, and that European carmakers are increasingly writing accreditation into purchase agreements. Tenke Fungurume received the Copper Mark in 2024; the two Glencore mines joined it in April.

How due diligence changes

Three layers now sit in the file: the state channel, the private assurance and the independent market evidence.

The mechanism is a stack. The state layer says who may export and by what route, so a trader offering cobalt must show the origin mine, the export authority and, for hand-dug material, the EGC chain. The private layer says how the mine behaves, which is where the Copper Mark and RMI assessments apply. The evidence layer lets a buyer test claims against independent supply estimates rather than a seller’s word.

The layers cover each other’s weak points. A decree cannot verify working conditions. A certificate cannot say whether a lot is licensed for export. A market report cannot identify a single shipment. A file that holds only one of them is incomplete, and a counterparty that offers only one is telling the buyer something.

One gap remains: none of the three says what happens when the suspension ends. The Cobalt Institute notes that mining companies are likely to keep producing through the ban, so supply keeps rising even though it cannot leave the country, and that some assets may shut their cobalt lines because of cash-flow pressure. The BCC’s provisional figures put first-quarter cobalt output at 41,721 tonnes, which shows mining continued. Whether stockpiles built during the suspension will be released under a quota, in full or not at all is not stated in any of the documents. Nor is it clear whether certification will count towards export authorisation.

The decision for buyers, lenders and miners

Build the three-layer file now, and put the review date in every contract.

Buyers and lenders should ask each cobalt counterparty for its ARECOMS status, its EGC documentation for artisanal material and its assurance certificates, and should write extension, quota and reopening scenarios into pricing clauses. Miners without certification should treat it as a commercial asset, as Tenke Fungurume, Kamoto and Mutanda have done. Small producers should secure their EGC position before the suspension ends, because when exports resume the buyers will check the rulebook before they check the price.