27/11/2025
FSSMAZ POSITION STATEMENT ON THE ARTISANAL MINING RIGHT (AMR) REGULATORY FRAMEWORK
The Federation of Small Scale Mining Associations of Zambia (FSSMAZ) is expressing profound concern regarding the set regulatory conditions for the Artisanal Mining Right (AMR).
Our position is that some of the requirements are fundamentally misaligned with the stated national objectives of formalizing the artisanal mining sector and curbing illegal mining.
While we fully support regulation that promotes environmental stewardship, safety, and economic development, the current AMR framework creates insurmountable barriers for its intended beneficiaries.
The core issue is a critical misapplication. The conditions attached to the AMR are suited for established small-scale mines, not for the artisanal miners and cooperatives they are meant to serve.
The stated requirements, including the need for a ZEMA-approved Environmental Project Brief, detailed proposals for local business development, and employment programmes, are administratively and financially prohibitive for the average artisanal miner. The cost of ZEMA compliance alone, estimated between K80,000 and K100,000, is a decisive obstacle. We must be CANDID tgat these conditions do not regulate artisanal mining; they effectively exclude it.
This creates a policy contradiction. On one hand, there is a drive to bring illegal miners into the formal economy. On the other, the pathway to formalization is laden with hurdles that the target demographic, often with limited formal education and business experience cannot overcome. The result is a perpetuation of the very informal and illegal activities the policy seeks to resolve.
Furthermore, our members face significant operational challenges beyond licensing. The mineral export process, which should be an efficient, at the very least 4 hours-long procedure, routinely takes 3-4 days due to systemic failures such as no network or the system is just offline. When digital systems at the airport are non-operational, there is no manual alternative, causing our members to incur substantial financial losses from missed flights and demurrage. A nation in economic recovery cannot afford such inefficiencies.
Therefore, the FSSMAZ urgently calls for the following actions:
1. Differentiate and Simplify the AMR: The regulatory framework must distinguish between artisanal/miner cooperatives and established small-scale mines. The AMR process must be drastically simplified, affordable, and accessible to individuals with basic literacy, focusing on core identification, land tenure, and basic environmental awareness.
2. Review the ZEMA Process for Artisanal Miners: A separate, streamlined, and low-cost environmental compliance pathway must be established for artisanal mining operations to make formalization a viable option.
3. Implement Efficient Export Protocols: The Ministry of Mines and relevant agencies must develop and enforce reliable, time-bound export procedures with functional manual backup systems to eliminate the current delays and financial losses. A one stop shop would be ideal.
We believe a complex process is not synonymous with a quality outcome. The true measure of effective governance in this context is the creation of simple, efficient, and accessible systems that enable citizens to participate lawfully in building the economy.
We urge a collaborative review of the AMR conditions to align them with the practical reality on the ground and the goal of a fully formalized, compliant, and prosperous mining sector for all Zambians.
Joseph Mwansa
President FSSMAZ
