19/11/2025
With over 16 CSOs convened in Lusaka today, Publish What You Pay Zambia has reviewed the Draft SI on Critical Minerals Regulations. While the proposal is a strong step towards boosting local beneficiation and strengthening mineral oversight, several gaps could create legal uncertainty, scare away investment, and reduce transparency.
Here are some highlights from Our Analysis:
🔹 A clear national list of critical minerals is essential (Copper, Cobalt, Lithium, Graphite, Rare Earths, etc.).
🔹 Strong incentives for local value-addition and industrial hubs are critical for long-term economic transformation.
🔹 However, ambiguous definitions of “value addition” and “beneficiation” create high dispute risks.
🔹 Overly broad pre-emption rights, unclear 40% State participation, and export prohibitions may undermine investor confidence.
🔹 Gemstone sector reforms need community safeguards to avoid market distortions.
Therefore, PWYP Zambia recommends:
✔The responsible Ministry must declare area's that have Gemstone as areas of interest and not restriction areas. The aspect of restricting areas has been noted as one of the root causes of unrest among citizens
✔Before an area is restricted, the responsible Ministry must hold transparent consultations with the local traditional leaders, academia, CSOs (including Community Based)
✔ Clear technical definitions and schedules of approved beneficiation processes.
✔ Transparent procedures for State pre-emption and equity financing.
✔ Replace criminal penalties with fair administrative mechanisms.
✔ Reserve at least 40% of extracted minerals for domestic value-addition.
📢 PWYP will continue engaging Parliament, government, and citizens to ensure Zambia secures fair, transparent and sustainable benefits from its critical minerals.