ZELO Endorses Lithium Export Ban, Says It Validates Findings of Its Mine to Market Report

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The Zimbabwe Environmental Law Organisation (ZELO formally ZELA) has thrown its weight behind the government’s immediate suspension of lithium concentrate exports, stating that the ban aligns with recommendations made in its recent Mine to Market Situation Report for critical minerals, Mining Zimbabwe can report.

By Rudairo Mapuranga

In a statement released Friday, ZELO said the ban will help plug mineral leakages that its research identified as a persistent problem in Zimbabwe’s lithium supply and value chains.

“Having identified the risks and vulnerabilities in the lithium sector in our recent Mine to Market Situation Report for critical minerals, which tracked Zimbabwe’s lithium supply and value chains, we take comfort in knowing that some recommendations in the situational report are aligned with the government’s position at this moment,” the organisation said.

Mines and Mining Development Minister Dr. Polite Kambamura announced the suspension on Wednesday, stating it would remain in force until further notice as authorities work to tighten export controls, promote local beneficiation, and ensure greater accountability in the country’s strategic minerals sector.

ZELO noted that this announcement validates observations in its 2025 report, which highlighted a “porous lithium value chain which is prone to illicit trade and revenue leakages.”

The organisation’s report focused on ensuring that Zimbabwe derives maximum economic benefits from the lithium sector and attracts more investment.

ZELO acknowledged that the government has introduced a range of policies and legislative instruments aimed at promoting beneficiation and value addition of lithium and other base minerals, including the Base Minerals Export Control (Unbeneficiated Base Mineral Ores) (Amendment) Order, 2023 (Statutory Instrument 57 of 2023).

This legislative direction, the organisation noted, underscores the government’s commitment to ensuring that the extraction of strategic minerals contributes meaningfully to domestic industrialisation and inclusive economic growth aligned with Vision 2030.

However, the report also noted that implementation needed improvement, as mineral leakages were still reported at borders, including the export of raw lithium passed off as concentrates even when it did not meet prescribed value addition thresholds.

ZELO’s report was particularly critical of oversight at border posts.

“The Minerals Marketing Corporation of Zimbabwe (MMCZ) currently lacks presence at border posts, leading to weak oversight,” the report stated. “The Zimbabwe Revenue Authority (ZIMRA) also lacks the technical capacity to verify mineral content independently, creating delays and risks of mineral leakage.”

The organisation noted, however, that MMCZ has since responded positively to this problem by stationing its officers at borders, a development that strengthens the enforcement of the current suspension.

The Stakes: Jobs, Infrastructure and Avoiding the Resource Curse

ZELO emphasised that if effectively implemented, Zimbabwe stands to realise substantial benefits from lithium mining and processing, including:

  • Job creation
  • The growth of new towns
  • Infrastructure development
  • Increased tax revenue
  • Improved livelihoods for rural communities

“However, to fully optimise these benefits, there is an urgent need for the government to strengthen its policy and legal frameworks governing the transitional minerals sector,” ZELO said.

“This includes ensuring investment security, fostering fair competition in the mining industry, promoting responsible and sustainable mining standards, and implementing progressive fiscal policies that enable the lithium sector to drive long-term economic growth and help the country avoid the resource curse.”

Key Recommendations to Complement the Ban

To ensure that the intended benefits of the ban are realised, ZELO reiterated several recommendations from its Mines to Market report:

  1. Strengthen Compliance and Export Monitoring

Government agencies, particularly the Ministry of Mines and Mining Development and MMCZ, must ensure strict enforcement of export regulations, including the ban on unbeneficiated lithium. Improved inspection, monitoring, and data transparency systems are essential to curb illicit trade and revenue leakages.

  1. Ensure Consistent Enforcement

The government should strictly enforce the ban on unprocessed lithium exports as provided under SI 213 of 2022 and ensure compliance with the concentrate thresholds stipulated in SI 57 of 2023 and SI 5 of 2023. Effective enforcement will strengthen local beneficiation and reduce risks of illicit trade.

  1. Strengthen Public-Private Partnerships (PPPs)

The government should encourage joint ventures and PPPs between local and international actors across the lithium value chain. Such partnerships should prioritise the establishment of Approved Processing Plants (APPs), energy hubs, and skills development programmes to promote technology transfer and local capacity building.

  1. Establish Special Economic Zones (SEZs) for Beneficiation

Create Special Economic Zones dedicated to lithium and critical mineral beneficiation into high-value products such as lithium metal oxide cathode material, graphite anode material, lithium-ion batteries, turbines, and solar panels. These SEZs can serve as catalysts for industrialisation aligned with Vision 2030 and the National Industrial Development Policy.

  1. Diversify Export Markets

ZELO called for national strategies aimed at reducing reliance on a single export market, particularly China. This can be achieved by exploring new global trade partners, expanding market outreach, and aligning domestic production with international demand trends.

“Market diversification will enhance resilience, improve competitiveness, and strengthen Zimbabwe’s bargaining power,” the organisation said.

  1. Broaden Investor Participation

The government should encourage competition by engaging additional investor countries through trade fairs, diplomatic missions, and international partnerships. Regional trade agreements such as AfCFTA, SADC, and COMESA should be leveraged to attract diversified investment portfolios and enhance Zimbabwe’s integration into regional and global value chains.

ZELO’s endorsement adds a civil society voice to the growing chorus of support for the government’s export suspension, framing the ban not as a punitive measure but as an evidence-based intervention to protect national interests.

The organisation made clear that, based on its research, the ban was “an expected development.”

With MMCZ now stationed at border posts and enforcement mechanisms being strengthened, the focus shifts to implementation and ensuring that the complementary measures—SEZs, PPPs, and market diversification—are pursued with equal vigour.

The trucks that once rolled across Beitbridge carrying raw lithium may have made their last journeys. The question now is how quickly Zimbabwe can build the processing capacity to replace those exports with something far more valuable: jobs, skills, and a place in the global battery value chain.

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