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Bat Guano and Clay Officially Declared Minerals Under New Statutory Instrument

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The Minister of Mines and Mining Development has gazetted Statutory Instrument 169 of 2025 — the Mines and Minerals (Declaration of Minerals) Notice, 2025 — officially declaring bat guano and clay as minerals under the country’s mining laws.

The new regulation, issued in terms of section 5(3) of the Mines and Minerals Act [Chapter 21:05], repeals and replaces the First Schedule to the original Mines and Minerals (Declaration of Minerals) Notice, 1990.

According to the notice, the updated First Schedule now reads:

“Substance declared to be mineral: Bat guano and clay, where it occurs in quantities sufficiently great to warrant extraction by mining or quarrying.”

This effectively means that both bat guano — a natural fertiliser derived from bat droppings — and clay deposits of commercial significance are now recognised as regulated minerals. Their extraction, processing, and trade will henceforth fall under the oversight of the Ministry of Mines and Mining Development.

Bat Guano in Zimbabwe

According to an article by Nomsa Ngono sometime ago, there seems to be limited research on geological exploration and mining of Guano islands or caverns within the cratons of Africa. The reasons remain unknown; probably it was due to the fact that they are not of economic interest, or it might be the fear of contracting cave disease and inaccessibility. Interestingly, Zimbabwe has now decided to go for Guano.

Implications for Industry and Environmental Management

The inclusion of bat guano is particularly significant for Zimbabwe’s agricultural and environmental sectors. The substance is known for its high nutrient content and is widely sought after as an organic fertiliser in global markets. Its formal recognition as a mineral resource allows for structured and sustainable extraction, ensuring environmental safeguards and equitable benefit sharing under the Mines and Minerals Act.

Similarly, declaring clay as a mineral strengthens regulatory control over its commercial quarrying, which supports industries such as ceramics, construction, and brick-making. This move is expected to enhance formalisation and potentially increase revenue collection from artisanal and small-scale operations that previously operated outside the mineral regulatory framework.

Promoting Resource Accountability

The declaration aligns with the government’s broader efforts to tighten oversight of all extractive activities, improve transparency in the use of natural resources, and promote value addition in line with Zimbabwe’s Vision 2030.

By extending mineral classification to substances like clay and bat guano, the Ministry of Mines continues to ensure that all economically viable natural materials are developed responsibly and contribute to national economic growth.

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