Over 15 years ago, the term “conflict minerals” was first coined—driving attention to Democratic Republic of Congo (DRC). International and regional efforts emerged to address the role that the illicit trade of high-value minerals from eastern DRC was playing in financing various armed groups and contributing to the protracted conflict and ongoing insecurity.

Private sector actors came under increasing scrutiny for their sourcing of tin, tantalum, tungsten (known as the 3Ts) and gold, with significant efforts aimed to identify and mitigate supply chain risks.

Despite years of attempts to break the link between minerals and conflict, history is repeating itself.

Mines and Transportation Routes Under Control of Armed Groups

Evidence shows the M23 seized Rubaya in late April 2024. The zone produces the majority of DRC’s coltan, which is the ore from which tantalum is extracted. According to the UN Group of Experts, the M23 established control over the mineral-rich area and created a new transportation route to Rwanda. Through taxation and smuggling of minerals, the armed group is financially benefiting from DRC’s mineral resources. It’s estimated that the group is receiving approximately $800,000 USD monthly from the production and trade of minerals at Rubaya.

While some mine sites in eastern DRC may not be directly affected by the conflict, early 2025 has started with violence in Goma (a major mineral export and transit hub), as well as insecurity moving towards South Kivu with recent clashes in in Nyabibwe, a mineral rich area known for 3Ts and gold, located halfway between Goma and Bukavu. As of mid-February, the M23 have occupied Bukavu, another major mineral export and transit hub in the region.

Recent reports also indicate armed groups in Ituri Province are forming alliances with the M23, while new violence in the province has sparked worries of a larger regional conflict. The UN Group of Experts estimated that armed groups based in Ituri Province generated approximately $140 million USD in 2024, dwarfing the illicit revenue generated by 3Ts.

The continued insecurity by the M23 calls into question what remaining transportation options and export points in North Kivu exist, especially for 3Ts, free from the influence of armed groups. As the M23 attempt to expand their presence in the east, the country’s lucrative gold sector is likely also to be disrupted by their influence, whether directly or indirectly.

Minerals Tied to Armed Groups Currently Being Sourced

Minerals directly tied to the M23 and other armed groups have been making their way to the international market.

Many private sector actors have failed to fully implement supply chain due diligence in alignment with international standards, most notably the OECD Due Diligence Guidance for Responsible Minerals Supply Chains from Conflict-Affected and High-Risk Areas (OECD Due Diligence Guidance). Companies are either turning a blind eye, preferring not to ask questions about the source of their purchases, or have been complicit by over relying on industry schemes despite red flags being raised in UN Group of Experts reports.

The concern around ITSCI—the sole traceability and due diligence provider for 3Ts in DRC—has been so great that in 2024 it lost its recognition with the Responsible Minerals Initiative (RMI), with RMI noting that important gaps remained in the scheme’s fulfilment of recognition terms. Despite this move, the UN Group of Experts has expressed concern that many private sector actors still rely on the scheme to conduct due diligence without carrying out additional independent quality controls required by international standards.

Further, authorities are also failing in their obligations to fully implement regulations and standards for responsible sourcing of 3Ts and gold. This includes the International Conference on the Great Lakes Region’s (ICGLR) six tools of the Regional Initiative against the Exploitation of Natural Resources, such as the Regional Certification Mechanism (RCM), which DRC and its neighbours agreed to implement and support when the Heads of State signed the Lusaka Declaration in 2010.

Sourcing Must Be Suspended When Financing Armed Groups

International and regional standards such as the OECD Due Diligence Guidance and the ICGLR’s RCM are unequivocal: mineral supply chains cannot directly or indirectly provide support to non-state armed groups.

The evidence that armed groups have control over mining areas and trade routes for both the 3Ts and gold in eastern DRC is conclusive.

Additionally, on February 12, the DRC government declared a number of mine sites across North Kivu and South Kivu as “red,” with no legal sourcing from the areas allowed.

Private sector actors must immediately cease their sourcing of minerals from any areas under influence of armed groups, including mine sites, transportation routes, and trading areas. They must carry out rigorous due diligence on their supply chains of materials exported where evidence shows these minerals are being smuggled to enter the legal market, including through neighbouring countries.

Cutting off sourcing relationships, particularly when this will negatively impact livelihoods for miners and their communities, is a last resort. While artisanal mining represents an important livelihood for thousands of women and men in the Great Lakes region, the primacy of life and the protection of civilians from insecurity and gross human rights violations prevails.

The Path to Peace

While cutting off mineral sourcing tied to armed groups may not alone resolve the conflict in eastern DRC, it is a basic measure of due diligence. The private sector cannot be complicit in the violence and human rights violations against civilians being carried out by armed groups in DRC.

The world relies on the minerals found in eastern DRC. These minerals are continuing to flow—whether there is conflict or peace.

The M23’s control of key mining areas in DRC has shown the fragility of our collective efforts to date, while also highlighting the extent to which these systems have not effectively contributed to long-term peace in the region.

Ultimately, the path to peace requires a regional solution.

The governments of the Great Lakes region must fulfill their obligations as part of the 2010 Lusaka Declaration in which they committed to jointly tackling the illegal trade of natural resources and their links to conflict and insecurity. Around the table, meaningful space must be made for the stakeholders affected by the violence and who can foster peace locally: communities, women, and civil society.

As IMPACT’s experience shows, addressing the illicit trade of minerals in the Great Lakes region—which easily flow across each other’s borders—will require a joint effort between these states. The region needs to come together to find a path forward. Hopefully it will be the path towards sustainable peace.

While the current situation is discouraging, many lessons have been learned over the past 15 years. It’s time to apply these to a renewed approach to once and for all, sever the link between minerals and conflict.

Notes for the Reader

Eastern DRC has significant mineral reserves including gold and 3Ts (tin, tungsten, and tantalum). These four minerals are defined as “conflict minerals.” The International Energy Agency has defined the 3Ts as critical minerals, needed for the green transition.

DRC produces over 40% of the world’s coltan (the ore from which tantalum is extracted). Coltan should not be mistaken for cobalt—also a critical mineral—mined in a different area of DRC, approximately 1,200 km away.