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Holdwise
Critical Raw Materials & Africa

A European Entity for African Producers

Africa holds a share of the world's mineral base that few outside the industry appreciate. According to the United States Geological Survey, the continent accounted for 79.3 percent of global platinum group metal reserves in 2025, 61.7 percent of chromium, 54.5 percent of cobalt, 36.5 percent of manganese, 32.4 percent of diamonds and 25.5 percent of bauxite. What has historically travelled abroad, however, is ore rather than product, and value rather than volume has been the thing left behind.

Two forces are changing that at once, and together they create a moment worth acting on.

African governments are legislating for in-country processing: thirteen countries now apply export restrictions, bans or beneficiation requirements. And the European Union is legislating for supply security: the Critical Raw Materials Act sets 2030 benchmarks and reaches beyond the Union's borders through Strategic Project designation. Producers standing between those two forces need a European counterparty.

The European framework in brief

The Critical Raw Materials Act entered into force on 23 May 2024 and sets the Union's 2030 benchmarks: ten percent of annual consumption extracted within the Union, forty percent processed, twenty-five percent from recycled sources, and a ceiling of sixty-five percent from any single third country per strategic raw material. Strategic Project status reaches beyond the Union's borders, bringing guidance on funding, attention from the financing hub that mobilises EU funds and the European Investment Bank, and greater certainty for off-takers. The Commission names off-take agreements with European downstream industry explicitly as a route to contributing to supply security.

Those agreements are signed by a European counterparty, and that is where a Dutch entity earns its place: as the party that contracts with European industry, reaches European trade finance, and holds the import position with the Article 23 licence that defers import VAT to the periodic VAT return. Our guide to a European entity for critical raw materials sets out the full picture.

Where CBAM applies, and where it stays out

A distinction that determines which conversation a producer is having. The Carbon Border Adjustment Mechanism covers processed goods: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Ores and concentrates sit outside it. A bauxite, copper concentrate or spodumene exporter therefore meets Europe through commerce and finance rather than carbon.

Beneficiation moves the line. As concentrate becomes refined metal and bauxite becomes alumina, the same producer enters CBAM scope and the European entity gains a second function: authorised declarant. Building that vehicle during the ore phase means the position exists before it is needed. See an EU entity for CBAM.

Four reasons a European entity earns its place

Off-take agreements

European industrial buyers contract more readily with a European counterparty: jurisdiction, enforcement, VAT treatment and payment mechanics all simplify. The Commission names off-take agreements with European downstream industry explicitly among the routes by which a project demonstrates its contribution to supply security.

Financing

A European company holding receivables from creditworthy European buyers borrows on European terms. For producers whose local borrowing costs run well above European rates, that differential frequently exceeds the mining margin itself. European public finance, from the European Investment Bank to Dutch development finance and export credit infrastructure, flows toward structures it recognises.

Joint ventures

When a European industrial partner takes a position in a project, the vehicle sits on ground both sides accept. See joint venture structures.

The trading margin

Selling at the mine gate hands the margin between origin price and delivered European price to an intermediary, on every shipment. See a commodity trading entity in the Netherlands.

Partnerships and corridors already in place

The European Union has concluded strategic partnerships on raw materials value chains with Namibia in 2022, the Democratic Republic of the Congo and Zambia in 2023, and Rwanda in 2024, alongside a Clean Trade and Investment Partnership with South Africa. The Lobito Corridor, a Global Gateway flagship connecting the Angolan Atlantic port to the copper and cobalt regions of the DRC and Zambia, is partly operational, with the Zambian extension planned for completion by 2029.

Projects located in partner countries carry an advantage in Strategic Project assessment, and the first selection round designated projects in South Africa, Madagascar, Malawi and Zambia among its thirteen third-country entries.

Country guides

Entering with the documentation in order

African ownership chains ask more of notarial and banking due diligence than European ones, and saying so plainly serves everyone. Groups with several intermediate holding layers, state participations or politically exposed shareholders need their file prepared to the standard European institutions apply, from the first exchange rather than at the point of refusal. Where tin, tantalum, tungsten or gold are involved, the EU Conflict Minerals Regulation adds supply-chain due diligence on top.

We open the banking conversation in parallel with the incorporation, prepare the ownership documentation to that standard, and coordinate the tax specialist who signs off on the chain before the notarial deed is drafted.

Frequently asked questions

Why would an African producer establish a company in Europe?

Four reasons recur: contracting off-take agreements with European industry as a European counterparty, reaching European trade finance and public financing on European terms, providing a jurisdiction both sides accept for joint ventures with European partners, and capturing the trading margin that otherwise sits with intermediaries.

Does CBAM apply to African ore exports?

The Carbon Border Adjustment Mechanism covers processed goods: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Ores and concentrates sit outside it. As beneficiation converts concentrate into refined metal, the producer enters CBAM scope.

Which African countries hold EU raw materials partnerships?

Namibia signed in 2022, the Democratic Republic of the Congo and Zambia in 2023, and Rwanda in 2024. South Africa holds a Clean Trade and Investment Partnership. Projects in partner countries carry an advantage in Strategic Project assessment under the Critical Raw Materials Act.

How large is Africa's share of world mineral reserves?

According to the United States Geological Survey, Africa accounted for 79.3 percent of global platinum group metal reserves in 2025, 61.7 percent of chromium, 54.5 percent of cobalt, 36.5 percent of manganese, 32.4 percent of diamonds and 25.5 percent of bauxite.

What should African groups expect on banking and due diligence?

Deeper notarial and banking due diligence than European ownership chains face, particularly with several intermediate holding layers, state participations or politically exposed shareholders. Preparing the file to the standard European institutions apply, from the first exchange, keeps the entity on a realistic path to operation.

Turn production into European contracts

Holdwise incorporates Dutch BVs for producers and trading groups across Africa, and prepares the documentation to the standard European institutions apply. Fully remote, entirely in writing.

Start your Dutch BV

Sources

  1. Regulation (EU) 2024/1252 on critical raw materials, in force since 23 May 2024.
  2. European Commission, Strategic projects under the CRMA (DG GROW).
  3. Government of the Netherlands, Tax treaty countries.
  4. United States Geological Survey, Mineral Commodity Summaries 2025, as reported in industry analysis of African reserve shares.
  5. European Commission, Commission selects 13 Strategic Projects in third countries (June 2025).
  6. Council of the European Union, Lobito Corridor: Global Gateway Flagship (DG INTPA presentation, 2025).

Last reviewed 10 August 2026.