Critical Raw Materials & Zimbabwe

Zimbabwe: Beneficiation and the European Market

Zimbabwe has the largest lithium reserves in Africa. In the year to December 2025 it exported 1.128 million tonnes of spodumene concentrate, which contains lithium. That was eleven percent more than the year before. Most of this concentrate was shipped to Asia, where it was converted into battery-grade material.

On 25 February 2026 the government suspended exports of all raw minerals and lithium concentrates with immediate effect. This also applied to material already in transit. The reasons it gave were processing in the country (beneficiation), transparency and the prevention of export leakages. Zimbabwe is one of thirteen African countries that now have export restrictions, bans or processing requirements. The others include Namibia, Botswana, Ghana, Nigeria, Tanzania, the DRC and Malawi.

Largestlithium reserves in Africa
1.128m tspodumene concentrate exported in 2025
Feb 2026raw mineral export suspension

The EU rules on critical raw materials

The Critical Raw Materials Act entered into force on 23 May 2024. Under this act, the EU has targets for 2030. By then, ten percent of the EU's yearly use of strategic raw materials should be extracted in the EU. Forty percent should be processed in the EU and twenty-five percent should come from recycling. At most sixty-five percent of each strategic raw material should come from a single country outside the EU. Projects outside the EU can also get Strategic Project status. Such a project gets advice on funding and attention from the EU financing hub, which brings together EU funds and the European Investment Bank. Its buyers, called off-takers, get more certainty. The Commission names off-take agreements with European companies that use these materials as one way to secure supply.

A European company signs these agreements. A Dutch entity can be that company. It signs contracts with European industry and can use European trade finance. It can also be the importer and use the Article 23 licence. With this licence, the import VAT is declared in the periodic VAT return. You can read more in the guide to a European entity for critical raw materials.

Processed metal falls under more EU rules

Concentrate is outside the Carbon Border Adjustment Mechanism (CBAM). Refined and processed metal is often inside it. When a company starts to export processed products, the carbon rules apply as well as the critical raw materials rules. The European company that handles the goods then also becomes the CBAM declarant.

A Zimbabwean group that is building processing capacity now has time to prepare. Set up the European company while you build the business relationships. The CBAM declarant status is then ready when the first processed cargo is shipped. You can read more about both stages in the guides to a European entity for critical raw materials and an EU entity for CBAM.

Finding new buyers in Europe

Until now, most concentrate was sold to Asia. Processed material can also be sold to European buyers that rarely bought concentrate. These are battery chemical producers, cathode manufacturers and other industrial users whose supply the Critical Raw Materials Act is meant to secure. These buyers sign contracts with European companies, and the seller can get finance against the European receivables. The buyers pay the delivered price in Europe, which is higher than the price at the mine.

Zimbabwe also has platinum group metals and chrome. For these metals, there are processing links with South Africa and demand from European industry. One Dutch company can trade all these commodities.

Structure and practical points

For companies from Zimbabwe, the ownership chain, the sanctions screening and the bank onboarding need extra care. We prepare the file from the start to the standard that European institutions use. Before the notary drafts the deed, we check the treaty position and the ownership chain with a tax specialist.

Setting up in the Netherlands

The Dutch BV is set up by notarial deed and registered with the Dutch Chamber of Commerce (KVK). Your group owns the shares. You sign a power of attorney, so the incorporation can be done from abroad. The BV then takes on the roles your plan needs: off-take counterparty, trading company, joint venture company or importer of record.

Banks look closely at commodity trade from this region. We start the talks with the bank at the same time as the incorporation. You can read more about a commodity trading entity and joint venture structures.

Frequently asked questions

What did Zimbabwe's February 2026 export suspension cover?

The government suspended exports of all raw minerals and lithium concentrates with immediate effect. This included material already in transit. The reasons it gave were processing in the country (beneficiation), transparency and the prevention of export leakages.

When does CBAM apply to Zimbabwean minerals?

Concentrate is outside the six CBAM sectors. Refined and processed metal is often inside them. When Zimbabwean producers start to process their minerals, their products can come under CBAM. The company that imports these products into the EU then needs the status of authorised CBAM declarant.

Are other African countries restricting raw exports?

Thirteen African countries have export restrictions, bans or rules that require processing in the country. They include Namibia, Botswana, Ghana, Nigeria, Tanzania, the DRC and Malawi. These countries want to earn more from processing the raw materials themselves.

Why establish a European entity before processing begins?

Business relationships and authorisations both take time. Set up the European company while the processing plant is being built. Then the offtake contracts, the bank account and the CBAM declarant status are ready when the first processed cargo is shipped.

Set up your Dutch BV before processing starts

We set up Dutch BVs for Zimbabwean producers and processing groups and arrange the registrations after that. You can do everything from abroad and 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.

Last reviewed 10 August 2026.

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