Gabon Raw Manganese Export Ban (Effective 1 January 2029)

Mechanism

The instrument is a Council of Ministers decision adopted 30 May 2025 establishing as a matter of national policy that all raw manganese exports will be prohibited from 1 January 2029. The decision is paired with a Commission tasked with drafting the implementing regulation (which will be the binding statutory instrument carrying penalties and customs codes), and a parallel work-stream by the Ministry of Industry and Local Transformation to negotiate transition modalities directly with the principal operators — primarily COMILOG (the Eramet subsidiary running the Moanda mine) but also CITIC's Nouvelle Gabon Mining and Ningbo Steel.

The ~3.5-year forward-notice is intentional: it is a window to let operators build the required ferromanganese / silicomanganese smelting capacity inside Gabon. COMILOG/Eramet has confirmed work on a 300 kt/yr ferromanganese plant at Moanda; the announcement of the ban is the policy lever forcing that capex decision (and analogous decisions by CITIC and Ningbo Steel) to convert from discretionary to load-bearing.

The structural template is Indonesia's hilirisasi / 2020 nickel-ore export ban — same instrument shape (forward-noticed raw-ore export ban with implementing-regulation tail), same theory of value (force the smelting/refining margin onto the producing country), applied to manganese as Indonesia applied it to nickel and bauxite.

Why severity 4

• Global supply share. Gabon is the world's #2 manganese

producer behind South Africa, with ~25% of global reserves and ~8 Mt/yr current output. China is the dominant downstream consumer (steel + battery-cathode precursors); a Gabonese beneficiation requirement removes the cheapest seaborne option for Chinese ferromanganese smelters.

• Forced capex on Eramet. Eramet's Moanda operation via

COMILOG is the dominant single source of Gabonese manganese. Eramet's 2 June 2025 response is conciliatory but the capex required to convert from ore-export to ferromanganese-export is multi-billion-euro scale; Bloomberg reported Eramet's stock declining on the announcement, and Mining Weekly's Feb 2026 follow-up shows the energy-supply constraint (Gabonese grid capacity for high-load smelters) is a live risk to the 2029 deadline.

• Theme alignment. Slots cleanly into the EM resource-upstream

-capture arc alongside Indonesia nickel/bauxite/copper bans, Zimbabwe lithium concentrate ban, DRC cobalt quota, South Africa chrome export control. Gabon is the first West/Central African producer to apply the template to manganese.

• First Gabon entry in IPTM register. Foundation action for

the country profile — bald gap up to this point.

Downstream implications

• Eramet (EPA:ERA). Forced capex; ferromanganese plant Moanda

capacity decisions accelerate. Long-run margin upside if Gabon-based smelting can be brought online before 2029, but near-term cash-flow drag and execution risk on power supply.

• Chinese ferromanganese smelters. Margin compression — the

cheapest seaborne ore option becomes a value-added ferro-alloy with Gabonese state-capture of the smelting margin.

• CITIC (Nouvelle Gabon Mining), Ningbo Steel. Same forced-

capex calculus; either build smelters in Gabon or exit.

• **South African chrome / manganese producers (proxy read-

through).** Pretoria's chrome-export-control gazette (filed as 2025-06-25-south-africa-chrome-ore-export-control-itac-permit) comes 26 days after the Gabon decision; the policy template is spreading across African mineral-producer states.

• Battery-cathode precursor supply chain. Manganese-rich NMC

cathodes and emerging LMFP chemistries source manganese sulfate from refined-manganese intermediates; Gabonese beneficiation reshuffles where in the EV-battery supply chain manganese- refining margin lands.

Open questions

• Implementing-regulation publication date. The Council of

Ministers decision sets the policy; the binding statutory instrument with HS-code coverage, customs procedures, and penalties is still in drafting. Track the Commission's output.

• Energy supply for in-country smelters. Mining Weekly Feb

2026 reporting flags Gabonese grid capacity as the binding constraint — without firm power, COMILOG cannot run a 300 kt/yr ferromanganese furnace. Gabon's response was to dismiss the concern; the engineering reality is a watch-item.

• CITIC and Ningbo Steel response. Will Chinese operators

build in-Gabon smelters, sell to in-country third parties, or exit? Their decisions set the marginal supply outcome.

• Possible carve-outs / transition exemptions. No exemption

framework is published yet; investment-incentive certificates (cf. Turkey EV / Indonesia hilirisasi precedents) are a likely shape.

• Eramet investor litigation / arbitration risk. Eramet's

conciliatory June 2025 response forestalls near-term ICSID exposure but the structural capex burden may surface bilateral-treaty claims if energy-supply commitments are not honoured.