DRC EGC × ERG Africa — Protocole d'Accord on artisanal cobalt formalisation in Lualaba Province

Mechanism

The MoU is the operational implementation layer that converts the December 2025 blanket suspension of artisanal copper-cobalt processing and marketing entities (2025-12-19-drc-artisanal-copper-cobalt-processing-suspension) into a structured re-entry channel. Rather than simply lifting the suspension, the DRC government is routing ASM cobalt back into the supply chain through a tightly governed public-private framework centred on EGC's statutory monopsony.

Pilot structure. ERG Africa grants EGC mining rights over an ERG Africa-owned exploitation area in Lualaba Province — the Katanga cobalt belt's epicentre. Within this pilot zone, EGC organises artisanal miners into compliant cooperatives, establishes designated ASM zones, and creates controlled buying points where miners sell directly to EGC under standardised conditions. This is the operational template that ARECOMS and the Ministry of Mines intend to replicate across DRC's broader ASM cobalt sector.

Institutional architecture. Five state and parastatal bodies are involved:

• ARECOMS (Authority for the Regulation and Control of Strategic Mineral Substances' Markets) — regulatory oversight and quota-compliance integration
• SEAMAPE (Service for Assistance and Supervision of Artisanal Mining) — field supervision of artisanal miners and zone delineation
• CEEC (Centre d'Expertise, d'Évaluation et de Certification) — certification of cobalt provenance and due-diligence chain-of-custody
• Gécamines — state mining SOE providing technical and operational coordination
• GIZ (Deutsche Gesellschaft für Internationale Zusammenarbeit) — technical partner for formalisation methodology and sustainability standards

EGC monopsony architecture. EGC was established precisely to be the sole buyer of artisanal cobalt in the DRC, replacing the informal trader network that had supplied conflict-cobalt and child-labour-tainted material to Chinese refiners. The MoU with ERG Africa is the first publicly-announced operational deployment of EGC's ASM-formalisation mandate at a specific industrial concession, establishing the precedent for similar arrangements with other major DRC mining-rights holders.

Downstream implications

• ASM cobalt supply-chain integrity: DRC accounts for ~70% of global mined cobalt;

ASM sourcing represents ~10–15% of that total. Formal supply-chain reintegration under EGC's controlled buying-point architecture directly addresses the conflict-cobalt and child-labour due-diligence requirements of the EU Battery Regulation (2023/1542), the US Uyghur Forced Labor Prevention Act FEOC provisions, and downstream OEM supply chains (BMW, CATL, Umicore, Freeport Cobalt).

• ERG Group exposure: ERG Africa operates Boss Mining, Comide, Frontier, and Metalkol

RTR in the DRC — ERG is one of the top-3 DRC cobalt producers by volume. Granting EGC mining rights over an ERG-held exploitation area is a material concession; the MoU also potentially aligns ERG's ASM-adjacent zones with the ARECOMS quota system (2025-02-22-drc-arecoms-cobalt-export-ban-quota-system) compliance framework.

• ARECOMS strategic reserve integration: The April 2026 ARECOMS strategic reserve

decree (2026-04-10-drc-strategic-reserve-minerals-arecoms) authorises compulsory allocation of quota volumes to a physical reserve. The EGC-controlled buying-point architecture at ERG-held zones is the upstream collection mechanism that could feed into the Reserve's physical stock, closing the loop from ASM extraction through EGC monopsony purchase to ARECOMS strategic stockpile.

• Template replicability: If the Lualaba pilot demonstrates measurable formalisation

outcomes (certified production volumes, reduction in informal trading flows, CEEC chain-of-custody compliance), the Ministry of Mines and ARECOMS are expected to mandate similar MoU structures with CMOC (TFM, Kisanfu), Glencore (Mutanda, KCC), and Ivanhoe Mines — which would substantially extend EGC's effective buyer reach across the cobalt belt.

Open questions

• What fraction of the ERG Africa exploitation area is covered by the pilot ASM zone?

(size of concession, estimated artisanal miner population, and monthly production capacity not disclosed at signing)

• How does EGC's buying price at controlled buying points compare to informal-market

prices? Price competitiveness is the primary formalisation-compliance lever.

• What are the CEEC certification standards applied to MoU-produced cobalt and do they

satisfy the EU Battery Regulation's due-diligence thresholds?

• Will GIZ's technical-partner role produce a public methodology document that can

serve as the sector-wide ASM-formalisation standard?