Zambia SI No. 15/2026 — Customs and Excise (Suspension) (Copper Concentrates) Regulations, 2026

Mechanism

SI No. 15/2026 was made by the Minister of Finance under Section 89 of the Customs and Excise Act, Chapter 322 of the Laws of Zambia. It suspends — reducing to zero — the ad valorem export duty ordinarily imposed at 10% on copper concentrates classified under HS tariff headings:

• 2603.00.21
• 2603.00.22
• 2603.00.23
• 2603.00.29

The instrument is a statutory instrument published in the Government Gazette on 5 March 2026 and took immediate effect on that date.

Trigger: Zambia's principal copper smelters entered extended maintenance rotations in early 2026, reducing domestic processing capacity below the concentrate offtake rate. The affected facilities include:

• Mopani Copper Mines (ZCCM-IH, Glencore legacy; state-managed since 2021): Mufulira and

Nkana smelter outages

• Lumwana (Barrick Gold): concentrator and SX-EW maintenance
• Kansanshi (First Quantum Minerals): flash smelter scheduled maintenance
• Nkana (Chinese-owned interest): periodic rebuild

Without domestic processing outlets, mines faced building stockpiles that could not be monetised under the existing export-duty regime (10% ad valorem on concentrates, designed to incentivise domestic beneficiation). The suspension eliminates the disincentive for the duration of the maintenance-constrained period.

Design tension: The 10% concentrate export duty is part of Zambia's downstream-processing incentive architecture — penalising raw mineral exports to encourage domestic smelting and refining. The suspension reveals a structural tension: policy design for normal-operations beneficiation pressure runs counter to force-majeure smelter-outage logistics. The follow-on SI 43/2026 resolved this by imposing company-specific quotas and channelling through an IDC-owned intermediary, preserving some state oversight over the suspension period.

Downstream implications

• Zero-duty window closes the stockpile overhang by allowing direct concentrate exports to

Chinese and other offshore smelters, preventing Zambian mines from curtailing production (which would otherwise be the economic response to unprocessable concentrate build-up).

• IDC's Industrial Resources Limited (IRL) becomes the statutory export channel under the

SI 43/2026 extension, effectively inserting a state-owned trading intermediary into the concentrate supply chain — a pattern with precedent in DRC's ARECOMS cobalt regime and Zimbabwe's Fidelity Gold routing.

• Chinese smelter exposure: the measure benefits Chinese-affiliated smelters with offtake

agreements on Zambian concentrate, reinforcing supply-chain dependency even as Zambia's MRC Act and local-content SI 68/2025 push back against Chinese-capital dominance.

• Precedent effect: once companies have established concentrate export logistics for the

suspension period, pressure to renew/extend the waiver will persist beyond the smelter maintenance backlog — an institutional path-dependency risk for Zambia's beneficiation policy.

Open questions

• Does SI 15/2026 specify an expiry date, or is it open-ended until revoked? (SI 43/2026

substitutes it from 1 June 2026 with a 30 Sep 2026 hard expiry — check whether SI 15/2026 itself included a sunset clause.)

• What quantity of concentrate was exported under SI 15/2026 (5 March – 31 May 2026 window)

before SI 43/2026 imposed quota controls?

• Will the Ministry of Mines align the suspension with the broader beneficiation-policy review

or treat it as a pure force-majeure instrument?