A resources watchdog has warned that Zimbabwe’s recent strategic minerals policy rests on weak legal footing, arguing that efforts to maximise value from strategic minerals are being pursued without corresponding reform of the country’s outdated mining legislation.
The warning by the Centre for Natural Resource Governance (CNRG) follows the government’s declaration of lithium, nickel, cobalt, graphite, platinum group metals (PGMs) and rare earth elements as “critical minerals,” while gold and diamonds were classified as “strategic minerals” under a new mineral classification framework.
Under the policy, the State will hold a mandatory minimum stake in critical mineral projects through special purpose vehicles. In addition, export of listed minerals require beneficiation compliance and ministerial approval.
The controversy over Zimbabwe’s mineral classification framework highlights growing tension between executive policy pronouncements and existing legislative provisions. Analysts and civil society groups warn that the absence of clear statutory definitions for newly-introduced mineral categories risks legal uncertainty, regulatory overlap and potential investor hesitation in a sector central to Zimbabwe’s economic recovery strategy.
CNRG said the introduction of three categories “critical,” “special critical,” and “strategic” minerals has no basis in Zimbabwean law.
“The ministry (Mines and Mining Development ministry) has introduced three categories, ‘critical,’ ‘special critical,’ and ‘strategic’ minerals, yet nowhere in Zimbabwean law are these categories properly defined. Instead, the classifications are based on broad policy criteria and executive discretion,” CNRG said in a statement.
“The declaration states that minerals may be classified according to supply chain vulnerability, economic value, beneficiation potential, rarity and employment generation. But these remain political and administrative criteria rather than legally binding statutory definitions.”
CNRG said the confusion was deepened by inconsistencies with the Mines and Minerals Amendment Bill currently before Parliament.
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“The Bill only recognises ‘strategic minerals,’ defining them broadly as minerals important to Zimbabwe’s economic, industrial or security interests. Crucially, the Bill identifies only diamonds as strategic minerals,” the resources watchdog said.
“The ministry’s new declaration, however, abruptly expands the category to include gold, coal, iron ore, oil and gas, limestone, potash, pyrites and phosphorus, while simultaneously creating entirely new classifications absent from the draft legislation. The result is legal incoherence.”
The organisation warned that Zimbabwe risks operating parallel governance systems —one embedded in unfinished legislation and another driven through executive decree.
“Investors, regulators, communities and even government institutions are left navigating overlapping frameworks where mineral categories can shift through ministerial authority rather than parliamentary oversight,” CNRG said.
It added that the policy significantly expanded ministerial control over mining rights and mineral exports.
“This uncertainty is compounded by the declaration’s aggressive expansion of ministerial power. The statement explicitly provides that applications for mining rights on these minerals shall be by prior approval of the Minister of Mines and Mining Development,” CNRG said.
“It further states that no person shall export any mineral listed in the schedule in its raw or unbeneficiated form unless such export is authorised under a conditional transitional plan approved by the minister. In effect, the declaration centralises extraordinary authority over Zimbabwe’s most valuable mineral assets in the office of the minister.”
The statement comes after Zimbabwe’s largest platinum group metals producer and one of the country’s biggest foreign currency earners, Zimplats Holdings Limited, raised concern over the new policy framework.
“Zimplats notes the Zimbabwean government's announcement dated May 22, 2026, classifying certain minerals, including PGMs, as critical minerals under the new policy framework. Zimplats expects the Zimbabwean government to provide further details on this policy framework in due course and will provide further updates as required,” Zimplats said last week.
“As a long-standing and committed investor in Zimbabwe, Zimplats values the strong and constructive relationship it has built with the Zimbabwean government and other key stakeholders. Zimplats is actively engaging authorities to understand the full implications of the new critical minerals framework to ensure alignment with national development objectives, while maintaining a stable and competitive operating environment.”
Zimplats reiterated its support for government efforts to ensure Zimbabwe derives greater value from its mineral resources.
“Zimplats remains one of the largest contributors to the Zimbabwean economy through foreign currency generation, employment, infrastructure development and fiscal contributions,” Zimplats said.
“Over the years, the company has made significant long-term investments in local beneficiation, including the development and expansion of processing capacity, in line with national priorities to move up the value chain.”
