Zimbabwe is attempting to govern a 21st-century mineral boom with a mining law inherited from the colonial era. As the global economy races toward electric vehicles, renewable energy systems, and strategic mineral security, Harare is responding not with deep structural reform, but with policy declarations layered onto an exhausted and outdated legal framework.
In its latest press statement, the Ministry of Mines and Mining Development justified the declaration of “Critical,” “Special Critical,” and “Strategic” minerals on the basis of “increasing global demand for critical minerals to underpin the Energy Transition Drive and need for the country to strategically plan on its mineral resources.” The Ministry further argued that these are “minerals whose supply chains are highly vulnerable to disruption,” minerals “on high international demand where Zimbabwe holds significant reserves,” and minerals capable of generating “substantial direct and indirect local employment and national economic benefits.”
The language is compelling. It reflects a Government eager to project itself as a strategic player in the global energy transition economy. It speaks to beneficiation, industrialisation, employment creation, and resource sovereignty. Yet behind the rhetoric lies a more uncomfortable reality: Zimbabwe is trying to build a strategic minerals regime through executive declarations while the long-promised reform of the Mines and Minerals Act remains trapped in legislative limbo.
For nearly two decades, Government has promised comprehensive mining sector reform. Draft Bills have circulated endlessly through Parliament. Consultations have been held. Technical committees have deliberated. Yet the country remains governed by a mining law crafted in 1961, long before battery minerals, green industrialisation, supply chain security, and modern environmental governance became central to global mining politics.
This reform paralysis is no longer merely administrative delay. It has become a governance crisis.
The latest declaration exposes a dangerous contradiction at the heart of Zimbabwe’s resource governance model: enormous economic ambition resting on weak institutions, unfinished laws, and expanding ministerial discretion. At a time when countries are strengthening legal frameworks to regulate critical minerals transparently and competitively, Zimbabwe is increasingly governing strategic resources through policy pronouncements rather than enforceable legislation.
That contradiction becomes immediately visible in the declaration itself.
The Ministry has now 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. 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.
The confusion deepens when compared to the current Mines and Minerals Bill before Parliament. The Bill only recognises “strategic minerals,” defining them broadly as minerals important to Zimbabwe’s economic, industrial, or security interests. Crucially, the Bill currently identifies only diamonds as strategic minerals. 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.
Zimbabwe now 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.
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.” 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.
While strategic oversight of critical minerals is legitimate, excessive executive discretion without strong legal safeguards creates fertile ground for opacity, selective enforcement, political patronage, and corruption. Mining governance cannot depend on administrative flexibility alone. Long-term investment, environmental accountability, and public trust require predictable laws, transparent institutions, and enforceable oversight mechanisms.
Yet Zimbabwe continues to substitute legal reform with ministerial control.
The Government’s emphasis on beneficiation is economically understandable. For decades, Zimbabwe has exported raw mineral wealth while importing finished industrial products at premium prices. The declaration seeks to reverse this pattern by prohibiting exports of “raw or unbeneficiated” minerals unless miners comply with approved transitional beneficiation plans. It also requires exports to align with “approved Government beneficiation levels.”
But beneficiation without institutional reform risks becoming another extractive slogan.
Zimbabwe still faces crippling electricity shortages, unstable currency conditions, deteriorating infrastructure, and inconsistent industrial policy, all major constraints to large-scale mineral processing. Without resolving these structural barriers, beneficiation requirements may simply become instruments of political negotiation and discretionary licensing rather than genuine industrial transformation.
The same concerns apply to the proposed State participation model.
The declaration states that “the State shall, through designated Special Purpose Vehicles (SPVs), exercise a mandatory minimum shareholding in the exploitation of these minerals.” In principle, State participation in strategic sectors is neither unusual nor inherently problematic. Botswana’s Debswana and Namibia’s Namdeb demonstrate that State equity can support national development when backed by strong institutions and transparent governance structures.
Zimbabwe’s proposal, however, remains dangerously vague.
There is no clarity on ownership thresholds, financing structures, governance systems, auditing obligations, parliamentary oversight, or public accountability mechanisms for these SPVs. In a country where quasi-state entities have often operated as opaque vehicles for elite accumulation and off-budget financial activity, the absence of legal safeguards should alarm both citizens and investors alike.
Without transparency and legislative clarity, SPVs risk becoming shadow institutions controlling strategic national assets with limited public scrutiny.
Perhaps most revealing is what the declaration barely mentions at all: communities, environmental protection, and human rights.
The framework is overwhelmingly focused on State control, export regulation, and industrial ambition, yet largely silent on the social and ecological consequences of extraction. Zimbabwe’s mining sector has repeatedly generated displacement, water pollution, labour exploitation, land conflicts, and environmental destruction. Communities living near lithium, coal, gold, and chrome operations continue to absorb the costs of extraction while receiving limited benefits.
Yet the critical minerals declaration offers little clarity on environmental safeguards, benefit-sharing obligations, community consultation, or rights protections.
This omission reflects a broader weakness in Zimbabwe’s resource governance architecture: communities remain peripheral to mineral policy even as their land, water, and livelihoods are central to extraction.
The energy transition is often presented globally as a pathway toward sustainability. But without democratic governance and rights-based protections, critical minerals risk reproducing the same old extractive injustices under a green label.
Zimbabwe’s latest declaration therefore reveals a State attempting to assert sovereignty over strategic resources while lacking the institutional architecture necessary to govern them effectively. It is an ambitious policy constructed atop outdated laws, weak oversight systems, and concentrated executive authority.
Zimbabwe does not suffer from a shortage of mineral wealth. It suffers from a shortage of accountable governance.
What the country urgently requires is not another ministerial declaration, but comprehensive legislative reform. The Mines and Minerals Act must finally be overhauled to clearly define mineral classifications, regulate State participation, establish transparent governance systems, strengthen environmental protections, and guarantee community rights.