Under CS3D, the EU Batteries Regulation and growing investor scrutiny, tracing a supply chain back to the point of extraction is no longer optional. For multinationals sourcing minerals from Africa, it is a legal and commercial obligation that is already in force and becoming more demanding.
The intelligence required to meet that obligation does not exist in any database. It exists on the ground, in the sourcing country, gathered by people who understand the terrain well enough to follow a supply chain to where it actually begins.
The Democratic Republic of Congo illustrates the challenge clearly. The country supplies a significant share of the world’s cobalt, a mineral that sits at the heart of the global transition to electric vehicles and rechargeable technology. The conditions under which much of that cobalt is extracted are relatively well documented. The ownership chain between the mine and the multinational manufacturer at the other end is considerably less so.
That chain passes through artisanal mining cooperatives operating with limited formal structure, informal traders moving material across borders, processing facilities whose ownership is layered across multiple jurisdictions, and intermediaries whose role in the chain is rarely disclosed in any filing. At each stage, ownership becomes less visible and accountability more diffuse. By the time the cobalt reaches a battery manufacturer in Europe or Asia, the distance between the finished product and the conditions of its extraction is vast and largely unexamined.
This is not a problem unique to cobalt or to the DRC. The same chain exists wherever Africa’s mineral wealth meets global demand. Copper in Zambia. Gold in Tanzania. Lithium in Zimbabwe. Manganese in South Africa. The commodity changes. The ownership structures through which it moves share the same characteristics: informal, layered and resistant to documentation.
What changes across these markets is the specific terrain, the regulatory environment, the enforcement culture and the local networks through which reliable intelligence can be gathered. What does not change is the nature of the due diligence gap or the fact that closing it requires people on the ground who understand each specific market well enough to navigate it.
The obligation to trace the chain exists. The tools to do it remotely do not.