This month, critical signals for European supply chains originate primarily from South Africa, underscoring the intensification of social and governance challenges in the mining sector. Local press coverage highlights two major issues: on one hand, the controversy surrounding "anti-development" discourse from civil society, which complicates the attainment of social license to operate for new projects (Mail & Guardian); on the other hand, the persistence of large-scale illicit mining ("Zama Zama"), which poses critical risks to traceability, security, and ESG compliance for supplies from the region (Daily Maverick). These developments underscore that securing critical raw materials for the EU depends as much on managing risks in the field as on regulatory frameworks such as the CRMA.

South Africa: challenges of mining governance as a supply issue for the EU

While the European regulatory front has remained calm during the reporting period, the most pertinent signals for critical raw materials actors originate from the upstream end of the value chain. Publications in leading South African media highlight growing tensions regarding governance and social license to operate, factors that determine the viability and security of strategic supplies for Europe.

1. The social license to operate controversy and "anti-development" rhetoric

[ESG & due diligence] · [Resource geopolitics]

An opinion article published by the Mail & Guardian on 8 June 2026, entitled "Injustices, civil society and the baseless anti-development rhetoric", signals emerging polarization in the debate over the social acceptability of mining projects in South Africa.

• Facts and analysis: The title of this article suggests the emergence of a counter-narrative aimed at disqualifying the opposition of certain civil society organizations to development projects, notably mining ones. This rhetoric places project promoters (mining, infrastructure) in direct conflict with community groups or environmental NGOs. For mining companies and investors, this context creates significant uncertainty. The "social license to operate" becomes a battlefield for ideology, transcending the framework of standard regulatory consultations and environmental impact assessments.

• Implications for European actors:

  • Project risk: For European companies seeking to secure supply contracts (offtake agreements) or to invest in new extractive capacity, this polarization increases the risks of delays, legal challenges, and local conflicts. A project can see its development blocked not on technical grounds, but due to social and political opposition that has become insurmountable.
  • Reputational and due diligence risk: Aligning with "pro-development" rhetoric that ignores or delegitimizes local concerns can expose an offtaker or European investor to accusations of complicity in violations of community or environmental rights. Conversely, supporting opposition can be perceived as a brake on economic development by national authorities. (Context) This complex situation will require enhanced diligence, well beyond formal compliance, within the framework of the forthcoming directive on corporate due diligence in sustainability matters (CSDDD).
  • CRMA strategy: The objective of the Critical Raw Materials Act (CRMA) to diversify supplies through strategic partnerships with third countries rests on the stability and predictability of these jurisdictions. The rise of these social conflicts in South Africa, a historic mining partner, illustrates the limits of a purely diplomatic approach and the necessity of integrating refined analysis of local dynamics into the evaluation of Strategic Projects outside the EU.

2. Illicit mining ("Zama Zama"): blind spot in supply chain traceability

[ESG & due diligence] · [Resource geopolitics] · [Recycling & circularity]

Publication by Daily Maverick on 8 June 2026 of an extract from the book "Zama Zama: Graham Coetzer digs into the illicit mining underworld" highlights the professionalization and scale of the illegal mining sector in South Africa. The "Zama Zama" phenomenon, which designates artisanal and often illegal miners, represents a systemic challenge for sector governance.

• Facts and analysis: Far from the image of a simple subsistence operation, the Zama Zama phenomenon is today a structured underground economy, often controlled by criminal networks, which operates in abandoned mines or sometimes in parallel with legal operations. This activity is characterized by a complete absence of safety, health, and environmental standards, and is associated with endemic violence. The fact that a major media outlet devotes a book extract to this subject testifies to the pervasiveness of the problem in South African public debate.

• Implications for European actors:

  • Contamination of legal supply chains: The principal risk for European companies is the "leakage" of illegally extracted minerals into legal circuits. These raw materials, extracted under disastrous human and environmental conditions, can be laundered and end up in batches destined for export. This constitutes a major risk of non-compliance with the European Regulation on minerals from conflict-affected areas and the forthcoming CSDDD.
  • Traceability challenges: For an automotive manufacturer or battery producer, guaranteeing a "clean" supply chain from South Africa requires extremely robust traceability systems (e.g., blockchain, chemical marking) and in-depth field audits capable of detecting and excluding materials of illicit origin. Standard certifications may prove insufficient against organized criminal networks.
  • Impact on formal production: Zama Zama activity can directly disrupt legal mining operations through ore theft, infrastructure sabotage, or the creation of an insecurity climate for employees, affecting the reliability and production costs of official operators.

Issues for the coming period

The coming period will be marked by the analysis and integration of these "upstream" risks into European supply strategies. While no major regulatory deadline is expected in Brussels on the CRMA, vigilance will focus on the capacity of EU companies and institutions to translate sovereignty imperatives into effective management of complex ESG and geopolitical risks in the field. Discussions within the European Critical Raw Materials Board will increasingly need to integrate this granularity of analysis to assess the real resilience of strategic partnerships envisaged in Africa and elsewhere.

Automated monthly briefing by Reverdin Consulting · AI-curated thematic intelligence