Executive summary republished from KI Intelligence Brief No. 04. The full report is available as PDF below.
Executive Summary
Brief No. 03 described Namibia's critical minerals position as resting on policy instruments enforced through ministerial discretion rather than codified law, and contrasted that with the hard deadline anchoring Zimbabwe's regime. This brief examines what actually governs that deadline. The distinction is narrower than it appeared.
On the published record, Zimbabwe's control on lithium exports is Statutory Instrument 5 of 2023, the Base Minerals Export Control (Unbeneficiated Base Mineral Ores) Order, as amended by Statutory Instrument 57 of 2023. Both were made under the Base Minerals Export Control Act [Chapter 21:05]; SI 5 replaced an earlier lithium-specific order, SI 213 of 2022. Export of unbeneficiated ore requires a ministerial permit. Lithium concentrate at or above set lithia contents — 3 per cent for spodumene, 2.5 per cent for petalite and lepidolite — is classed as beneficiated, and SI 57 provides that permits to export it may be granted only where prescribed conditions are met and the price is not below a floor set by the Minerals Marketing Corporation of Zimbabwe. Contravention of an order, or of the conditions of a permit, is an offence carrying a fine or imprisonment of up to two years. Koussi has not traced amendments made after May 2023.
The measures of 2026 sit on top of that. Exports of raw minerals and lithium concentrate were halted in late February 2026 and resumed under conditions from April. A Mineral Classification and Declaration was signed on 22 May 2026. The end of concentrate exports from January 2027 had been announced by Cabinet in June 2025. Koussi has searched the Statutory Instruments published by Veritas Zimbabwe across SI 2026-036A to SI 2026-148 and located no instrument giving effect to any of these measures. That listing has gaps and the absence is not conclusive. Veritas was asked directly on 16 September 2026; no response had been received at the time of publication. In an interview published on 25 August 2026, Minister of Mines and Mining Development Dr Polite Kambamura referred to the beneficiation requirement as a Government directive. On 19 June 2026 the Lithium Association of Zimbabwe asked government to extend the January 2027 deadline. On 24 June 2026 Minister of Finance, Economic Development and Investment Promotion Mthuli Ncube said the government would maintain it. Koussi has located no record of a legal challenge to the requirement.
The measures in this sequence have been introduced by announcement, several with immediate effect. SI 5 and SI 57 were both made with immediate effect, and the 2026 measures, on the record located, were announced rather than gazetted. The position set out here is the position at publication. It can change without notice.
What that leaves is a regime in which the penalties are statutory and the operation of the control runs through ministerial permits. Whether the January 2027 deadline is itself an exercise of that permit power is not established here. Koussi sets out the instruments and the sequence and leaves the reader to assess the relationship between them.
Against that, the Koussi Compliance Register records the following positions for seven assessed Zimbabwean operators as at 16 September 2026. These are forward- looking assessments of readiness against a future deadline. The prohibition is not in force and none constitutes a finding of current breach.