With the October 16, 2025, launch of its new cobalt-export quota system just days away, the Democratic Republic of Congo (DRC) has yet to publish the decree required to implement it, corporate lawyer Romain Battajon said in a LinkedIn post.

Battajon, head of the Chamber of Mines’ legal commission at the Federation of Congolese Enterprises (FEC), echoed concerns widely shared across the industry.

The long-awaited decree is expected to outline the rules for granting and allocating quotas, set export fees for regulation and inspection, introduce a pre-payment mechanism for state contributions, and update customs procedures. Without it, cobalt exports cannot legally resume, effectively extending the existing export embargo beyond October 15.

The uncertainty particularly affects Chinese miner CMOC, whose Congolese subsidiaries Tenke Fungurume and Kisanfu shipped a combined 95,779 tons of cobalt in 2024. The company–majority-owned by battery producer CATL–depends on Congolese output to meet soaring demand for electric vehicles and industrial uses in China. Its trading arm, IXM, declared force majeure on supply contracts on June 30 after the embargo was extended earlier this year.

The Strategic Mineral Substances Market Regulation and Control Authority (ARECOMS) ended the embargo and announced the start of the quota regime on September 20, 2025. For the final quarter of 2025, cobalt exports will be capped at 18,125 tons–3,625 tons in October and 7,250 tons each in November and December. Annual quotas for 2026 and 2027 are set at 96,600 tons.

Boaz Kabeya