The Strategic Mineral Substances Markets Regulation and Control Authority (Arecoms) finalized the practical terms for implementing the Democratic Republic of Congo's (DRC) new cobalt export quota policy on October 10, 2025. The policy was first announced on September 20.

The quotas, approved by the Arecoms Board, allocate export volumes for the last quarter of 2025 to 21 companies.

China's CMOC Group, the world's largest cobalt producer, was granted 6,500 tons,4,250 tons for its Kisanfu Mining (KM) subsidiary, and 2,250 tons for Tenke Fungurume Mining (TFM). This total represents nearly 36% of the global volume allocated. Glencore follows with 3,925 tons, split between 2,775 tons for Kamoto Copper Company (KCC) and 1,150 tons for Mutanda Mining (MUMI). Combined, the two foreign giants capture 58% of the available quotas.

This dominance is rooted in the allocation formula. The Arecoms document specifies that "the base quota is distributed pro rata based on the historical quantities exported between January 1, 2022, and December 31, 2024." Exemptions were made for the state-owned Entreprise générale du cobalt (EGC) and the Société du Terril de Lubumbashi (STL), which were allotted 1,175 tons and 300 tons, respectively. During the 2022-2024 period, CMOC and Glencore controlled nearly 60% of total Congolese cobalt exports.

CMOC, whose primary shareholder is Chinese battery maker CATL, has not yet officially responded to the decision. However, the allocation poses a major challenge for the group, which relies heavily on Congolese cobalt to meet surging demand in China. Its metal trading subsidiary, IXM, already declared force majeure on June 30 due to the initial Congolese export embargo imposed in February 2025.

Despite the export suspension, CMOC maintained its operational pace in the DRC, extracting 61,073 tons in the first half of 2025 and projecting a full-year output of 100,000 to 120,000 tons. With only 6,500 tons authorized for the fourth quarter of 2025 and an estimated 31,200 tons for 2026 (based on the December quota being rolled over), the company will only be able to sell a small fraction of its production. Over two years, its total authorized exports would likely be capped at 37,700 tons, falling far short of its annual capacity.

Even if CMOC were to secure the entirety of the 9,600 tons set aside for "strategic quotas" in 2026, a volume reserved for projects deemed "of national importance" and allocated at Arecoms’ sole discretion,the situation would remain critical for the company.

Enforcement and Market Risk

CMOC also risks having its quotas revoked entirely. Sanctions are prescribed against any company that processes mining tailings or concentrates obtained from unauthorized third parties or artisanal miners, sells its quota to another firm, fails to export the allocated volumes, or violates existing laws.

While the export embargo is scheduled to end on October 15, the resumption of shipments could still face delays. To obtain an export certificate, operators are now required to present proof of prepayment of the mining royalty, validation of their available quota, a traceability certificate issued by Arecoms, and an environmental and fiscal compliance certificate.

Since the imposition of the embargo, the price of cobalt has more than doubled. On October 12, 2025, a tonne of cobalt was trading at $42,725 on the London Metal Exchange, compared to just $21,000 at the end of February.

Pierre Mukoko