With around two weeks remaining in 2025, the Democratic Republic of Congo is still piloting a new cobalt export procedure under its quota system. Many mining companies now say they will be unable to use their full annual allocations and are questioning what will happen to any unused quotas.

Under an Oct. 10, 2025 decision by the board of the Regulatory and Control Authority for Strategic Mineral Substances Markets (ARECOMS), which set the conditions for obtaining, allocating, and executing cobalt export quotas, base quotas per operator are neither transferable nor carried over into a future period. The decision states that any monthly export quota not used by the last day of the month in question is considered lost and automatically reallocated to ARECOMS’ annual strategic quota.

The decision includes an exception for this year. Monthly quotas per operator are exceptionally cumulative until Dec. 31, 2025, but no carryover from one year to the next is permitted. If applied strictly, companies unable to export their full 2025 quotas would forfeit them. Industry representatives say this would be unfair, arguing that the delays are not the operators’ fault.

Asked to comment, ARECOMS told Bloomberg that quotas from the last quarter would not be lost by mining companies and that it was examining all implementation options to limit the impact. The U.S. media also said DRC authorities had allowed producers to retain their 2025 quotas. However, as of the end of last week, several industry players said they had received no official notification to that effect.

Cobalt exports were due to resume on Oct. 16 but remained blocked for more than a month due to the lack of formal implementing rules required under ARECOMS directives. The interministerial Mines and Finance circular setting out the practical arrangements for cobalt exports was published only on Dec. 2. According to the Mining Chamber of the Federation of Enterprises of Congo (FEC), the document does not address concerns raised by cobalt exporters.

Authorities have since launched a testing phase, which began last week with a small shipment of cobalt belonging to Glencore, the owner of Kamoto Copper Company (KCC) and Mutanda Mining (MUMI) in Greater Katanga. “All means are being deployed to finalize the testing phase in the coming days, which will mark the resumption of cobalt exports from the DRC,” ARECOMS told Bloomberg.

Operators hope that once this phase is completed, the regulator will agree to talks to clarify ambiguities in the new system. According to industry sources, as of the end of last week, Mines Minister Louis Watum Kabamba had not responded to correspondence sent by the Mining Chamber on Dec. 4 requesting a working session under the consultation mechanism established in October.

For the fourth quarter of 2025, ARECOMS authorized the export of 18,125 tonnes of cobalt. CMOC and Glencore hold 58% of these volumes, with allocations of 6,500 tonnes and 3,925 tonnes respectively. Annual production is expected to reach nearly 200,000 tonnes.

Pierre Mukoko & Ronsard Luabeya