BRIEFING

Mineral extraction, environmental harm, and conflict: The role of EU due diligence in promoting sustainable practices in conflict hotspots 

In many conflict-prone regions, mining activities often contribute to both environmental degradation and the intensification of local conflicts. These issues are exacerbated by weak governance structures, poor enforcement of regulations, corruption and limited accountability for extractive industries. Environmental harm, such as temporary tree cover loss and long-term deforestation, water pollution, and land degradation, further deepens local grievances, intensifying competition over resources and heightening tensions. This briefing examines the role of mineral extraction as both a driver of conflict and environmental degradation, using recent data from the Democratic Republic of Congo (DRC). It also analyses the shortcomings of EU due diligence frameworks in mitigating these impacts and provides recommendations to enhance responsible mining practices that reduce both environmental damage and the risk of conflicts.

The nexus between environmental degradation, resource extraction, and conflict

In conflict-affected and high-risk areas (CAHRAs), the exploitation of mineral resources has been found to contribute, directly or indirectly, to human rights abuses, social unrest, and environmental harm, amplifying existing grievances. Even outside conflict-prone regions, mining operations often lead to significant environmental degradation, such as soil depletion, erosion, water pollution, temporary tree cover loss as well as long-term deforestation. These environmental impacts not only damage ecosystems but also directly affect local communities that rely on natural resources for their livelihoods, thereby exacerbating existing vulnerabilities and stress factors that contribute to instability. For instance, the long-term environmental consequences of coltan and gold mining in the Congo Basin have led to deforestation and biodiversity loss, intensifying land-use conflicts.

In the DRC, artisanal and small-scale mining (ASM) holds severe environmental consequences, disrupting local ecosystems and livelihoods. The Kufatilia database, IPIS’ incident monitoring platform, reveals that in 2024, 62 environmental incidents related to mining were reported across eastern DRC. The most frequent issues, mercury contamination, water pollution, and deforestation, are not only ecological crises but also sources of community grievances and intergroup conflict. For instance, in Ituri, the pollution of the Talolo and Ituri rivers has intensified tensions between local populations and mining cooperatives, as access to clean water becomes more restricted. Similarly, in Haut-Uele, deforestation around mining sites in Kesi and Bavaingbe has led to disputes, as forest-dependent communities are displaced or lose access to vital resources. These examples illustrate how environmental degradation resulting from mining operations in the DRC is closely linked to the intensification of local conflicts.

Environmental incidents reported via Kufatilia in 2024.

The involvement of armed groups and certain undisciplined units of the Congolese national army (FARDC), who are frequently engaged in illegal activities surrounding mining operations, including taxation, extortion, and providing unauthorized protection services to mining sites, further enhances the critical situation. This pattern of exploitation not only depletes local resources but also undermines conservation efforts and law enforcement, facilitating a cycle of environmental destruction that intensifies conflict over diminishing natural resources. In the case of the M23, for example, large areas of forest have been cleared for charcoal production and firewood collection, contributing to accelerated deforestation. The environmental harm, especially the loss of access to clean water and arable land, exacerbates grievances, fueling competition for the remaining resources and increasing the likelihood of conflict.

Environmental governance in conflict hotspots: too hot to handle?

While weak governance, inadequate regulatory oversight, and local corruption can exacerbate the negative social and environmental impacts of mineral resource extraction, particularly in conflict-affected regions, the reality is that environmental governance is often politically and economically too difficult to manage.  The regulatory frameworks that exist are frequently undermined by vested interests, as mining revenues provide a critical economic lifeline to a range of actors, including political elites, local businesses, and armed groups. Moreover, corruption and local complicity allow environmentally harmful practices to continue with impunity, as seen in Kufatilia reports of authorities’ acceptance of cyanide use in Sombe and unauthorized mercury sales in Djalasiga.

The absence of effective environmental governance can further undermine efforts to regulate and monitor resource extraction activities. Local communities often lack the resources to address the environmental damages caused by mining, as companies and cooperatives frequently fail to remediate the harm they cause. The weak enforcement of land rights and mining regulations exacerbates the situation, leading to disputes between farmers, pastoralists, and mining interests. While some of the Kufatilia-reported cases are resolved or closed, many remain unresolved or persistent. The data highlights the need for stronger local enforcement mechanisms and greater investment in environmental governance, particularly in CAHRAs.

Mining companies operating in conflict-prone and high-risk areas often evade environmental obligations, taking advantages of regulatory loopholes and weak enforcement. In eastern DRC, cases of toxic waste dumping by industrial mining operations have been reported, contaminating water sources used by nearby communities and causing long-term damage to local ecosystems. While communities, and especially women and gendered-marginalized groups, are the first ones to pay the cost of environmental degradation caused by mining, they are often excluded from decision-making processes, including those governing the prevention, mitigation and remediation of social and environmental harm. Without inclusive and continuous meaningful stakeholder engagement, harm and grievances risk staying unaddressed, further fuelling distrust, resentment and conflict, as highlighted at one of IPIS’ panel events in October 2024.

EU due diligence frameworks and the fine line between sustainable governance and competitivity

In the last few years, the EU has adopted several due diligence legislations, such as the Conflict Minerals Regulation (CMR), the Critical Raw Materials Act (CRMA), and the Corporate Sustainability Due Diligence Directive (CSDDD), aimed at promoting responsible business practices, including in the extraction of minerals and other critical raw materials. These frameworks require companies to assess the social, and sometimes environmental, risks of their operations and to implement measures to mitigate these risks. They mandate that companies ensure their operations do not contribute to conflict financing or human rights abuses. One could think that the EU’s approach is therefore based on the broader idea that transparency can improve resource governance while safeguarding both its political and economic interests in conflict zones.

However, these existing due diligence frameworks lack concrete conflict-sensitive environmental policies as they are formulated now, and their effectiveness in addressing environmental risks remains limited. The CMR focuses primarily on human rights violations and conflict financing, with little emphasis on mitigating environmental harm. The CRMA prioritizes securing the EU’s access to critical minerals but lacks strong enforcement mechanisms for environmental protection. The CSDDD requires companies to conduct risk assessments in their supply chains, but it does not impose binding environmental due diligence obligations as comprehensively as it does for human rights issues. As a result, many environmental violations linked to mining in CAHRAs remain unaddressed, despite existing regulatory frameworks.

The Kufatilia data highlights ongoing environmental risks in the DRC’s mining sector, demonstrating that despite EU due diligence efforts, issues such as mercury pollution, cyanide contamination, and deforestation persist. Furthermore, the recent Omnibus proposal introduced by the European Commission (EC) may have significant implications for the environmental due diligence requirements under the CSDDD. While aimed at increasing efficiency and reducing regulatory burdens for businesses, the proposal could potentially dilute some of the social and environmental safeguards included in the original framework. If adopted, it might limit the scope and enforcement of environmental accountability, raising concerns about the long-term effectiveness of EU due diligence regulations in addressing environmental harm, particularly in high-risk sectors like mining. There is an inherent trade-off between strengthening environmental governance and maintaining a competitive economic framework for businesses. Without stricter due diligence requirements, the EU risks failing to meet its own sustainability commitments.

Recommendations for enhancing environmental governance and resilience in conflict hotspots

Environmental degradation caused by mining operations intensifies competition over resources, fuels social grievances, and contributes to cycles of violence, particularly in conflict-prone regions. Despite existing frameworks such as the EU’s CMR, CRMA, and CSDDD, environmental risks remain inadequately addressed in due diligence requirements. Strengthening these frameworks, improving corporate accountability, and making sure affected communities have a say in environmental decision-making are necessary steps to ensure that mineral extraction contributes to sustainable development in conflict-affected and high-risk areas, rather than exacerbate environmental harm and conflict. This includes specific recommendations:

  • For the EU: Strengthen due diligence frameworks by integrating conflict-sensitive environmental policies in existing due diligence frameworks, such as the CMR, CRMA, and CSDDD, and stricter enforcement mechanisms. Support capacity-building initiatives for local governance in resource-rich conflict-affected and high-risk zones to enhance regulatory oversight.

  • For businesses: Mining companies must move beyond regulatory compliance and adopt comprehensive environmental risk assessments. Sustainable extraction methods and meaningful community engagement, such as community-based environmental rehabilitation projects, are essential for long-term conflict prevention and environmental protection.

  • For CSOs: CSOs should continue advocating for stronger EU regulations that integrate environmental resilience into conflict prevention strategies. They play a key role in monitoring mining impacts, raising awareness of resource extraction-related conflicts, and supporting affected communities.

Moving forward, a more conflict-sensitive approach to environmental governance is necessary, not only enforcing regulations but also acknowledging the power dynamics that make environmental oversight “too hot to handle” in conflict zones. By implementing stronger enforcement mechanisms and ensuring corporate compliance, stakeholders can help mitigate the environmental damage that fuels instability. Ultimately, addressing environmental governance is not just a sustainability issue, it is a necessary strategy for conflict prevention and long-term peacebuilding in resource-rich but fragile regions.

Further reading

This briefing was produced with the financial assistance of the European Union. The contents of the editorial is the sole responsibility of IPIS and can under no circumstances be regarded as reflecting the position of the European Union.