ITSCI deeply regrets the negative security developments in North and South Kivu Province, DRC and its severe humanitarian impact. We also regret increasingly generalised reporting about tin, tantalum, and tungsten (3T) mineral supply chains in the Great Lakes Region (GLR) which do not recognise differing local context and risks.
By publishing this statement, we aim to inform public opinion and promote transparency regarding our Programme and actual risks in 3T supply chains. Our hope is to limit widespread undifferentiated supply chain embargo and further harm to local communities. We also take the opportunity to address prevalent misconceptions and false allegations in Amsterdam & Partners and some media reporting.
Whilst due diligence is ultimately a company’s responsibility, ITSCI’s longstanding presence on the ground enables us to provide credible first-hand information, supporting businesses to make appropriate and effective decisions to fulfil their due diligence, and supporting government authorities and local civil society to take steps towards progressive improvement and good governance in mining.
Principles of Due Diligence in Conflict-Affected and High-Risk Areas
The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRA) was developed collaboratively through a multistakeholder process, involving the OECD, governments of the ICGLR[1], the UN Group of Experts (UNGOE), industry and civil society. This followed the publication of similar guidelines by the UNGOE.[2] Stakeholders agreed on best practices and good faith efforts, providing clear guidance and confidence to companies on how to remain engaged when sourcing from CAHRA. We regret that these principles of joint and coordinated efforts do not seem to remain fully supported by all, creating uncertainty for, and de-risking by companies with renewed negative unintended consequences for local communities.
Set-up in 2010 and designed explicitly to assist with implementation of the recommendations of the OECD Guidance, ITSCI has established partnerships with in-region governments to provide on-the-ground solutions and support companies to make informed decisions. ITSCI remains dedicated to upholding and promoting the principles of multi-stakeholder cooperation – as agreed per OECD Guidance – rather than division; ongoing and sustainable improvements rather than short-term and counterproductive de-risking; and detailed and nuanced analysis rather than undifferentiated and generalised narratives.
Ongoing work in Conflict-Affected and High-Risk Areas
ITSCI’s operations in the GLR have met complex and high-risk situations, in different areas and at different times. Risks, unfortunately including active conflict, have always existed and will continue to be expected in the GLR – and beyond. In the last 15 years, ITSCI has demonstrated that it is not only possible, but also highly impactful to work jointly with local and international stakeholders to practically address these real issues. Even today our field teams based in Goma and in North and South Kivu continue to report.
Many risks can be mitigated or resolved, including occasional presence of armed actors or illegal taxation. However, mitigation in active conflict areas is not possible. Such extreme situations can only be managed through suspension of activities, which ITSCI, in coordination with state services, has done in identified conflict areas of Masisi, North Kivu. We recognise that suspension raises pressure on control measures in other areas.
ITSCI follows the same standard in all countries we support and includes measures for core risks specific to each location and their individual context. In North Kivu, special focus has been placed on risks related to abuses by both state security forces and non-state armed groups as well as enhancing traceability controls in consideration of complex local economic, social, political and ethnic factors. In Rwanda, particular emphasis has been put on tag management, state control, and both internal and cross-border mineral fraud.
Commitment to enhanced transparency
ITSCI drives transparency by making public extensive information on 3T supply chains that was not available before our Programme was established and is not available from other sources, nor in any other CAHRA. ITSCI publishes information beyond what is explicitly recommended in the OECD Guidance.
We provide first-hand and accurate information about the 3T supply chains we monitor, shining a light on risks and encouraging progressive improvement. Key information includes comprehensive reporting on OECD Annex II risks, including incidents involving armed groups and human rights abuses, highlighting mitigation efforts and outcomes, whether resolution is achieved or not.
Information is provided in a timely fashion to all ITSCI company members, all participating governments at national and local level, and to all relevant local stakeholders from industry, state services, authorities and civil society. Any company in the supply chain, whether upstream or downstream, can access ITSCI information through membership prior to publication for their own due diligence.
ITSCI’s scope and efforts to address risks of fraud
ITSCI is implemented at scale, covering ~3,000 mine sites across Burundi, DRC, Rwanda, and Uganda. ITSCI does not cover all supply chains in those 4 countries and does not cover all countries in the GLR. There are companies mining, processing, exporting and occasionally smelting 3T minerals in those countries which are no longer, or have never been, participants in the ITSCI Programme. Any assumption that all 3T minerals in ITSCI-covered countries in the GLR are in-scope of ITSCI traceability, reporting or other activities is not accurate. Minerals are also known to be fraudulently and falsely presented as in-scope of ITSCI at international level.[3]
ITSCI acknowledges long-term risks of internal domestic fraud as well as cross-border fraud between countries such as the DRC and Rwanda. Fraudulent misrepresentation is an OECD Annex II risk which ITSCI has, and will always, report when credible information is available. We make good faith efforts to address all identified risks, fostering our collaboration with local governments and partners, and working within the legal frameworks of the countries in which we operate. We do not replace any government’s sovereign right and responsibility for law and enforcement matters.
No system of traceability, whether in CAHRA or not, will be perfect, and we continue efforts to progressively improve measures to avoid or reduce fraud. We will continue to provide public updates on those measures for example as in our public statement on the 2023 Final report of the UN Group of Experts. Local domestic or cross-border fraud can have many drivers, including distortions from mineral pricing, commercial agreements, and legal frameworks. To manage and resolve any fraud, causes must be addressed in a holistic way, including by addressing any underlying governance issues.
Mining sector in Rwanda and mineral fraud
ITSCI reports on the general context of the mining sector in each implementation country and its development over the years, as do other stakeholders and media. Suggestions that there are no mineral resources available for mining in Rwanda are not credible. Geological evidence often refers to 3T deposits found in the east-central African Kibara Belt which stretches over 1,300 km from south-western Uganda via Rwanda and Burundi into southern DRC and onwards towards the Angola–Zambia–DRC border. ITSCI’s areas of operation closely match the known geology. References are provided in Annex 2.
Nevertheless, despite government implementation of traceability, ITSCI does not assume all minerals are plausibly obtained from the claimed mine sites. ITSCI regularly identifies and records incidents of misrepresentation of mineral origin or plausibility risk, including from misuse or sale of tags by state services or other actors. As noted in our latest annual review, these issues made up 14% of all ITSCI incidents across the GLR and are taken seriously, whether other stakeholders also highlight those events, or not. Working with government services, local companies and civil society to identify and resolve traceability issues is an important aspect of ITSCI’s work, while offering a whistleblowing programme to enable confidential reporting of concerns. Spot checks of mineral exporters are also in place.
We reiterate that there are risks of cross-border fraud of minerals from North Kivu to Rwanda and that risks have increased since the suspension of ITSCI tagging in Masisi, North Kivu, in December 2023[4]. We have re-doubled efforts and measures to identify and manage risk in that situation.
We provide in Annex 1 additional notes on tantalum statistics, including ITSCI exports data in Rwanda.
Insecurity in North Kivu presents challenges but with past success
ITSCI transparently communicated background context and expected risks in North Kivu prior to starting activities in the Province, with a public governance assessment of the Rubaya area in 2013. Our systems apply measures appropriate to those risks and continued to develop over time. We have published regular updates on risks, including on cross-border fraud, which are publicly available and transparent.[5]
In a period of relative stability (2013-2018) we worked in Masisi territory and the Rubaya area in partnership with local stakeholders to jointly achieve an improved working environment for miners, fostering collaboration among parties who have historically regarded each other as adversaries. This demonstrates the power of dialogue and mediation and confirms that the presence of minerals is not per se the cause of conflict although minerals may unfortunately be associated with conflict.
Certification vs. ongoing and pro-active due diligence
ITSCI is not a certification scheme. Neither ITSCI, nor any 3T smelter audit programmes provide certification of minerals as ‘conflict-free’[6], and this is not an expectation of the OECD Guidance which recommends companies take specific good faith steps of due diligence. Expectations for guaranteed ‘conflict-free certification’ lead to a general harmful de-risking by companies.
ITSCI is a facilitation initiative which assists with establishing traceability from mine to smelter and supports companies to perform their due diligence by providing information from continuous monitoring of risks and engagement with local stakeholders to manage and, when possible, mitigate risks. ITSCI does not use the term ‘bag & tag’ which over-focuses on traceability rather than risk management. Traceability or chain of custody is just one tool or step within the 5 steps of due diligence.
Impacts and achievements of ITSCI’s multi-stakeholder due diligence model
Reports, such as from Amsterdam & Partners, present a general picture of the GLR’s 3T mineral sector with seemingly no change or improvements in risk reporting or management over many years. Such statements ignore or discount evidence of increased transparency and other positive developments on-the-ground. Prior to 2010, there was no traceability in place, no mechanism to report and discuss risks, nor regular publication of risks or their mitigation; a situation diametrically opposed to today’s context. ITSCI has contributed to this change by:
- Building from a one-mine pilot project to a large-scale programme benefitting ~3,000 mine sites.
- Establishing 73 local and provincial multi-stakeholder committees for inclusive discussion.
- Transparently reporting 1,869 incidents or risks in 2024 directly shared with 594 Full Members upstream across 47 countries, and locally with relevant stakeholders.
- Achieving the volunteer departure of non-state armed groups from 3T mines in provinces like North Kivu and South Kivu[7], resulting in 3T mining areas becoming ‘safety hubs’.
- Developing trusted relationships with government and public security forces to implement joint risk mitigation, including by high-ranked army officials sanctioning soldiers involved in incidents.[8]
- Enhancing accountability of local actors, fostering confidence and investment in the 3T mineral sector, with a track record of mines evolving from artisanal to small-scale or semi-industrial mines.
While noting there are 3T mines and actors in the GLR outside the scope of ITSCI, many risks and abuses we have documented would have remained unreported and likely unresolved without ITSCI’s presence on the ground. Of course, neither ITSCI nor any other due diligence approach can operate in the face of widespread active M23 conflict, but we have previously engaged in dialogue with non-state armed groups to obtain their cooperation in leaving certain mine areas or not interfering in mineral trade.[9]
ITSCI is proud of these achievements which demonstrate the value of joint and good faith efforts, constructive multi-stakeholder dialogue and trusted cooperation between actors from government, industry and civil society at local and international level.
Note on the Amsterdam & Partners report
The Amsterdam & Partners report presents various misconceptions and mostly reuses and recycles allegations from Global Witness (2022) which itself refers to many past historical topics, including risks already publicly reported by ITSCI. We regret that Amsterdam and Partners has presented a selective picture, not referencing nor seemingly taking into consideration ITSCI’s extensive and detailed 74-page reply to Global Witness. While we acknowledge and continue to report ongoing supply chain risks, we reject all stated or implied allegations of wrongdoing, facilitating deliberate misuse of ITSCI systems or illegal activity.
-END-
[1] International Conference on the Great Lakes Region
[2] https://main.un.org/securitycouncil/en/sanctions/1533/due-diligence-guidelines
[3] See for instance ITSCI incidents NK-2024-0237 or NK-2024-0247.
[4] Tagging in Masisi briefly resumed in April 2024 before being suspended again in May.
[5] Refer for instance to our News section, ITSCI Annual Reports, and other public information.
[6] The RMAP 2017 Standard also underlines this point. See RMAP 2017 Standard. IV. Disclaimers. “This assurance process does not result in a material certification, nor does it determine that material at the auditee is conflict-free.” (page 6).
[7] Read for instance: https://www.itsci.org/2018/07/10/itsci-support-halts-illegal-taxation-and-conflict-from-mine/
[8] Read for instance: https://www.itsci.org/2022/09/29/addressing-oecd-annex-ii-risks-with-partners-in-the-drc/
[9] See for instance ITSCI incidents NK-2024-0073 or SK-2024-0108.
[10] As explained, this figure of 225t corresponds to tantalum concentrate which will be several times higher than, and cannot be compared to, the USGS estimates in tonnes of tantalum.
Additional resources for more information
We appreciate the trust and support of our members and partners. Any parties with concerns or questions about our Programme or its role are encouraged to contact us directly. We are committed to addressing any inquiries and maintaining open, honest communication. We would also like to encourage anyone interested in our activities to visit our website where public information showcases ITSCI’s years’ worth of insight including data on mine production and very positive developments and progress.
- Read our ITSCI Annual reports including updates on continuous improvements.
- Read ITSCI’s latest Alignment Assessment
- Review ITSCI whistleblowing policy and contact information
- Contact us at [email protected].
- For media enquiries, contact [email protected]
Annex 1. Notes about tantalum statistics
Disclaimer – ITSCI focuses on collection and evaluation of our own data. While we make general comparisons to other available figures for supporting information, we are not tantalum market analysts.
Numerous claims have been made by various commentators alleging significant changes in the export of tantalum concentrate from Rwanda due to vast uncontrolled smuggling from DRC. These claims appear to be based on assumptions related to annual trade data available from public databases.
ITSCI is happy to provide information and clarify some factual aspects important to understanding the usefulness and limitations of such data.
Addressing the 50% increase question
Recent media articles have carried quotes stating that “Figures from the US Geological Survey show Rwanda’s tantalum concentrate exports rose by 50% between 2022 and 2023”.
The USGS annual publications make rounded estimates of mine production figures and do not generally include verified mine production nor export figures. As a result, USGS estimated figures for one year can change and be improved. There are two estimates published for mine production of any given year. They are quoted as tonnes of tantalum whereas ITSCI and other trade data, are usually quoted as tonnes of tantalum concentrates.
By referring to Rwanda tantalum mine production figures in USGS online documents (and copied below) it is seen that;
- The initial January 2024 USGS Publication estimate for 2023 Rwanda production of 520t of tantalum was a 50% increase on their figure for 2022 (347t).
- The revised January 2025 USGS Publication reduced the estimate for 2023 Rwanda production from 520t to 350t of tantalum, effectively the same as given for 2022 .
While the USGS made an initial estimate of an expected 50% increase from 2022 to 2023, the revised January 2025 estimate has indicated no material increase (347t in 2022 to 350t in 2023). Claims that USGS figures show a 50% increase between 2022 and 2023 are based on out-dated estimates.
In using USGS publications it is important to understand that figures are estimated based on assumptions about tantalum grade of exports and tantalum content. USGS may use and adjust official Rwandan concentrate export figures to estimate mine production, but this is not stated and could be clarified.
The UN Group of Experts Report of June 2024 also claimed that there was an unprecedented 50% increase in tantalum concentrate export from Rwanda between 2022 and 2023. ITSCI requested further information from the UN and MONUSCO on the basis of that claim but has not yet received any response. We must assume the UN GOE claim is also based on now revised USGS figures.
ITSCI previously confirmed that the 50% figure did not reflect and was significantly higher than the level of tantalum concentrate exports recorded by ITSCI noting that we cannot comment on non-ITSCI minerals exported from, or smelted in Rwanda by non-ITSCI actors.
Sharing ITSCI Data on Rwanda exports
In light of the current questions on Rwandan exports ITSCI is happy to share our own figures.
Note that ITSCI tracks minerals both domestically within production countries, and internationally until shipments are delivered to the smelter. In addition to mineral traceability within mining countries we also hold multiple documents on the international transport route of exports and the contents of each shipment. Many of these documents are produced by independent assay companies or other bodies. This allows us to closely analyse exports and have confidence in our data.
We make the following observations on Rwandan tantalum concentrate exports;
- There has been ongoing documented development and investment in the Rwandan mineral sector over many years, including efforts at tin and tantalum smelting. A number of government donor organisations have contributed to this development.
- While ITSCI export figures for 2024 are provisional, we note a variation of 12% compared to 2023, which equates to an increase of 239 tonnes of tantalum concentrates[1] and a total of approximately 2,297 tonnes. This is the lowest increase in recent years. It is not unusual for mineral exports from any area to increase or decrease by 20-30% in a year, and sometimes much more, due to multiple factors (pricing, licence regulations, or other factors).
- ITSCI operations were suspended in the key tantalum areas of Masisi, North Kivu for almost the entirety of 2024. We have not observed a significant jump in Rwandan exports from 2023 to 2024 but a continuation of the long-term trend.
- Statements from MONUSCO and the UN Group of Experts in their December 2024 claim that 120 tonnes per month of tantalum is smuggled by M23 from Masisi to Rwanda. That would equate to 1,440 tonnes per year. As above, this is drastically higher than the increase observed in ITSCI tantalum concentrate export figures in Rwanda in 2024.
- We emphasise that not all 3T operators – whether mine company, exporters or smelters – in Rwanda participate in ITSCI and we do not report on non-ITSCI tonnages.
Notwithstanding all comments above, ITSCI remains highly concerned over the high risk of infiltration of minerals associated with M23. We strive to implement measures that enable us to identify and address that risk including through continual dialogue with our partners. We welcome suggestions and support to enable further improvements in our measures.
Notes on trade data in general
For completeness we also provide some general information on trade databases.
- There is no individual trade code only for tantalum ores and concentrates; trade in tantalum ores and concentrates are normally only reported aggregated with niobium, vanadium and sometimes zirconium ores and concentrates. This increases difficulty in use of trade data for tantalum.
- Trade data of all commodities is known to be liable to mis-categorisation errors on paperwork used to compile the databases. For example, mis-categorisation may occur for ores vs. metal, or metal vs. waste, or one material vs. a different material. Errors can also be made in country names such as Congo (Brazzaville) or Democratic Republic of Congo.
- Trade data is reported for both exports and imports; exports by country A to any other countries X, Y, Z, and imports into countries X, Y, Z from country A. The two sets of data invariably do not match and benefit from refining by expert analysis.
- A commonly referenced trade database is UN Comtrade. Differences can be observed in government vs. Comtrade figures, as well as mismatches between Comtrade export and import data.
- Note that some country governments, for example in the EU, do not report trade data to protect confidentiality of their business sector.

Source: US Geological Survey, Mineral Commodities Summaries, January 2024: Tantalum. https://pubs.usgs.gov/periodicals/mcs2024/mcs2024-tantalum.pdf

Source: US Geological Survey, Mineral Commodities Summaries, January 2025: Tantalum. https://pubs.usgs.gov/periodicals/mcs2025/mcs2025-tantalum.pdf
Annex 2. third-party reports on the mining sector in Rwanda
Source: Philip Schütte, Uwe Näher, Tantalum supply from artisanal and small-scale mining: A mineral economic evaluation of coltan production and trade dynamics in Africa’s Great Lakes region, Resources Policy, Volume 69, 2020, 101896, ISSN 0301-4207, https://doi.org/10.1016/j.resourpol.2020.101896.
“Most coltan mineralization in the Great Lakes region is hosted by granite-related pegmatite deposits forming part of the Kibara metallogenic province (Pohl et al., 2013; Melcher et al., 2017). These deposits are mainly located in the eastern DRC, Rwanda and, to a lesser extent, in Burundi as well as Uganda, occupying a total north-south extension of about 1300 km.”
“The broadly continuous trend of Rwandan coltan exports, albeit its relative price-sensitivity, indicates that the artisanal trading network promotes flexibility and resilience in the local coltan supply chain. (…) By aggregating coltan deliveries from dozens of small producers and intermediaries into larger shipments, traders and exporters play a key role in balancing export volumes and mitigating risks of supply disruptions while also ensuring liquidity in the local ASM supply chain. Even though temporary or permanent production stops at small sites may frequently affect the coltan output of individual producers, these trade disruptions are buffered through the large ASM supply networks maintained by local exporters. These considerations suggest that, to a certain extent, artisanal supply networks are resilient at a subnational level, thus contributing to tantalum supply chain resilience at the international level.”
