Sector Programme
Extractives and Development

New Publication: Study on the Needs and Gaps in the Implementation of EU Due Diligence Regulation in Mineral-producing Countries

The GIZ Sector Programme “Extractives and Development” and Global Programme “Investing in Resilient and Sustainable Global Supply Chains (IGS)” (External link) (formerly: “Initiative for Global Solidarity”) have published a study on behalf of the Federal Ministry for Economic Cooperation and Development (BMZ) which examines the needs and gaps in the implementation of EU due diligence regulation in mineral producing countries.

The study has been conducted by Levin Sources Ltd. and is based on four qualitative case studies of mineral-producing countries: Indonesia, Brazil, Mexico and Zambia.

Read the Publication (External link)

Within the EU, several legislations aimed at strengthening corporate Human Rights and Environmental Due Diligence (HREDD) performance have entered into force in recent years. These include in particular

This study analyses the awareness of stakeholder groups in mineral-producing countries of these legal acts, the current perceptions of stakeholder groups thereof, the preparations so far taken by stakeholders with regard to their implementation and the measures that could help to mitigate negative impacts.

Figure 1: (Anticipated) Positive Impacts (Fig. 8 of the study)

Figure 1: (Anticipated) Positive Impacts (Fig. 8 of the study)

The study reveals that the stakeholder groups surveyed are moderately aware of EU due diligence regulation, with the EU Corporate Sustainability Due Diligence Directive being by far the best-known regulation. Moreover, it shows that stakeholders broadly support EU due diligence regulation as it opens opportunities for dialogue between civil society and industry actors and improves the country’s credibility and market position. However, stakeholders also voiced concerns about, among other things, disproportionate impacts on small and medium-sized enterprises and artisanal and small-scale mining actors, as well as competitive disadvantages for companies supplying to EU markets. Among the stakeholders engaged in the study, almost half have started preparing for the implementation of EU due diligence regulation.

Figure 2: (Anticipated) Negative impacts (Fig. 8 of the study)

Figure 2: (Anticipated) Negative impacts (Fig. 8 of the study)

Building on the insights from the case studies, the study proposes targeted measures to be taken by development cooperation agencies like GIZ to reduce adverse impacts and to assist stakeholder groups in mineral-producing countries in preparing for the implementation of EU due diligence regulation.
These proposed measures include

  • expanding inclusive awareness-raising beyond EU-linked firms to local SMEs and senior management level,
  • strengthening understanding and the practical application of due diligence
  • establishing local HREDD focal points to support sector-specific due diligence
  • and addressing confusion by promoting alignment between mandatory regulations and voluntary standards.

Quote of Interviewee:

Presentation of the analysis at Mining Indaba 2026

Presentation of the analysis at Mining Indaba 2026


“With around 57 different [ESG] regulations originating from different Ministerial agencies, our national regulation is very fragmented. Indonesia needs to streamline those somehow… and choose a good due diligence framework to benchmark against. European due diligence regulation could be just that” (26 June 2025).

The study’s key findings have been presented at the GIZ Side Event Day (External link) during the Investing in African Mining Indaba 2026 (External link) and were subject to a lively debate in a subsequent panel discussion on common challenges, market effects and implementation needs across mineral supply chains.


We would like to thank the Global Battery Alliance, the International Forum on Mining, Minerals, Metals and Sustainable Development, and the United Nations Environment Programme for their support in producing this report.

Presentation of the analysis at the side event organised by the GIZ Sector Programme Extractives and Development during Mining Indaba 2026

Presentation of the analysis at the side event organised by the GIZ Sector Programme Extractives and Development during Mining Indaba 2026

If you have any further questions, please contact the Sector Programme Extractives and Development (External link).