The Democratic Republic of Congo's regulatory authority for strategic mineral markets, ARECOMS (Autorité de Régulation et de Contrôle des Marchés des Substances Minérales Stratégiques), derives its mandate over cobalt, coltan, and germanium from Decree 18/042, which establishes both mining royalty rates and the legal classification of strategic minerals [1] [2]. This statutory foundation has underpinned a sequence of increasingly structured interventions in the cobalt export market throughout 2025, culminating in a formal quota regime that now governs the flow of DRC cobalt to international buyers.
The regulatory sequence began with Decision No. 001/ARECOMS/2025 of 22 February 2025, which imposed an initial four-month suspension on cobalt exports from the DRC [3]. That instrument has since been superseded. On 21 September 2025, ARECOMS extended the suspension, though that extension order has itself been superseded by the subsequent quota framework [4]. The IEA Policy Tracker independently documented the export suspension as a discrete policy event [5], providing secondary official corroboration of the chronology.
Effective 16 October 2025, ARECOMS replaced the suspension regime with a quota system allocating 18,125 tonnes for Q4-2025 and 96,600 tonnes per year across 2026 and 2027 [6] [7]. Company-level allocations have been published by ARECOMS for named exporters: CMOC has been assigned 6,500 tonnes, Glencore 3,925 tonnes, and ERG 2,125 tonnes [8] [7]. These figures represent discrete ceiling entitlements rather than guaranteed offtake volumes, and the aggregate Q4-2025 quota reflects a partial-quarter activation of the new framework.
Compliance obligations under the quota regime are operationally demanding. Exporters are required to pay a 10% royalty within 48 hours of a shipment and must obtain a compliance certificate prior to export [7]. Industry reporting has noted that export conditions in the DRC have tightened materially under this framework [9], with the certificate and royalty-payment requirements introducing procedural steps that were absent under the pre-suspension licensing environment. Exporters operating outside named quota allocations face structural exclusion from the market for the duration of the 2025–2027 regime window.
From a supply-chain exposure standpoint, the quota architecture concentrates permissible export volumes among a limited set of named counterparties and caps annual throughput at 96,600 tonnes from 2026, a figure that market participants and commercial intelligence sources have assessed against prevailing DRC production capacity [10]. The transition from an open suspension to a bounded quota system introduces a defined but constrained supply envelope for cobalt sourced from the DRC, which accounts for a dominant share of global mined cobalt output. Institutions with supply-chain, offtake, or financing exposure to DRC cobalt operations should note that the primary regulatory instruments remain sourced from the ARECOMS Journal Officiel archive, which is paywalled and as yet unverified at the primary-document level [6] [7].