The Dark Side of the Clean Energy Mineral

Cobalt powers the modern world. From smartphones and laptops to the batteries in electric vehicles, this mineral sits at the core of the green energy transition. Yet behind the clean image of renewable technology lies a much darker reality. A new report by Siddharth Kara, Blood Batteries: The Human Rights and Environmental Impacts of Cobalt Mining in the Democratic Republic of the Congo (2025), reveals that the majority of the world's cobalt is extracted under conditions that raise serious red flags for compliance, procurement, and sustainability teams. The study surveyed over 1,400 artisanal and small-scale miners (ASM) in the cobalt-rich provinces of the DRC. Nearly 37% met the definition of forced labor, and almost 1 in 10 were children. With no written contracts, no unions, and daily incomes averaging just $3.28, most miners work because survival leaves them no alternative. These are not edge cases — they are systemic conditions baked into the supply chains of the world's most recognizable consumer brands. The environmental toll is equally alarming. Satellite and geospatial analysis show vast loss of farmland and water sources around Kolwezi due to mining expansion. Water samples from nearby rivers and wells contained toxic metals at levels up to 930 times higher than WHO guidelines. Communities relying on these sources suffer chronic illness, while environmental destruction removes alternative livelihoods, reinforcing the cycle of poverty and child labor.

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Why Traditional Due Diligence Falls Short

The blending of artisanal and industrial cobalt at the source makes standard certification schemes fundamentally insufficient.

One of the report's most critical findings is that artisanal and large-scale mining (LSM) supply chains are far more intertwined than the industry has acknowledged. In practice, ASM cobalt is routinely mixed with industrial output at depots, processing facilities, and even inside industrial concessions themselves. Once blended, it becomes impossible to distinguish so-called clean cobalt from cobalt mined under exploitative conditions. This reality dismantles the assumption that companies can simply audit their Tier 1 or Tier 2 suppliers and declare their supply chains compliant. Traditional audit programs and certification schemes are not designed to address this fungibility problem. The blending happens early and deep in the supply chain — long before cobalt reaches a refinery or battery manufacturer. Companies that rely solely on supplier questionnaires or third-party certifications are operating with a false sense of security. Real visibility requires tracing risk back to the raw material level, across multiple tiers of the supply chain, in real time.

The Regulatory and Reputational Stakes Are Rising


Expanding due diligence laws and growing investor scrutiny mean ESG failures in cobalt sourcing carry direct legal and financial consequences.

The legal landscape is shifting rapidly. Regulations like the EU's Corporate Sustainability Due Diligence Directive (CSDDD) and the U.S. Uyghur Forced Labor Prevention Act now require procurement leaders to demonstrate real, documented visibility into mineral sourcing — not just policy statements or high-level supplier commitments. Non-compliance can result in shipment seizures, market bans, and significant reputational damage. ESG failures in the cobalt supply chain are not abstract risks. They represent direct reputational, operational, and regulatory exposure. Customers and investors increasingly demand verifiable proof of responsible sourcing. Companies that cannot substantiate their claims face growing pressure from boards, shareholders, and regulators alike. The question for supply chain leaders is no longer whether cobalt poses a risk — it is whether they have the tools and processes to identify and address that risk before it becomes a crisis.

What Supply Chain Leaders Should Do Now

Practical, immediate steps procurement and compliance teams can take to get ahead of cobalt-related human rights risk.

The path forward starts with mapping your supply base beyond Tier 1. Most cobalt risk is buried deep in the supply chain, invisible to teams that only monitor direct suppliers. Leading platforms like FRDM trace supplier relationships down to raw materials, uncovering hidden connections to high-risk regions and commodities like cobalt. Continuous monitoring — rather than point-in-time audits — is essential to stay ahead of emerging risks. Practically, supply chain leaders should identify the top suppliers by spend that provide goods or services requiring cobalt use, review their responsible sourcing policies, and assess how many are actively tracing risk in their own supply chains. Teams should also read the full Kara report to understand the depth of the issue. Longer term, organizations must invest in deeper traceability infrastructure and engage suppliers in meaningful remediation — not just documentation. The cobalt that fuels the clean energy future comes at a devastating human and environmental cost, and for procurement and compliance professionals, ignoring these risks is no longer an option.

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