Where this intersects with child labor is less settled. One camp, reflected in reporting from groups like New America, argues that forcing in-country processing gives Kinshasa more revenue and more leverage to eventually fund labor oversight and enforcement, something international programs like the ILO’s GALAB project have struggled to do at scale given how informal artisanal mining remains. A competing view holds that concentrate bans target the industrial, corporate-run side of the supply chain. Meanwhile, the CEEC’s estimate of at least 25,000 children working in Congolese cobalt mines is concentrated in artisanal and small-scale mining, an informal sector the export ban does not directly regulate.

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