Executive summary

Global demand for transition minerals is surging as the shift to clean energy accelerates, intensifying competition between major economies. China currently dominates global supply chains, controlling the processing and refining of minerals extracted abroad and holding a strong position in downstream technology manufacturing. This report identifies a critical opportunity for Chinese companies to ensure this energy shift is fair and does not harm local communities, workers, or the environment. However, allegations of abuse are rising, with 326 recorded instances linked to Chinese overseas investments in transition minerals between 2023 and 2025. Indonesia recorded the highest number of allegations, totalling 96 reports, particularly in the processing and refining stages. While company responsiveness has increased to a 27% response rate, persistent governance gaps remain, and attacks on human rights defenders are increasingly common.

Context

China is the leading global force in manufacturing renewable energy technologies, with significant strengths in solar, wind, batteries, and electric vehicles (EVs). To secure supply chain security, Chinese firms have invested over USD 120 billion in overseas mining and upstream processing between 2023 and 2025. The Chinese government has introduced new oversight measures, including the Regulation on Overseas Investment (2026), which emphasizes compliance obligations and corporate responsibility for environmental and labour rights. Additionally, the National Human Rights Action Plan (2026–2030) highlights commitments to strengthening corporate social responsibility and adhering to the UN Guiding Principles on Business and Human Rights (UNGPs). Despite these frameworks, civil society groups highlight ongoing challenges regarding meaningful stakeholder engagement and access to effective remedies.

Methodology

This research analyses 323 allegations of human rights and environmental abuses related to Chinese overseas investments across 93 projects and 11 key minerals. The analysis covers the phases of project development, extraction, and processing, smelting, and refining. In addition to the nine minerals tracked by the global Transition Minerals Tracker, this report includes chromium and graphite. The research draws from media reports, non-governmental organisations (NGOs), and other civil society groups, although it acknowledges limitations due to restricted civic space in certain countries and language barriers.

Key findings

Of the 323 allegations recorded, 179 (55%) related to adverse impacts on communities, 143 (44%) involved workers, and 169 (52%) were linked to environmental damage. The ten Chinese companies connected to the highest number of allegations accounted for nearly two-thirds of all recorded cases. The findings highlight a steady increase in allegations of abuse from 2021 to 2025, suggesting that human rights and environmental risks in Chinese-associated supply chains are significant. Notable concerns include the lack of transparency among mining and metals companies, with some of the most-accused firms failing to implement their public human rights policies effectively.

Human rights and environmental impacts

Water pollution is the most significant alleged environmental impact, with 102 recorded cases. This issue is often linked to broader consequences for public health, food security, and livelihoods. In Zambia, a tailings dam leak at a mine owned by Sino-Metals Leach released an estimated 50 million litres of toxic waste into the Kafue River ecosystem in 2025. In Indonesia, failures at tailings facilities in the Morowali Industry Park (IMIP) killed three workers and polluted local rivers. Other major impacts include occupational health and safety (100 cases), impacts on livelihoods (85), soil pollution (69), and personal health (69). Work-related deaths were also recorded in 47 instances.

Migrant and immigrant workers

Migrant workers, particularly those from China working in Indonesia, are disproportionately exposed to exploitative conditions. Between 2023 and 2025, 37 allegations of abuse affecting migrant workers were documented, accounting for over 25% of all worker-related allegations. Common issues include work-related deaths (14 cases), wage-related complaints (16 cases), and injuries (12 cases). Reports also detail restricted movement and passport confiscation as methods of control. The lack of participation in labour unions reduces the bargaining power of these workers, making them more vulnerable to violence and intimidation.

Geographies of abuse

The 323 allegations spanned 24 countries, with the majority concentrated in Asia and the Pacific (142 allegations, 44%) and Africa (119 allegations, 37%). Indonesia recorded the highest total (96), followed by the Democratic Republic of Congo (52), Myanmar (36), Serbia (32), and Zimbabwe (20). Since 2021, there has been a significant increase in recorded abuses, rising from 51 in 2021 to 148 in 2025. In Eastern Europe and Central Asia, allegations increased considerably, largely due to copper mining activities in Serbia by Zijin Mining.

Phases of the supply chain

The extraction phase accounted for the majority of allegations, with 213 cases (66% of the total), representing a significant increase from 48% in the previous 2021-2022 period. The processing, smelting, and refining phase maintained a stable share of approximately 25% (80 allegations). Conversely, the project development stage saw a sharp decline in allegations from 24.5% to 9%, likely due to more projects progressing into active operations or facing delays and permit revocations following community resistance and legal challenges.

Allegations by mineral

Nickel (91 allegations) and copper (72) remain the minerals most associated with abuse. The expansion of the nickel industry in Indonesia has driven a steady rise in nickel-related allegations, which have now overtaken copper. Significant increases were also observed in lithium (39) and rare earth elements (REEs) (35). Lithium-related abuses were primarily linked to impacts on Indigenous Peoples and water resources in Africa and Latin America, while REE-related allegations were prominently linked to mining activities in Myanmar.

Human rights defenders and civic space

Between 2023 and 2025, 18 attacks against human rights defenders were documented, bringing the five-year total to 27. Over half of these attacks targeted environmental activists. Judicial harassment is a recurring issue, with five attacks involving legal proceedings against defenders in Serbia and Indonesia. Six attacks targeted women human rights defenders, including Indigenous environmental defender Dewi Anakoda in Indonesia, who has reportedly faced violent attacks and intimidation since 2024. Among the top ten companies linked to the most allegations, only Zijin Mining has explicit policy commitments against tolerating attacks on defenders.

Company response rates and human rights policies

The overall company response rate improved to 27%, up from 18% in 2021-2022. However, this is still below the global sector average of 36%. Responses were concentrated among a small group of companies with established ESG departments, such as Zijin Mining (89% response rate) and Zhejiang Huayou Cobalt (70%). Several major firms, including Tsingshan Group and China Nonferrous Metal Mining (CNMC), recorded a 0% response rate. Alarmingly, half of the top ten companies associated with abuses do not have a publicly available human rights policy.

Qualitative analysis of company responses

Of the 40 responses received, 90% were specific rather than general statements, indicating an improvement in the level of detail provided by Chinese firms. Furthermore, 68% of responses referenced international standards, a sharp increase from 21% in 2021. Despite this awareness, companies remain more likely to prioritize compliance with local laws (83%) over international human rights frameworks.

Corporate accountability and access to remedy

Opacity remains a major barrier to corporate accountability in transition mineral supply chains. Many affected groups struggle to find effective legal or non-legal channels for redress. In 2023, Chinese migrant workers filed a complaint with the Indonesian National Human Rights Commission (Komnas HAM) regarding unsafe conditions at nickel smelters. While such actions attract public attention, they have yet to address systemic labour risks. Indigenous communities in Indonesia and Zambia continue to face challenges in legal proceedings due to power imbalances and retaliation from companies and local police.

Recommendations

The report recommends that governments pass and enforce mandatory human rights and environmental due diligence (HREDD) legislation aligned with the UNGPs. The Chinese government should ensure access to effective remedy for migrant workers and utilize inter-departmental mechanisms to oversee businesses operating abroad. Host countries are urged to strengthen laws protecting Indigenous Peoples and ensure licensing is conditional on meaningful community engagement. Companies should establish publicly available HREDD policies, implement the principle of free, prior and informed consent (FPIC), and create project-level grievance mechanisms. Investors should adopt board-level policies that treat human rights harms as systemic risks and use their leverage to encourage responsible business conduct.