OPENING THE
BLACK BOX: LOCALINSIGHTS INTO
THE FORMAL AND
INFORMAL GLOBALMERCURY TRADEREVEALED

OPENING THE
BLACK BOX: LOCALINSIGHTS INTO
THE FORMAL AND
INFORMAL GLOBALMERCURY TRADEREVEALEDIUCN NL

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Opening the black box: global mercury trade revealed

DISCLAIMERACKNOWLEDGEMENTS

This report was compiled by IUCN NL (Stichting

IUCN NL would like to thank the partner

IUCN Nederlands Comité) as part of theorganizations that investigated the mercury trade

programme Shared Resources Joint Solutionsin the focus countries: Centro de Documentación(SRJS), a strategic partnership between IUCN NL,e Información Bolivia (CEDIB) for Bolivia; Social

WWF NL and the Netherlands Ministry of Foreign

Solutions for Suriname, Ian Gaulbert Sutherland for

Affairs. The report is a compilation of findings

Guyana, Rickford Vieira for Guyana & Suriname; Thefrom IUCN NL partner organizations in Bolivia,

Centre for Environment Justice and Development

Burkina Faso, Guyana, Suriname, Kenya, Tanzania,(CEJAD) and The Africa Centre for Energy andUganda and the Philippines. The findings,

Mineral Policy (ACEMP) for East Africa; L’Associationinterpretations and conclusions expressed hereintervillageoise de Gestion des Ressources naturelles

are those of the authors and do not necessarily

et de la Faune de la Comoé–Léraba (AGEREF/CL)

reflect the views of the Netherlands Ministry

and Alliance for Responsible Mining (ARM)(regionalof Foreign Affairs, WWF NL, IUCN NL or any

office) for Burkina Faso and BanToxics for theindividual partner organization.

Philippines.

This publication may be reproduced in whole or in

We further want to thank the regional consultants,

part and in any form for educational or nonprofit

Marcena Hunter (Global Initiative against

purposes without special permission from theTransnational Organized Crime), Bram Ebus, Jesper

copyright holders, provided acknowledgement ofJonsson and Yves Bertran (ARM) for their support andthe source is made.

advice.

AUTHORSThis report was compiled by Barbara Hendus andreviewed by Mariel Cabero, Frederique Holle andMark van der Wal. The regional chapters werereviewed by the respective partner organizations.
Graphic design: Margo Vlamings
Cover image: Mercury in the bare hand
© Bram Ebus/InfoAmazonia

IUCN NL

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Opening the black box: global mercury trade revealedA miner washing out soil to extract gold © Bram Ebus/InfoAmazonia

IUCN NL

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Opening the black box: global mercury trade revealed

EXECUTIVE SUMMARYBACKGROUND

infiltrate or understand. For many mining operations,the mine manager or operation owner is the person

Mercury is continually used in the artisanal andwho buys mercury. The mercury can be bought at

small-scale gold mining (ASGM) sector even thoughhardware and mining stores in the cities and larger

it is highly poisonous to both humans and themining towns or directly at the mining sites whereenvironment. There are an increasing number of

local traders offer mercury. These traders are often,

projects, initiatives and conventions, including the

but not always, gold traders who also trade with

Minamata Convention, working on the reduction

mercury. In some cases, mercury gets supplied inof mercury use in ASGM. However, a long-lasting

advance and the price gets settled when miners sellchange away from mercury is hard to achieve andthe recovered gold to the same trader.

there seem to be mechanisms in place that prevent

MAIN DRIVERS OF MERCURY TRADE

a mercury-free ASGM sector. As mercury tradeand use is mostly regulated and restricted, a lotof mercury used for ASGM is traded informally. To

Miners, their families and surrounding communities

better understand the factors at play, the mercury

are often the most negatively affected by mercury.

supply chain of both formal and informal mercury

However, while they are the end users, they are not

was investigated in eight countries with large

the driving force behind the trade. Many miners are

ASGM sectors (Bolivia, Suriname, Guyana, Kenya,caught in multiple circuits that cause the continued

Tanzania, Uganda, Burkina Faso and the Philippines).

use of mercury. Firstly, miners are trapped in a

Investigations on formal and informal imports,

poverty cycle in which mercury is the only affordable

domestic trade routes, the supply chain and actors

method to produce gold. Within the second cycle,

involved established a similar picture across thegold/mercury traders take advantage of the sector’sdifferent regions.

informality and generate trade mechanisms thatguarantee the continued use of mercury. Through the

IMPORTS, TRADE ROUTES AND SUPPLY CHAIN

trade with both minerals, power imbalance between
miners and gold traders can occur. In these cases,

Depending on the country, mercury enters via

traders create dependencies in which the miners

multiple formal and informal pathways. In the casehave to keep using mercury and cannot easily breakof entrance through formal ports, mercury is either

ties with the dealer (e.g. by providing mercury up

misdeclared and passes customs unnoticed or

front to be offset with the gold buying price andofficials are bribed to look the other way. For informal

under the condition that the produced gold can only

entrance, similar pathways are used as for otherbe sold to the same trader). The gold/mercury traderssmuggled goods. Large trading hubs are generally

increase their profits through the trade with boththe capitals and larger cities. The mercury tradingminerals.

network is multilayered with importers, wholesalers

The investment necessary for changing to mercury-and retailers involved. The networks are wellfree extraction methods, are mostly unaffordable forestablished and generally operate in secret, as mostthe individual ASGM miners. Generally, the tradersof the trade is informal. High up in the supply chain,or investors of mining operations could afford

trade is based on trust and networks are difficult toinvestments, however, they have no incentive to do

IUCN NL

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Opening the black box: global mercury trade revealed

so as the trade with both mercury and gold is veryneighboring country with looser regulations.

lucrative. Instead, they create trade mechanisms that• To address the mercury problem at the level of theencourage miners to keep using mercury. Mercury

miners, the ASGM sectors should be formalized

trade is a lucrative business on all levels in the supply

to provide miners with access to governmental

chain. It is often linked to the gold trade and in many

support.

cases the same actors are involved in both trades.

• Inclusive, long-term institutionalized support

Nonetheless, there are also actors involved thatthat facilitates the transition to mercury-free gold

have no such links to gold trade and only trade withextraction techniques should continue. These

mercury.

should include research on the most affective
extraction method for the mining site and include

MAIN RECOMMENDATIONS

miners in the search for affordable and doable

A combination of factors is driving the continued• Financing schemes that enable miners to accessuse of mercury, including the lucrativeness of thenecessary equipment for these mercury-freetrade, the informality of the ASGM sector, the poverty

techniques need to be put in place.

of many miners and the power imbalance between• Markets for mercury-free gold need to be enlarged

many traders and miners. Mercury governance within

and a certification scheme for mercury-free gold

the focus countries has potential for improvement. To

needs to be supported.

methods.

tackle the mercury problem, action should be takenthat addresses the problem from all angles.

Implementing these recommendations would ensure• Reliable data concerning formal mercury trade andthat the power imbalance between miners andthe ASGM sectors of the countries is necessary togold/mercury traders would be reduced and miners

better understand mercury trade for ASGM.

would have an incentive to change to mercury-free• As informal trade is hard to tackle, we recommend

techniques.

improving legal trade regulations and monitoring
for both mercury and gold within the different
countries.
• Laws and regulations concerning mercury imports,
domestic trade and use should be clarified.

Miners, their families
and surrounding
communities areoften the mostnegatively affectedby mercury• Yearly quotas for formal imports should be put inplace.
• Licensing and monitoring schemes for domestic
trade should be created and enforced.
• Custom agencies should receive training on
recognizing, handling and storage of mercury.
• Environmentally sound interim storage facilities
need to be created with monitoring schemes inplace to guarantee safe keeping of confiscatedmercury.
• There is the need for increased regional andinternational cooperation on informal trade. In manycases, the stricter implementation of regulations
in one country led to a shift of imports into a

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Opening the black box: global mercury trade revealed

LIST OF ACRONYMS AND ABBREVIATIONSASGMArtisanal and Small-Scale Gold Mining

ENSOEnquête nationale sur le secteur de l’orpaillage (Burkina Faso)

DRC

Democratic Republic of Congo

IGF

Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development

IUCN NLIUCN National Committee of the Netherlands

NAP

National Action Plan

PH-EITI

The Philippine Extractive Industries Transparency Initiative

SRJS

Shared Resources, Joint Solutions

UNEP

United Nations Environment Programme

UNIDO

United Nations Industrial Development Organization

LIST OF FIGURES
Figure 1: Global trends and causality in mercury supply, trade and demand• 15

Figure 2: Map of the main formal and informal mercury imports and domestic trade routes in Bolivia
Figure 3: Mercury supply chain in Bolivia

•

• 17

18

Figure 4: Map of main trading routes in Guyana• 20

Figure 5: Mercury supply chain with main actors and flows in Guyana
Figure 6: Map of main mercury trade routes in Suriname

•

• 21

23

Figure 7: Mercury supply chain with main actors and flows in Suriname

• 23

• 26
• 28
Figure 10: Regional mercury trade within West Africa with main focus on Burkina Faso as a trading hub • 31
Figure 11: Mercury supply chain in Burkina Faso • 32
Figure 12: Primary entry points, trade hubs and trade routes in Mindanao, Philippines • 33
Figure 13: Mercury supply chain in Mindanao, Philippines • 34
Figure 8: Domestic mercury trade within the East African countries of Kenya, Tanzania and Uganda

Figure 9: The supply chain of mercury in the East African countries of Kenya, Tanzania and Uganda

LIST OF TABLES
Table 1: Overview over the status of the Minamata Convention in the different focus countries• 13

Table 2: Reported price ranges of mercury bound for ASGM at various distribution levels in the different
focus countries

IUCN NL• 38

8Opening the black box: global mercury trade revealedTABLE OF CONTENTS
Executive summary • 6
List of acronyms and abbreviations • 8
List of figures • 8
List of tables • 8
Table of Contents • 9
1 Introduction • 10
1.1 Project background and objective • 10
1.2 Methodology • 11
2

Minamata Convention • 13

3 Mercury trade • 14
3.1 Small-scale mining and mercury • 14
3.2 Global mercury trade • 14
3.3 Mercury trade in the selected countries • 16
4 Common findings across regions • 35
4.1 Use of mercury in ASGM • 35
4.2 Knowledge of the negative health effects of mercury among small-scale gold miners • 35
4.3 Mercury imports • 36
4.4 Domestic trading routes • 36
4.5 Acquisition of mercury by gold miners • 36
4.6 Mercury supply chain & actors involved • 37
4.7 Mercury prices through the value chain • 37
4.8 Mercury exports • 38
5 Analysis of findings • 39
5.1 Factors hindering the understanding of the informal mercury trade • 39
5.2 Factors contributing to mercury use • 39
5.3 Driving forces • 41
5.4 Mercury governance issues • 42
6 Conclusions & recommendations • 43
6.1 Conclusion • 43
6.2 Recommendations • 43
References • 45
Annexes • 47
Annex 1: Additional information per country • 47

IUCN NL

9Opening the black box: global mercury trade revealed1 INTRODUCTION
1.1 PROJECT BACKGROUND AND OBJECTIVE

gold economies. Where does the mercury used in
ASGM originate? How is it transported, through which

Mercury is obtained from mercury ore, or cinnabar.

channels, formal or informal and by whom? And who

To date, only a few primary mines of mercury ore

benefits from this trade?

remain in use and these are located in Mexico,

An insight into the supply routes and value chain of

China and Indonesia. Mercury was and still is usedmercury markets with special focus on the informal

in a variety of objects and processes, e.g. dental

trade is needed to support the reduction of mercury

amalgam, laboratory processes and gold mining.

use in ASGM.

Within the last decades, the negative impacts ofmercury on both human and environmental healthTo gain insight into the formal and informal mercury

have been widely documented and mercury is

trade, IUCN NL initiated a study on the politicalconsidered one of the top ten chemicals of major

ecology of the gold-mercury link to identify informal

public health concern (World Health Organization,

mercury flows, trade hubs and key players in multiple

2017). Mercury is released into the environment

countries located across three continents, namelyfrom anthropogenic and natural sources and once

Guyana & Suriname, Bolivia, Philippines, Tanzania,

entering the atmosphere, it circulates world-wide

Uganda, Kenya and Burkina Faso. The objectives ofmaking mercury pollution a global problem. Mercury

this study were:concentrations in the atmosphere are already 450%1) To improve the understanding of mercury flows,

higher than natural levels (AMAP/UN Environment,

trade hubs and key players.

2019), and large amounts of additional mercury are2) To enhance the governance of mercury in theemitted through anthropogenic activities each year.

ASGM sectors of the target countries.

With more than 37%, the main contributor to these3) To enhance recognition of the scale and impact ofanthropogenic mercury emissions is the artisanal andthe informal mercury trade.

small-scale gold mining (ASGM) sector.

4) To showcase that this is a global problem.

Many projects, initiatives and global treaties, suchas the Minamata Convention, have been working on
reducing mercury use in ASGM. Approaches include

The aim of the study is to support the National Action

introducing small-scale gold miners to mercury-freePlans (NAP) developed by the abovementioned

mining techniques and enhancing mercury-free gold

focus countries that are currently developed for the

supply chains. However, most projects are struggling

Minamata Convention. The gained insights into theto achieve a lasting change, and miners quickly

informal mercury trade may enhance the governance

return to using mercury post-project. A key questionin the phasing out of mercury in the ASGM sector.

that remains is thus which forces are constraining

Furthermore, we aim to raise awareness in the global

mercury-free artisanal gold production?

community about the role and influence of the

While official data on exports and imports of mercury

informal mercury trade on ASGM.

is available for most countries, this data does notseem to match with mining realities on the ground.

This report compiles results from country/regional

Little information is available on informal pathways ofreports done by local partner CSOs in the target

the mercury trade and how these drive the artisanalcountries and highlights common findings.

IUCN NL

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Opening the black box: global mercury trade revealed

Mining landscape in Guyana (Cuyuni) © Bram Ebus/InfoAmazonia

Information refers to the respective country/regional

by local partner organizations supported byreports if not stated otherwise. The full country/

globally recognized expert consultants under theregional reports can be found at (www.iucn.nl/

coordination of IUCN NL.

mercury). Within this report, the terms formal andEach focus country has a significant ASGM sector

informal mercury trade are commonly used, however,

and we identified the specific target countries based

the informal trade also includes illicit mercury trade.

on countries included in the SRJS programme and

The Mercury governance project was initiated byin consultation with UN Environmental Programme

IUCN National Committee of the Netherlands (IUCN(UNEP) taking into account already available

NL) under the Shared Resources, Joint Solutions

information to assure our added value.

(SRJS) program funded by the Dutch Ministry ofInformation on both formal and informal mercury

Foreign Affairs.

trade in each focus country was collected througha combination of desk research and field work as

1.2 METHODOLOGY

well as qualitative stakeholder interviews. Due tothe informality of the sector and secrecy around it,

Work in the selected focus countries, namely

different levels of details could be obtained for the

Guyana, Suriname, Bolivia, Tanzania, Uganda, Kenya,various aspects of mercury trade in the different

Burkina Faso and the Philippines was conducted

countries.

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Opening the black box: global mercury trade revealedFrom its original source to thegold mining sites at the otherend of the world, trade routes
of informal mercury remain
largely elusive to this day.

1.2.1 Desk Research

1.2.3 Stakeholder interviews

Desk research was conducted focusing on current

To gain further insight, qualitative stakeholder

mercury and gold trading practices both inside andinterviews with open-ended questions wereoutside of the countries. Documents included in

conducted. Interviewed stakeholders included

the research were academic studies, government

miners, mining financers, gold traders, mercury

and research reports, national policies and website

traders, custom officials and other government

articles. Information gathered through desk research,

officials. Interviews varied in content and lengthe.g. on trading routes, was later discussed anddepending on the type of stakeholder. Generally,

validated with interview participants. Furthermore,questions focused on mercury use, information

national policies concerning the ASGM sector andregarding mercury flow into the country and trademercury were reviewed.

routes within the country, quantities and prices of
mercury and key players in the mercury trade.

1.2.2 Field work

Due to the informality of mercury import and tradein many cases, quantitative data on the informal

As many mercury imports and the mercury trade itself

mercury trade is difficult to obtain. However, theare informal in most of the selected countries, little

results presented here provide an initial insight into

detail on trade routes and mechanisms is available.

the informal mercury supply chain and key players

To get a better picture of the informal mercury

involved. As the topic is sensitive due to its illegality

market, partner organizations made visits to minein some countries, this report will not name specificsites, gold buyers and shops selling mining materials.

people or companies involved, but rather identify
routes and trading hubs, supply chains and groups
involved as well as explain power relationships.

IUCN NL

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Opening the black box: global mercury trade revealed2 MINAMATA CONVENTION
The Minamata Convention on Mercury, a global

to notify the Minamata secretary and develop andtreaty to protect human health and the environment

implement a Nation Action Plan to achieve theirfrom the adverse effects of mercury, entered into

goals (Minamata Convention, Annex C). Within theforce in August 2017. As of March 2020, 118

NAPs, countries are required to include “strategies

countries are Parties to the Convention. Among otherfor managing trade and preventing the diversion ofthings, the convention regulates the international

mercury and mercury compounds from domestic andtrade of mercury and prohibits the use of mercury

foreign sources to use in artisanal and small scalefrom primary mining in the ASGM sector (Article 3).

gold mining and processing”.

Ratifying parties of the convention are obliged toreduce, and where possible eliminate, the use of

An overview of the status of the Minamata

mercury in ASGM (Article 7). Parties that have an

Convention in the different focus countries can be

ASGM sector that is more than insignificant, havefound in table 1

SIGNEDRATIFIED

COUNTRYMINAMATAMINAMATA

NAP

Bolivia10.10.2013

26.01.2016

In progress

Guyana10.10.2013

24.09.2014

EXPECTED DATEAIM

In progress

No later than 08/2021

75% Hg reduction by

02.08.2018

In progress

2021

2027
SurinameKenya

10.10.2013x

In progress

Tanzania

10.10.2013x

In progress

Uganda10.10.2013

01.03.2019

In progress

70% Hg reduction
by 2024; providing
alternatives\ substitutefor mercury use by 2030

Burkina Faso
Philippines

10.10.2013

10.04.2017

10.10.2013x

In progress

Table 1: Overview of the status of the Minamata Convention in the different focus countries

IUCN NL

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Opening the black box: global mercury trade revealed3 MERCURY TRADE
3.1 SMALL-SCALE MINING AND MERCURY

large amount of ore (whole ore amalgamation).
During amalgamation, mercury is added to capture

In recent years the ASGM sector has been booming

the gold particels. When added to the whole ore, aas gold prices have continued to rise. The incentive

large quanitity of mercury is needed (3-50:1 Hg:Au)of making fast money is drawing more people into

and a lot of it is realeased into the environment.

the ASGM sector. Up to 20% of the global gold supply

In concentrate amalgamation mercury is added

originates from ASGM (World Bank, 2013) produced

to the concentrated ore and much lower mercury

by 10-20 million miners in over 70 countries

amounts are needed. The mercury gets separated

worldwide (planetGOLD, 2019). An estimated 30%

from the gold by burning the amalgam. Mercuryof all miners globally were women in 2003, but theirevaporates, leaving the gold behind. Exposure to

involvement may be much higher today (Hinton et

the vapors is harmful and mercury gets releasedal., 2003). Approximately 70-80% of miners operate

into the atmosphere. The release of mercury at thisinformally (IGF, 2017), opening doors for corruption

stage can be reduced and health-risks mitigatedand criminality, as well as keeping miners away fromby burning mercury with a capturing system forlegal protection and support services. Therefore,

example retorts. Globally, an average of three grams

ASGM is often linked to extreme poverty as minersof mercury is used to produce one gram of gold

live from hand-to-mouth (World Bank, 2012). This

(Telmer, 2011), resulting in an estimated releaseapplies especially to women, as cultural barriers andof 1220 tonnes of mercury into the environment ingender-based discrimination often force them to take2015 (UN Environment, 2019). Currently, the ASGM

on lower paid and low-skilled jobs such as ancillary

sector is the major contributor of anthropogenicroles, e.g. as cooks or service providers (ibid). Thismercury emissions to the air contributing 37.7%

poverty cycle is nearly impossible to break without

globally and up to 70-75% in the regional emissions

external support.

of South America and Sub-Saharan Africa (AMAP/UN

Mercury has been used to extract gold for thousands

Environment, 2019).

of years. It is still seen as a favorable technique by

3.2 GLOBAL MERCURY TRADE

miners as it is an easy process that does not involve
any expensive equipment and mercury is often
relatively cheap and easily available. Mercury canInformation on the formal global mercury trade

be used during various stages of the mining process

can be found in various publications, including

and depending on the method, different amounts

UN Environment (2017, 2018). Information on theof mercury are needed. Generally, the following

informal trade is less readily available and this report

steps are involved in the extraction of gold by using

attempts to address this. Mercury trade, both formal

mercury. First, gold deposits get extracted by either

and informal, has been affected by the mercury

hard-rock or alluvial mining. The extracted ore

export ban of the European Union in 2011 and thegets further processed to liberate gold from other

US in 2013 as both regions were mercury exporters.

minerals. In many cases, the liberated gold gets

Since the bans, trade flows have shifted and prices

concentrated through gravity or other techniques.

have increased (Fig.1). This report will focus on data

However, in some cases this concentration is notafter the export bans to reveal the current situation in

taking place and mercury is directly added to a

the mercury trade.

IUCN NL

14

Opening the black box: global mercury trade revealedMercury export ban inEuropean Union (2011)
and United States (2013)

Reduced volume of
mercury from traditionalsources, including
chloralkali industry

supplyMercury price increase

Primary mercury mining
increases in Mexico andIndonesia (withproduction estimate at
800-1100 tonnes in 2015)

trade
Mercury trading hubs have
moved from previous Spanish
and Dutch ports to Singaporeand Hong Kong, and to lesser
extent Turkey and Vietnam

Overall increase of
mercury supply
from 2005 to 2015

In some cases, legal mercury
trade subjected to additional
scrutiny

Increase in illegal
mercury trade

Mercury shipments notalways recorded correctly
and shared with COMTRADE

Global mercury tradedifficult to track andmeasureForseen challenges
with managing
mercury trade andimplementation of
the Minamata
Convention

Overall increase of the ASGM activity
due to, among other factors:• Relatively high market price of gold
• L ack of other economic opportunities
in rural areas

Chlor-alakali production
has declined
Demand for mercuryadded products has
slightly decreased
Demand in ASGM has
increased (in Africa,
Asia and Latin America)

Overall increase in global
demand for mercury
from 2005 to 2015

demandFigure 1: Global trends and causality in mercury supply, trade and demand,
Source: UN Environment (2018) based on UN Environment ( 2017)

An overview of the officially recorded data of mercury

country’s ASGM sector. Mercury is used in a certain

trade reveals the main official flows and trading

ratio to gold (Hg:Au) during the mining processcountries (within this report, official data refers to data

and both global as well as regional estimates ofobtained from either the UN Comtrade database orthese ratios exist. Using the ratios and the declared/

national agencies). However, comparison of data fromestimated gold production by ASGM, it is therefore

exporting countries and importing countries show

possible to estimate the amounts of mercury needed

discrepancies. In addition to this, gold trading data

to support the ASGM sectors in the countries.

is also problematic. Official gold production figures

Mercury imports and gold production never add up

from ASGM are often unreliable as a large proportion

to 100% as mercury is also used for other activities,of the sector works informally and the extracted

e.g. in laboratories, and mining can also be donegold leaves the country through informal channels.

without mercury. However, major misalignment ofHowever, estimates for ASGM production exist for

mercury imports and ASGM gold production canmost countries.

indicate that a black market exists. Based on this, thequestions arise where all the mercury used in ASGM

Furthermore, official mercury imports into someoriginates.

countries are significantly smaller than what would
be required to support the large ASGM communities

This report will not go into detail of the estimations,in these countries. In other cases, mercury imports

but rather highlight the conclusions drawn by these.

are significantly higher than amounts required for the

For more details, please see the regional reports.

IUCN NL

15

Opening the black box: global mercury trade revealed3.3 MERCURY TRADE IN THE SELECTEDCOUNTRIESASGM gold extraction than recorded, stockpilingof mercury within the country, informal exports ofmercury to neighboring countries or a combination of

Bolivia

these.

Most miners in Bolivia are organized into

Most imports originate from Mexico (93%), where

cooperatives in which a group of miners become

mercury is produced from mercury ore (Instituto

partners and work together. Of a total of ca. 30

Nacional de Estadística, 2018). These imports alone

tonnes of officially produced gold in 2018, most wasrepresent 25% of all commercial flows of mercury

extracted by cooperatives (89%), so basically the

globally. Imports enter Bolivia mainly by land (98%)

ASGM sector (Ministerio de Minería y Metalurgía,

after arriving on the continent by ship to Arica, Chile

2019). In 2018, more than 136 thousand people(Instituto Nacional de Estadística, 2018) (Fig.2). Small

relied directly on ASGM for their livelihood in Bolivia.

portions are imported by air (1%) and via land fromThe organizational structure of cooperatives was

Peru (1%). The majority of imports are registered in theinitially put in place for social purposes. Over time,city of La Paz (393 t, 61%), followed by the city of El

it gained a more permissive regulatory framework

Alto (191 t, 30%). However, La Paz and El Alto bordercompared to other mining entities with looser laboreach other making this differentiation negligible.

and environmental regulations, a preferential tax

Following this, more than 90% of the imported

regime and direct state support. Due to the size andmercury arrives in the trading hub La Paz-El Alto.

economic importance, the cooperative mining sector
has immense political power, influencing regulations
and policies. Unfortunately, this importance also
creates a power imbalance between cooperative
leaders and employed miners and it is common thatleaders take advantage of their employees in theform of long working hours, low wages and unsafe
working conditions.
In Bolivia, mercury imports fall under a legal gap
in regulations. The mercury import ban from theneighboring country Peru in 2015 led to a significant
change in Bolivian imports. Bolivia experienced aleap in imports with a 12-fold increase and a historicpeak of 152 tonnes from 2014 to 2015. Imports sincehave stayed high and made Bolivia the second
largest importer of mercury in the world. Before 2015,
mercury imports were lower than estimates needed
for the declared gold creating a “deficit”. In contrast,
imports since 2015 are well above what is required
for the cooperative gold extraction sector, creatinga significant “surplus”. The deficit is an indication of
possible informal imports of mercury before 2015. On
the other hand, the surplus is an indication of a higher

IUCN NL

16

Opening the black box: global mercury trade revealedl
To B razi

BRAZIL

CobijaPeru (insignificant)PERU

BOLIVIA
To Peru

Trinidad

San Borja
Via Peru

La PazSanta Cruz
RoboréSucre
Via Chile (98%)

PotosiCamiriCHILE
PARAGUAY

Formal imports from ports via landInformal imports

Figure 2: Map of the main formal and informal
mercury imports and domestic trade routes in Bolivia

Main domestic trade routes
Possible informal exports
Local trade hubs
Mining areas

Information on the amount and value of these

the hardware and household appliances sector (6%)

mercury imports are based on two different sources

and the chemical, textile and cosmetic sector (0.6%).

(Great Export Import, 2018; Penta-Transaction, 2018)

Informal imports into Bolivia seem negligible during

as Bolivian customs denied access to information. As

the last years as volumes are small. Only in the region

in most other cases, the accessible sources did notbordering Madre de Dios in Peru, small quantities ofalign perfectly, however, imports of mercury in the

mercury are informally acquired from traders in Peru

timeframe 2014-2018 seem to range from a minimum(Fig.2). This seems to be a matter of accessibilityof 647 tonnes to a maximum of 1,366 tonnes. The

as Madre de Dios (Peru), a region in which ASGM ismajority of imports were imported by mining-booming, is located a lot closer than the main trading

related market entities (84%), followed by importers

hubs in Bolivia.

without information regarding their sector (9.2%),

IUCN NL

17

Opening the black box: global mercury trade revealedA total of 37 companies formally imported mercury

Peru. Different levels in the supply chain seem to be

into Bolivia within the period of 2015-2018. Of these,

the source of these informal exports. Mercury might

the top nine are responsible for 84%, and even more

be directly diverted by importers or by mercury

striking the top 3 for more than 50%, of all imports.

retailers, especially the ones based in areas close toFour of the large importers have ties to the Peruvian

the borders to Peru and Brazil.

mining sector and could be linked to both formal andAt the import level, costs of mercury are rather low

informal imports in Peru. The importers are selling

ranging from 10 to 31 USD/kg. Importers however,

mercury to wholesalers but also acting as wholesalers

sell the mercury to intermediate retailers for prices

themselves (Fig. 3). Most large transactions are

ranging from 166 to 217 USD/kg while the final retailorganized in La Paz and most stores involved are

price that the end user pays ranges from 200 to 240

located in El Alto. The wholesalers in turn sell mercury

USD/kg. Of this multi-million dollar business, theto retailers, mining cooperatives and companies andimporters who sell the mercury for 5 to 20 times theindividual miners. Transport to the larger mining

purchased price make the greatest profit within thetowns or towns located near mining areas where

value chain.

most retailers are located is done via land, involving
passenger transport companies, cargo fleets and

The investigations in Bolivia were rather difficult.

sometimes the buyers’ private vehicles. Retailers sell

While investigating in the field, our informants

mercury mostly in small quantities to cooperatives,

received multiple threats and were warned to dropcompanies and individual miners (Fig. 3).

further investigations. However, they were able

Only one official export of 212 kg to Peru in 2017

to identify that networks supplying Bolivia withhas been registered in the last years. However, themercury are partially connected to networks of large

amount of excess mercury and the abovementioned

transnational crime organizations involved in illegal

ties of importers to Peru suggest that large quantities

activities such as drug and human trafficking.

of mercury are leaving the country informally towards

Formal importers

Minor informal imports(near the region Madrede Dios, Peru)(La Paz/El Alto)Intermediate wholesalers(La Paz/El Alto, major
mining towns)

Individual
minersIntermediate
retailers (major
mining towns)

Cooperativas andmining companies

Intermediate retailers(La Paz/El Alto, major
mining towns)

Possible informal
exports

Cooperativas andmining companies

Cooperativas andmining companies

Individual miners

Individual miners

Possible informal
exports

Figure 3: Actors within the mercury value chain in Bolivia

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Opening the black box: global mercury trade revealedGuyana

It can therefore be assumed that additional mercury
was either stockpiled and/or exported informally to

In Guyana, the ASGM sector is fully legalized,

neighboring countries. Evidence suggests that both

however both legal and illegal mining operations

stockpiling and informal exports occur.

exist. Around 19 t of gold were declared in 2018

The main entry point for mercury is the Georgetown(Ministry of Finance , 2019). Estimates of theseaport (Fig.4). Another point of entrance is thecontribution of the ASGM sector to the production

Cheddi Jagan International Airport. Since the EU andrange from 59% to 70% (Ministry of Finance (2019)

US trade bans on mercury, India is the main supplierand Pasha et al. (2017), respectively). However, theseof mercury supplying 25% of all formal mercury,

numbers need to be taken cautiously as there isfollowed by Russia, Turkey and Singapore. While

concern that a significant part of gold is not declared

Mexico is a minor supplier, one shipment of 3 tonnes

but smuggled to Suriname (30-60%) where royalty

was declined entry by Guyanese officials and had

payment is less (Stabroek News, 2018 and Stabroek

this shipment been approved, it would have replaced

News, 2016, respectively).

India as the main supplier.

In the region, Guyana is the only country where

No informal imports have ever been intercepted bymercury can be imported relatively easily. While noofficials. However, multiple informants reported that

restrictions were in place concerning import amounts

mercury enters the country informally from China inin previous years, since 2019, no more than 1,000

container ships. It is believed that Chinese-operated

flasks/year or 34,500 kg per year can be imported.

businesses are allowed to import containers that

After a peak of mercury imports in 2012 and 2013,

are not being subject to customs checks. Under-

imports decreased in 2014 to approximately 5 t.

invoicing and under- or mis-declarations seem to be

Since then, imports have risen again with fluctuations

common practice as reported by informants.

reaching nearly 22 t in 2018. Over the past five years,

Furthermore, mercury might also be transported

the average amount of mercury imported per year

through the porous borders from neighboringis 20.46 t. Up until 2013, Guyana imported double

countries like many other smuggled goods.

the amount of mercury needed for its ASGM sector.

Extracted gold in the hands of a miner © Bram Ebus/InfoAmazonia

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Opening the black box: global mercury trade revealed

Port Kaituma

ATLANTIC OCEAN

Baramanniv ia
VENEZUELA

bo

at

or

pla

Charityne

via plane

Georgetown

via boat
Eterinbang

NI

RI

VE

ss

ib

Bartica

R

le

ro

ut

e

e

RU

rp

Lindendo

Imbaimadai

Corriverton

Takamav iaro a

Kamarang

ZA

l an

MA

po

GUYANA

informalexp orts to
S urinamero ad

Mahdiav ia

Main transport route
Main trading hub

RE

U IB O RSURINAME

ES S EQ

ER

LethemWA

Mining locations thatsell mercury

IV E R

BRAZILR IV

Regional hubs

Figure 4: Map of main trading routes in Guyana

Since the drop in mercury imports in 2014, theorigin of the traded mercury. It was suggested bynumber of importers also decreased. As of 2015, only

informants that mercury sold in a secretive manner

three official importers have been registered, one

originates from the informal trade. Interviewees

businessman and miner from Georgetown and two

indicated that Chinese mercury can be obtained

businessmen from Corriverton (close to the Suriname

cheaply from Chinese businesses. Mercury is either

border). One of the latter stopped importing mercury

sold in bulk in its original flask to bigger secondary

due to new requirements for mercury storage.

retailers or re-packaged into plastic bottles for sale

After arriving in the Georgetown port, a significant

to miners. Many miners buy mercury directly inamount of mercury is transported to Corriverton on

Georgetown in small amounts and transport it openly

the Corentyne coast where two of Guyana’s major

to the mining sites. Domestic transport is via land,

importers of mercury are based (Fig.4). The rest ofwater and air in small quantities and usually transport

the mercury is sold to mining companies, suppliers ofgoes unhindered by the authorities. Retailers who

mining equipment, general stores and gold dealers

buy mercury in Georgetown also transport mercury

who retail the mercury further (Fig.5). Most of thesein the original flasks of 34.5 kg to the main mining

transactions are done in Georgetown making it

towns (Fig.4). In the main mining hubs of Bartica, Portthe major trading hub. Trade is done both openly

Kaituma and Mahdia, the retailers who are commonly

and more secretly depending on the shop and the

suppliers of mining material, sell the mercury to

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Opening the black box: global mercury trade revealedminers. Some smaller shop owners also have smaller

smuggled mercury from Guyana is Brazil. Sources

quantities of mercury available for sale.

identified a well-known operator who transports
mercury via the Georgetown-Lethem road. This route

Mercury imported and taken to Corriverton, is sold

was also confirmed by a bus driver who transports

to miners directly at the wharf in Georgetown or

mercury to the border from where it is taken overfrom a warehouse in Corriverton. (Fig. 5). However,

the informal river crossing via boat and further

the east of Guyana has rather few gold mining sites

transported to Boa Vista (Brazil) by bus or taxi. Fromand interviewees from multiple different stakeholder

there, it might be brought to Venezuela. Mercury alsogroups, including government officials, reported thatleaves the country directly towards Venezuela via

mercury is believed to be smuggled into Suriname.

different routes. Transport can be done via the river

None of the interviewees could state with any

to Etheringbang, via plane or boat along the coast,certainty what quantities were likely to be smuggled.

however information on the latter is sparse. Guyana

Another country that has been reported to receive

recorded no formal exports since 2008.

Formal Importers,
businessman
Georgetown

rgetow n
ct c

o nn

ect

ion

un c

lea

harf in G eo

E xa

r

Informal exports
to Brasil and
Venezuela

Storage inwarehouse in
Corriverton

re ctly at w

Possible
Georgetownbased informal
sellers (secretive
trade)

Bo ught diGeorgetownbased formal
sellers (opentrade)

Formal Importers,
businessman
Corriverton

Smaller retailers

minersminersInformalexport toSurinameminersFigure 5: Mercury supply chain with main actors and flows in Guyana

Prices of mercury are higher further down the supply

prices might be even higher, 300 USD/kg depending

chain. Importers purchase mercury for as little as 17.4

on difficulty of transport to the smaller mining towns.

USD/kg and sell it for up to 126 USD/kg, making a

Profits for retailers are at least 33 USD/kg, even for

more than three-fold profit. Retailers in turn sell thethose using the lower price ranges. Similar to Bolivia,

mercury for at least 159 USD/kg to miners, but prices

the largest profit lays with the importers.

go up to 234 USD/kg in the city. Outside the city,

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Opening the black box: global mercury trade revealed

SurinameMercury is transported within the country mainly via
road. The main trading route goes along the coast,

Most mining in Suriname takes place in thetransporting mercury from the border river between

Greenstone Belt and is carried out by Brazilians andGuyana and Suriname in the west to Paramaribo, theMaroons, indigenous people of African descent,major trading hub (Fig.6). It is first taken by boat towho dominate the work force in the ASGM sector

Nickerie, then further in cars and trucks over land

(Heemskerk et al., 2016). Mining generally takes

to Paramaribo. In some cases, miners themselves

place in official mining concessions, however undertravel to Guyana, in other cases, Nickerie-based

illegal circumstances. Many exploration title-holders

middleman bring the mercury across the border

let informal miners mine at their sites and receive aand sell it directly in Nickerie to miners who do not

percentage of their earnings in return. In total, 17

want to transport it themselves (Fig. 7). Vendors fromt of gold were declared in 2018 in Suriname1 andParamaribo also cross the borders to buy mercury inestimates from 2014 suggest that about 65% of the

Guyana. Along the road a police checkpoint mainly

country’s gold originates from ASGM (Centrale Bank

checks for drugs, weapons and illegal immigrants.

van Suriname, 2016). While some undeclared gold

At times, seizures of mercury seem to happen at thismight exist, figures seem to be smaller than in othercheckpoint as reported by news articles. However,countries.

no mercury has been confiscated at the site since2014 according to the Chief Inspector responsible forSince Suriname placed mercury on a list of goods

the checkpoint. Once mercury reaches Paramaribo,that need a special license for import in 2003, no

it is sold by informal vendors, who are also often

official mercury imports have been documented. As

taxi drivers. The main trading is done in the

Suriname has quite a large ASGM sector and nearlyneighborhood of Little Belem, where many mining

all miners use mercury, it can be assumed that all

shops are located. Most miners stock up on mercury

mercury enters the country informally. All informants

on trips to Paramaribo. From there, smaller amounts

noted that most mercury enters the country via

seem to be transported to mining areas where it isGuyana. The routes involve transport via land andsold. Informally imported Chinese mercury can bewater using the same routes as used for otherbought both in Paramaribo and in mining cities where

smuggled goods. Via land, mercury is transported

it was reported that nearly all Chinese supermarkets

in 34.5kg-flasks or in repackaged 1- 1.5 l bottles bysell mercury. Some mercury gets further transported

Surinamese or Guyanese citizens, often taxi drivers.

to the east to Albina, where many Brazilian miners

The border is porous and the Suriname borderworking in French Guiana buy mercury.

control can be bypassed by using small-motorizedboats instead of the official ferry to cross the Corantijn
River. Initiatives to increase patrols on the border are
being implemented, however, the “backtrack” route
into Suriname connects with a sand road that can betaken to avoid authorities close to the border.
It seems likely that mercury is also informally
imported from China via container ships. While these
shipments have never been officially intercepted,
informants mentioned that customs officials are

NOTE

commonly bribed to let other goods enter the country

1 Deviezencommissie, pers. com. 23/05/2019, see regional
reportinformally.

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Opening the black box: global mercury trade revealed

Georgetown

via plane (small amounts)

possible informal
imports from China

ATLANTIC OCEAN

New Amsterdam

suspected route by sea

Corrivertor

via roParamaribo

ad

Nieuw
Amsterdam

Totness

GUYANA
AlbinaEN A ME R IV E

R

Brokopondo

COPP

LAKE
BROKOPONDO

Figure 6: Map of main mercury trade routes in Suriname

informalexports
to French
GuianaFRENCHGUIANA

Main trading hub
Main transport routeTransport distributing mercury to ASGM areas

Retailersin Guyana

Paramaribo-basedvendors

Nickerie-based
middleman

Of

t

en

bo

ug

h

y
tb

th

e

m

in

er

n
si

Pa

r

am

ar

ib

Albina retailersoMiners from
French Guiana(informal bordercrossings)

minersFigure 7: Mercury supply chain with main actors and flows in Suriname.

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Opening the black box: global mercury trade revealed

Suriname officially exported mercury for two years

Estimates for the scale of the Tanzanian ASGM

within the last decade, 1.300 kg to the Netherlands

sector vary greatly with numbers ranging from 500

in 2010, and 102 kg of mercury to the United States

thousand to one million people relying directly onin 2016 (UN Comtrade, 2019).No further exports

the sector and millions indirectly (World Bank, 2015;

have been recorded since then. Nonetheless, it isKinyondo & Huggins, 2019). These quoted numbers

thought that mercury is being informally exported toof people involved in ASGM makes the estimation

French Guiana. Most miners from French Guiana buy

that around 10% of the national gold supply originate

mining equipment, including mercury, in Suriname.

from ASGM seem rather low (UN Environment,

However, mercury has never been seized at the2012). While ASGM regulations have been in placepolice control post on the route to Albina and Frenchsince 1998 including efforts to formalize the sector,

Guiana2. Furthermore, Guyanese informants noted

many registered mining sites still are sub-leased tothat there might be smuggling from Suriname tounregistered miners for a share of their produce and/

Guyana, contrary to the aforementioned route inor earnings.

which most mercury is transported from Guyana to

The Ugandan ASGM sector has expanded

Suriname. This is thought to be due to the cheaper

substantially in the past decade and estimates are

retail price of mercury in Suriname compared tothat around 50 thousand people work within the

Guyana. Sources indicated that mercury commonly

ASGM sector, though numbers could be larger

traded in Suriname is of lower quality and might be(Schipper et al., 2016 ). A large portion of miners

recycled mercury. Retail sellers purchase mercury

operates informally, extracting an estimated quantity

from Guyanese wholesalers for 58-72 USD/kg andof 1.2 tonnes of gold per year (UN Environment,

resell it in Paramaribo for 100-130 USD/kg (retail price2012).

in Guyana is 159 - 234 USD/kg). Prices in the border
towns to French Guiana are higher with ca. 210-350

All three countries have formal mercury imports

USD/kg. However this is still cheaper than mercury

which are mainly registered for industrial use by

prices in French Guiana itself which have beenchemical companies based in Kenya (16), Tanzania

reported to be 350-525 USD/kg .3(9) and Uganda (6). Official data from the Kenya
National Bureau of Statistics, the Tanzania National

East Africa

Bureau of Statistics (NBS), the Uganda Bureauof Statistics (UBOS) and UN Comtrade on import

The East African countries Kenya, Tanzania andstatistics shows that Kenyan imports (average 12

Uganda are closely connected when it comes tot/year) are substantially higher than imports of

networks of mercury trade. Therefore, they are

Tanzania (average 3 t/year) and Uganda (average 0.3

discussed together and in relation to each other.

t/year). Kenyan imports are more than double to 15-

In Kenya, small-scale mining is the main source offold of the imports of Tanzania and more than 100- toincome for many people and more people search for

1000-fold of Ugandan imports in the last five years.

daily income within the ASGM sector. An estimated
140 thousand people are directly employed by thesmall-scale mining sector and over 800 thousand
NOTES

people depend indirectly on it (Barreto et al., 2018).
Most mining endeavors are run informally with a legal

2 R egional Police Commander East, pers. com. March 22, 2019,see regional report
3 F.M. Le Tourneau, geographer. Pers. com. 21/03/2019, seeregional reportframework for ASGM only being put into place in2016.

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Opening the black box: global mercury trade revealedKenya’s official imports come mainly from China,

the importing companies, most of the companies

Mexico, India, Singapore, Germany and the US.

remained unresponsive and the one company that

Imports to Tanzania arrive mainly from China, India

replied claimed not to be involved in mercury trade.

and Switzerland and imports to Uganda from Kenya,

A reason for the high imports might be that the

Malaysia and India (UN Comtrade, 2019). For all threemercury gets informally redirected to the ASGM

countries information can be found that mercury

sector once it has entered the country legally. Whilewas imported from EU countries or the US, which

the countries vary drastically in size and also in size

would be illegal due to the export bans in place. Thisof their ASGM sector, estimates suggest that Kenya

information however, needs to be taken with caution.

imports more mercury than is needed for its ASGM

As explained in the “Global mercury supply, trade

sector, while Tanzania and Uganda import too little.

and demand” by UN Environment (2017) origins of

Most of the official imports in Tanzania seem to be

mercury in transit are often unclear. Mercury thatimported for other sectors than ASGM. Therefore,

gets repackaged in transit at an EU or US port isthere are only small quantities of formally imported

sometimes incorrectly assigned an EU or US origin

mercury available for the ASGM sector, suggestingat its final destination. This might be the reason thatthat most mercury used in ASGM comes fromEU countries and the US are listed as exporters by the

informally traded mercury. Data on official imports

importing countries even though it is assumed thatfrom the different Ugandan Ministries and agencies

there are no real exports from these countries to thevary significantly. All these findings together, indicate

importing country.

that a lot of Kenya’s officially imported mercury isused in Kenyan ASGM but also informally exported to

The sheer amount of officially imported mercury,

Tanzania, Uganda and even further afield.

especially at the port of Mombasa in Kenya, gives rise
to doubts that all the mercury is used by chemical

Regional mercury trade is not uni-directional fromcompanies. When researchers tried to contact

trade hub to mining sites, but multi-directional
across borders. Mercury dealers in Kenya, Tanzania
and Uganda import and export mercury informally
between each other depending on supply and price.
This goes to a degree that traders might even passeach other at the porous borders that are difficult to"Previously my workmates used to importmercury covertly amongst other mining
chemicals and equipment that the company
imported from China. They would then sell it
to ASGM operations and gold dealers. They
had developed some sort of informal business
partnership with ASGM miners that thecompany’s management was not aware of."control by officials. As trade routes are not just onedirectional, but create a network of pathways, flows
have been categorized as primary and secondary
flows (Fig. 8). Primary flows are routes through whichmercury is transported from one big mercury hub toanother area. Secondary flows are characterized asgoing in the opposite direction to primary flows. As
an example, mercury flows are mainly from Kenya to
Tanzania and Uganda (primary flows), however, inWorker at a Chinese mining equipment company,

some cases mercury is transported the other way,Dar-es-Salaamfrom Tanzania and Uganda to Kenya (secondaryflow). These changes in direction are mainly due tosupply, demand and price.

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Opening the black box: global mercury trade revealed

ETHIOPIA

SOUTH SUDAN

Karamoja
SOMALIAUGANDA
KENYA

Kitumbi KAMPALABusia

Kakamega

Bondo
MigoriLAKE
VICTORIA

RWANDA
BURUNDI

MwanzaGeita

NAIROBI

Sirari

MusomaNamanga

Shinyanga

KahamaMombassa
Tanga
INDIAN OCEAN

MpandaTANZANIA
Dar es Salaam

ChunyaZAMBIA

Mbeya
Tunduma

Songwe-Kasumulu

Primary flows
Secondary flows
MOZAMBIQUE

Figure 8: Domestic mercury trade within the East African countries of Kenya, Tanzania and Uganda. Primaryflows are defined as flows from major trading hubs to other areas, secondary flows as flows of the opposite
direction that may appear due to variation in mercury supply and price.

Formally imported mercury arrives in Kenya, mainly

Malaba for Uganda (Fig. 8). Mercury might further

at the port of Mombasa, in sealed metal jars of

be transported to DRC, Burundi and South Sudan.

34.5 kg or in bottles of 1 or 2 kg. Large quantities

Miners prefer Tanzanian mercury as it is regardedof this mercury are thought to be diverted into

as elemental mercury. This has led to the reporting

informally traded mercury used for ASGM, bothof secondary flow transportation from Tanzania towithin Kenya and in neighboring countries. For

Kenya, close to Migori.

further transportation, mercury is re-packaged into
smaller quantities of 2 kg, 1 kg, 500 g and 250 g

Three main routes have been identified in Tanzania, abottles. Mercury is transported to Nairobi from where

northern, a southern and an eastern flow (Fig. 8). The

it reaches mining areas both within Kenya as well asnorthern flow originates from Kenya where mercury

in Tanzania and Uganda. Primary flows of mercury

is transported from Nairobi mainly via Sirari (lessto Tanzania go through the bordering towns of Sirari

frequently via Namanga) to the main towns of theand Namanga and through the borders at Busia andLake Victoria Gold Fields, in particular Mwanza, Geita,

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Opening the black box: global mercury trade revealedA strong relationship exists
between the gold and themercury supply chain

and Kahama, which further supply the mining areas

e.g. by public busses form major cities to smallerin the area. Mercury from the southern route enters

trading hubs and further by motorbikes, bicycles

the continent via South Africa, where trade is legal

or on foot across the borders. Generally, transport

and is transported via Zimbabwe through Malawi or

and trade are kept secret and people transporting

Zambia to Tanzania. It enters the country at Tunduma

mercury are kept in the dark about its origin andfrom Zambia or Songwe-Kasumulu from Malawi fromdestination as a precaution in case the person getswhere it is taken to Mbeya, a regional trading hub,caught. Local transport within the mining areas isand further supplied to the mining sites through amainly done via motorbike by young adult men who

combination of primary and secondary flows. The

are well connected within the ASGM sector of theeastern route supplies mercury that enters Tanzania

area. Informants reported that sometimes people withat the port of Dar es Salaam. The mercury entering

disabilities are hired by large wholesalers to transport

the port flows towards smaller ASGM sites, e.g. inmercury across the borders as custom officials checkthe region of Tanga, but also into both the northern

them less frequently.

and southern route, supplying Mbeya and the Lake
Victoria Gold Fields.

Besides the main trade routes, mercury is sometimes
distributed through indirect sources. Informants

Mercury used in Ugandan ASGM is reported tomentioned that mercury can –at times- get purchased

come through Kenya across the border at Busia andfrom individuals working in hospitals, medical

Karamoja. From these two areas, it is distributed tolaboratories and pharmacies, licensed shops selling

the ASGM sites in the whole country. The border

other mining chemicals and individuals working

between Uganda and Kenya is porous with many

within military camps.

informal entry routes, making illegal crossings hard tocontrol. In addition, mercury traders have informants

Within East Africa, the mercury trade is secretive andwho monitor the movements of officials along thethe supply chain is built on trust between different

border so that traders can avoid the controlled

actors, making it hard to enter the business as apathways. Both custom officials and mining

newcomer. A strong relationship exists between theinformants reported that mercury trade seems to begold and the mercury supply chain, however, manyhigher along the border to DRC and Kenya compared

non-gold actors are also involved in the mercury

to the border with Tanzania. Trade at the Tanzaniansupply chain. Formal mercury importers and large-

border is probably lower as most mercury arrives

scale informal importers as well as gold smiths importstraight from Kenya. Transport of mercury is done in

the mercury into the region (Fig. 9). Wholesalers

multiple ways, often with a combination of vehicles,order mercury from these large-scale traders and act

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Opening the black box: global mercury trade revealedas intermediaries supplying retailers, gold brokers/

Uganda. Most ASGM miners sell their gold to gold

dealers, gold processors and ASGM miners. However,dealers and it used to be common practice thatboth wholesalers and retailers are mostly based in

mercury was provided to miners in advance andthe large cities and act through agents in the local

the recipient settled the debt upon selling gold tomining areas. To transport the mercury into thethe same dealer. Smaller retailers were reported tomining areas, it is repackaged from the original 34.5

often be jewelry shop owners that sold directly to

kg flasks into smaller 1 kg bottles. Agents do notminers. Mining pit owners – while often not directly

always own the mercury themselves, but sometimes

involved in the mercury trade- create trade networks

sell it for the traders, receiving a commission forto facilitate miners with mercury and increase gold

the amounts sold. Similar to wholesalers, retailers

extraction. The role of actors within the supply chain

also supply both gold brokers/dealers and ASGM

is not clearly defined and delineated and some actors

miners directly. The amounts sold directly to themight overlap, for example, in the case of agents who

miners can be small, e.g. as low as 1 g in Kenya andare also gold traders themselves.

Large-scale informal
importers & gold smiths

Formal importers /dealers

In capitals /large cities

Wholesalers

Retailers

AgentsIn local mining
towns / sites

Gold brokers / dealers

MinersFigure 9: The supply chain of mercury in the East
African countries of Kenya, Tanzania and Uganda

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Opening the black box: global mercury trade revealed

The trade operates in secrecy and is controlled bysuch as distance and remoteness of the ASGM site,gold dealers and mercury suppliers since they haveseasonality, stage in the supply chain and fear of

financial capital and connections to the mercury

political turmoil.

supply chain outside the region. At lower levels, thetrade is primarily controlled by local gold dealers,

While Tanzania and Uganda have had no formal

mine pit holders and owners of gold concentration

mercury exports in the last decade, Kenya reported

and extraction operations.

a total of 32,292 kg in the period 2009-2018. Official
data stated that mercury was traded with theImport prices of mercury are not known for East

Democratic Republic of Congo (DRC), Tanzania andAfrica. However, similar to other countries, prices

Uganda. However, exports have decreased sinceincrease with decreasing mercury amounts and2014 and exporting partners vary with only one

further down in the supply chain. On average, thereported export to Tanzania and one to Uganda since

wholesale price ranges from 113 to 202 USD/kg

2014. The main trading partner still remains DRC,

while the retail price is up to 150 to 391 USD/kg. In

however, no exports to DRC have been recorded in

Kenya, average wholesale prices range from 113

2017 and 2018.

to 148 USD/kg while retail prices range from 150 to

Burkina Faso

180 USD/kg. Tanzanian prices are higher, with anaverage wholesale price of 130 to 202 USD/kg andretail prices from 150 to 391 USD/kg, when quantities

Burkina Faso’s gold sector is large considering theare small. In Uganda, average wholesale prices range

size of the country. Approximately 700 thousand

from 175 to 202 USD/kg while retail prices range

miners work in ASGM (UNIDO, 2019), making it thefrom 250 to 270 USD/kg. However, prices seemsecond largest source of income after agriculture.

to vary a lot depending on time and other factors

The recent report on initial estimates of the artisanaland small-scale gold extraction sector in Burkina
Faso done for the Minamata Convention, extrapolates
the national gold production to ca. 126 tonnes per
year (Kaboré, 2019). While estimates of the annual"… in 2014, I was called by a friend of mine who
is a police officer. He told me that he had some
10kgs of mercury that he hoped I could buy.
We agreed on a place to meet close to the police post. When I reached there, we negotiatedthe price per kg. He wanted USD 120 per kg.
But I insisted that I could only pay him USD 80
per kg. Since he wanted to sell and we knew
each other well, I insisted on my offer. Eventually he agreed, I paid and brought the mercury
home. I think he had confiscated them fromsomeone they had arrested, and he wanted tomake money out of it. He was my friend and hetrusted me..."gold production by ASGM from other sources vary
greatly, most estimates lay around 25 tonnes per year
(Hunter, 2019). However, official exports of gold aresmall with only 236 kg reported in 2017, so most gold
is thought to leave the country undeclared (Hunter,2019). Nearly half of the reported gold originatedfrom the region “Sud-Ouest”, followed by the region“Nord” which accounted for about a quarter, themining sites in the region “Centre-Nord” reported
small production (ENSO, 2017). Like in many of theother countries, the ASGM sector is poorly organized
and miners have no access to financial, social andhealth support from the state. As a result of thepoverty many miners face, child labor is a commonly
reported problem as many miners’ children drop outof school to support their parents in the gold mining

Mercury trader, Bondo, Kenya

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Opening the black box: global mercury trade revealedactivity. Mercury use in ASGM has been banned since

be needed to support the countries ASGM (several

2015, nonetheless, nearly all ASGM miners report

hundred tonnes)(Lassen et al., 2016). Due to thisusing mercury.

and the informality of the sector, most mercury isthought to arrive in the region informally. Informants

Mercury enters Burkina Faso mostly through its

reported that informal mercury enters Burkina Faso

neighboring countries, while Burkina Faso itself only

via Lomé seaport from China. From Togo, mercury isimports small amounts (less than 100kg/year in theinformally transported to Burkina Faso and Ghana.

last 5 years (UN Comtrade, 2019)). The main importer

Mercury arrives in Burkina Faso mainly by landin the region is Togo where mercury enters throughfrom Togo, but also in smaller amounts from Ghana,

the port of Lomé (Hilson et al., 2018) (Fig.10). Togo

Côte d’Ivoire, Mali and Niger (Fig.10). Interviewed

receives formally traded mercury mainly from China,

miners further mentioned two countries, Angola andHong Kong, India, Indonesia, Singapore, Vietnam

South Africa, from which mercury enters Burkina

and Turkey. While Togo has almost no ASGM sector,

Faso by plane. Once inside the country, mercury

large amounts of mercury enter the region throughis transported to the different regions. The central

Togo each year. Some of it is probably used for otherregion seems to be a main hub from where mercury

sectors (e.g. dental amalgam), however, an estimatedis distributed. Exchanges between regions are based

80% of the mercury demand in the Economic

on geographic proximity and the availability ofCommunity of West African States (ECOWAS) region

the product. Burkina Faso is a trading hub for both

is for ASGM (Lassen et al., 2016).

mercury and gold in the region and a lot of mercury

Official imports of ECOWAS countries, including

leaves the country to its direct neighbors from where

Togo and Burkina Faso, are a fraction of what would

it is transported further.

The mercury
and gold supply
chains in Burkina
Faso are stronglyinterlinked
creating a cyclethat is difficult to
break

Measuring gold returns © Bram Ebus/InfoAmazonia

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Opening the black box: global mercury trade revealed

MAURITANIA
MALI

NiameyBURKINA FASO

BamakoOuagadougou
GUINEEBENIN

NIGERIA

Abuja
IVORY COAST

LIBERIA

GHANA

TOGO

Yamoussoukro
Lome

Cotonou

Accra

AbidjanFigure 10: Regional mercury trade within West Africa with main focus on
Burkina Faso as a trading hub. Primary flows are defined as flows frommajor trading hubs to other areas, secondary flows as flows in the opposite
direction that may appear due to variation in mercury supply and price.

Primary flows
Secondary flows

Wholesalers in Burkina Faso re-package mercury in

not uncommon for mercury to be kept in residential

steel cans and bottles which are placed in wooden

houses and stores. For retailers, two indicators

cases and stored out of sight in gold panningthat mercury is available for sale were reported byequipment shops. To show that mercury is available

interviewees: a small transparent bag in front of thefor sale, shops place a blue canister, a black canistershop and the combination of a small drawer table,

and a zinc bar in front of the shop. Mercury isa watch post’s chair and a small bench in front of afurther repackaged into plastic bags and cans andshed.

transported to mining sites via motorbike, public

In many cases, mercury wholesalers and retailers

transport, trucks and private vehicles. It is sold toare also gold traders and mercury is supplied tominers at gold buying stations or through retailers

guarantee a flow of gold. The gold buyers sell

(Fig. 11). Retailers repackage the mercury again into

mercury to miners linking the price they will pay forsmall, transparent plastic bags and store them in

the recovered gold directly to the supply of mercury.

larger plastic wrappings or in cans and drawers. It is

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Opening the black box: global mercury trade revealed

are often either bribed, occupied with other topics or
benefit in some way from ASGM. A large proportion

Primary sourcesof the population is somehow involved in, or benefits(Main entry point in Lomé,
Togo, from China, Indonesia,
Singapore, Vietnam

from, ASGM and the sector has a strong political

Secondary sources(Re-export mainly from
Ghana, and then locallyfrom neighbouring
countries: Ivory Coast,
Niger, Guinea, Mali)

lobby at local and national levels.
Burkina Faso reports no formal mercury exports.
Illegal imports

Official imports(entry by gold dealers
from Burkina Faso andneighbouring countries)(Medical anddentistry entry,
through customs)

Nonetheless, the country seems to be a major trading
hub for informal mercury in the region. Mercury
passing through Burkina Faso is transported on intoneighboring Mali, Ivory Coast and Niger. It has beenreported that mercury is transported as far as Senegal
passing further through Mali and Guinea (Lassen et

Wholesalers in regions(Mainly gold dealers)al., 2016).

Philippines
Local dealers

Approximately 70% of the Philippines gold is(Mainly local gold dealers)

produced by ASGM (Seccatore et al., 2014), making it
one of the largest ASGM gold producers in the world(Ban Toxics, 2016). Therefore, it is not surprising that

ASGM producers

up to 500 thousand miners and indirectly millions
of people are relying on small scale mining for

Figure 11: Mercury supply chain in Burkina Faso

an income (PH-EITI, 2018). ASGM is illegal in thePhilippines and therefore no regulations for safety or
minimum wage exist, wherefore it is heavily linked
to extreme poverty. Miners often face bad working
Retail prices for mercury vary greatly between

conditions and child labor has been reported. A large

regions with a range of 170 to 670 USD/kg, withpercentage of the produced gold seems to exit the

an average of 501 USD/kg. The higher end of thecountry illegally with estimates up to 95% (Lucas,

range in particular, is way above global market price2012). Therefore, official figures of declared gold,and even higher than mercury in most of the othersuch as 23 tonnes in 2017 (PH-EITI, 2018), do notinvestigated countries. Prices seem to fluctuate

represent actual production numbers.

without obvious reasons. It was difficult to obtain

Since the EU and the US banned mercury exports in

information on how many times mercury is re-sold2011 and 2013, the Philippines officially imported

at the different levels. While no prices through the

only very small amounts of mercury, namely 428

entire value chain could be obtained, it was clear

kg in 2016, 189 kg in 2017 and 34 kg in 2018, allthat mercury sellers at all levels profit from the trade.

of which came from Japan (UN Comtrade, 2019).

Some traders even reported that they make a profit of

The country’s ASGM sector is estimated to use

100%. The mercury and gold supply chains in Burkina

significantly more than these amounts per year,

Faso are strongly interlinked creating a cycle that issuggesting that most mercury used in ASGM entersdifficult to break. Actors that could step into action to

the country informally. Informants stated that mostwork against illegal trade such as the police, agents

mercury arrives from China, Indonesia and Malaysiaof the Ministry of the environment or local politicians,(Fig.12). Indonesian mercury seems to provide the

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Opening the black box: global mercury trade revealedmajority of mercury used in ASGM and is preferred

informal ports. Mercury is often smuggled by fishingby miners instead of Chinese mercury as it is thought

vessels from neighboring countries that transport

to be of better quality. It was also reported that

their cargo to fishing areas such as Balut Island.

mercury enters the country informally through either

There, they either dock at informal ports or throwformal or informal ports (Fig.13). Mercury entering

the loaded mercury overboard without docking.

informally through formal ports, especially on the

Mercury entering this way is mostly from Malaysia

island of Mindanao (Davao City, Cagayan de Oro City,and Indonesia (Fig.12). Some mercury also seems

Zamboanga City, and Saranggani Province), is either

to originate from other sources, such as confiscatedmis-declared or passes officials through bribing.

mercury sold by government officials or recycled

Mercury entering at formal ports is often shipped

mercury sold by miners. Furthermore, some formallyfrom China directly. The majority of mercury imported

imported mercury may be deviated to informal use

from Malaysia seems to be Indonesian mercury

in ASGM, however, the amount seems rather smallthat was imported to Malaysia formally and thencompared to the informally imported mercury.

informally shipped to the Philippines.
Another way of entry for informal mercury is via

ASGM
communities in
Luzon and Visayas

China

Primary entry points
Transport to major/minor trading hubs
Transport to selected ASGM
communities in Mindanao
CompostellavalleyTagum city andDavao city

South Cotabato

Balut Island
SarangganiIndonesia andMalaysia

Figure 12: Primary entry points, trade hubs and trade routes in Mindanao, Philippines

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Opening the black box: global mercury trade revealed

Once mercury has entered the country it moves

No formal exports of mercury are recorded for the

relatively freely due to a lack of regulations. From

Philippines. Informal exports were not indicatedthe entry points at official and unofficial ports, it

by informant interviews, so it seems that none oris brought to the cities in Minadano, e.g. Marawi

insignificant amounts of mercury leave the country.

City, Zamboanga City and Cagayan de Oro City.
From there, mercury is transported to Tagum
City and Davao City, the major trade hubs dueto their proximity to the ASGM sites. To facilitatetransportation, mercury is repackaged into smaller
amounts and is placed in plastic bags wrappedwith paper and masking tape. The repackaged
mercury gets sold all over the country, not just on
Mindanao but also the other islands. It is transported
via land and sea concealed inside vehicle parts andcompartments to hide it from potential inspections.
Mercury prices range from 135 to 230 USD/kilogramat the retail seller. No information could be obtained
about the prices through the value chain as allimports are informal. However, it should be noted thatprices have increased, they are now 10-times higher
than 15 years ago.

Entry through Formal Ports

Primary
Sources(China,Indonesia,
Malaysia)

SecondarySourcesAccredited Mercury
Importers:
Chinese and Filipino
Smugglers (through bribes)
Entry through Informal Ports
Filipino / Maranao
Smugglers(through entrypoints suchas Balut Island and otherinformal ports)

Mercury
Wholesalers(Hardwarestores, local
shops, mercury
wholesalers
Sold To
based intrading hubs
such as Tagum
City, andDavao City)

Confiscated Mercury(sold by uniformed authorities
such as the police)

Local Mercury /Gold Traders
Sold To(often basedin ASGM or
adjacent
communities)

ASGM
Communities

Sold To

Recycled Mercury(sold by miners / ball mill operators)

Sold To

Figure 13: Mercury supply chain in Mindanao, Philippines

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Opening the black box: global mercury trade revealed4 COMMON FINDINGSACROSS REGIONS
4.1 USE OF MERCURY IN ASGM

•P
 hilippines: Many miners seem unaware or do notbelieve that mercury is bad for their health when

• Mercury use in ASGM in most of the focus countries

educated on the topic

is prohibited or at least regulated•S ome miners who are aware of the risks put certain•For some countries, where estimates are available,measures in place to mitigate the risks (e.g. bymore than 95% of gold miners use mercury

burning the amalgam in open air)•Mercury is used during different stages of the•E ven if educated about the risks of mercury usage,

mining process, resulting in varying amounts ofminers might not take measures as (1) mercury

mercury used. Mercury can be used for concentratepoisoning takes a long time to show symptoms andamalgamation, resulting in smaller mercury to gold

therefore is difficult to connect directly to the use

ratios or whole ore amalgamation, resulting in highof mercury and (2) miners face a multitude of othermercury-gold ratios

risks every day such as mining accidents, high noise•Mercury to gold ratios (Hg:Au) vary widely, not only

levels, dust inhalation, etc.

between countries but also within (e.g. 1.3:1 in• Gender dynamics: within some regions (e.g.

Burkina Faso, 3.3:1 in Suriname, 10.6:1 to 48.1:1 in

the Philippines), women are at a disadvantage

the Philippines). These differences are mainly due

concerning exposure to mercury. Women are

to miners using either concentrate amalgamation

believed to be more honest, thus, they are assigned(small ratios) or whole ore amalgamation (highto watch over amalgam burning, resulting in theratios)direct inhalation of mercury fumes•While some miners recycle mercury during theextraction process, many miners do not, which
results in high losses of mercury to the environment

4.2 KNOWLEDGE OF THE NEGATIVE HEALTH
EFFECTS OF MERCURY AMONG SMALLSCALE GOLD MINERS•Bolivia, Suriname, Guyana & Burkina Faso: miners
seem to be well aware of the negative impact of
mercury on human health and the environment, but
do not know of or have any other way of extracting
gold and therefore keep using mercury•East Africa: some miners are unaware of health risks,
others are aware but choose to run a calculated riskor mitigate this risk (not through retorts but throughstanding at a distance at the opposite of the winddirection while burning)

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Opening the black box: global mercury trade revealed"I have had joint pain, insomnia for almost five
years and I am constantly tired. I also have apersistent cough despite taking antitussives.
This cough is more severe at night. I can’t
sexually satisfy my wife so much that she ends
up leaving me. I also have tremors in my limbs
when my blood pressure is normal. I can’t
walk straight. I have worked with mercury forten years. I buy the gold and burn it under the
unprotected hangar. I was rather concerned
about the amount of gold I could recover. I
even kept mercury at home because I am aretailer, and I handled it with my bare hands.
I didn’t know mercury could cause me somuch trouble. I really regret everything that
happened to me."• High informal ASGM gold extraction• Informal mercury trade between neighboring
countries• Combination of both

Informal mercury imports• Informally traded mercury arriving at official entry
points (e.g. ports) is rarely seized due to mislabelingand bribing of officials as reported by informantsfrom multiple countries (including custom officers)• Mercury entering through unofficial entry points(e.g. at porous borders) often gets transported in
the same ways as other illegal goods as reported
through informants

4.4 DOMESTIC TRADING ROUTES• Mercury is transported to large trading hubs from

Artisanal gold miner at the Solhan site in Sebba,

where it gets distributed throughout the country

Burkina Faso

• Mercury gets repackaged into smaller amounts fortransport and resale• Domestic transport is mainly via land, hidden in
vehicles

4.3 MERCURY IMPORTS• Most transport is unhindered by officials• Routes are not always one-directional, depending

Formal mercury imports

on supply, demand and prices• Officially available data shows discrepancies

4.5 ACQUISITION OF MERCURY BY GOLDMINERS

between exporting and importing countries &between different entities inside some countries• China and Mexico are the main global mercury
suppliers• In large cities and mining towns, mercury can be• There is a discrepancy between the estimatedpurchased in hardware and mining supply storesmercury use (by taking into account the (estimated)• Mining operation owners or managers buy mercury

ASGM gold production of the country and thefor the mining teammercury to gold ratio used in the region) and formal• Mercury is supplied/sold by gold traders in theimports:mining areasÆ Some countries import more mercury than 		• In Suriname and Guyana, many miners buy mercury

needed for their estimated national goldin larger cities as it is cheaper in the trading hubs

production by ASGM, other countries importless than what is needed for their ASGM
sector, hinting towards:

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Opening the black box: global mercury trade revealed4.6 MERCURY SUPPLY CHAIN & ACTORSINVOLVEDÆ Some gold traders provide mercury to miners• The mercury supply chain is multi-layered includingÆ Traders threaten to not buy gold from miners

for free under the condition that the miners
sell their gold only to them for a reduced pricemercury importers, wholesalers and retailers

who are not also buying mercury from them• The networks are well connected and trade is often✪ Some miners don’t have a choice in who they tradedone in secret, making it difficult to understandwith once inside the trade circle and need to keep

themusing mercury• Gender dynamics within the trade depend on the

4.7 MERCURY PRICES THROUGH THE VALUE
CHAIN

region (e.g. in East Africa, more men are involvedin the mercury trade as they are owners of mines,
while women are usually workers at the mines.

• Mercury gets more expensive in smaller amounts

Depending on the region within the Philippines,
women are known sellers and gold buyers who also

and further down the supply chain (Table 2)burn mercury)• Mercury is generally cheaper in the big trading hubs

• Mercury trading networks are often linked to gold

than in remote mining areas

trading networks, however, mercury trade in itself is• Mercury trade is a profitable business, providing

lucrative and a stand-alone business for some actors

profit on all levels• Many mercury traders are also gold traders,• For the countries where full information on prices

profiting from both trades. This can create a power

through the value chain could be obtained,

imbalance between traders and miners:

importers are making the largest profits (Table 2)

Mercury in smaller quantity as often found at the mining sites© Bram Ebus/InfoAmazonia

Mercury as transported in large flasks© Bram Ebus/InfoAmazonia

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Opening the black box: global mercury trade revealed

VALUE INCREASE FROMCOUNTRY

Bolivia

GuyanaSuriname

Kenya

Tanzania

UgandaBurkina Faso

Philippines

AVERAGE PRICEONE STEP TO THE NEXT

DISTRIBUTION LEVEL(USD/KG)

IN THE VALUE CHAIN

Import10-31

Wholesale

166-217

5-22 fold

Retail200-240

1.1-1.4 fold

Import17.4

Wholesale126

7.2 fold

Retail159-234

1.3-1.8 fold

ImportNA

Wholesale

58-72

Retail100-130

ImportNA

Wholesale

113-148

Retail150-180

ImportNA

Wholesale130-202

Retail150-391

ImportNA

Wholesale

175-202

Retail250-270

ImportNA

Wholesale

NA

Retail170-670

ImportNA

Wholesale

NA

Retail

135-230

1.3-2.2 fold

1-1.5 fold

1-3 fold

1.2-1.5 fold

Table 2: Reported price ranges of mercury bound for ASGM at various
distribution levels in the different focus countries.

4.8 MERCURY EXPORTS• A change in import regulations from one country
immediately affects imports and informal exports in• While some countries seem to have no or negligibleneighboring countries

mercury exports (either formal and informal), othercountries seem to re-export most of the imported

For more details on some of the abovementioned

mercury

topics in the different countries, please see Annex 1.

• Countries with looser regulations on mercury
imports often supply mercury informally toneighboring countries who have stricter importregulations

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Opening the black box: global mercury trade revealed5 ANALYSIS OF FINDINGS
5.1 FACTORS HINDERING THE
UNDERSTANDING OF THE INFORMAL
MERCURY TRADE

that most miners grew up with mercury makes it
difficult to change their perspective on it. As mercury
poisoning often only shows symptoms after years of
exposure, it is often hard for miners to link symptoms

During the research period (2018-2020), various

directly to the use of mercury. Furthermore, manyfactors aggravated the understanding of mercury

cases of mercury poisoning are never officiallytrade and its supply chain. As the official data onrecorded as miners often lack access to basic healthformal global mercury trade is not reliable, it isservices. The cultural factor is therefore, one of the

difficult to draw a base line of formal imports into thereasons why many miners continue to use mercury

different countries. Furthermore, the size and scaleeven after being informed about its negative healthof the ASGM sector in the different countries rely on

effects.

estimates. As most ASGM miners operate informally,
there is no exact data on the number of miners, theThe role of women within mining communities

production of gold or the amounts of mercury used.

varies per region, yet in some of the investigatedBasing estimates of mercury use within a country

countries, women were over-proportionally exposedon estimates of the number of miners creates further

to mercury due to fixed gender roles. Women withinvagueness.

ASGM communities generally do not share equal
ownership of resources and are often not involved in

In addition, the informality of the trade hinders accessdecision making processes (World Bank, 2012). As

to information. A difference in attitude towards

women often occupy secondary roles within mining

interviews along the supply chain was recognized.

communities (e.g. as cooks or service providers)

Generally, miners were open to being interviewed(World Bank, 2012), they are generally not in direct

and explained freely how and where they got

skin contact with mercury through panning. Panningmercury from. The further up in the supply chain,

is often a male’s role, but women are frequently

the more difficult it became to get information. On

exposed to mercury vapor in cases where amalgam

multiple occasions in Bolivia, informants were warned

is burned in residential areas. In addition, womento leave and not ask questions about mercury. Even

are assigned to watch over amalgam burning ingovernment officials advised field agents to leave thesome regions, resulting in the direct inhalation ofarea for their own safety.

mercury vapor. Women are most vulnerable to theeffects of mercury particularly when pregnant. In

5.2 FACTORS CONTRIBUTING TO MERCURY
USE

pregnancy, mercury exposure can have severe
effects on the unborn child. Yet women may be theones in the community that are more receptive to

The continued use of mercury in ASGM is due to araising awareness about the negative health effects

combination of interconnected social, economic,

of mercury.

and political factors. First of all mercury is deeply
embedded in the ASGM tradition. Mercury has been

Another major point related to mercury use isused in the communities for decades as it is easy topoverty. Most ASGM mining takes place informallyuse, readily available and cheap to obtain. The fact

and most miners live in poverty. Miners and their

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Opening the black box: global mercury trade revealedfamilies live from hand-to-mouth and therefore

leaving miners with less income and less money toneed a processing technique that is fast, cheap

invest. Looking at the base level of miners and not

and easy, which is exactly what mercury provides.

connecting them to any other actors in the supply

Operating in informality also means that miners havechain, it is obvious that all these factors combined are

no access to governmental support such as training

causing miners to be stuck in a cycle of continued

or financial support. Poverty and lack of financial

mercury use.

support, prevent miners from working with mercuryfree techniques or leaving the ASGM sector andMarket and supply chain factors are an additional

earning their livelihood elsewhere. Most mercury-free

force driving the continued use of mercury. In somegold processing methods need an initial start-up

cases, there is a power imbalance between miners

investment as they involve expensive equipment.

and gold traders who also often trade with mercury.

In addition, many of these methods take more time

Due to the profits from both trades, traders involved

and require extensive training. For miners that rely

in mercury and gold trade have no incentive toon their daily earnings to live, this is unachievable.

stop the use of mercury. Miners are often caught inThis problem is aggravated as mercury prices haveanother cycle of mercury use as they cannot afford

increased in many countries over the last few years,

to sever ties with the local gold traders. Many miners

Gold panning in Guyana © Bram Ebus/InfoAmazonia

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Opening the black box: global mercury trade revealed5.3 DRIVING FORCES

have to sell their gold locally to traders as mostformal channels for selling gold are inaccessible toindividual miners. These official stations are usually

Generally, mercury trade is a lucrative business on all

located in larger cities and miners do not only use

levels. Information on the price of mercury throughsignificant working time to travel there, but also

the value chain was not available for all countries.

cannot afford to pay the tax placed on the gold. ThisIn the cases where prices on all levels are known

economic gap and the power imbalance between(Bolivia and Guyana), profits are highest for importers.

miners and local gold/mercury traders further widens

From there, profits get smaller, however the trade is

as mercury prices increase.

still lucrative for both wholesalers and retailers. ThisAt the local level, gold traders are the ones that could

is especially true for traders who are also trading withafford investment into mercury-free techniques.

gold. The informal mercury trade follows the opposite

However, as they profit from this lucrative parallel

route to the informal gold trade. Gold is transported

trade of gold and mercury, they have no incentive

from the mining sites via retailers and wholesalers

to do so. Instead, they keep miners in a circuit thatto the trading hubs and finally exported. Mercury isallows them to get a steady supply of gold throughimported, and distributed - via mostly the same routes

the use of mercury.

and actors - to the miners. This double trade adds
profits for actors involved in both trades and attracts
new contacts in both the mercury and gold value
chain. Within the gold trade in particular, markets arecontrolled by “cartel” like structures. These networks
are well established and entering the markets as
a newcomer brings certain risks. As the trade is

The continued use of
mercury in ASGM isdue to a combinationof interconnectedsocial, economic,
and political factors

profitable for many involved actors, there is a driving
force in place that keeps the use of mercury in ASGM
ongoing. These actors do not support the change
to mercury-free mining techniques and create trademechanisms that force miners to keep using mercury.
In these cases, the miners, as end consumers, havelittle impact on the market due to power imbalances
and the poverty they are caught in. Miners that do
not experience the power imbalance often still do
not have a choice as they cannot afford the change
to mercury-free techniques. However, miners, theirfamilies and the surrounding communities areoften the ones that are most negatively affected bymercury.
Generally, there seem to be few obstacles in informal
mercury trade. Mercury entering countries formallyas declared for other purposes such as industry or
dental amalgam, is easily diverted to informal use
in ASGM. Informal imports are rarely checked andseized. Domestic transport goes mostly unhindered.

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Opening the black box: global mercury trade revealed

This lack of risk and hindrance, in combination withthe lucratively of the trade, drives the continued useof mercury.

5.4 MERCURY GOVERNANCE ISSUES
Mercury governance varies greatly between
countries. In some of the investigated countries,
there are no specific laws on mercury. In these cases,
mercury often falls under broader regulations, forexample the ones for hazardous substances or evenunder multiple different frameworks. When there are
restrictions on the import of poisonous substances,
but no mention of mercury on the list that defines
these substance, loop holes and legal windows for
mercury imports open up.
Even in cases with clearer regulations on mercury
trade, imports and use fall under multiple laws
and acts and are often ambiguous and difficult tounderstand. In some cases, governing bodies aretrying to tackle the mercury problem by banning itcompletely from ASGM without any gradual phase

Mining landscape in Guyana © Bram Ebus/InfoAmazonia

out. This approach is driving the mercury trade
further into the black market. The profits made byactors higher in the supply chain are too big to lose

have facilities that are designed for the safe storageand many miners have no other choice than to useof mercury. It was reported for multiple countries,

mercury. Therefore, miners are further criminalizedthat mercury that had been confiscated re-enteredmaking it even harder to break the cycle they are

the market. This might be due to a combination ofcaught in and the mercury market persists.

lack of proper storage facilities which facilitates
the disappearance of seized mercury (as no data

Overall, in most of the countries investigated, there

recording and monitoring systems are in place) and

was a general lack of enforcement concerning

the profit that can be made by re-selling the mercury.

mercury. Informal mercury enters countries easily
and domestic trade goes mostly unhindered. This is

In addition, communication and cooperation

partly due to corruption issues, but also due to thebetween national institutions including ministries

lack of knowledge of custom agencies. Most custom

and customs is lacking. This in turn contributes toagents are trained to search for particular items suchproblems around seized mercury and facilitates

as guns or drugs. Furthermore, many might not be

the return of it to the black market. Looking at aaware of the issues related to mercury and might notregional level, we encountered many cases where

be able to identify mercury. If mercury is seized, there

the stricter regulations on mercury imports in one

is often a lack of knowledge on how to handle andcountry directly affected the imports in neighboring

store it correctly. In addition, many countries do notcountries.

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Opening the black box: global mercury trade revealed6 CONCLUSIONS &RECOMMENDATIONS
6.1 CONCLUSION• f ormalize the ASGM sector accompanied by aregulative framework and monitoring mechanisms

The mercury trade is a lucrative business and many

that include gender responsive legislation/policies

actors profit from it. Networks of informal mercury•c larify laws and regulations concerning mercury

are well established and often linked to the gold

• put yearly quotas for formal mercury imports

trade, operating in a counter direction. At a higher• create a licensing and monitoring scheme forlevel, the trade mainly operates in secret and isdomestic mercury trade (with easy applicationdifficult to access for outsiders. The systems in place

procedures and quick response time)

take advantage of miners and their circumstances• increase enforcement of these regulations

and miners themselves have little power to change• ratify the Minamata Convention

the mercury market. To discourage mercury trade,• increase regional, national and international

regulative frameworks should therefore focus oncooperation

mercury importers and traders rather than miners.
To reduce the power imbalance between miners

6.2 RECOMMENDATIONS

and gold traders and in combination with aformalization of the ASGM sector, governments and

To reduce mercury use in ASGM and tackle the

CSOs should:

informal trade, actions should be taken to address the• r aise awareness of miners and mining communities

mercury trade on multiple levels and from different

about the negative impacts of mercury

angles.

•p
 rovide (gender sensitive) training for correct

The availability of and access to data allow

handling, use and storage of mercury (for the short-

understanding of formal mercury supply and mercury

term)

demand. To increase accuracy of data, we suggest• s trengthen linkages with formal gold andthat governments put efforts into the following:mercury markets• increase monitoring and data recording for formal• improve economic opportunities for miners andmercury imports and exports

their communities (with special attention to women)• make trade data more transparent by reporting

and access to low interest loans

formal gold and mercury imports and exports to• include ASGM miners and their communities (alsointernational trade statistic databaseswith focus on women) in finding other solutions and• assess the informal ASGM sector and create

how to reduce the power imbalance further

better estimates for the number of miners, gold

• support the transition to mercury-free

production and mercury use

technologies with institutionalized, long-term
support byÆ involving ASGM miners in the process of

Mercury governance plays an important role infinding alternative methods that are feasible

addressing the problem. Governments should
therefore:

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Opening the black box: global mercury trade revealedÆ supporting research on most suitable mercuryfree techniques in different regionsÆ continuing to encourage the shift to mercuryfree technologies by incentivizing itÆ providing financing schemes for mining
equipment needed for mercury-free goldÆ i mproving markets for mercury-free goldÆ fascilitating certification schemes for mercuryfree gold
Concerning the informal trade, governments should:• s trengthen border controls through capacity
building by providing training on recognizing
mercury and improve knowledge on handling andstorage• create appropriate, environmentally soundinterim storage facilities for confiscated mercury• i mprove monitoring and data-records on
confiscated mercury to prevent mercury reappearing on markets• increase collaboration between regional, national
and international agencies
To further increase understanding of the mercury
trade, there is need for:• coordination between different projects andinitiatives• implementation of more research focused on:Æ informal mercury trade in other countriesÆ key players up-streamÆ financial flows related to mercury trade

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Opening the black box: global mercury trade revealed

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Opening the black box: global mercury trade revealed• Lucas, D. (2012). Smugglers now control 95% of• S tabroek News. (2018). SARA seeking to curb

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stabroeknews.com/2018/news/guyana/12/24/sara-control-95-of-philippine-gold-trade.net, 15.01.2020

seeking-to-curb-gold-smuggling/, 15.01.2020• Ministerio de Minería y Metalurgía. (2019).

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• U N Comtrade. (2019). Retrieved from https://• Pasha, S., Wenner, M., & Clarke, D. (2017). Toward

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• planetGOLD. (2019). About the programme.

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• World Bank. (2012). Gender dimensions of artisanal

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• World Bank. (2013). Retrieved from Artisanal and• S eccatore, J., Veiga, M., Origliasso, C., Marin, T.,

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Opening the black box: global mercury trade revealed

ANNEXES
Annex 1: Additional information per country
BOLIVIA

Guyana is relatively easy and does not involve any
complicated administrative work. Up until 2019, noMercury, its trade and use are not specifically

restrictions existed upon the amounts that could be

regulated within Bolivia, but standards are in place

imported. Since then, a maximum of 1,000 flasks per

as mercury is a toxic substance. However, theseyear or 34,500 kg per year can be imported. Tradestandards are covered under different regulations andwithin the country is unlicensed and mercury usuallyshow significant gaps. Generally, harmful substances

moves freely. While regulations for trade and storagecannot be imported into Bolivia, however, mercury is

do exist, little enforcement has taken place in the

not on the list of these substances, creating a legal

past; however, efforts to increase compliance checks

window. Mercury use within ASGM is allowed under

have been taken. Regulations concerning the use of

the condition that recovery equipment, such as

mercury in ASGM also exist and include health risk

retorts, are used. Gold extraction within the country

mitigations such as burning of amalgam in open air

has quadrupled in the last nine years. While large

only and the use of retorts to recover mercury.

mining companies were the main producers in thepast, the cooperative sector is the responsible for

Calculations from the regional report of Guyana on

most extracted gold in the recent years. Most miners

the amounts of mercury used to recover gold havefrom cooperatives in Bolivia seem to be aware ofyielded ratios of 2.01:1 to 2.71:1 for the period 2008

the toxicity of mercury. However, the exact impact

to 2015. These are in line with previously publishedand the scale of toxicity might not be clear to many

ratios, e.g. 3:1 (Legg et al., 2015). However, Legg etminers. In addition, many do not know of or haveal. (2015) mentioned that mercury to gold ratios haveany other forms of concentrating gold and therefore

increased over the last years and were as low as 1.5:1

keep using mercury. Some miners use mitigatingin 2008.

mechanisms, such as retorts. Retorts reduce
inhalation while burning and recover mercury that

Most interviewed miners reported that they purchasewould otherwise be released into the environment.

mercury in Georgetown.

Nevertheless, small producers in particular find the

SURINAME

recycling of mercury not efficient enough and would
rather buy larger quantities. Other miners do notseem to know much about recycling and the possible

While Suriname has placed restrictions on the importmitigation of health effects. In addition, minersof mercury, few regulations exist concerning thementioned their interest in mercury free techniques

trade, use and export of the mineral. For imports,

as long as they are affordable.

a special license has been necessary since 2003,
however, no such license has ever been issued andGUYANAno formal imports have been registered since 2014.
This implies that all mercury entering the country is

Regulations concerning mercury fall under several

informally traded.

laws and regulations. Importing mercury into

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Opening the black box: global mercury trade revealedOther than this regulation, no legal instrumentof miners about mercury and its health effects has

specifically mentions mercury. However, as mercury

improved very little in the last few years (Duijves &is not entering the country formally, domestic trade

Heemskerk, 2014).

and use in ASGM can also be seen as informal.

EAST AFRICA
Nonetheless, nearly all miners in Suriname (97.8%)
use mercury and there are no regular controls on

The policy frameworks concerning mercury in Kenya,

either possession or use of mercury. Within the

Tanzania and Uganda are generally broad based andmining community, the equipment owner or site

cut across multiple sectors. Mercury imports in all

manager decided how much and at which stage

three countries are allowed, but bound to clearance

mercury is used and how to burn the amalgam.

protocols for mercury imports associated with certain

Commonly it is also the mine owner or manager

industries such as ASGM, agriculture and cosmetics.

who buys mercury for the mining team. As mercury

The regulations on mercury use in ASGM within theis a lot cheaper in the city, most mercury is bought

different countries are rather difficult to understand.

in Paramaribo by miners or mine managers andMultiple acts include mercury, such as mining acts

transported by themselves to the mining areas. Within

and environmental management acts and many

the city of Paramaribo, mercury is known to be sold inremain ambiguous. In Kenya, the use of mercury in

the neighborhood of “Little Belem” by informal sales

ASGM is not allowed. Tanzania’s most recent Mining

persons who are often cab drivers. Most of the sellers

Act (2018) does not include any information on

are Surinamese nationals. Some Chinese mining

mercury, but the older version included the use of

equipment stores in the same neighborhood are also

retorts while burning amalgam. For Uganda, mercury

said to sell mercury as well as Chinese shops in theuse in ASGM is neither allowed nor restricted, as

mining areas. Some miners also travel to Guyana toartisanal miners are not recognized under the 2003

buy mercury directly. Concerning the amounts of

Mining Act. However, the Mining and Minerals Policy

mercury used, an average mercury to gold ratio ofof 2018 aims towards a formalization of the sector and3.3:1 could be calculated based on interviews withincludes regulations on mercury use.

miners (Heemskerk et al., 2016). From this in turn,mercury emissions for 2018 were estimated to be

There seems to be a balance between miners who

at 56 t mercury per year, with a minimum of 17 t per

are and miners who are not aware of negative healthyear.

effects of mercury. Miners who have worked in
the sector for a long time have probably received

Compared to other counties, gold miners in Suriname

training or participated in some kind of awarenessare aware of the effects of mercury on healthraising initiatives. However, younger miners or new(Heemskerk & Olivieira, 2004; Duijves & Heemkerk,

comers to the sector might be unaware. Similar to2014). More than 80% could name behaviors thatthe situation in other countries, most miners do not

expose oneself to the risk of mercury poisoning andknow of feasible alternatives and some try to mitigate

80% knew that breathing in mercury vapor that gets

negative effects by taking some precautions, e.g.

released while burning the mercury-gold amalgam

burning of the amalgam in open air. Another aspect

is dangerous (Heemskerk & Olivieira, 2004). Fewer

to consider is that working within the ASGM sector

miners however knew about the danger of eating

comes with various risks besides mercury use, e.g.

mercury-polluted fish and handling mercury bare-mining accidents or dust exposure, wherefore the risk

handed. Furthermore, the symptoms of mercury

of mercury poisoning might be seen as neglectablepoisoning were not well known. The knowledge

by some miners.

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Opening the black box: global mercury trade revealed

BURKINA FASO

but rely on personal estimates, which results in large
differences of the amounts of mercury used evenWith the 2015 mining code came a ban of mercury

under the same processing technique. Furthermore,

use in ASGM. However, as the sector has no real

the volumes used depend how easily mercury isalternative, this ban is not realistic at this momentavailable. In areas with a steady supply, miners use

and most miners use mercury to extract gold. The

mercury as early as during the panning stages,

estimates for a gold to mercury ratio for Burkina Faso

whereas mercury is only used during the gold

are in the range of 1.3:1 (Hg:Au) (Persaud and Telmer,

processing stages in areas with a less steady supply.

2015) and most recently calculated as 1.5:1 (Hg:Au)(Kaboré, 2019).

Miners access mercury in different ways. Most miners
report that they get mercury from their financers or

Miners are often not aware of the mercury’s origin.

gold traders. Some of these gold traders also finance

They acquire it from gold traders and gold buying

mining operations and force miners to buy mercury

counters and often the price of gold is linked to theby threatening to stop financing the mines. Other

previous supply of mercury.

gold traders provide miners with mercury for free
under the condition that they only sell the obtained

Within Burkina Faso, there seems to be a certain

gold to the same trader. Another way to accessawareness concerning the negative health effects ofmercury is through mining supply stores, goldsmiths

mercury among miners, however, many miners do not

and private gold buying stations. In most cases,

have an accessible alternative to the use of mercury.

mercury is sold discreetly and only people who knowSome interviewed miners stated that they are using

the sellers will be offered mercury.

measures to reduce the health risks of mercury suchas the usage of masks while burning the mercury-

Miners and mining communities in the Philippines

gold mixture. Nonetheless, this is not always theare often unaware of the negative health impacts

case and many miners handle mercury without anyof mercury. Many miners reported playing withprecautions including the burning of mercury in theirmercury as children and claim not to have any healthhomes.

problems. However, many miners do not have accessto health care, so many mercury- related health issues

PHILIPPINES

probably go undiscovered and are not linked to thechemical by the miners themselves. Those who are

Mercury can be formally imported and used inaware of the toxicity often simply ignore the risks ascertain industries and sectors. Mercury use within

they lack an alternative to mercury use.

the ASGM sector, however, is officially not allowed in
the Philippines. However, the majority of miners use
mercury and amounts used vary greatly dependingon the region and technique used. Depending on
the method chosen, mercury gets used at different
stages of the extraction process and different
quantities of mercury are needed. Due to this, themercury to gold ratio varies significantly with e.g.
10.61 g of mercury for 1 g of gold in Agusan del Sur
to 48.1 g mercury for 1 g of gold in South Cotabato.
Miners often do not measure the amounts of mercury

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Opening the black box: global mercury trade revealed

Mining site in Guyana © Bram Ebus/InfoAmazonia

As the trade is profitable formany involved actors, there
is a driving force in place thatkeeps the use of mercury in
ASGM going