Brazil's Minerals Law Ties Incentives to Home Value Addition at COP31

A Brazilian lawyer used a COP31 side event on Nov. 14, 2026, to walk through Law 15.506, a framework that ties mineral incentives to value added inside Brazil and gives a national committee oversight of international supply deals. Six speakers from Brazil, Argentina, the U.S., Turkey and Benin made a shared case: producer countries must capture refining, jobs and community benefit, not just ship raw ore. Time ran out before any debate, so none of those claims were tested on the record.

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• Brazil's Law 15.506 links fiscal incentives to domestic value addition and creates a committee to review foreign supply deals.
• Brazil ranks second in rare earth reserves but twelfth in production, the Brazilian Mining Association said.
• Graphite shortfall: Brazil produces 68 kilotons against projected needs of more than 16,000.
• 86% of refining sits in three countries, ORF America said, as it urged issue-based coalitions among nations.
• Globant pitched AI as a trust layer for mineral supply chains and warned that "cloud is a mine."

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Brazil Writes Sovereignty Into Its Minerals Law

The basics: Critical minerals are inputs such as lithium, graphite, copper and rare earths that clean energy, digital and defense technologies depend on. Refining is the "midstream" step between digging ore and making usable materials.

Why it matters: Brazil is testing whether a producer country can use law to keep more mineral value at home without scaring off foreign capital. Other resource-rich nations are watching that balance closely.

Where things stand: Maria Rolim, partner at Rolim Goulart Cardoso, described Law 15.506's main parts:

• A dynamic list of critical minerals that can change over time
• Fiscal and financial incentives tied to value added in Brazil
• A funding mechanism to reduce risk for projects
• A low-carbon certificate
• A committee that approves changes to the framework and controls international supply deals

Rolim said the committee draws on Australian, U.S. and European models. She argued sovereignty in the law means the capacity to choose partners and terms, not closing the door to investment. She also said refining, not mining, is the main bottleneck.

Community terms: Rolim named three priorities for community engagement: informed consultation, shared value for host communities, and water, land and tailings. She added traceability and due diligence, and grievance and remedy systems.

"Social license is essential to explore any raw materials in any way," said Rolim.

Decisions and stakeholder impacts: The panel took no action. For foreign investors and offtake buyers, the committee's control of supply deals adds a review layer, which Rolim framed as a choice rather than exclusion. For host communities, the law's priorities on consultation and remedies set expectations that companies will be measured against. Domestic processors stand to gain most from incentives tied to value added at home.

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Big Reserves, Thin Output: Brazil's Mining Gap

Why it matters: Brazil's industry says the country's geology outpaces its capacity to find, process and deliver minerals the energy transition needs.

Where things stand: Claudia Sales, manager of sustainability at the Brazilian Mining Association, said Brazil produced 1.2 billion tonnes of minerals last year and exported more than 430 million tonnes. She said less than 30% of Brazil's territory is geologically mapped at an appropriate scale.

Sales said rare earths rank second in reserves but twelfth in production. She cited an average of 70 years from prospecting to product and a lack of midstream capacity.

Demand math: A study launched during COP30 projected that copper demand will roughly double for wind, solar and stationary batteries. The graphite gap is starker.

"Graphite nowadays, we only produce 68 kilotons and we will need more than 16,000," said Sales.

Climate footprint: Sales said mining accounts for about 0.5% of Brazil's emissions. She pointed to a new decree setting criteria for critical minerals and to mining's inclusion in Brazil's carbon market and sustainable taxonomy, a classification system for green investment.

Decisions and stakeholder impacts: Sales did not propose a specific policy fix. Her data show that long lead times and weak mapping limit how quickly Brazil can convert reserves into supply. Investors in refining and mineral exploration face the largest openings and the longest timelines.

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Globant: The Cloud Runs on Mines

Why it matters: Data centers and renewable energy compete for the same minerals. Most of those minerals come from the Global South, said Facundo Armas, Global Head of Sustainable Business at Globant.

Where things stand: Armas argued the gap is not a lack of data but a missing "intelligence layer" that connects data that already exists. He described several tools:

• Agentic AI
• Edge AI for mines with poor connectivity
• Early warning systems
• EU deforestation regulation compliance work with a Chilean paper company
• An agentic procurement system for an Argentine energy operator

"That cloud is a mine at the end," said Armas, connecting digital infrastructure to physical extraction.

Trust over license: Armas cited the GeSI SMARTer reports on how information technology can cut emissions in other sectors. He also offered a trust equation: credibility, reliability and intimacy divided by self-orientation. He called for moving from "social license" to "social trust" and mentioned the Antalya AI Pledge. He acknowledged that AI itself consumes resources.

Decisions and stakeholder impacts: Armas argued that transparency tools could shift bargaining power toward producer communities. Exporters facing EU traceability rules are the clearest near-term market for these tools.

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Producer Regions Push for Refining, Not Just Digging

Why it matters: Two speakers argued that concentrated refining and high borrowing costs keep the Global South at the bottom of the value chain.

Where things stand: Piyush Verma, Senior Fellow and Head of Energy and Climate Policy at ORF America, said demand for critical minerals is also driven by semiconductors, data centers and defense. He said demand will double by 2030 and quadruple by 2040.

"86% of the mineral refining is concentrated in top three countries," said Verma.

Verma urged local value creation, component and product manufacturing, and complementary partnerships. He cited a pilot linking India, Brazil, South Africa and Indonesia (IBSA plus Indonesia). He called for interoperable standards across minilaterals, the small issue-based coalitions such as the Quad, BRICS and an Australia-Canada-India grouping. He also raised climate-resilient mining, accountability and traceability standards, offtake demand signals and recycling. He said financing costs run two to three times higher in emerging economies.

West Africa's ask: Ambali Olulade, co-founder and executive director of CASSADE (Centre d'Action pour la Sécurité Alimentaire et le Développement Durable) in Benin, said West Africa is rich in lithium, bauxite, gold and iron ore. He said much of the value from those minerals is created outside the region while many villages lack electricity.

Olulade proposed five priorities:

• Stronger governance and transparency
• Local processing
• Regional infrastructure and energy connectivity
• Opportunities for youth, women and communities
• Environmental protection

He also called for regional cooperation and climate finance, framing the goal as a shift "from extraction to transformation, from dependence to opportunity, and from pit to prosperity."

Decisions and stakeholder impacts: Both speakers put financing and processing capacity at the center. For lenders and development finance institutions, the two-to-three-times cost gap Verma cited is the lever. For West African communities, Olulade tied the stakes directly to jobs and electricity access.

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A Turkish Exporter Prepares for Europe's Carbon Border

The basics: CBAM, the EU's Carbon Border Adjustment Mechanism, requires importers of certain goods, including steel products, to report and pay for embedded carbon emissions.

Why it matters: Suppliers in countries that sell into the EU are rebuilding their operations around European carbon rules.

Where things stand: Izel Çelik, Sustainability Manager at Şimşek Ambalaj, described the İzmir-based metal packaging maker. Exports account for 45% of its sales. A board-led sustainability committee oversees three working groups.

Çelik cited the company's credentials:

• GreenCheck Gold
• ISO 50001 energy management certification
• Verified greenhouse gas inventories
• ISO 14046 water footprint assessments
• An improved EcoVadis score

She described the company's CBAM experience supporting European customers and a product carbon footprint project.

"In 2024, 95% of our procurement budget went to local suppliers," said Çelik.

She framed metal packaging as recyclable and showed soil exposure samples.

Decisions and stakeholder impacts: The case shows how CBAM pushes reporting duties down to mid-sized exporters. Companies with verified emissions data are better positioned to keep European buyers.

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Minor Items

• Article 6 initiative launched: Alexandra Darms, lead journalist and moderator for Responding to Climate Change (RTCC), announced the RTCC Article 6 for Peace and Resilience initiative. Article 6 is the Paris Agreement's carbon cooperation provision, and Darms said more than 120 million forcibly displaced people are excluded from its design, benefits and governance.
• IEA outlook cited: Darms cited the International Energy Agency's July 2026 critical minerals outlook, which reports investment fell 9% in 2025 and refining remains concentrated.
• No debate held: "Unfortunately, we don't have any time for panel discussion or questions," said Darms, closing the session.

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Looking Ahead

No resolutions or commitments came out of the session. The open questions are whether producer countries can finance refining at emerging-market borrowing costs, and whether Brazil's committee model attracts investors or slows deals.