Gold mining formalisation must not legitimise environmental destruction – CLGB

The Chamber of Licensed Gold Buyers (CLGB) has urged the government to adopt a conditional and evidence-based approach to formalising Ghana’s artisanal and small-scale mining (ASM) sector, warning against granting legitimacy to operations that cause environmental destruction.

The Chamber says the GoldBod-led formalisation programme presents an opportunity to address longstanding challenges in the sector through an accessible, transparent and enforceable regulatory framework.

However, in a policy statement, it stressed that government must distinguish between mining operations that can be conducted lawfully and responsibly and those that threaten water bodies, forests, agricultural lands and public health.

The position follows reported comments by GoldBod Chief Executive Officer, Sammy Gyamfi, concerning mining operators whose activities do not interfere with water bodies.

While acknowledging the importance of protecting livelihoods in mining communities, the CLGB cautioned that the absence of direct interference with rivers should not automatically qualify an operation for formalisation.

It argued that mining activities could still cause environmental damage through land degradation, contaminated runoff, unsafe processing and other practices, even when operations are not taking place directly within water bodies.

“Not polluting a water body is a necessary consideration, not a complete test of legality, environmental responsibility or suitability for formalisation,” the statement said.

The Chamber is proposing comprehensive, site-specific assessments before operators are granted approval to mine. These should cover mineral rights, lawful access to land, proximity to protected areas and critical water sources, biodiversity protection, worker safety, responsible processing methods and rehabilitation plans.

The CLGB has outlined five principles it believes should guide the government's formalisation programme.

The first is the establishment of clear eligibility criteria, including non-negotiable exclusions for protected areas, prohibited river zones and other environmentally sensitive locations.

Second, it wants accessible and affordable licensing procedures, with decentralised processes where possible, to enable small-scale operators to obtain permits and lawful access to mineralised land.

The third principle is a compliance framework that combines regulatory obligations with environmental and safety training, technical support, access to appropriate equipment and financing, and rehabilitation arrangements.

On gold trading, the Chamber says GoldBod, regulators, miners and licensed buyers must establish a reliable chain of custody to ensure that gold can be traced from approved mining sites to the point of sale.

It says licensed buyers must conduct due diligence, maintain transaction records, ensure transparent weighing and assaying, and reject gold from prohibited or unverifiable sources.

The fifth principle focuses on independent monitoring and enforcement through regular site inspections, corrective-action procedures and sanctions for serious or repeated violations.

The Chamber maintains that formal status should be earned and continuously maintained rather than granted once as permanent authorisation.

Beyond environmental protection, the Chamber says the formalisation agenda must reflect the economic and social realities of mining communities.

It notes that artisanal and small-scale mining supports household incomes, local businesses and livelihoods in several communities, making it important for government to involve miners, traditional authorities, landholders, local authorities, women and young people in the process.

The statement warns that expensive or inaccessible licensing systems, particularly those disconnected from viable mineral deposits, could push operators further into informality.

It also cautions against placing the entire cost of compliance on small-scale miners without providing the technical and financial assistance needed to meet regulatory requirements.

The Chamber is therefore urging government to assess the programme beyond the number of miners registered or permits issued.

It wants performance indicators to include miners' net earnings, compliance costs, formal gold sales, access to legitimate financing, local employment, environmental remediation and women's participation.

The CLGB is also advocating the use of technology to strengthen monitoring and accountability in the sector.

It says geospatial mapping, digital registration, production records, satellite monitoring and transparent digital weighing and assaying systems could improve traceability and help identify illegal mining activities.

However, it cautions that technology alone cannot guarantee responsible mining without effective institutions, credible inspections and independent oversight.

Drawing lessons from Mongolia, Peru and Tanzania, the Chamber says Ghana should adopt a sustained formalisation programme that combines simplified licensing with technical support, miners' participation and consistent enforcement.

It argues that international experiences show that registration is only the beginning, with operators requiring continued assistance to meet environmental, labour and production standards.

To translate its proposals into action, the CLGB has recommended a six-stage implementation model involving government, the Minerals Commission and GoldBod.

The proposed framework begins with mapping existing mining activities, environmentally sensitive areas, water sources, land rights and community interests.

This would be followed by accessible registration and screening to determine which operators and sites meet the required legal, environmental and safety standards.

Eligible sites would then receive conditional and time-bound authorisations, with clearly defined operating boundaries, production records, environmental safeguards and rehabilitation obligations.

The remaining stages would involve supporting operators to meet compliance requirements, verifying their activities through regular inspections and monitoring, and periodically reviewing the programme against independently assessed performance indicators.

In its concluding remarks, the Chamber said Ghana's mining policy should not create a false choice between environmental protection and safeguarding livelihoods.

It called for a lawful pathway for responsible small-scale miners while insisting that operations in protected areas or those causing serious environmental damage must be stopped.

“The policy choice is not between gold and clean water, nor between livelihoods and the law. Ghana’s task is to secure all three: lawful livelihoods, responsible production and protected natural resources,” the statement said.

The CLGB believes the GoldBod-led initiative could strengthen the integrity of Ghana's gold supply, improve traceability, reduce smuggling and illicit financial flows, and increase public revenue if supported by transparent market arrangements and consistent regulatory enforcement.

It cautioned, however, that the number of miners registered, permits issued or gold purchased should not, on their own, be treated as evidence of success.

The Chamber said formalisation would only achieve its objectives if legal compliance was accessible, environmental responsibility independently verified, economic benefits fairly distributed and violations met with appropriate sanctions.