# Myanmar Conflict Minerals The world's most conflict-entangled jade supply, roughly half the world's heavy rare-earth feedstock, and a tin mine that moves global prices — and **almost none of it falls under any binding conflict-minerals regime on earth.** That gap is the reason this page exists. It is the cleanest available demonstration that the regimes built for the Congo are commodity-shaped and geography-shaped, and that the minerals simply moved. ## The regulatory hole | Regime | Covers Myanmar? | |---|---| | **[[Dodd-Frank Section 1502]]** | **No.** Double exclusion: it covers only 3TG — so jade and rare earths are out entirely — and only 3TG originating in the DRC and nine adjoining countries. **An SEC registrant sourcing tin from a mine controlled by a 30,000-strong armed group in Wa State has no reporting obligation, because the tin is Burmese.** | | **EU Conflict Minerals Regulation** | **Partly.** Also 3TG-only, but geographically global, so **Myanmar tin is in scope** for EU importers. Jade and rare earths are not. | | **[[OECD Due Diligence Guidance]]** | Conceptually yes — mineral- and geography-agnostic. But voluntary, with no enforcement. | | **Sanctions** | This is what actually bites. OFAC designated **MEHL** and **MEC**, the military conglomerates, in March 2021, and **Myanma Gems Enterprise** — which controls all gemstone permitting and sales — on 8 April 2021. The EU listed MEHL and MEC in April 2021 and No. 2 Mining Enterprise in July 2023. | Compounding all of it: **nearly all of both the jade and the rare earths go to China**, which is subject to neither Western regime. > [!warning] There has been no credible official data for eight years > Myanmar joined the Extractive Industries Transparency Initiative in 2014 and was among the first countries to launch a beneficial-ownership register. It was **suspended on 24 February 2021**, days after the coup, and **delisted on 29 February 2024**. The last EITI report covers 2017–18. Every current figure on this page is derived from Chinese customs data, satellite imagery or field reporting. ## Jade Hpakant township in Kachin State is the world's primary jadeite source. [[Global Witness]]'s 2015 report *Jade: Myanmar's "Big State Secret"* is the foundational document — and the source of a number that needs permanent qualification. > [!warning] The $31 billion figure is an upper-bound outlier > Global Witness estimated 2014 jade production at **up to $31 billion**, roughly 48% of Myanmar's GDP. Against that: Myanmar's own **EITI report showed $1.5 billion** in emporium sales; Chinese import data showed $12.8 billion; Global Witness's own alternative calculation using 2014 emporium data gave **$5.64 billion**; Harvard/Proximity estimates ran $8–15 billion; a later recalculation put it at $6.3–6.6 billion. 2014 was also an anomalous base year — a price peak on a volume trough. **Credible alternatives cluster in the $6–15 billion range.** The state received under $374 million officially, whichever denominator you use. The money went to the military conglomerates **MEHL** and **MEC**, to companies tied to the Than Shwe family, and to a set of politically connected firms. Global Witness's 2021 follow-up found jade is also **the largest single source of income for the Kachin Independence Organisation**, and that after the coup the Tatmadaw controls the sector's governance outright. The workforce at the bottom are the ***yemase***, freelance scavengers — perhaps 400,000 across northern Myanmar — who work the tailings dumps of mechanised operations, mostly unregistered internal migrants, which is why the death tolls are never final. Tailings piled hundreds of feet high above rain-filled pits collapse in the monsoon: at least ten failures at Hpakant between 2015 and 2020, the worst in **July 2020 killing roughly 175–200 people**, with further disasters in 2021, 2022, 2023, January 2025 and June 2026. > [!note] Do not say "the KIA captured Hpakant" > It captured the roads and besieged the town. The [[Kachin Independence Army]] took the Namtyar base controlling access in April 2024 and had encircled Hpakant for about a year by mid-2025, but the junta held the town itself, torching mining machinery as it counter-attacked. The rare-earth towns — Chipwi and Pangwa — *were* captured. That distinction is the one most often collapsed in secondary sources. Meanwhile the jade market has crashed. China's 2024 crackdown on border scam centres and tax fraud gutted the Ruili trade; Chinese merchants largely stayed away from the November 2025 emporium; and in February 2026 the junta signed a memorandum with Yunnan officials to hold an exhibition in a Chinese border trade zone — growing dependence on the only buyer left. ## Rare earths — the live story Heavy rare earths, principally **dysprosium and terbium**, are mined in Chipwi and Pangwa townships in Kachin Special Region 1, on the Yunnan border. Mine sites went from about 130 in 2020 to **370-plus by the end of 2024**; Chipwi alone has over 2,500 leaching pits. **Myanmar supplies roughly half the world's heavy rare-earth feedstock**, essentially all of it to China, which holds around 98% of global heavy-REE separation capacity. In the first three quarters of 2025, Myanmar supplied 53% of China's imported rare earths. The extraction method is **in-situ leaching** — drilling boreholes into hillsides and injecting ammonium sulfate solution to dissolve the ore in place. A worker's description: "like injecting medicine into a patient's vein." Thai university testing found extraction-area water samples severely contaminated with radioactive elements and toxic heavy metals, above thresholds that would be enforced inside China. **The method is heavily restricted in China itself. It was offshored across the border into an unregulated conflict zone.** **In October 2024 the [[Kachin Independence Army]] seized Chipwi and Pangwa** from the militia that had run the mines for Chinese operators. China closed the border gates. Terbium rose from about $1,200/kg to over $1,950/kg within weeks; Chinese rare-earth imports from Myanmar fell 89% year-on-year by February 2025. The KIA settled on a fixed levy of 35,000 yuan per tonne plus an in-kind cut, permitted only previously operating companies, and issued no new licences. China's response was to shift sourcing south into United Wa State Army and NDAA territory in Shan State, and into Laos. Myanmar's 2025 rare-earth exports were about $624 million, down roughly $100 million on 2024. The strategic irony is worth stating plainly: **Myanmar has structural indispensability and no leverage**, because it has no domestic separation capacity and one buyer. Western sanctions since 2021 narrowed its options and deepened that dependence. In July 2025 OFAC quietly delisted several Myanmar-linked business figures without explanation, weeks after Min Aung Hlaing wrote to Trump praising his leadership. ## Tin **Man Maw**, in United Wa State Army territory, has historically supplied over 70% of Myanmar's tin, and Myanmar overtook Indonesia to become the world's second-largest producer in 2023. The UWSA suspended mining from **1 August 2023**. Myanmar tin concentrate exports to China collapsed by 77%; LME tin rose from below $30,000/t in April 2025 to over $35,000/t by late August. Permits were reissued in July 2025 and exports have recovered partially — but the workings are flooded, and in **February 2026 Wa authorities imposed a 5% dewatering cost-share on top of the existing 30% tax-in-kind**, bringing the operator burden to about 35%. Full pre-suspension output has not been restored. **A non-state army of 30,000 acting as a systemically important commodity supplier, whose internal decisions move a London exchange** — that is the shape of the problem this whole cluster describes, and no regime touches it. ## See also [[Kachin Independence Army]] · [[Conflict Resources Atlas]] · [[Critical Minerals]] · [[Dodd-Frank Section 1502]] · [[Rare Earth Elements]] · [[Conflict Minerals Hub]]