Graphite Mining Tanzania: Which Licence Fits, the 16% State Stake, 3% Royalty, Concentrate Exports and the Projects Moving in 2026

Graphite mining in Tanzania runs under the Mainland Mining Act, Cap. 123, its regulations and project framework agreements with the Government. This guide covers each licence, the ownership and royalty rules, exports of concentrate, the projects that signed in 2026 and a costed export shipment.

What the law says about graphite mining in Tanzania

Tanzania has no graphite statute. Six instruments carry a graphite project from exploration to the port.

• The Mining Act, Cap. 123. We read the Mining Act on TanzLII, revised to 30 November 2019. Section 2 says "This Act shall apply to Tanzania Mainland." It sets the licence classes, state participation, royalty and the inspection fee.
• Graphite in the definitions. Section 4 lists graphite as a non-metallic mineral under "Mineral Concentrate". It does not list graphite among "industrial minerals", which the Act limits to phosphate, kaolin, lime, gypsum and similar minerals.
• The mineral rights rules. The Mining (Mineral Rights) Regulations, 2018, GN 1 of 2018, set the forms, area limits and fees, with the fee schedule substituted by GN 47 of 2018.
• The sovereignty statute. Section 9 of the Natural Wealth and Resources (Permanent Sovereignty) Act, 2017 requires resource agreements to ensure no raw resources are exported for beneficiation abroad.
• Value addition. The Mining (Value Addition) Regulations, 2020, GN 687 of 2020, govern what may leave the country. Their text sits behind a TanzLII subscription, and we could not read it.
• State participation. The Mining (State Participation) Regulations, 2022, GN 574 of 2022, carry the template framework agreement each investor signs with the Treasury Registrar.

On numbering: the Act was reissued as Cap. 123 R.E. 2023. We cite the 2019 section numbers we read. Zatra's fee register gives the R.E. 2023 numbers for royalty (section 111, formerly 87) and the inspection fee (section 115, formerly 90A).

Who should read this

• Foreign explorers holding or buying graphite prospecting licences in Lindi, Morogoro, Tanga, Manyara or Mtwara.
• Developers moving from feasibility to a mining licence or special mining licence and negotiating a framework agreement.
• Offtakers, traders and anode makers buying Tanzanian flake concentrate who need to know who may lawfully ship it.
• Tanzanian citizens and companies with small graphite claims, or supplying services to graphite mines.

This guide is the graphite layer. For the general licence rules, read our mining licence guide and prospecting licence guide. For battery metals as a group, see our note on copper, nickel and battery metals.

Which licence suits a graphite project?

Licence choice turns on scale and on who owns the company. The capital bands come from section 4 of the 2019 text. Fees are from the Zatra fee register at 26 September 2026 and are paid to the Mining Commission against a GePG control number.

Two points need confirming for graphite specifically. First, the rent class: the register charges USD 3,000 a km2 for metallic and energy minerals and USD 2,000 for building and industrial minerals. Second, the prospecting expenditure class: USD 100 a km2 for industrial minerals against USD 500 for most minerals (F0618). The Act does not place graphite in the industrial group, so ask the Commission which class it applies before you budget.

Most graphite projects start as a prospecting licence and convert. Section 39 makes the holder an "entitled applicant" over its own area. A foreign investor cannot hold a PML, so a small-scale route runs through a citizen partner on documented terms, or through conversion of PMLs into a mining licence under section 58.

How much of a graphite company must Tanzanians or the Government own?

Four separate rules apply, and they are often confused.

• The Government's free carried interest. Section 10(1) gives the Government "not less than sixteen percent non-dilutable free carried interest shares" in a mining company under a mining licence or special mining licence. Under section 10(2) it may acquire up to 50% in total, commensurate with tax expenditures granted to the company.
• The framework agreement. Clyde & Co wrote on 19 November 2024 that the template agreement sits in GN 574 of 2022. It said the mining licence is not issued until the framework agreement is signed, and that some projects have gone to 20%.
• Indigenous equity. Breakthrough Attorneys reported in February 2019 that regulation 8(2) of the Mining (Local Content) Regulations requires a non-indigenous mining licence applicant to have at least 5% equity held by an indigenous Tanzanian company.
• Dealers. A company that buys and exports graphite it did not mine needs a dealer licence with at least 25% Tanzanian participation, under section 73(3) and register line F0622.

Clyde & Co's October 2022 summary of GN 574 of 2022 adds that the state's shares carry dividends once distributable profit arises and that the Government pays no cash on later capital increases. Model the 16% in the cap table and the lender's base case.

The graphite deals of the last five years follow the floor. Black Rock Mining's Faru Graphite Corporation, EcoGraf's Duma TanzGraphite and Lindi Jumbo's Ndovu Graphite Limited each carry a 16% state stake. The Morogoro deal with Yudi in August 2026 set 17%. TanzaniaInvest reported on 17 December 2021 that Black Rock was relieved of requirements to issue 5% of its stock to local interests and to list 30% on the Dar es Salaam Stock Exchange. Treat any such exemption as negotiated, not automatic.

What royalty and fees does graphite pay?

Section 87(1) of the 2019 text sets royalty by mineral group. Graphite is not uranium, a gemstone, a metallic mineral or a gem, so it falls in paragraph (e): "other minerals", at three per centum. The Zatra fee register states the same 3% for other minerals (F0624). An independent Bridge Street Capital Partners note on the Chilalo project, January 2022, modelled a 4% state take, which matches 3% royalty plus the 1% inspection fee.

Section 66 adds a surcharge on royalty unpaid after 90 days: 50% for a company. Corporate income tax at 30% and withholding on dividends sit on top. A dealer that exports graphite it bought pays a "payment in lieu of royalty" under section 88 at the same 3%. Our mineral royalty and inspection fee guide explains the ministerial review of double charging ordered on 4 October 2026.

Can graphite concentrate be exported from Tanzania?

Yes, in practice, with conditions. The law and the record point in different directions, so read the layers in order.

• The sovereignty rule. Section 9 of the Permanent Sovereignty Act bars resource agreements that allow raw resources to be exported for beneficiation abroad. The Mining Act defines raw minerals as those "not yet processed, beneficiated or value added".
• The 2020 graphite rule. Mining Weekly reported on 15 September 2020 that regulations on graphite concentrate exports required a minimum of 65% total graphitic carbon, with royalties due on exports. They revoked the 2019 Mining Guidelines. The timing fits GN 687 of 2020, which we could not read.
• Exports are happening. Mining Weekly reported on 26 July 2024 that Lindi Jumbo completed its first concentrate consignment to Dar es Salaam for the trader Wogen, part of an order for a European customer.
• The licensing condition. The Guardian reported on 1 May 2024 that Minister Anthony Mavunde told Parliament no mining licence or special mining licence would be issued to an investor without a strategic plan for adding value.
• The framework agreement. Clyde & Co wrote in November 2024 that a beneficiation facility suited to the mineral is generally mandatory, though some minerals may be exempted.

Flake concentrate at 94% to 96% carbon clears the reported 65% floor by a wide margin. The open question is how far the Government will push value addition beyond concentrate. EcoGraf's half-year report of 10 March 2026 describes a planned plant at Ifakara to turn flake into spherical graphite for export. A purification or spherical graphite plant needs a processing licence (F0631); see our mineral processing licence guide.

Every shipment needs its own Mining Commission export permit, issued after weighing, valuation, payment and sealing. Concentrates also fall under TASAC's exclusive clearance mandate under GN 184 of 2025, as our mineral export permit guide explains.

What do local content, CSR and the EIA add?

Three obligations travel with every graphite mining licence. Each has its own regulator file and its own calendar.

The EIA is the long pole. A mine is a Type A extractive project, and the National Environment Management Council review fee scales with project cost, from TZS 5 million below TZS 1 billion to TZS 100 million above TZS 500 billion (F0498). Section 50(1)(g) of the Mining Act lists an environmental certificate as a condition of grant.

Real numbers show the scale. The Guardian reported on 31 May 2026 that Lindi Jumbo spent TZS 57.5 billion with local suppliers in 2024 and 2025, 91% of procurement. It reported more than TZS 162 million allocated to CSR.

How does the Mining Commission process work for graphite?

The Mining Commission grants and polices mineral rights. Applications run on the Online Mining Cadastre Transactional Portal. The sequence for a foreign-owned graphite developer:

1. Company. Incorporate a Tanzanian company with a local address, then obtain a TIN.
2. Prospecting licence. Search the cadastre map, apply, pay against control numbers and meet the yearly expenditure and reporting duties.
3. Feasibility and EIA. Define the resource, register the EIA early and prepare local content, procurement and training plans.
4. Framework agreement. Negotiate with the Government team and the Treasury Registrar, including the free carried interest and the value-addition plan.
5. Licence grant. File Form MRF.3 for a mining licence or special mining licence; an SML also goes to Cabinet under section 42.
6. Operations. Start within 18 months (s.52 for an ML, s.47 for an SML), pay rent yearly, file reports, and seek an export permit for each shipment.

Licences can be lost. Section 63 lets the Commission suspend or cancel after a default notice and 30 days to remedy. Mining Weekly reported on 3 August 2026 that the Ministry cancelled Volt's Bunyu graphite licences, ML 591/2018 and ML 592/2018, and that Volt was weighing an appeal. Section 65(1) of the 2019 text allows judicial review within 60 days. A default notice or cancellation goes to an advocate the day it arrives; see our guide to appealing a licence refusal or revocation.

Which graphite projects are moving, and what did the Government sign?

The Guardian reported on 17 August 2026 that Tanzania produces about 75,000 tonnes of graphite a year from two operating projects, with 27 others yet to start. The status below is as reported by the sources linked; confirm each before relying on it.

Sources for the table:

• TanzaniaInvest on the Epanko framework agreement, 18 April 2023.
• TanzaniaInvest on the Epanko SML, 6 March 2025.
• TanzaniaInvest on Chilalo, 18 April 2023.
• The Citizen on Lindi Jumbo, 1 June 2026.
• TanzaniaInvest on the STAMICO deal, 5 April 2026.
• TanzaniaInvest on the December 2025 State House meeting.

Two cautions. Black Rock's shares were suspended on the ASX in 2025 after it could not disclose the status of the Mahenge SML, TipRanks reported. And STAMICO's own graphite packages are partnership offers on licences it holds; see our STAMICO joint venture guide.

Does the Mining Act apply to graphite in Zanzibar?

No. Section 2 limits the Mining Act to Tanzania Mainland. Every licence, fee and permit in this guide is a Mainland instrument, and the known graphite deposits are on the Mainland.

The Citizen reported on 28 November 2024 that Zanzibar was preparing its own mining law. We could not confirm enactment. Routing Mainland concentrate through a Zanzibar port does not avoid the Mining Commission's permit.

Worked example: exporting 2,000 tonnes of graphite concentrate

This example is hypothetical. A Tanzanian mining licence holder, 84% foreign-owned and 16% held by the Government, ships 2,000 tonnes of flake concentrate at 94% carbon. We assume a free-on-board price of USD 700 a tonne, so gross value of USD 1,400,000. We use TZS 2,450 to the dollar for illustration; the rate on the control number governs.

• Share of value: Commission charges come to 4.1% of gross value, and 5.8% with TASAC clearing.
• Council: the 0.25% service levy on this turnover adds USD 3,500 (TZS 8,575,000), paid to the council on its own cycle (F0630).
• Not a fee: the Government's 16% is a share of dividends. On USD 5 million of distributable profit it takes at least USD 800,000.
• Unknown: any NEMC per-tonne fee on graphite (NEW-05-04 prints no graphite rate). Ask NEMC before you close the budget.
• A trader instead: a dealer exporting bought concentrate pays the same royalty in lieu, plus a dealer licence of USD 200 to apply and USD 500 a year if graphite sits in the coal and industrial minerals class (F0622).

Zatra's professional fee for the export file is quoted separately and is never added to these government charges.

What to do now

1. Fix the scale. Size planned capital against the ML and SML bands and choose the licence path from your prospecting area.
2. Build the cap table. Model the 16% free carried interest, any indigenous equity and lender security before you sign term sheets.
3. Confirm the mineral class. Ask the Commission in writing which rent, expenditure and dealer class it applies to graphite.
4. Write the value-addition plan. Set out the concentrate grade, any purification or spherical graphite stage, and the timetable.
5. Start the EIA early. Register the project with NEMC as soon as the footprint and resettlement area are known.
6. Prepare the framework agreement. Brief the negotiating team on the financial model, dividends, offshore accounts and dispute resolution.
7. Plan each shipment. Book weighing, valuation and sealing, pay control numbers, and line up TASAC before freight.
8. Route trouble to an advocate. Default notices, cancellations, valuation disputes and seizures need legal advice before any reply.

Key dates

Royalty and levy rates change by Act of Parliament, usually from 1 July.

How Zatra helps

Zatra's sector business permits service prepares prospecting and mining licence files, local content and CSR plans, and export permit packs for graphite projects. Our investment due diligence service checks licence title, rent, royalty and state participation records for buyers and lenders. See our Tanzania mining page, the government fees handbook and pricing.

Two cost buckets stay separate. Royalty, the inspection fee, levies, rent and permit fees are paid by the client to each authority at the official rate against its control number. Zatra's professional fee is quoted on its own and never marked up onto them.

The Mining Commission, the Ministry, NEMC, TRA and TASAC make every decision. Zatra prepares and coordinates the file; it does not decide or guarantee any authority's outcome. Framework agreement negotiation, licence cancellations, disputes, seizures and formal legal opinions go to the advocate on our team.

Sources and status

Accurate as at 26 October 2026. Section numbers are from the 2019 text of the Act unless marked R.E. 2023. Fees are from the Zatra fee register at 26 September 2026.

• Mining Act, Cap. 123: TanzLII, text as at 30 Nov 2019.
• Mining (Mineral Rights) Regulations, GN 1 of 2018: TanzLII, 10 Jan 2018.
• Permanent Sovereignty Act, 2017: TanzLII, as amended to 2021.
• Mining (Value Addition) Regulations, GN 687 of 2020: TanzLII, 28 Aug 2020, record only.
• Mining Commission and cadastre portal: official sites, live Oct 2026.
• National Environment Management Council: official site, live Oct 2026.
• Mining framework agreement: Clyde & Co, 19 Nov 2024.
• State Participation Regulations 2022: Clyde & Co, 3 Oct 2022.
• Mining local content regulations: Breakthrough Attorneys, 28 Feb 2019.
• Graphite export rules: Mining Weekly, 15 Sep 2020.
• First Lindi Jumbo shipment: Mining Weekly, 26 Jul 2024.
• Bunyu licences cancelled: Mining Weekly, 3 Aug 2026.
• Value-addition plans for licences: The Guardian, 1 May 2024.
• Lindi Jumbo state participation: The Guardian, 31 May 2026.
• TZS 266 billion graphite deal: The Guardian, 17 Aug 2026.
• Government 16% in Lindi Jumbo: The Citizen, 1 Jun 2026.
• Faru Graphite Corporation, Epanko framework agreement, Epanko SML, Chilalo, Mirerani graphite and State House meeting: TanzaniaInvest, 17 Dec 2021 to 9 Dec 2025.
• Black Rock ASX suspension: TipRanks, updated 22 Apr 2025.
• Chilalo research note: Bridge Street Capital Partners, Jan 2022.
• Zanzibar mining law: The Citizen, 28 Nov 2024.
• Zatra fee register lines F0241, F0343, F0390, F0498, F0615 to F0626, F0628, F0630, F0631 and NEW-05-04: fees at 26 Sep 2026. Accessed 26 Oct 2026, as were all sources above.

Figures to confirm before you act

• Mineral class: whether the Commission applies the metallic and energy or the industrial class to graphite for rent, prospecting expenditure and the dealer licence
• Export grade: the current minimum carbon content for graphite exports under GN 687 of 2020, reported in 2020 as 65%
• Value-addition terms: what the Government now requires beyond concentrate in a new framework agreement
• Indigenous equity: whether the 5% rule in regulation 8(2) of the local content rules still applies to mining licence applicants
• NEMC fee: any per-tonne environmental fee on graphite production
• R.E. 2023 numbering: current numbers for ss.8, 10, 39, 42, 63, 65, 73 and 88; we read the 2019 text
• Project status: licence and funding status of Mahenge, Nachu and Bunyu, which moved during 2025 and 2026
• Worked example inputs: USD 700 a tonne and TZS 2,450 to the dollar are assumptions, not quotes

This article is general information based on official sources available at the date of publication. It is not legal, tax or financial advice. Laws and notices change. Verify with the issuing authority or consult Zatra before acting.