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Mining Plan 2050 and the Basic Framework
for Sustainable Brazilian Mining, which were
approved by the Ministry of Mines and Energy in
2026, and incorporate social and environmental
responsibility, governance and decent work into
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the sector’s planning. These instruments show
that increasing the supply of critical minerals alone
is not sufficient for the energy transition; such
expansion must take place on an environmentally
responsible and socially just basis.

In this sense, the legitimacy of the transition
depends not only on the emissions avoided by
the final product, but also on how the minerals
it requires are extracted and processed. Mining
sustainability should therefore be treated as a
prerequisite for decarbonisation, rather than as an
expected consequence of its expansion. Without a
responsible mineral supply chain, energy may be
cleaner in use, but not necessarily at its source.

1 Energy Research Office (EPE). Report on Critical and
Strategic Minerals for the Energy Transition. Rio de Janeiro:
Energy Research Office, 2025. Available at: https://www.epe.
gov.br/sites-pt/publicacoes-dados-abertos/publicacoes/
PublicacoesArquivos/publicacao-877/Caderno_Minerais_
English.pdf
2 International Energy Agency (IEA). The Role of Critical
Minerals in Clean Energy Transitions. Paris: International
Energy Agency, 2021. Available at: https://www.iea.org/
reports/the-role-of-critical-minerals-in-clean-energy-
supports it. Ignoring this dimension can give rise transitions
to greenwashing, in which the positive narrative 3 The world’s three largest producers account for more
surrounding the final product - the technology than two-thirds of global production of cobalt, lithium and
nickel, and for almost 90 per cent of rare-earth elements
enabling the energy transition - obscures the
production; this concentration exposes supply chains to
environmental and social impacts of extracting additional geopolitical, commercial and environmental
and processing raw materials. risks (OECD, 2026). Available at: https://www.oecd.org/en/
topics/sustainable-mining-for-development.html
4 BRAZIL. Ministry of Finance. Action Plan for the Brazilian
Recent regulatory initiatives are beginning to
Sustainable Taxonomy (TSB). Brasília, 2025. Available at:
reflect this understanding. In Brazil, for example, https://www.gov.br/fazenda/pt-br/orgaos/spe/taxonomia-
the Brazilian Sustainable Taxonomy includes the sustentavel-brasileira/audiencias/plano-de-acao-da-tsb
extractive sector within its scope, recognising the 5 Ministry of Mines and Energy. Ministerial Ordinances Nos. 924
and 925. Approve the National Mining Plan 2050 (PNM 2050)
structural role of critical minerals in the low-carbon
and establish the Basic Framework for Sustainable Brazilian
economy and requiring related activities to meet Mining. Official Gazette, Brasília, 2026. Available at: https://
4
specific criteria to be considered sustainable. www.gov.br/mme/pt-br/assuntos/secretarias/geologia-
mineracao-e-transformacao-mineral/pnm-2050
A similar rationale underpins the National
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