On 1 December 2025, the Chinese Mining Association released two documents to guide mining companies on their environmental, social and governance (ESG) performance.
Though voluntary, they are the first attempt by a Chinese industry body to standardise ESG practices in the Chinese mining sector.
The sector includes some of the world’s largest mining companies, which are widely involved in extracting critical minerals. The environmental and social impacts of these minerals are currently poorly governed. A number of them are central to the global transition away from fossil fuels, due to their use in renewable power equipment and electric vehicles.
The documents, which cover information disclosure and governance capability, could affect Chinese mining companies’ operations both at home and abroad, experts and industry representatives have told Dialogue Earth.
Aligning Chinese and international norms
The first guideline document lays out principles for ESG disclosure, and provides a detailed structure for reporting. It uses a four-tier system of indicators, from broad themes down to 115 granular metrics, to guide companies on what information to disclose and how.
The second offers a way to rate companies’ ESG governance, with scores ranging from C to AAA, creating a benchmark for comparing how well companies manage sustainability.
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The international ESG ratings of Chinese mining companies show weakness – around 80 per cent are rated as industry laggards by agencies, limiting their access to global capital.
Sun Renbin, researcher, China Geological Survey
They were launched by the Chinese Mining Association (CMA) and primarily drafted by the Development Research Center of the China Geological Survey (CGS). According to the documents, which are not yet publicly available, a wide range of voices were consulted during their creation, including government research bodies, leading mining companies, and investors who contributed insights both as stakeholders and as users of ESG data.
Sun Renbin from the CGS is lead contributor to the new standards. He tells Dialogue Earth they were developed in the context of rising ESG requirements both internationally and domestically. He mentions the EU’s 2022 and 2024 directives on sustainability reporting and supply chains, which have made sustainability disclosure mandatory.
“The international ESG ratings of Chinese mining companies show weakness – around 80 per cent are rated as industry laggards by agencies such as MSCI, limiting their access to global capital,” Sun explains, referring to Morgan Stanley Capital International, a leading provider of financial information.
“At the same time, China has rolled out its own national frameworks for sustainability reporting, and mining companies are increasingly expected to adapt,” he says.
Sun notices differences between how Chinese companies and international ratings agencies understand ESG and the frameworks they use to codify it.
Up until now, the most prominent environmental concept that Chinese mining companies have been encouraged to focus on has been “green mines”. In 2017, China issued an implementation plan for green mines, and later provided a detailed scoring framework. The system is primarily environment-focused but does include a limited number of social and governance-related elements, such as indicators on community relations and poverty alleviation. China had established more than 5,100 green mines at the provincial level or above by November 2025, according to Xinhua.
Because of the framework’s environmental focus, it fits poorly with global ESG standards, leading to “the risk of misinterpretation by global rating agencies”, Sun explains. “One of the key motivations behind developing the new standards is to align more closely with international norms.”
Progressive or performative?
Deng Yaowen, an independent ESG consultant, says the CMA’s guidelines are a “very positive development”. He notes that the documents largely align with international ESG frameworks used in mining.
“They appear to cover most of the key material risks people would expect to see, from climate and tailings, to safety and community issues,” he tells Dialogue Earth.
Chen Yu, senior China advisor at Global Witness, tells Dialogue Earth the new guidelines represent China’s first ESG disclosure framework specifically for mining.
“They turn the Ministry of Finance’s national sustainability principles into practical, sector-level guidance,” she says.
“For mining companies, these two sets of standards hold much significance,” says a representative from the ESG office of Zijin, one of the world’s top three multinational metals mining company by market capitalisation. “They … put forward relatively complete framework requirements for ESG information disclosure and governance capabilities.”
Chen highlights the attention the guidelines pay to social issues, which is progressive in the Chinese context. “The standards require companies to promptly disclose major ESG events to all stakeholders, including local communities,” she explains. This goes beyond both the Ministry of Finance’s 2024 Corporate Sustainability Information Disclosure Principles and existing guidance from China’s stock exchanges, she notes.
However, Deng Yaowen says the guidelines’ focus show that many Chinese mining companies are still early in their ESG journey. “The emphasis seems [to be] very much on whether management systems and policies are in place, and on the quality of information disclosure, rather than on evaluating outcomes on the ground,” he says.
He adds that while the standards could provide a foundation for more constructive dialogue with civil society, they “have limits in showing the real-world impacts of mining operations”.
Deng says there is an increasing expectation internationally for mining companies to carry out regular risk-based ESG assessments at the site level, and communicate important findings to key stakeholders, including affected communities and civil society groups. He pointed out that many mining-related ESG risks are long-term and cumulative, and understanding them often requires being on the ground and having genuine conversations with affected stakeholders.
Towards international best practice
Chen adds that the guidelines align closely with the mining standard of the Global Reporting Initiative (GRI). Known as GRI 14, this is considered the world’s leading standard for ESG in the mining sector. However, gaps remain in the Chinese guidelines’ coverage and depth, especially regarding local communities. “GRI 14 requires detailed reporting on both positive and negative impacts on local communities, whereas the Chinese rules do not explicitly distinguish between these,” she explains.
She also notes that while the Chinese rules recommend disclosing community-complaint mechanisms and the frequency of communication, they lack GRI 14’s level of detail. That includes grievance data such as the percentage addressed and resolved, site-level health and safety impacts, and agreements on community development. Chen further highlights the absence of guidance on Indigenous peoples, reflecting China’s cautious use of the term in regulatory and industry contexts.
Zijin’s representative also notes slight discrepancies between the guidelines and international standards relating to differences in context. “While they share common principles such as governance accountability and continuous improvement, differences remain in the practices of certain topics, particularly social issues like human rights and community engagement. This partly reflects differences in [national and economic] development stages, values and cultural contexts between China and the west.”
He adds that the guidelines offer a “clear starting point” for which Chinese mining companies can build their ESG governance and disclosure systems. “However, companies with international operations will need further alignment with international disclosure standards and rating frameworks to meet the expectations of wider stakeholders.”
Going global
Chen Yu says the CMA’s guidelines are notable for addressing Chinese mining companies’ overseas operations, providing clear guidance on reporting local impacts and related actions.
Chinese miners are increasingly expanding into global markets. As of end-2025, Zijin Mining has operations in 15 countries outside of China. Other major players include CMOC Group, the world’s largest producer of cobalt, and Ganfeng Lithium, the world’s third largest lithium producer, with operations in Australia, Argentina and Mexico. Demand for cobalt and lithium, for use in batteries and other electronic and industrial goods, is booming due to energy transitions around the world.
The Zijin representative says that for Chinese companies investing overseas, the guidelines offer a number of benefits. Firstly, they can help companies steer their way through global ESG requirements, which are increasingly important for securing finance and project approvals.
Secondly, they can help companies manage project risks at an early stage. If left unaddressed at the outset, ESG issues can quickly escalate into systematic risks, he emphasises.
Lastly, they will help transform Chinese companies operating overseas from “participants in compliance” to “partners in responsible development”, the representative says.
Further momentum
On 30 December, a third set of guidelines relating to environmental and social impacts was released. This one came from China’s Ministry of Commerce (Mofcom), a central government body with much greater power than the CMA.
The guidelines, which relate specifically to Chinese companies’ overseas operations, break down responsibilities regarding support for economic development, improvement of livelihoods and social cohesion, environmental protection and green transitions, as well as the promotion of “healthy and sustainable development”.
Under the environmental section, the guidelines highlight the need for mining companies to improve environmental protection standards, encourage recycling and low-carbon technologies, and implement ecological restoration.
Global Witness’s Chen Yu sees Mofcom’s guidelines as “a positive signal of a regulatory tendency … ‘testing’ China’s green mining practices overseas”.
She cautions that they lack enforceability, however – a weakness we have seen across Chinese government attempts to strengthen the environmental and social credentials of companies’ overseas operations.
This article was originally published on Dialogue Earth under a Creative Commons licence.
