๐Ÿ‡จ๐Ÿ‡ซJurisdiction Guide

Your customer or buyer is asking about supply chain exposure to the Central African Republic. Here is what the regulatory environment requires.

The Central African Republic (CAR) is one of the world's poorest and most conflict-affected countries. It has significant mineral resources โ€” diamonds, gold, uranium, and timber โ€” but ongoing armed conflict has made formal economic activity extremely difficult. The country has been classified as a conflict-affected and high-risk area under the OECD Due Diligence Guidance since 2013. The Kimberley Process suspended CAR diamond exports in 2013 due to conflict financing concerns, partially lifting the ban in 2015 for a limited number of compliant zones. Russian Wagner Group (now Africa Corps) forces have been present in CAR since 2018, raising additional human rights concerns. Any supply chain exposure to CAR requires the highest level of ESG due diligence.

Key regulations in Central African Republic โ€” ESG Supplier Guide

Kimberley Process โ€” Diamond Export Restrictions

In Force
CAR diamond exports suspended by KPCS in 2013. Partial lifting for compliant zones from 2015. Significant restrictions remain.

The Central African Republic's diamond exports were suspended by the Kimberley Process Certification Scheme (KPCS) in 2013 following the Sรฉlรฉka coup and evidence of conflict diamond financing. A partial lifting of the ban in 2015 allowed exports from a limited number of 'compliant zones' under enhanced monitoring. However, significant KPCS restrictions remain. EU jewellery and luxury goods companies sourcing CAR diamonds face the highest level of ESG scrutiny โ€” KPCS compliance is a minimum requirement, not a sufficient standard.

EU CSDDD โ€” Enhanced Due Diligence for Conflict-Affected Areas

Upcoming
CSDDD transposition deadline: July 26, 2028. CAR qualifies as a conflict-affected and high-risk area requiring enhanced due diligence.

CAR is classified as a conflict-affected and high-risk area under EU CSDDD. EU companies with any supply chain exposure to CAR must conduct enhanced human rights and environmental due diligence. Key ESG risks include: conflict financing through mineral revenues, human rights abuses by armed groups and Russian Wagner/Africa Corps forces, forced labour, sexual violence, and environmental damage from artisanal mining.

OECD Due Diligence Guidance โ€” Conflict Minerals

In Force
OECD Due Diligence Guidance applies to all minerals from CAR. CAR is a designated conflict-affected and high-risk area.

All minerals from CAR โ€” including diamonds, gold, and uranium โ€” require enhanced due diligence under the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Companies sourcing from CAR must conduct a conflict analysis, identify and assess risks, and implement risk mitigation measures. In practice, most responsible companies avoid sourcing from CAR entirely.

EU EUDR โ€” Timber

Upcoming
EUDR applies to large EU operators from December 30, 2026.

CAR has significant tropical timber resources. EU importers of CAR timber must demonstrate deforestation-free sourcing. Given the conflict context and governance challenges, EUDR compliance for CAR timber is extremely difficult to verify. Most EU timber importers avoid CAR timber entirely.

What this means for you as a supplier

CAR is one of the highest-risk jurisdictions globally for supply chain ESG compliance. Diamond exports face KPCS restrictions. All mineral sourcing from CAR requires enhanced OECD and CSDDD due diligence. In practice, most responsible EU buyers avoid sourcing from CAR entirely. Companies with any CAR supply chain exposure should conduct a comprehensive conflict risk assessment and implement the full OECD five-step due diligence framework.

Key dates

FY2024 (ongoing)

CSRD โ€” large EU companies must report on supply chain sustainability including any CAR exposure

December 30, 2026

EUDR โ€” CAR timber exports require deforestation-free verification (extremely difficult to verify in conflict context)

July 2029

CSDDD Phase 1 โ€” enhanced due diligence required for conflict-affected areas including CAR

Highest-risk jurisdiction: Wagner/Africa Corps presence and conflict minerals

The Central African Republic is one of the world's most complex ESG risk environments. The country has been in near-continuous conflict since 2012. Russian Wagner Group forces (rebranded as Africa Corps following Yevgeny Prigozhin's death in 2023) have been present since 2018, providing military support to the government in exchange for mining concessions โ€” particularly gold and diamond mining rights. Human rights organisations including Human Rights Watch and Amnesty International have documented serious abuses by Wagner/Africa Corps forces, including extrajudicial killings, torture, and sexual violence. The UN Panel of Experts on CAR has documented Wagner's involvement in conflict mineral extraction. EU companies sourcing any minerals from CAR โ€” or investing in companies that do โ€” face the highest level of CSDDD due diligence requirements. The OECD Due Diligence Guidance recommends that companies either implement the full five-step due diligence framework or suspend/disengage from CAR supply chains entirely.

Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change โ€” verify current requirements with a qualified adviser.

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