Your customer or buyer is asking about supply chain exposure to Eritrea. Here is what the regulatory environment requires.
Eritrea is a small East African country with one of the world's most closed and authoritarian governments. The country has significant mineral resources — gold, copper, zinc, and potash — and the Bisha mine (operated by Zijin Mining, a Chinese company, after the Canadian company Nevsun Resources was acquired) is one of the country's most important economic assets. Eritrea has been subject to UN sanctions (lifted in 2018) and faces ongoing international criticism over human rights — particularly the use of indefinite national service (effectively forced labour) in mining and other sectors. ESG compliance in Eritrea is primarily relevant for mining companies operating there and for buyers of Eritrean minerals.
Key regulations in Eritrea — ESG Supplier Guide
EU CSDDD — Enhanced Due Diligence for High-Risk Areas
Eritrea's authoritarian government and use of indefinite national service (effectively forced labour) make it a high-risk jurisdiction under EU CSDDD. EU companies with any supply chain exposure to Eritrea must conduct enhanced human rights due diligence. The Nevsun Resources case — in which Eritrean workers sued Nevsun in Canadian courts over alleged forced labour at the Bisha mine — established an important precedent for supply chain human rights liability.
EU CSRD — Mining Supply Chains
EU companies sourcing gold, copper, and zinc from Eritrea face CSRD supply chain reporting requirements. Key ESG issues include: forced labour through the national service programme, community rights in mining areas, environmental management, and governance under an authoritarian government.
Forced Labour — National Service Programme
Eritrea's national service programme requires all citizens to serve indefinitely in the military or civilian sectors — including mining. The UN Special Rapporteur on Human Rights in Eritrea has documented the use of national service conscripts in mining operations, effectively constituting forced labour. EU companies sourcing Eritrean minerals face significant forced labour risks under CSDDD and the EU Forced Labour Regulation.
EU Forced Labour Regulation
The EU Forced Labour Regulation prohibits the import into the EU of products made with forced labour. Eritrea's national service programme — which has been documented as involving forced labour in mining — means that Eritrean minerals face significant risk of being banned from EU import under this regulation. EU companies sourcing Eritrean minerals should assess forced labour risks urgently.
Eritrea Data Protection & Cyber Obligations
Eritrea does not have a comprehensive data protection law or mandatory cyber incident reporting regime. The Ministry of Information oversees telecommunications. International sanctions and the restricted operating environment significantly affect engagement with Eritrean entities. Suppliers should obtain specialist legal advice before engaging with Eritrean entities and implement robust supply chain screening.
What this means for you as a supplier
Eritrea is a high-risk jurisdiction for forced labour and human rights. The national service programme effectively constitutes forced labour in mining operations. EU companies sourcing Eritrean minerals face significant risks under CSDDD, the EU Forced Labour Regulation, and CSRD. Most responsible EU buyers avoid Eritrean mineral supply chains entirely. Companies with any Eritrean supply chain exposure should conduct an urgent forced labour risk assessment.
Key dates
FY2024 (ongoing)
CSRD — large EU companies must report on supply chain sustainability including any Eritrean exposure
December 2027
EU Forced Labour Regulation — products made with forced labour (including Eritrean national service) banned from EU import
July 2029
CSDDD Phase 1 — enhanced due diligence required for high-risk areas including Eritrea
Nevsun Resources: the landmark forced labour case
The Nevsun Resources case is one of the most significant supply chain human rights cases in history. Eritrean workers at the Bisha copper-zinc-gold mine (operated by Nevsun Resources, a Canadian company) filed a lawsuit in Canadian courts in 2014, alleging that they were forced to work at the mine under Eritrea's national service programme — effectively forced labour. The Supreme Court of Canada ruled in 2020 (Nevsun Resources Ltd v Araya) that the case could proceed in Canadian courts, establishing that Canadian companies can be held liable in Canadian courts for human rights abuses committed abroad. Nevsun was subsequently acquired by Zijin Mining (Chinese) in 2019. The case established an important precedent for supply chain human rights liability and is directly relevant to the EU CSDDD, which creates similar liability for EU companies. The EU Forced Labour Regulation, which comes into force in December 2027, would prohibit the import of products made with Eritrean national service labour.
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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