The expansion of the mining sector in Central Asia could exacerbate existing environmental risks. The reduction of greenhouse gas emissions, the sustainable use of water resources and the management of mining waste and tailings are among the main challenges that governments will have to address to ensure the development of viable CRM sectors. Current findings show that, while national legislation and strategies are attempting to tackle these challenges through targets and policy plans, governments could be more ambitious in setting sector-specific goals and providing clear incentives for mining-sector actors to develop more sustainable practices.
Advancing Security and Transparency for the Governance of Critical Raw Materials in Central Asia
Abstract
While CRMs are central to the green transition, mining and processing are responsible for a range of environmental and sustainability challenges, including in Central Asia. These include land degradation, high greenhouse gas (GHG) emissions - some being hard-to-abate -, water and air pollution, biodiversity loss and hazardous waste (Eurasianet, 2024[1]) (East Asia Forum, 2025[2]) (Global Voices, 2024[3]). Mining activities can also require intensive use of water resources, which is a challenge in regions already under severe water stress (The Times of Central Asia, 2025[4]). Managing environmental risks should therefore be embedded in any government plans for critical minerals development, ensuring that these align with climate mitigation and adaptation goals, as well as objectives relating to sustainable management of natural resources, biodiversity protection, and conserving and protecting water for other economic and social uses.
Central Asia is highly exposed to climate and environmental risks. The region has already experienced major environmental disasters (as, for example, the desiccation of the Aral Sea) and is currently facing numerous environmental challenges, such as the receding levels of the Caspian Sea (OECD, 2025[5]), desertification (World Bank, 2023[6]) (UNCCD, 2023[7]) and glacier melt (France24, 2024[8]) (Jouberton, 2025[9]). Legacy from past mining activities and local conflicts over the use of natural resources or environmental impact of mining operations highlight the need for Central Asian governments to address future risks stemming from the development of critical minerals sector.
The detrimental impact of mining on sustainability creates a paradox at the core of Central Asia’s CRM agenda: net‑zero pathways rely on a rapid expansion of mining and processing to supply transition minerals, yet current practices are highly carbon‑ and resource‑intensive and can aggravate climate and environmental risks in an already fragile region. Unless mining and processing are progressively decarbonised and made more resource‑efficient, and environmental management related to pollution from mining sites and waste storage is brought up to international standards, efforts to position Central Asia as a supplier of “green” minerals risk undermining the very climate and sustainability objectives they are intended to support (Mining Digital, 2024[10]).
As environmental risks and their social consequences translate into economic and corporate risks, failing to address those at the policy level can lead to competitiveness issues as countries seek to attract investments in critical minerals development. In Central Asia, mining companies are increasingly facing demands to adopt risk mitigation measures to limit negative impacts on local communities and to complement their mining activity with social projects aimed at improving the quality of life in neighbouring localities. Public consultation processes and community approval are central components of companies’ “social license to operate”, which is becoming a major criterion for quality investment and a prerequisite for international financing of mining and mining-related projects. A robust environmental policy framework addressing risks in the mining sector plays a role in de-risking investment in critical minerals development.
Central Asian governments’ ongoing efforts to develop CRM strategies offer a unique opportunity to embed strong environmental and sustainability safeguards into mining policies and regulations. The detrimental effects of mining on the environment, and subsequently, on local communities, typically extend beyond the life of a mine, which itself spans decades (OECD, 2019[11]). Governments have all adopted green economy and climate mitigation and adaptation strategies, recognising the importance of tackling climate change and environmental risks for sustainable economic growth. Kazakhstan, Uzbekistan and the Kyrgyz Republic have adopted or are in the process of adopting net-zero strategies. Given the mining sector’s economic significance and environmental footprint across the region, governments’ ability to align any plans for CRM development with their environmental and sustainability goals will be critical to enable that future CRM sectors effectively contribute to sustainable economic growth.
GHG emissions
Mining leads to high levels of greenhouse gas (GHG) emissions. Although Central Asian countries are modest contributors to global GHG emissions, the geographical features of the region make it particularly vulnerable to their subsequent impacts. GHG emissions may cause prolonged droughts and heatwaves which threaten rain-fed agriculture, still a dominant sector in Uzbekistan, and steppe ecosystems, vital to Kazakhstan’s biodiversity. Mountainous countries such as the Kyrgyz Republic may be threatened by other impacts of increased GHG emissions, such as glacier retreat and landslide risks. Moreover, GHG emissions may have negative impacts on the availability and quality of water resources, as rising emissions lead to altered river regimes and water scarcity, putting pressure on rural livelihoods in a region already severely touched by desertification. Finally, GHG emissions present an important health risk, especially in communities leaving near mining sites, where risks of lung cancer and water-borne diseases are exacerbated.
Water stress and water pollution
Mining operations contribute to water stress, one of the main environmental challenges in Central Asia. The situation is particularly acute in Uzbekistan, where mining operations contribute to water overuse and water pollution through inefficient operations of wastewater management: according to the World Resources Institute (WRI) data, Uzbekistan ranks among the 25 countries most vulnerable to water stress. Water mismanagement also leads to desertification, as the use of aging water-supply infrastructure leads to ineffective land rehabilitation. Other impacts of mining on water resources include acid water drainage, notably in Kazakhstan, where it affects areas well beyond mining sites and their surroundings and puts populations in danger (Kunarbekova, 2024[12]). The Kyrgyz Republic experiences the same issues as its neighbours, which are nevertheless coupled with the country’s particular geography, resulting in many mining projects being located in the upper part of watersheds, making their environmental impact potentially broader than the immediate vicinity of mining operations.
Waste and tailings management
Kazakhstan, the Kyrgyz Republic and Uzbekistan are home to large numbers of waste and tailings storage facilities and dumps. All three countries are uranium producers (the Kyrgyz Republic lifted its ban on uranium mining in 2024), Kazakhstan and Uzbekistan being among the world leaders in this sector. This situation presents a considerable risk of radioactive contamination for local communities and ecosystems (UNECE, 2024[13]). Even if mine waste and tailings are properly managed in waste dumps and storage areas, high rainfall can cause dams and earthworks to fail, leading to discharges of contaminated water into the water table (OECD, 2019[11]).
The management of mining waste and tailings remains a significant challenge. In the Kyrgyz Republic, the State Cadastre of Mining Industry Waste counted 92 facilities with toxic and radioactive mining waste in the country; waste mismanagement in the past has led to a significant decline in biodiversity. Kazakhstan and Uzbekistan are facing similar problems, reflecting the scale of their uranium production.
Chapter outline
This chapter will examine all three risks in detail, identify opportunities and challenges for Kazakhstan, the Kyrgyz Republic and Uzbekistan, and offer general recommendations.
Carbon and energy intensity of national economies and industrial contribution to GHG emissions
Mineral and metal production accounts for around 10% of global GHG emissions. Under the Net Zero Emissions (NZE) scenario, rising demand for Energy Transition Metals (ETMs) is expected to increase the overall carbon footprint of mineral production, with GHG emissions from copper and other metals projected to double by 2050 (World Bank, 2023[14]).
Central Asian countries have all committed to GHG emission reduction under the Paris Agreement. The total contribution of Central Asian countries to global emissions is relatively low. In 2023, Kazakhstan accounted for 0.7% of global CO₂ emissions from combustible fuels, Uzbekistan for 0.3%, and the Kyrgyz Republic for a negligible share, with the three together representing only about 1% of global emissions (IEA, 2025[15]). Nevertheless, recognising the risks climate change is posing to the environment and economies, as well as concurrent effects of GHG emissions such as pollution, Central Asian countries are all parties to the Paris Agreement and have adopted Nationally Determined Contributions (NDCs). Several of them have pledged to reach net zero by mid-century. Fulfilling these commitments will necessitate a substantial transformation of their industrial systems, along with their energy generation and transport infrastructure (OECD, Forthcoming[16]).
Achieving convergence with OECD levels of carbon productivity will require Central Asian economies to decouple economic growth from GHG emissions. Despite modest global emissions contribution, the economies of Kazakhstan, the Kyrgyz Republic and Uzbekistan remain heavily carbon-intensive relative to both output and population, largely due to their reliance on outdated, fossil-fuel based energy infrastructure. Based on OECD data on production-based carbon productivity (see Figure 3.1), Kazakhstan and Uzbekistan generated respectively 2.7 and 2.86 USD per unit of CO2 emitted in 2023, performing below such peers as Canada (3.96 USD) and Australia (4.44 USD) in the same year. Kazakhstan and Uzbekistan are structurally more reliant on fossil fuels, as they have only been generating between 2 and 3 USD per unit of CO2 since 2017. Thanks to its large hydropower sector, the Kyrgyz Republic performs better in this respect, with a production-based carbon productivity on par with Canada and Australia (4.61 USD in 2023). All three countries nevertheless generate considerably less revenue per unit of CO2 than Chile (7.62 USD in 2023).
Carbon productivity and energy productivity are closely related in Central Asian countries, where fossil fuel reliance is compounded by other factors including infrastructure wear and tear, geographic and climatic conditions affecting energy distribution systems, and national economic structures. (see Figure 3.2). The Kyrgyz Republic and Uzbekistan, despite having a smaller GDP per capita than Australia and Chile, display higher energy intensity numbers in 2022 (1.66 kWh/USD for the Kyrgyz Republic and 1.51 for Uzbekistan in 2022, against 1.24 for Australia and 1.12 for Chile in the same year). This reflects their reliance on very emissive economic activities like mining, though Chile and Australia are also major mining economies. Kazakhstan, while having a GDP per capita comparable to that of Chile (26,492 USD against 22,741 USD in 2022), presents higher energy intensity numbers (1.63 kWh/USD against 1.12 in 2022); the comparison between Kazakhstan (1.63 kWh/USD) and Australia (1.24 kWh/USD), a country with a much higher GDP per capita, is even more revealing.
USD per unit of CO2
Source: (OECD, 2025[17])
Source: (Our World in Data, 2022[18])
Available data show that the Kyrgyz Republic presents a lower share of GHG emissions from industry in total GHG emissions (7.7% in 2023) than Kazakhstan and Uzbekistan (14.8% and 11.2% respectively) (EDGAR Database, 2025[19]). This could reflect both historical pressure from Kyrgyz civil society to reduce industrial pollution in the country and the modest size of the industrial sector in the Kyrgyz Republic compared to Kazakhstan and Uzbekistan. Kazakhstan also presents a higher share of emissions from the power sector (34.6% in 2023, well above Uzbekistan’s 22.3% and the Kyrgyz Republic’s 12.2%), which indicates Kazakhstan’s continued reliance on hydrocarbons to generate electricity (EDGAR Database, 2025[19]). Overall, Central Asian mining sectors are characterised by several hard-to-abate industries, such as iron, aluminium and zinc in Kazakhstan, copper in Uzbekistan, and gold in all three countries: challenges for GHG emissions reduction in these industries include the use of diesel-fuelled heavy mobile equipment (haul trucks, loaders and drilling rigs), the energy intensity of such processes as ore crushing and grinding, the use of explosives and chemical reagents, and the remote location of many mines which are situated off-grid or at weak grid edges. Therefore, specific measures will be required for these sectors.
In this context, mobilising current and future mining operators to invest in energy‑efficiency measures, low‑carbon technologies, and cleaner energy sources is a key lever for enhancing industrial productivity and long‑term competitiveness. High energy intensity is not only a constraint on the achievement of greenhouse‑gas mitigation targets, but also a material economic and trade‑related risk. As mining output expands, energy tariffs increase in the context of national energy‑sector reforms, and climate‑related trade instruments, such as the Carbon Border Adjustment Mechanism (CBAM), are progressively implemented, such investments become critical to containing production costs, preserving access to export markets, and maintaining competitive positioning within carbon‑constrained global value chains.
Sectoral climate targets in policy planning
In spite of increasing climate ambitions and supporting plans, measures supporting the decarbonisation of the mining sector remain limited
Kazakhstan has set pollution reduction objectives for its largest industrial emitters (see Annex 3.A). It is the only Central Asian country with specific GHG emission reduction objectives for its largest mining enterprises. The Action Plan for implementing the Concept for the Transition of the Republic of Kazakhstan to a “Green Economy” for 2024-2030 sets emission reduction objectives for the 50 most polluting enterprises in the country, including:
Qarmet, Steel Department (Qarmet is an SOE operating Kazakhstan’s largest coal mine in Temirtau, as well as several steel enterprises): the enterprise must reduce emissions from 285 thousand tons in 2021 to 149 thousand tons by 2027.
Kazakhmys, Zhezkazgan copper smelting plant (Kazakhmys is Kazakhstan’s largest copper producer): the enterprise must reduce emissions from 63.2 thousand tons in 2021 to 31.06 thousand tons by 2025.
Kazakhmys, Balkhash copper smelting plant: the enterprise must reduce emissions from 75.2 thousand tons in 2021 to 31.1 thousand tons by 2025.
Kazzinc, Öskemen Metallurgical Complex (Kazzinc is Kazakhstan’s largest zinc producer): the enterprise must reduce emissions from 26.299 thousand tons in 2021 to 22.5 thousand tons by 2025.
Kazakhstan’s planned Emissions Trading System (ETS) reforms, including the reduction of yearly free emission allowances, can incentivise mitigation in the mining sector. The ETS covers approximately 42.9% of national greenhouse gas (GHG) emissions and includes more than 200 industrial facilities from major sectors such as oil and gas, mining, power generation, metallurgy, and chemicals (Kazenergy, 2023[20]; UNFCCC, 2025[21]). In line with its NDC 3.0 ambitions, Kazakhstan is planning to accelerate the decrease of annual free allowances, with a planned annual reduction of 3.41% through 2030 (UNFCCC, 2023[22]). A gradual phase‑out of free allowances would address existing over‑allocation, as mining currently uses only about 70% of its allocated quotas, and would steadily raise carbon costs, creating stronger incentives for investment in decarbonisation. Other considered reforms, including market stabilisation measures, can further increase carbon pricing under the ETS and incentivise measures to reduce GHG emissions from mining companies. Kazakhstan plans to achieve economy-wide carbon neutrality by 2060, which remains an ambitious target considering that the country remains among the top 20 GHG emitters worldwide, and among the top 5 for carbon emissions relative to GDP and per capita emissions (Adilet, 2024[23]). Ongoing efforts to develop a roadmap for achieving this objective could catalyse GHG emission reductions in the mining sector, particularly if a clearly defined sectoral contribution is established.
Uzbekistan’s latest national strategies include ambitious targets for GHG emissions. The Uzbekistan – 2030 Strategy sets a general target to reduce GHG emissions by 30% by 2030 compared to 2010 levels. The NDC 3.0, submitted in November 2025, further sets an unconditional objective of 50% GHG emissions reduction by 2035 and a net-zero target by 2055. The plan mentions GHG reduction in the mining sector, although it does not flesh out specific quantitative sectoral targets or clear measures. The government is developing a Long Term-Low Emission Development Strategy, which could support the development of a sectoral decarbonisation plan.
Uzbekistan’s largest mining SOEs are developing climate plans, with specific GHG emission reduction targets. The mining SOEs in Uzbekistan are working to develop their own climate goals, while also implementing international green management standards such as ISO, IFC, GISTM and GRI. The Almalyk MMC (AMMC) has set a target of reducing its GHG emissions by 15% by 2030 (UNFCCC, 2025[24]) and by 30% by 2050. The company is currently developing a decarbonisation strategy, with the support of international partners. Financiers, though their financing conditions, can drive climate mitigation measure adoption, as exemplified in recent investment projects: AMMC’s new copper smelter, financed by a European bank, is planned to be equipped with GHG capture facilities, which will allow to avoid 90% of GHG emissions. The Navoi MMC (NMMC), Uzbekistan’s largest gold producer, has elaborated a climate strategy by 2030 and undergoes regular third-party inspections and audits to keep track of progress. Recently, the company conducted a climate-risk assessment and is developing a strategy for mitigating identified risks.
The Kyrgyz Republic’s NDC 3.0 updates national GHG emissions reduction targets and sets broad objectives for the industrial sector, but mining is not mentioned in the document. The plan outlines an unconditional reduction of GHG emissions of -18% by 2030 and a conditional reduction of -30% compared to a BAU scenario. For 2035, the target for a further unconditional reduction of GHG emissions is set at -16% and a conditional reduction with additional international support is set at -39%. The NDC also states some specific objectives for the industrial sector, such as the launch of a pilot decarbonisation project for 20 industrial enterprises, the creation of a system for the inventory and monitoring of GHG emissions in industry, and the implementation of stimuli for lower-carbon industrial activity (UNFCCC, 2025[25]).
Climate objectives are absent from national critical minerals strategies
Central Asian national mining development strategies do not integrate GHG emission reduction objectives. Kazakhstan’s Comprehensive Plan for the Development of the Rare and Rare Earth Metals Industry for 2024-2028 predominantly focuses on industrial development but does not refer to the alignment of sectoral development with climate objectives (Adilet, 2023[26]). The Kyrgyz Republic recently adopted the Strategic Development Programme for Critical Minerals through 2030, which incorporates environmental provisions. These provisions, however, mainly focus on alignment with EITI and other international standards, expanding opportunities for green financing and improving general environmental rankings, while GHG emissions are not mentioned in the document. Uzbekistan does not yet have a CRM strategy, but its draft project supported by the Boston Consulting Group has been reported to include environmental provisions.
Aligning the development of critical minerals with national climate goals requires articulating plans for GHG emissions reduction and mining development. To this end, governments should consider integrating GHG emission reduction targets, as well as clean energy, energy efficiency and clean technology adoption goals in their critical minerals’ development plans. Given the importance of the mining and metals sectors in Central Asian countries, investment interest from international trade partners and the carbon- and emissions-intensity of mining operations, there is a strong case to prioritise the development of sectoral decarbonisation plans laying out mining sectors’ contributions to national GHG reduction and net zero targets. Countries can also consider integrating references to climate goals in their CRM strategies, as well as renewable energy development, and other measures underpinning decarbonisation. They could envisage embedding measures supporting the adoption of technologies such as carbon capture and use of renewable hydrogen for specific industrial processes, as well as digital technologies for the monitoring of processes such as grinding, crushing and ventilation. Any investment incentives in the mining sector should include conditions pertaining to their alignment with national climate goals, while efforts to attract international investment could include specific emphasis on sustainable technologies. The Kyrgyz Republic and Uzbekistan could follow the example of Kazakhstan and set GHG emissions reduction targets for the largest emitting mining companies. Uzbekistan could consider outlining more specific targets to reduce GHG emissions in industrial processes. The experience of Chile provides a good example of climate ambition integration in mining sector development plans (seeBox 3.1).
Chile is the world’s first copper producer and a major lithium producer planning for a substantial expansion of its lithium industry. The country pledged to reach carbon neutrality by 2050 and to exit coal mining by 2040. Various initiatives supporting the decarbonisation of the mining sector have already been implemented, such as the Energy Efficiency in Mining project (2019), which aimed at providing technical advice and trainings to mining companies.
Chile’s latest NDC provides specific decarbonisation targets for its mining industry. CO2 emissions are planned to be reduced by 57% in open-pit copper mines, 74% in underground copper mining, and 52% in other mining activities. The NDC encourages electric vehicle use in mining, thermal electrification and hydropower. Renewable energy use is a key element, the NDC projecting to reach 90% of renewable energy in large mining operations by 2030. The objective for carbon neutrality in mining is set by 2040, ten years before the overall country goal.
Industry and mining remain the largest energy consumers in Chile, accounting for 38% of all energy use in 2020, a 18% rise compared to 2010-2020 levels. Therefore, the country has set the target to reduce GHG emissions from industry and mining by 70% by 2050 compared to 2018 levels. To that end, the government has been encouraging renewable energy use. According to the PEN, at least 90% of energy for heating in industry must come from low-carbon sources such as solar by 2050. In 2021, renewable energy already accounted for 44% of mining electricity consumption and was expected to exceed 60% by 2025.
Chile’s carbon tax on stationary GHG emission sources entered in force in 2017 and allows offsets for compliance. The tax applies to facilities emitting more than 25,000 tonnes of CO2 per year or more than 100 tonnes of particulate matter per year. The tax rate stands at 5 USD per tonne of CO2, which is considered low by international standards: the government proposed to raise it to 35-40 USD per year by 2030.
Governments could also support the controlled experimentation of low‑carbon innovation in the mining sector, particularly the use of renewable hydrogen to decarbonise operations where alternatives remain limited or prohibitively expensive. Kazakhstan and Uzbekistan are already developing large‑scale renewable hydrogen projects, with growing technical expertise in major SOEs, such as KazMunayGas in Kazakhstan and Uzkimyosanoat in Uzbekistan, that could be leveraged to pilot applications in mining. Renewable hydrogen offers multiple decarbonisation pathways: powering heavy mobile equipment such as haul trucks through hydrogen fuel cells, providing long‑duration renewable energy storage, supplying on‑site electricity generation, and acting as a reductant and high‑temperature heat source in carbon‑intensive downstream industries like steel and copper production. Mongolia’s experience piloting a 1.5 MW electrolyser at Oyu Tolgoi, one of the world’s largest copper and gold deposits, further illustrates the potential for early adoption to support mine‑site energy needs. Positioning major mining operations as early off-takers of renewable hydrogen would help create an anchor domestic market for this emerging technology, accelerating cost reductions, strengthening local value chains, and advancing national and sectoral GHG mitigation goals.
The regulatory frameworks for GHG emissions in mining are ambitious but contain important gaps
The implementation of emissions trading systems (ETS) to reduce emissions in carbon-intensive sectors such as mining and metallurgy is under way (see Annex 3.B). Kazakhstan’s current environmental regulatory framework provides for a well-developed ETS, with enterprises subject to its quotas being required to develop a monitoring plan for their GHG emissions, while the results of GHG inventories must undergo a verification process. In Uzbekistan, the government has recently adopted a series of new laws, including the Law “On Limiting Greenhouse Gas Emissions” which sets the basis for the creation of an ETS. The current GHG-related legislation in the Kyrgyz Republic stipulates that nature users can use GHG emissions sources only if they possess a sufficient volume of maximum permissible emissions (quotas). However, these requirements do not correspond to the existence of a market-based emissions trading system as in Kazakhstan or Uzbekistan.
Some regulatory gaps in mining legislation may nevertheless be observed. The current environmental legislation of Kazakhstan, while mandating environmental screening for mining activities, does not include GHG emissions impacts into accounting during the EIA process (Adilet, 2021[31]). Moreover, GHG emissions generally do not require specific ecological permits in Kazakhstan or in Uzbekistan (Lex.uz, 2025[32]). The Kyrgyz Law On State Regulation and Policy in the Field of Emission and Absorption of Greenhouse Gases mandates public participation for decisions at the stages of development, approval and implementation of climate projects, a provision absent from the current Kazakh and Uzbek legislations on GHG emissions management (Government of the Kyrgyz Republic, 2022[33]).
As further steps, the three governments could consider establishing specific ecological permits for GHG emissions from mining. The Kyrgyz Republic could follow Kazakhstan and Uzbekistan and consider creating a genuine emissions trading system (ETS) to be able to effectively incentivise GHG emissions reduction. Kazakhstan and Uzbekistan could in their turn follow the Kyrgyz legal framework and consider establishing mechanisms of public consultation regarding GHG emissions during the development, approval and implementation of mining projects.
Environmental regulations, Strategic Environmental Assessments (SEAs) and Environmental Impact Assessments (EIAs)
Strategic Environmental Assessment (SEA) refers to “analytical and participatory approaches that aim to integrate environmental considerations into policies, plans and programmes and evaluate the inter linkages with economic and social considerations” (OECD, 2006[34]). The main aim of SEA is to integrate environmental considerations alongside economic and social ones into strategic planning and decision-making. On a government level, SEA processes can be integrated not only into broad strategies and plans, but also in budget support programmes, mining-specific policy reforms, mining policies, mining investment plans and so on. SEAs are different from Environmental Impact Assessments (EIAs): while SEAs assess policies, plans and strategic programmes and integrate environmental considerations before strategic directions are fully determined, EIAs assess specific projects (for example, mine developments) and are conducted during planning or design stage.
Applying Strategic Environmental Assessments (SEAs) in the mining sector helps countries align mineral development with climate‑mitigation and broader sustainability objectives. At the national level, SEAs support coordinated planning between mining and infrastructure needs, ensure alignment with climate and development policies, and assess institutional capacity to manage environmental and social risks. They strengthen regulatory frameworks on sustainability, improve governance and revenue management, encourage skills development and technology investments that reduce environmental footprints, and promote long‑term planning for mine closure and rehabilitation. At the regional level, SEAs help assess mining’s impacts on other economic sectors, identify priorities for conservation and low‑carbon development, and enable cross‑sectoral coordination across infrastructure, utilities, land‑use planning and biodiversity. They also provide a structured approach to assessing and managing impacts on communities.
Kazakhstan has a legal framework for Strategic Environmental Assessment (SEA), but its effectiveness is weakened by implementation challenges. The Environmental Code mandates SEAs for key economic sectors, including mining, and territorial development plans and defines the process, including screening, scoping, reporting, quality review, monitoring, and stakeholder participation (Government of Kazakhstan, 2021[35]). However, implementation remains limited, and constrained by weak sectoral guidance, regulatory complexity, and low public participation (OECD, Forthcoming[36]).
The Environmental Code requires business activities with environmental impacts to undergo a comprehensive Environmental Impact Assessment (EIA), overseen by the Ministry of Ecology, Geology, and Natural Resources. If a preliminary screening determines that an Environmental Impact Assessment (EIA) is necessary, the latter should be conducted for open-pit mining for hard minerals exceeding 25 hectares, the extraction and processing of common minerals for over 10 000 tons per year, and the underground mining of hard minerals. The EIA process mandates a 30‑day public consultation period, with documentation published on the Unified Environmental Portal (Ecogosfond.kz, 2026[37]). Interviews, however, indicate that the practical application of this requirement has been mixed (OECD, 2025[38]). Assessments of EIA implementation in Kazakhstan indicate deficiencies in their effectiveness. Furthermore, institutional capabilities are lacking at sub-national level (OECD, Forthcoming[36]).
Per the Law of the Kyrgyz Republic “On Environmental Protection”, any planned economic activity which may have an impact on the environment must undergo a State Ecological Expertise. Without a positive conclusion, the project will be prohibited. The law also mandates Maximum Permissible Concentrations of harmful substances in water. Waste water discharge into water bodies of general use and underground water horizons is prohibited. The Law of the Kyrgyz Republic “On Environmental Expertise” mandates EIAs for all types and stages of development.
The newly adopted Law of the Republic of Uzbekistan “On Ecological Expertise, Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA)” mandates EIAs as a pre-requisite for the Ecological Expertise which ensues. For new projects, the EIA documentation includes a Draft Statement of Environmental Impact, a Statement of Ecological Consequences and, if required, a Statement of Environmental Impact. The project initiator is required to conduct public hearings as part of the EIA to discuss the potential environmental impacts of the planned activity among the public. If motivated objections from participants are included in the final documents of the public hearings, the project’s implementation may be deemed as inadmissible. The EIA is followed by an Ecological Expertise, which consists of two separate processes: the State Ecological Expertise for materials concerning the selection/allocation of land plots for construction, pre-project and project documentation, existing objects which have a negative impact on the environment and objects with a special legal regime, and the Public Ecological Expertise, which is an environmental review conducted NGOs, local communities and citizens; its conclusions bear an advisory and non-binding character for the government’s decision to approve the project. For projects included in strategic planning documents designed by the government (for example, mining projects submitted by SOEs), these planning documents should be subject to a SEA. At the time of writing, the Almalyk MMC is conducting a SEA for its new smelter project which should serve as a basis for further SEAs in the mining sector.
All three governments could consider working on three main directions regarding their current ecological expertise frameworks:
Integrating social and economic considerations into the current SEA processes to allow for a full sustainability appraisal (OECD, 2006[34]). As of today, the three government frameworks do not yet demand the integration of economic and social considerations into SEA documentation.
Integrating institutional capacity assessments into the current SEA processes to be able to enhance the governance framework in environmental, social and economic risk management (OECD, 2006[34]). Current frameworks do not yet include such an assessment.
Include the possibility of independent review into the current SEA processes to allow for a quality assurance system (OECD, 2006[34]); in Uzbekistan, the Public Environmental Expertise could be made legally binding for government actors.
Targeting the mining sector more specifically, Central Asian governments could consider the following actions:
Strengthening the regulatory and institutional national framework for SEA (e.g. in the Low-Carbon implementation roadmap, other relevant policies and national/sectoral strategies including mining) and designate “champions” in ministries in charge of mining development.
Developing practical guidelines for sectoral application of SEAs in the mining sector, drawing from international experience.
Ensuring resources (e.g. financial and human) are adequate and provide clear timelines aligning with project preparation processes.
Promoting and raise awareness across mining stakeholders at national and local levels.
Implementing capacity-building and training programmes for national and sub-national implementers specifically in the mining sector.
Water stress and water use inefficiency
Central Asia is particularly vulnerable to water stress
Central Asia suffers from water scarcity due to the historic mismanagement of surface and groundwater resources and intensive agriculture activities. Water stress is being exacerbated by rising demand, climate change and reliance on transboundary flows. The region has witnessed the rapid drying of its major water bodies, most notably the Aral Sea, once the world’s third-largest lake and the region’s main saltwater body. During the Soviet period, large-scale irrigated agriculture expanded across the arid plains of Kazakhstan, Uzbekistan and Turkmenistan, diverting water from the Aral Sea’s two main inflows, the Amu Darya and the Syr Darya, primarily for cotton and rice cultivation. Over time, between the 1960s and the 2010s, the sea’s surface area declined by nearly 90%. In Uzbekistan, the production of cotton, known as “white gold”, drove a dramatic expansion of irrigated land, while in Kazakhstan, the country’s main rice-producing region of Kyzylorda relied heavily on Syr Darya water as part of the Aral Sea basin (World Bank, 2004[39]) (France 24, 2025[40]) (NPR, 2024[41]) (IIETA, 2023[42]). As a result, by the late 1980s most of the southern (Uzbek) Aral Sea had dried up, leaving only the smaller northern Kazakh section, which later became the focus of restoration efforts. Water stress is now affecting the Caspian Sea, especially its northern part boarded by Kazakhstan’s Atyrau and Mangystau regions, and is becoming a major cause for concern, as the sea is projected to lose up to a third of its surface area by the end of the century. At the same time, nearly 10 million people in Central Asia (13.5% of the population) still lack access to clean drinking water, as an estimated 80% of the region’s water infrastructure is outdated and causes water losses of up to 55% (Vinokurov, 2024[43]).
Kazakhstan is dependent on a declining flow from transboundary water bodies, while its water consumption is expected to increase
Kazakhstan depends significantly on water that originates beyond its borders, with transboundary sources providing about 44% of its total surface water inflow (FAO, 2022[44]). Over time, Kazakhstan has experienced a 27% decline in surface water flows due to the combined effects of climate change and rising water demand both domestically and in upstream countries (World Bank, 2024[45]). At the same time, national water consumption is expected to grow by 56% by 2040 (PrimeMinister.kz, 2020[46]). At the sectoral level, agriculture is by far the largest water consumer, accounting for approximately 60% of total withdrawals, primarily for irrigation purposes. Industry follows with about 23.5%, most of which goes to power generation and, to a lesser extent, extraction and refining. Household consumption is relatively minor, at about 4% (The Astana Times, 2025[47]). Water productivity in agriculture remains low due to water-intensive, low-value crops and ageing irrigation systems that suffer substantial losses. Water-use efficiency in industry, including mining, is also constrained by deteriorating infrastructure. A shortage of qualified staff and limited research in the water-use sectors add to these constraints, which, together with broader economic and regulatory factors highlighted in the copper mine case below, contribute to rising freshwater dependence in the mining sector (see Box 3.2) (World Bank, 2024[45]) (Radelyuk, I.; Klemes, J.J.; Jia, X.; Yelubay, M, 2023[48]).
A study on a newly developed copper mine in Kazakhstan (MineX) analysed the water-use patterns of the country’s expanding mining sector over seven years. By prioritising modern technology, efficiency, and closed-loop water management, the mine was able to reuse 84% of its operational water and discharge none to the environment. However, it still recorded 10% annual growth in freshwater withdrawals and 66% of total water consumption became entrained in the Tailings Storage Facility (TSF), contributing to a relatively high water intensity (0.69 m³ per ton of ore). MineX on its own accounted for an estimated 1.5% of extractive-industry water withdrawals and, given the 50% growth in mining companies over the past decade, the cumulative effect on the transboundary basin, which was already experiencing medium-high water stress, is considerable.
Water use inefficiency in Kazakhstan’s mining sector stems from a combination of weak water governance and operational characteristics that create structurally high freshwater dependence. Industrial water tariffs remain extremely low (USD 0.04-0.10/m³, compared with a global average of USD 2.5–3.0/m³), making it far cheaper for companies to withdraw freshwater than to invest in treatment or additional reuse. At MineX, outdated allocation norms further undermine efficiency, with water permits allowing MineX to withdraw up to 30% more water than needed. At the same time, discharge regulations are set on a case-by-case basis, creating regulatory uncertainty that discourages investment in treatment plants and limits incentives to return water to the basin. Operationally, MineX loses a substantial proportion of water to tailings, meaning that much of it cannot be recovered and recycling becomes increasingly limited as production grows. Together, low economic incentives, regulatory gaps and these structural water losses mean that even with efficient internal recycling, the mine as well as the whole sector remain heavily reliant on withdrawing cheap freshwater, reinforcing unsustainable patterns in an already water-stressed region.
Note: the mine is referred to as ‘MineX’ for confidentiality reasons, as the identity of the company cannot be disclosed.
The Kyrgyz Republic holds abundant water resources, but it could improve water access and productivity
The Kyrgyz Republic, with its abundant water resources and exceptionally low dependency ratio (only 1% of its surface water originates from neighbouring countries), is less exposed to water stress and plays a significant role in maintaining water security across the region. Its current water withdrawals amount to 15.6% of total internal renewable resources, and the overall water stress level of around 50% places the country in the low-medium range. Yet the Kyrgyz Republic still needs to ensure a more even distribution of safe drinking water across the country, as access remains far lower in rural areas than in cities. Only 67% of the rural population has access to safe drinking water, compared with 92% in urban areas, and out of the country’s 2 014 villages, only 796 currently have access to clean water (The Times of Central Asia, 2025[50]). Overall water productivity in the Kyrgyz Republic is very low (0.84 USD per cubic metre, compared to the regional average of ≈1-2 USD), driven largely by agriculture, which uses over 90% of national withdrawals yet generates limited economic value due to inefficient flood irrigation. Within this context, industrial water-use efficiency also remains modest. Although industry accounts for only about 4% of total withdrawals, its economic water productivity, around 5.5 USD per cubic metre, is somewhat better. This weak performance is linked to systemic inefficiencies: only 19% of wastewater is safely treated. Industrial discharges, especially from mining, energy production and untreated wastewater, are major contributors to the country’s water quality decline. Taken together, these factors mean that the industrial sector generates comparatively little economic value from the water it uses while imposing disproportionately high environmental costs (World Bank, 2024[51]).
Uzbekistan is experiencing water scarcity, while its water productivity remains low
Uzbekistan’s water endowment is in the low-medium range and around 80% of its surface water originates outside its borders. This reliance on transboundary inflows makes the country highly vulnerable to water-intensive activities upstream, such as dam construction and hydropower operations in countries like Tajikistan (World Bank, 2024[52]). Access to safe drinking water remains uneven, with only 71% of the rural population covered compared with 89% in urban areas (UNECE, 2025[53]). Climate change is expected to further intensify scarcity, with projections of a 30-40% decline in water availability and a 25% rise in irrigation demand in upcoming years (World Bank, 2025[54]). Overall economic water productivity in Uzbekistan is very low; the agricultural sector withdraws over 90% of total water yet produces very little economic value per unit, with productivity of just 0.45 USD per cubic metre. The industrial sector, while withdrawing less water (about 3.6%), shows moderate productivity (12-19 USD per cubic metre), but its overall water-use efficiency is hindered by broader systemic constraints. For example, at the Almalyk Mining and Metallurgical Plant, large volumes of wastewater (around 1,750 cubic metre per day) receive only partial treatment because purification equipment is obsolete and the technology no longer meets operational needs. Thus, limited treatment capacity reduces the potential for recycling and ultimately increases the mining sector’s demand for fresh water (World Bank, 2024[52]) (Egamberdiyev, 2025[55]). In 2025, AMMC launched a pilot project for wastewater purification with the Finnish EPSE OY (Agmk.uz, 2025[56]).
Water management policies
All three countries rely on an existing body of legislation that regulates subsoil water use for mining, including water abstraction and discharge (see Annex 3.C).
In Kazakhstan, any water abstraction project must be approved by the government if the volume exceeds 1000 m3 per day. For water discharge, the current legislation differentiates between category I and II objects (having a negative environmental impact) and category III objects (having a negative environmental impact but less damaging than category I and II objects): for category I and II objects, an environmental permit for discharge of purified sewage and industrial waters, while a declaration of environmental impact is necessary for category III objects. The discharge of incidentally extracted underground waters during subsoil use operations is classified under special water use, thus requiring a special permit as well. However, the inflow of underground water into mining excavations during mineral extraction does not require any special permit or license, while the discharge of quarry and mine waters is not linked to immediate purification requirements.
In the Kyrgyz Republic, the utilisation of water resources requires a license, water concession or lease. Wastewater discharge is subject to permission from specially authorised government bodies and must be co-ordinated with sanitary supervision and fish stock protection authorities. Wastewater discharge is permitted only if it does not increase the concentration of polluting substances in the water body beyond established norms, and only if the water user purifies the wastewater to specified limits.
In Uzbekistan, water abstraction for mining requires abstraction quotas based on technological water needs norms set by the Ministry of Mining Industry and Geology for underground waters. Abstraction involving water-lifting devices constitutes special water use and requires a special permit from the Ministry of Mining Industry and Geology for operations abstracting more than 5 m3 per day. Water discharge is also considered as special water use and requires a permit. Discharge is only allowed if it does not lead to pollutant concentrations exceeding established norms and if the water user purifies the wastewater to government-set limits. Compensation payments for pollution are based on the “polluter pays” principle.
However, existing national programmes, even when they set objectives for water use, rarely outline specific objectives for the mining sector. In Kazakhstan, industry-specific objectives are not translated in numbered targets and seem to be more directed towards the hydrocarbon industry rather than mineral mining. In the Kyrgyz Republic, mining-specific targets are not outlined in national strategies, whereas in Uzbekistan, most water management targets are directed towards irrigation, stemming from the dominant position of the agricultural sector in water use; industry-related goals in Uzbekistan’s strategies include the determination of water abstraction limits based on water resource forecasts and the improvement of the quality of the state water cadastre. The Ministry of Mining Industry and Geology of Uzbekistan is planning to transform its institute of hydrogeology into the first internationally accredited laboratory in Central Asia for the analysis of water, air and soil pollution on mining sites. The Ministry acknowledges that no mining company is currently using 100% recycled water but plans to reach this target in the foreseeable future. It is also planning to digitalise the balance accounting of ground and subsoil water by equipping all wells with adequate meters.
As further steps, governments could consider integrating mining-specific water objectives into future strategic development and environmental plans, setting clear, measurable targets for water use, consumption limits and pollution monitoring and reduction. The design or revision of CRM and mining strategies could likewise incorporate a substantive environmental component with explicit goals and limits for water consumption and contamination. Revisions to water tariffs could also help strengthen incentives to use water more efficiently. To strengthen oversight, the Kyrgyz Republic could also introduce separate abstraction permits or quotas for mining operations. In addition, both Kazakhstan and the Kyrgyz Republic could reinforce the “polluter pays” principle by establishing clear compensation mechanisms for contamination.
Water pollution
Official data on water pollution, which would permit and assessment of the consequences of mining for water bodies, remains scarce. Out of the three national statistics agencies, only the Kazakh agency provides numbers on water pollution levels. The indicator used is the Water Pollution Index (WPI), a composite indicator which typically includes pH, electrical conductivity, Total Dissolved Solids (TDS), major ions, heavy metals and trace elements, turbidity, Biological Oxygen Demand (BOD), Dissolved Oxygen (DO), Chemical Oxygen Demand (COD) and fecal coliform counts. The WPI assessment is organised in grades (or classes) derived from scores:
1st grade: very clean (<0.3).
2nd grade: clean (0.3-1.0).
3rd grade: moderately polluted (1.0-2.5).
4th grade: polluted (2.5-4.0).
5th grade: dirty (4.0-6.0).
6th grade: very dirty (6.0-10.0).
7th grade: extremely dirty (>10.0).
Kazakhstan’s WPI data shows potentially high levels of pollution resulting from mining. The data are available for 2022, but the grades are given without the exact scores which they are derived from. Results are particularly alarming for the rivers Nura, Talas and Tobol, which are reported to be polluted beyond the 5th grade (dirty). The Nura flows through the city of Temirtau, home to the country’s largest coal mine, and close to the coal industry hub of Karaganda, which may partly explain the high levels of water pollution. The Tobol flows through the city of Rudny, which is home to the country’s largest iron ore metallurgical combine, consisting of several open pits and owned by ERG, and the town of Lisakovsk, which is home to an iron ore mine also extracting bauxites and zinc ore. The Shortandy, one of Tobol’s tributaries, flows through the town of Zhitikara, home to the country’s largest asbestos combine consisting of several open pits as well. The pollution levels of the Talas can be explained by the discharge of municipal waste from the city of Taraz, but also by the upstream mining activity in the Talas region of the Kyrgyz Republic (KazStat, 2023[57]).
Official and publicly accessible Kyrgyz data does not provide statistics on water pollution from mining. The most recent data containing WPI grades dates to 2017 and touches only upon the affluents of the Syr Daria river in the south of the country, mostly in Manas, Osh and Naryn regions. The results show only moderate pollution levels in some rivers. However, the lack of more recent WPI data for these water bodies does not allow for decisive conclusions (Karymshakov and Tazhibaev, 2017[58]). Indeed, the Mailuu-Suu river, one of Syr Daria’s affluents having received a WPI grade of 3 (moderately polluted) in 2017, has been proven to possess an abnormally high concentration of uranium, selenium and heavy metals in a 2025 study using other indicators (Egemberdieva, 2025[59]), highlighting the risk of radioactive pollution from uranium mining. There are no WPI data on water pollution in the Issyk-Kul Lake, located close to the country’s largest gold mines, and the Chüy-Talas basin in the north of the Kyrgyz Republic. However, recent studies found traces of heavy metals such as arsenic, chromium, lead, copper and zinc in the Issyk-Kul basin, which presence may be due to mining activities followed by heavy rains that make these metals leak from waste dumps (Liu, 2020[60]). The same heavy metals were found in water bodies of the Chüy-Talas basin, some of them probably originating from mining as well (Ma, 2020[61]).
Official and publicly accessible data does not provide statistics on water pollution from mining in Uzbekistan. The latest WPI data dates to 2018 and touches only upon the most polluted water bodies, two of which are water collectors. The Zarafshan river in the city of Navoi, home to the country’s largest gold mining and metallurgical complex (NMMC), was reported to be moderately polluted (UNECE, 2020[62]). However, the lack of further data does not allow for a thorough assessment of water pollution in the country as a whole. In recent years, several projects have been completed at NMMC facilities, including the reconstruction of pumping stations at the Amu Daria-Zarafshan water pipeline and the increased reuse of wastewater and groundwater, which may have had a positive effect on the water quality of the Zarafshan (Ngmk.uz, 2025[63]).
As further steps, and building on the integration of mining-related objectives into national policy frameworks, governments could strengthen oversight of water pollution by ensuring more systematic and accessible monitoring data across major water bodies. Regular public disclosure of water-quality indicators would further enhance transparency and support more effective pollution management.
The expansion of mining and resulting challenges related to mining waste
Central Asia is home to numerous waste and tailings sites, the management of which entails significant risks
Kazakhstan, the Kyrgyz Republic and Uzbekistan are home to many active and legacy tailings storage facilities, some of which contain hazardous waste. Kazakhstan’s tailings facilities are predominantly located in the East Kazakhstan region, where most of the country’s zinc and lead industry is concentrated, but also in Karaganda and Jambyl regions in the centre and the south of Kazakhstan. In 2022, the Ministry of Ecology and Natural Resources intervened to halt the construction of a tailings dump project in Akmola region which did not undergo public hearings or state expertise, highlighting a rise in awareness within state bodies about mining-waste-related issues (Business and Human Rights Centre, 2022[64]). In the Kyrgyz Republic, the State Cadastre of Mining Industry and Waste counted 92 facilities with toxic and radioactive mining waste: most of these sites are located in the Manas, Osh and Batken regions, close to the border with Uzbekistan. Regular debates arise on the subject of mining waste and tailings management in the Kyrgyz Republic, most recently targeting the new waste storage facility planned by the Finnish company Metso at the Kumtor gold mine (The Times of Central Asia, 2024[65]). Uzbekistan is likewise home to several tailings sites, some of which also contain radioactive waste from uranium mining. Uranium-mining-related waste management is a common issue for all three countries, as Kazakhstan and Uzbekistan are leading uranium producers, and the Kyrgyz Republic recently lifted its 2019 ban on uranium mining and revived its uranium industry. The development of new CRM mining sites will create larger volumes of chemically and radiologically hazardous waste, thus aggravating the existing risks for the ground and surface water, a tendency which could be exacerbated by heavier rainfalls, landslides and mudslides, as well as by high seismic activity in the Kyrgyz Republic and Uzbekistan.
Governments are beginning to address the issue through legislation and policy planning
All three countries rely on an established body of subsoil and environmental legislation that, beyond general waste-management rules, also applies to mining waste and tailings, with a primary focus on safe handling, secure storage and, increasingly, resource recovery (see Annex 3.D).
Circular mining economy and waste management
The current levels of sustainable waste treatment are insufficient
Official data on hazardous waste management in Central Asia remains scarce. Kazakhstan is the only country to provide official and relatively recent statistics on the treatment of hazardous waste. The numbers show that the share of recycled, incinerated and landfilled hazardous waste in Kazakhstan has significantly declined, going from 20% in 2018 to 7.3% in 2022; however, this decline is probably due to a statistical discontinuity, as a stricter definition of hazardous waste has been introduced in the Kazakh Environmental Code adopted in 2021, which led to a reduction in reported hazardous waste volumes. Available UNECE data on the Kyrgyz Republic show a significant increase in recycling, incineration and landfilling of hazardous waste (from 3.22% in 2010 to 40.22% in 2017); however, the lack of more official government data on this subject does not allow for clear conclusions. Uzbekistan does not provide official data on hazardous waste treatment, and data from other sources was not found. Both Kazakhstan and the Kyrgyz Republic remain below the levels of Australia: even though the levels of recycling, incineration and landfilling of hazardous waste in Australia have decreased (from 86.51% in 2016-17 to 72.36% in 2022-23), they remain considerably above those of Kazakhstan and the Kyrgyz Republic (see Figure 3.3).
Current government strategies aim for a more circular approach to waste management
In Kazakhstan, mining residues, including uranium-related waste, may be placed only in authorised subsoil sites, and the disposal of unprocessed or mixed hazardous and non-hazardous waste is not permitted. Operators must treat mineral-production waste as a potential secondary resource and restore land disturbed by extraction. National planning documents set several mining-waste-related targets, including increasing industrial-waste recycling to 50% by 2030 (up from 40% in 2022), introducing strengthened recycling and monitoring obligations for major industrial facilities by 2030 and reprocessing 11 mining-waste and ore deposits between 2024 and 2028.
In the Kyrgyz Republic, tailings facilities and mine dumps must meet strict requirements for the safe storage of hazardous and radioactive materials, regular monitoring and the recultivation of land affected by extraction, financed through dedicated reclamation funds. National strategies set several mining-waste-related targets, including bringing 16 uranium-legacy tailings and waste dumps into a safe condition by 2030 and carrying out a full audit and risk assessment of existing tailings and mine-dump sites for safer reprocessing and closure between 2023 and 2035. Additional measures include reducing accumulated industrial waste by expanding waste-processing capacity and limiting the burial of recyclable materials, implemented through five-year integrated plans under the Ecological Security Concept of 2023. Secondary processing of tailings is allowed only by government decision, ensuring tightly controlled reuse of hazardous mining residues. The new Strategic Development Programme for Critical Minerals plans to accelerate the recovery of minerals from mining waste.
In Uzbekistan, mining and industrial waste may not be disposed of if technologies for recovery or utilisation exist, and operators must incorporate waste-processing and resource-recovery measures into mine-closure plans. Any project involving the placement, processing or utilisation of waste is subject to ecological expertise prior to approval. Strategic planning documents complement these requirements with a target to recultivate 6075 hectares of land degraded by mineral extraction by 2030, reinforcing both the secondary use of mining waste and the rehabilitation of extraction-affected areas.
The lack of quantitative targets does not yet allow for the streamlining of circular mining economy objectives
Most strategies still propose only general objectives for waste management and rehabilitation, without outlining comprehensive, sector-specific quantitative targets for mining waste. This does not allow Central Asian countries to leverage their significant potential for reprocessing mining waste from legacy sites. While Kazakhstan provides a clear target for the increase of waste recycling, the government strategies of the Kyrgyz Republic include only limited mining-waste-related goals. Kazakhstan’s legislation and government targets on waste and tailings appear to be more focused on promoting recycling, secondary processing and reuse of industrial and mining waste, while the Kyrgyz Republic imposes tighter regulations on secondary processing, focusing instead on waste monitoring and reduction. Uzbekistan’s current legislation encourages processing, recycling and utilisation of mining waste and sets a land-recultivation target in its national strategy, but the lack of further mining-waste-specific objectives in government programmes suggests that it is not yet a priority of the country’s mining policy, although some recent investment can be highlighted in the processing of tailings from tungsten mining sites.
Only Kazakhstan’s legislation explicitly mentions the possibility for re-mining, which would allow restoring legacy mine sites to develop CRMs that were previously considered as waste (for example, antimony and arsenic which are often by-products of gold mining). However, Kazakhstan trails behind its neighbours on the recultivation of tailings and waste dumps: while recultivation is mandatory in the Kyrgyz Republic and Uzbekistan has set a quantitative recultivation target, Kazakhstan’s national strategies do not yet include comparable commitments.
As further steps, governments could consider working in the five following directions:
Integrate quantitative targets for the reduction of unrecycled mining waste and tailings in government strategies and programmes.
Develop national criteria according to which certain mining waste materials could be considered as by-products, allowing for the reuse of such materials (OECD, 2025[67]).
Improve the enabling environment for secondary extraction by providing clarity in subsoil code on preferential royalty rates and environmental liability concerns.
Encourage foreign investment in legacy mining sites for the integration of new waste reuse technologies (see Box 3.3).
Launch Public-Private Partnership (PPP) projects at priority legacy mining sites to demonstrate how mining waste can be safely reprocessed and converted into usable materials.
The Kounrad copper mine, located near the city of Balkhash in Kazakhstan, was operational from 1936 until 2005, when it closed and left behind significant waste dumps containing recoverable copper. In 2007, the UK-owned publicly traded company Central Asian Metals PLC acquired an interest in the site.
By 2012, it had constructed a solvent extraction – electrowinning (SX-EW) plant. The process produces copper cathode by using in-situ leaching to remove copper and other metals from the waste dump. It then uses a concentrating and electrowinning process to make copper cathode. Besides allowing for effective waste reuse, this process is considerably less cost-intensive than traditional mining because it involves no drilling, blasting, or ore transporting activities.
In 2016, the facility was further expanded, to continue extracting more copper.
Source: (Central Asia Metals, 2025[68])
Governments could also consider implementing country-specific measures:
Kazakhstan could include objectives and quantitative targets on the recultivation of mining waste dumps and tailings storage facilities.
The Kyrgyz Republic could ease the current restrictions on the secondary processing of tailings, which would allow for more re-mining opportunities for by-products of gold mining.
Uzbekistan could introduce Green Public Procurement (GPP) incentives that give preference to offers using certified secondary materials recovered from tailings, complemented by targeted financial support for companies developing the technologies needed to supply them.
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Source: Sources are indicated next to the names of the laws/strategies.
Source: Sources are indicated next to the names of the laws/strategies.
Source: Sources are indicated next to the names of the laws/strategies.
Source: Sources are indicated next to the names of the laws/strategies.