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Pressure builds for a more responsible critical minerals supply chain

By Sirkularium Editorial Team, 9 min read

Mineral processing operation with conveyor infrastructure

Indonesia supplies roughly 60 percent of the world's mined nickel, and both the European Union and the United States are now writing rules that decide how much of it their markets will actually accept. Meeting those rules, and answering mounting evidence of deforestation in nickel concessions, is becoming the real test of the energy transition story Indonesia is telling.

At a glance
~60%
Share of the world's mined nickel supply that comes from Indonesia
65% cap
Maximum share of an EU strategic raw material the bloc wants from any single non-EU country by 2030
25% threshold
Chinese ownership share above which a producer loses US IRA tax credit eligibility, a line most Indonesian capacity crosses
30+ companies, 81%
Firms in Indonesia's June 2025 nickel decarbonization roadmap, targeting an 81 percent emissions cut by 2045

Why buyers are scrutinizing Indonesia's nickel supply chain

Indonesia mines roughly 60 percent of the world's nickel, more than every other producing country combined, which makes its supply chain practices a global question rather than a domestic one. Nickel sits at the center of the batteries the world wants for electric vehicles and grid storage, and Indonesia's downstreaming policy has made the country central to how that demand gets met. That scale has drawn a clear message from analysts, buyers, and regulators alike: minerals that power the energy transition should not leave a trail of environmental and social harm behind them, because a clean-energy supply chain built on poorly governed extraction is a contradiction that buyers, and increasingly regulators, are learning to price into their sourcing decisions.

What Europe is asking for

The European Union's Critical Raw Materials Act, in force since May 2024, sets explicit 2030 benchmarks for the strategic materials it depends on, including battery-grade nickel: at least 10 percent of the EU's annual needs from domestic extraction, 40 percent from domestic processing, 25 percent from recycling, and, critically for Indonesia, no more than 65 percent of the bloc's needs for any single strategic material sourced from one non-EU country at any stage of processing. The Act does not name Indonesia directly, but the arithmetic does: a country supplying the majority of the world's nickel is, by definition, the kind of concentrated single-country dependency the 65 percent cap is designed to diversify away from. For Indonesian producers, that means the EU market increasingly rewards documented, verifiable, and diversifiable sourcing relationships over simple volume.

What the US is closing off

The United States has drawn a sharper and more immediate line. Under the Inflation Reduction Act's foreign entity of concern (FEOC) rule, a battery mineral producer more than 25 percent owned, controlled by, or subject to the direction of a government in China, Russia, North Korea, or Iran loses eligibility for IRA tax credits, covering board seats, voting rights, and equity stakes alike. According to Fastmarkets research, the vast majority of Indonesia's roughly 2.2 to 2.3 million tonnes per year of existing nickel processing capacity, along with another 1.4 million tonnes per year under construction, carries more than 25 percent Chinese ownership, placing it on the wrong side of that line. Separately, IRA vehicle credits require battery minerals to draw at least 40 percent of their value, a share that rises annually, from the United States or an FTA partner, and Indonesia does not currently have a free trade agreement with the US. Between the ownership rule and the FTA requirement, most Indonesian nickel is effectively locked out of the most generous segment of US battery demand for now, regardless of the ore's own environmental record.

The environmental record under the microscope

Buyers assessing Indonesian nickel are not only reading trade regulations. Independent monitoring has sharpened scrutiny of the industry's land footprint. Research shared by IUCN NL found nickel mining concessions on Sulawesi overlapping directly with Key Biodiversity Areas (KBAs), including roughly 58,000 hectares of overlap between 22 separate concessions and KBAs within the Morowali Industrial Park area alone. A separate analysis of satellite-based forest-loss alerts found the rate of alerts inside nickel concessions roughly doubled between 2020 and 2023, with 6,115 hectares of alert-flagged forest loss recorded across 329 concessions in 2023 alone, and more than half a million hectares of forest within active nickel concessions identified as at risk over the longer term.

Not every disclosure in this space runs one direction. PT Vale Indonesia has itself identified and published roughly 14,137 hectares of Key Biodiversity Area overlap within the area it considers mineable in its Sorowako block, the kind of proactive, company-published figure that lets outside observers actually assess exposure rather than infer it after the fact.

That distinction matters. A concession overlapping a KBA is not automatically a site of harm, and Indonesia's environmental permitting process requires impact assessment before extraction proceeds. But the gap between concessions where overlap is disclosed and quantified by the operator itself, as PT Vale has done, and concessions where the only public data comes from third-party satellite monitoring after the fact, is precisely the kind of measurement gap that determines whether a buyer, a lender, or an EU customs officer applying due diligence rules can trust a given tonne of nickel's environmental story.

Indonesia's own response is taking shape

The response is not starting from zero. On June 12, 2025, Indonesia's Ministry of National Development Planning (Bappenas) and WRI Indonesia formally launched the National Nickel Industry Decarbonization Roadmap, built with more than 30 nickel mining and smelting companies across Sulawesi and North Maluku alongside national ministries, local governments, and academic institutions. The roadmap targets an 81 percent cut in nickel industry emissions by 2045, aligned with Indonesia's broader net-zero commitment, through four strategies: energy and material efficiency, including waste-heat recovery; fuel switching away from thermal coal toward LNG, diesel, and biodiesel; material substitution, including lower-grade ore feed and biomass-based reductants; and a shift to low-carbon electricity, anchored by a proposed 47.3 gigawatts of new hydropower, wind, and solar generation reaching nickel smelters by 2045, plus a further 5.1 gigawatts of green hydrogen-based capacity recommended for North Maluku specifically.

Separately, Indonesia's nickel industry association has signaled it intends to develop its own global ESG standards for the sector, an effort explicitly framed as a response to the international scrutiny described above rather than a defensive dismissal of it. Whether that standard-setting effort converges with EU due diligence requirements, US FEOC-style ownership screening, and independent biodiversity monitoring, or produces a parallel domestic standard that buyers still discount, will likely determine how much of Indonesia's nickel clears the growing list of market-access filters over the next several years.

Sirkularium's view

Indonesia does not need to choose between downstreaming ambition and credible environmental governance. It needs the same rigor applied to both. The country's roadmap toward an 81 percent emissions cut and a genuinely diversified, renewable-powered smelting base is a serious, well-resourced start on the energy side. The unfinished half is land and biodiversity: consistent, independently verified, company-level disclosure of KBA overlap, deforestation exposure, and reclamation commitments, produced routinely rather than only after an NGO's satellite analysis forces the question. PT Vale's own published KBA figures show that kind of disclosure is already possible within Indonesia's existing mining sector. Extending it, along with the GIS-based mapping and standardized economic-loss methodology that already underpin Indonesia's environmental accounting elsewhere, across the rest of the nickel industry is the clearest way for Indonesian producers to convert scrutiny into an advantage, and to make sure the transition minerals the world needs from Indonesia keep meeting the market-access tests that Europe, the United States, and increasingly Indonesia's own regulators are all writing at once.

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Sirkularium

Sirkularium is a thought-leadership and advisory institution accelerating the circular transition across solid waste, water, and energy, working with government and public institutions.

In sustainable resources, Sirkularium advises on water, tailings, and ESG governance so resource projects stay credible and investable.

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