Strategic Goods & Permits — What You Need Before Importing or Exporting Controlled Items

Zimbabwe is, before it is anything else in trade terms, a mining country. Gold, platinum-group metals, diamonds, lithium-bearing minerals, chrome, coal and coke, black granite and other dimensional stone, and a long tail of base and industrial minerals dominate the export ledger and underwrite the fiscus. Whoever stands at the export gate — Robert Gabriel Mugabe International Airport for gold and diamonds, Beitbridge and Plumtree for bulk minerals by road, Chirundu and Forbes/Mutare for the regional corridors — is standing at the single most revenue-sensitive, smuggling-exposed point in the whole customs system. This lesson teaches the discipline that makes that officer effective: minerals identification — the capacity to recognise a mineral presented for export (or import), verify the declared species against the documents, and detect the mis-declaration of one mineral as another, of a high grade as a low grade, or of brass as gold.

The identification skill is technical, not legal — it draws on basic mineralogy: the eleven physical properties used to identify minerals (crystal form, habit, hardness, specific gravity, colour, streak, lustre, cleavage, fracture, fusibility, fluorescence, plus magnetism), the Mohs Scale of Hardness (Talc 1 → Diamond 10), and the distinctive signatures of the economically important species. But the skill exists to serve a legal and fiscal purpose, and that is where customs law enters. Under Section 61(1) of the Customs and Excise Act [Chapter 23:02], where the exportation of any goods is restricted or controlled by any enactment, those goods may be exported only in conformity with that enactment — and minerals are the textbook case. The controlling enactments sit largely outside the Customs Act: the Minerals Marketing Corporation of Zimbabwe (MMCZ) export-control framework, the Reserve Bank of Zimbabwe / Fidelity Gold Refinery monopsony for gold, the Kimberley Process Certification Scheme for rough diamonds, and the Mines and Minerals Act [Chapter 21:05] royalty regime. Customs is the enforcement chokepoint where those controls are physically verified at the border, and identification is what makes verification real rather than nominal.

Mineral identification serves four customs purposes simultaneously. (i) Tariff classification — minerals fall across several Harmonized System (HS) chapters (gold and diamonds in Chapter 71, coal and coke in Chapter 27, lithium-bearing ores in Chapter 25 or 26 depending on processing), and the classification drives the rate and the controls. (ii) Valuation — per-unit values differ by orders of magnitude (gold is worth tens of dollars per gram; coal cents per kilogram), so identifying the species and grade is the precondition for a defensible Value for Duty Purposes (VDP) under the First Schedule to the Act. (iii) Regulatory verification — MMCZ permits, RBZ authorisations and Kimberley Process certificates are species-specific; mis-declaration defeats the control. (iv) Anti-smuggling — minerals are high-value, easily concealed and historically the most enforcement-intensive flow in the country, gold to Dubai and South Africa above all.

The fiscal layer has changed materially and a 2026 reader must hold the current position. The mineral export levy in Section 22P of the Finance Act [Chapter 23:04] (read with Section 36P of the Income Tax Act [Chapter 23:06]) — a levy on top of mining royalty — was set at 2% of gross value by Finance Act No. 7 of 2024 with effect from 1 January 2025 on lithium, black granite, quarry stones and uncut/cut dimensional stone, and was raised to 3% by Finance Act No. 7 of 2025 with effect from 1 January 2026, with coal added to the listed minerals. Gold royalty is now a tiered, price-linked charge under the Twenty-Fourth Schedule of the Income Tax Act — 3% at or below US$1,200/oz, 5% between US$1,201 and US$2,499/oz, and 10% at or above US$2,500/oz — withheld at source by Fidelity Gold Refinery. And for related-party mineral exports, Section 31 of Finance Act No. 7 of 2025 inserted a new paragraph 4(5)(f) into the Thirty-Fifth Schedule (Transfer Pricing) mandating the Quoted Price Method — the active-market reference price on the transaction date — from 1 January 2026. For VAT, mineral exports are zero-rated under Section 10 of the VAT Act [Chapter 23:12], while imports of mining and assay equipment attract VAT on importation under Section 6(1)(b) read with Section 12A at the standard rate, now 15.5% from 1 January 2026.

This lesson stands on the classification → valuation → origin → duty spine built earlier in the chapter (Tariff Classification, Customs Valuation, Origin & Preference, Duty/Surtax/Excise/VAT computation) and on the controls and enforcement modules that precede it (Prohibited & Restricted Goods, Strategic Goods/CBRN, Green Customs & MEAs, Searches, Offences). It is, in a sense, where the technical and the legal meet a rock in an officer's gloved hand. Read it as the practical capstone of mineral-export control: the moment where knowing what the thing is determines what the law does to it.

A.1 From the abstract border to the physical mineral

Every prior customs lesson has, in one way or another, dealt with representations of goods — a tariff heading, a declared value, a certificate of origin, a Customs Procedure Code keyed into ASYCUDA World. Minerals identification is the lesson where the representation meets the physical object. A clearing agent declares "30 tonnes of lithium ore (Petalite)" or "rough diamonds, 1,200 carats" or "gold bullion, 12 kg". The declaration is a claim. The officer's job, here, is to test that claim against the rock itself — its colour, its weight-for-volume, its hardness, the way it scratches glass or is scratched by a knife, the way it conducts heat to the lip. Identification is the bridge between the paper world of the declaration and the mineral world of the consignment.

A mineral, to begin from first principles, is a solid chemical compound with a fairly well-defined chemical composition and a specific crystal structure that occurs naturally in pure form. That definition does three things at once. It excludes liquids and gases (a mineral is solid). It requires a definable chemistry (gold is Au; diamond is carbon, C; quartz is SiO₂) — which is why minerals can be tested chemically. And it requires a crystal structure — an ordered, repeating atomic lattice — which is why minerals have consistent physical properties (hardness, density, cleavage) that can be measured in the field. Because the chemistry and the lattice are fixed for a given mineral, the physical properties are diagnostic: they are nature's fingerprint, and the officer's identification kit is simply a way of reading that fingerprint.

A.2 Where the topic sits in the chapter

Having mastered Tariff Classification (the HS and the General Rules of Interpretation), Customs Valuation (the six methods and the First Schedule), Rules of Origin & Preference, and the Duty/Surtax/Excise/VAT computation cascade, and having worked through the controls and enforcement modules — Prohibited & Restricted Goods, Strategic Goods (STCE/CBRN), Green Customs & MEAs, Searches, and Offences — we now turn to the one discipline that those modules presuppose but do not teach: the ability to identify the commodity. Classification presupposes you know what the good is. Valuation presupposes you know its species and grade. Export control under Section 61(1) presupposes you can tell whether the thing in the box is, in fact, the controlled mineral the documents describe — or a decoy concealing it. Minerals identification supplies that missing competence for the highest-stakes commodity class in Zimbabwe's trade.

A.3 Why ZIMRA enforcement interest is extreme here

Three features make minerals the apex of customs enforcement interest. First, value density: a briefcase can hold gold worth more than a truckload of FMCG goods, so the incentive to smuggle is enormous and the concealment easy. Second, fiscal leverage: minerals carry royalty (Mines and Minerals Act), a mineral export levy (Section 22P Finance Act), gold royalty tiers (Twenty-Fourth Schedule), and feed the country's foreign-currency receipts through the CD1 exchange-control system — so a mis-declared or smuggled mineral leaks revenue on several axes at once. Third, inter-agency dependence: unlike most customs work, mineral control is irreducibly multi-agency — ZIMRA at the border, MMCZ as the marketing/export-control authority, RBZ/Fidelity Gold Refinery for gold, the Kimberley Process authority for diamonds, and the Ministry of Mines for titles and royalties. Identification is the officer's contribution to that coordinated control; without it, the coordination has a blind spot at the precise point where the mineral physically crosses the line.

B.1 The Customs and Excise Act [Chapter 23:02] — the export-control spine

The Customs Act does not itself name minerals, and that is the key structural point: it provides the machinery and the offences, and imports the substantive control from other enactments. The relevant provisions:

• Section 16 — Prohibition of importation or exportation except through appointed ports or by defined routes. Minerals, like all goods, must leave Zimbabwe through an appointed port of exit. This is why mineral export is channelled to specific posts (RGM International Airport for gold/diamonds; Beitbridge and Plumtree for bulk) where the verification capability is concentrated.

• Section 54 — Exporter to deliver customs documents and produce goods. Every person (or authorised agent) exporting goods must, before exportation, deliver to an officer a bill of entry (or prescribed documents), recording full particulars of the goods and their destination on the Customs computer system (ASYCUDA World) where direct trader input exists. Crucially, Section 54(5) empowers the officer to require the exporter to produce all invoices and documents and, at the exporter's own risk and expense, to unload, open, unpack, repack any packages the officer requires for examination — the statutory hook for physically inspecting and testing a mineral consignment. Section 54(3) requires a separate bill of entry per consignment; Section 54(8) makes export in contravention an offence (fine up to level six or up to six months' imprisonment, or both).

• Section 54A — Person in charge of a vehicle to report goods before leaving Zimbabwe. A road exporter (the typical posture for bulk minerals at Beitbridge) must make a full report of the vehicle and goods at the port of departure.

• Section 60 — Time of exportation. For goods other than post or pipeline, the time of exportation is when the bill of entry is delivered to an officer or when the goods cross the border, whichever is earlier. This fixes the moment at which the rates, controls and exchange rates in force apply (compare Section 226, rates of duty in relation to time of importation/exportation/entry).

• Section 61 — Restriction of exportation. This is the master hinge for minerals. Section 61(1): "If the exportation of any goods is restricted or controlled by any enactment, such goods shall only be exported in conformity with the provisions of such enactment." Section 61(2): exporting (or assisting to export) goods whose export is prohibited or restricted by any enactment, in contravention of that enactment, is an offence. Section 61(3) deems a wide range of acts — entering goods for export, loading them, handing them to a carrier, placing them in the post — to be an attempt to export, so the offence bites early. By this section, the entire web of MMCZ, RBZ/Fidelity, Kimberley Process and Mines and Minerals Act controls becomes customs-enforceable at the border.

• Sections 47 and 48 — Prohibited and Restricted importations, and Section 183 — Importation of a prohibited or restricted thing to be an offence (fine up to level twelve or three times the duty-paid value, whichever is greater, or up to five years' imprisonment, or both). These bite on the import side — e.g. mercury for amalgamation, or controlled assay reagents — and on re-imports, and they illustrate the penalty architecture that parallels the export controls.

• False declaration and seizure machinery — the false statement/false declaration offences (the Section 173–174 family) and the seizure power are the operational tools when an identification reveals that the declared mineral, grade or value is untrue. (Confirm the exact section numbers for false declaration and seizure against the consolidated Act before pleading them; the project's Offences and Searches modules set them out.)

• Valuation: the First Schedule (WTO Valuation Agreement / GATT Article VII), worked in the Customs Valuation module, supplies the transaction value primary method and the prescribed fallbacks. For minerals, valuation is intimately tied to identification and grade — see § C and § E.

B.2 The controlling enactments outside the Customs Act

Section 61(1) points outward. The principal external controls (substantive law lives here; confirm exact instruments before citing in a ruling):

• Minerals Marketing Corporation of Zimbabwe (MMCZ) framework. MMCZ is the principal mineral-export controlling authority, empowered to control the export of all minerals (with statutory exceptions) and to require an MMCZ export permit/certificate for each consignment. ZIMRA verifies the MMCZ permit at the border as a Section 61(1) conformity condition. Exemptions noted in the source: gold or silver exported by the RBZ, and goods where MMCZ itself is the exporter or the exporter's agent, are outside the certificate requirement. ; confirm the precise export-control SI (the Module cites "SI 111 of 1983, Section 4") and any successor instrument.]

• Reserve Bank of Zimbabwe / Fidelity Gold Refinery monopsony for gold. Gold is, in the formal channel, bought and exported through the State gold-purchase authority — historically Fidelity Printers & Refiners, now Fidelity Gold Refinery — under the RBZ framework. Gold export is therefore restricted principally to authorised channels, and gold presented for private export in commercial quantity is a red flag. The gold royalty is withheld at source by Fidelity Gold Refinery in the formal channel.

• Kimberley Process Certification Scheme (KPCS). For rough diamonds, Zimbabwe is a KPCS participant; export requires a Kimberley Process certificate addressing "conflict diamond" concerns, in addition to MMCZ documentation. The customs officer verifies both certificates.

• Mines and Minerals Act [Chapter 21:05]. Source of the mining royalty (administered with the Ministry of Mines), and the title regime; Section 245 is cited in the ZIMRA guidance both for royalty and for the consequence that mining title may be suspended for material default on the specified-minerals levy.

B.3 The fiscal overlay — levy, royalty, tiers and transfer pricing (current law)

A mineral leaving Zimbabwe can attract, in parallel, several distinct charges. Keeping them straight is essential, because they have different bases, different administrators and different returns:

• Mining royalty — Mines and Minerals Act [Chapter 21:05] Section 245, read with the Schedule to Chapter VII of the Finance Act [Chapter 23:04]. A charge on the gross fair market value of mineral output, declared on the REV 5C. Confirmed source rates: coal 2%, black granite 2%, other cut/uncut dimensional stone 2%, quarry stones 2% (the last introduced w.e.f. 1 January 2025). **

• Mineral export levy — Section 22P of the Finance Act [Chapter 23:04], read with Section 36P of the Income Tax Act [Chapter 23:06]. A levy on top of royalty, on the gross value of the sale within Zimbabwe or on export of listed minerals. Old rule: Finance Act No. 7 of 2024 substituted Section 22P to impose 2% on lithium, black granite, quarry stones and uncut/cut dimensional stone with effect from 1 January 2025. New rule: Finance Act No. 7 of 2025 raised the rate to 3% and the listed minerals are coal, lithium, black granite, quarry stones, and uncut and cut dimensional stone, with effect from 1 January 2026. The levy is payable in the currency of trade (USD-sales → USD levy; ZiG-sales → ZiG levy; no netting across currencies). The specified-minerals return (coal and cut & uncut dimensional stone) is monthly, due on or before the 10th of the following month, filed on the ZIMRA Self-Service Portal. **

• Gold royalty tiers — Twenty-Fourth Schedule of the Income Tax Act [Chapter 23:06]. A price-linked, tiered royalty on the gross value of gold sold or exported, effective 1 January 2026: 3% at or below US$1,200/oz; 5% for US$1,201–US$2,499/oz; 10% at or above US$2,500/oz. The applicable tier is fixed by the price realised at the point of sale; ZIMRA guidance on price-averaging for batched shipments is expected. Withheld at source by Fidelity Gold Refinery in the formal channel.

• Transfer pricing — Thirty-Fifth Schedule of the Income Tax Act, new paragraph 4(5)(f) inserted by Section 31 of Finance Act No. 7 of 2025, effective 1 January 2026. For minerals exported from Zimbabwe, the Quoted Price Method (QPM) is mandatory: the benchmark is the active-market reference price prevailing on the transaction date (LME, COMEX, Shanghai Futures Exchange and other recognised exchanges), displacing thin "comparable" related-party prices. Where the actual related-party sale price was below the quoted price, a transfer-pricing adjustment increases taxable income.

• VAT — VAT Act [Chapter 23:12]. Mineral exports are zero-rated under Section 10 (the export of goods), so no output VAT arises on export and input VAT is recoverable. Imports of mining, assay and laboratory equipment attract VAT on importation under Section 6(1)(b) read with Section 12A, at the standard rate of 15.5% from 1 January 2026 (up from 15%). Local sales of minerals (e.g. coal to a domestic power utility) are standard-rated.

The discipline for the officer is to recognise that identification feeds all of these: the wrong species or grade mis-states the royalty base, the levy base, the gold tier, the transfer-pricing benchmark and the VAT treatment in a single stroke.

C.1 The eleven physical properties

Minerals are identified by physical properties because, as § A.1 explained, a fixed chemistry and lattice produce consistent, measurable characteristics. The eleven commonly used (a twelfth, magnetism, is often added) are:

(a) Crystal form. Minerals are built from groups of atoms, and the atomic arrangement governs the crystal's form (shape). Different chemistries give different atom groups and therefore different crystal forms — so the form is diagnostic. Diamond, in the cubic system, can appear as octahedra; quartz forms hexagonal prisms.

(b) Habit. The general appearance a mineral tends to take — blocky crystals, long slender ones, or aggregates. Glassy but cubic crystals, for instance, tell you the specimen is not quartz. Habit is the "body language" of the mineral.

(c) Hardness. One of the most important properties: resistance to scratching, measured by comparison against the Mohs Scale (§ C.2). Hardness is consistent for a given mineral and so is a primary diagnostic.

(d) Specific gravity (SG). The weight of a substance in air divided by the difference between its weight in air and its weight when immersed in water — i.e. density relative to water. SG is powerful for minerals because the heavy ones (gold SG 19.3) are dramatically denser than ordinary rock (SG ~2.6), so "weight-for-volume" is an immediate field signal.

(e) Colour. A highly variable characteristic that cannot be relied on alone — impurities change the colour of one mineral, and different minerals share colours. Colour is a starting hypothesis, never a conclusion (see Pitfall H.1).

(f) Streak. The colour of the mineral's powder, obtained by grinding/scratching a small amount on a porcelain streak plate. The streak may differ markedly from the colour of the mass and is more reliable than colour, because the powder removes surface and crystal-size effects.

(g) Lustre. The appearance of a fresh surface when reflecting light. Types include metallic (like polished metal, e.g. gold), sub-metallic (imperfect metallic, e.g. tantalite), and adamantine (brilliant, like diamond). Lustre quickly separates metallic minerals from non-metallic.

(h) Cleavage. The tendency of a crystallised mineral to break along definite directions, yielding smooth cleavage planes. A perfect cleavage gives smooth, lustrous surfaces easily — which is why even diamond, the hardest mineral, can be cleaved with a hammer and chisel along its cleavage plane (exploited by diamond cutters).

(i) Fracture. A break other than along a cleavage — the surface produced when the mineral does not split cleanly.

(j) Fusibility. The relative ease with which a mineral melts on heating. Stibnite fuses in a candle flame; garnet needs ~1,200 °C. Fusibility separates low-melting from refractory minerals.

(k) Fluorescence. Some minerals emit light under ultraviolet light (e.g. scheelite) — a UV lamp is a simple field discriminator.

(l) Magnetism (the twelfth). Certain metallic minerals are magnetic (e.g. magnetite, and to a lesser extent pyrrhotite). A magnet is a cheap, decisive field test for these.

The officer's basic field kit — a Mohs reference set or proxies (fingernail ~2.5, copper coin ~3, knife/glass ~5.5), a streak plate, a magnifying lens (loupe), a magnet, and access to acids for confirmatory chemistry, plus a UV lamp — lets these properties be tested at the border. For high-value or contested cases, the consignment is referred to MMCZ technical staff or an accredited laboratory (e.g. micro X-ray fluorescence, µXRF) for definitive analysis.

C.2 The Mohs Scale of Hardness

The Mohs Scale ranks ten reference minerals by increasing hardness; an unknown is placed by seeing what it scratches and what scratches it:

Mohs No.	Standard mineral	Field proxy
1	Talc	scratched by fingernail
2	Gypsum	scratched by fingernail (~2.5)
3	Calcite	scratched by copper coin (~3)
4	Fluorspar (fluorite)	—
5	Apatite	scratched by knife (~5.5)
6	Orthoclase feldspar	scratches glass
7	Quartz	scratches glass readily
8	Topaz	—
9	Corundum	—
10	Diamond	scratches everything; scratched by nothing natural

A fingernail scratches talc and gypsum but not calcite; a knife blade scratches apatite but not feldspar. The scale is the international standard, valued precisely because it needs no instrument — only comparison — which makes it ideal at the border.

C.3 Gold

What gold is. Gold is a metal, gold/yellow in colour, that "may look like brass". The decisive difference: brass dissolves in sulphuric or nitric acid; gold does not (gold resists individual acids and dissolves only in nitrohydrochloric acid / aqua regia). Local names include mukute, igolide, chuma, "stuff", "yellow".

The seven forms of gold. The officer must know each, because gold presents very differently depending on stage:

1. Alluvial gold — fine particles deposited in riverbeds, washed down by water; average ~98% purity; recoverable without sophisticated machinery.
2. Gold concentrate — pulp or mortar with very high gold concentration.
3. Reef gold — gold embedded in rock, requiring equipment to extract.
4. Gold nuggets — large natural pieces.
5. Gold amalgam — an alloy of gold and mercury.
6. Retort — the product of an amalgam after the mercury has been removed.
7. Gold bullion — the product of smelting (refined bars).

Characteristics and tests. Gold is the most malleable and ductile of metals — beaten to sheets or drawn to wire without breaking. Melting point 1,063 °C; an excellent conductor of heat and electricity; yellow where most pure metals are grey/silver. Diagnostic triad: specific gravity 19.3 (weight feels disproportionate to volume), hardness ~2.5 (soft, fingernail-scratchable), and acid behaviour (resists nitric/sulphuric; dissolves in aqua regia — distinguishing it from brass, which dissolves, and from pyrite/"fool's gold", which is harder and brittle).

Customs significance. Gold is Chapter 71 of the HS (precious metals). Export is restricted to the RBZ/Fidelity Gold Refinery channel; gold royalty is tiered and price-linked (Twenty-Fourth Schedule; § B.3). Identification at RGM International Airport is the front line against the country's most intensive smuggling flow.

C.4 Diamonds

What a diamond is. From the Greek adamas, "indestructible". Chemically carbon (C) in the cubic crystal system; the hardest known mineral (Mohs 10). Rough diamonds are un-worked (un-cut) stones.

Recovery — and why it shows in the shape. Two recovery settings, which the officer must distinguish:

• Mine (pipe) deposits — kimberlite. Kimberlite is rock from a volcano that burst to the surface, cutting through and carrying chunks of overlying rock in which diamonds are found. These diamonds have not been eroded or weathered, so they are typically angular, showing classic crystal shapes with clearly defined faces and edges.
• Placer deposits. Diamonds moved from their source rock by erosion and other forces, coming to rest in river beds, beaches or sea floors. Transport scratches, bumps and rounds the edges, so placer diamonds tend to have worn, rounded edges like stream pebbles, and irregular/elongated shapes.

Types. (a) Natural — formed in nature, recovered by mining on land or in water; (b) Synthetic — laboratory-made, usually uniform in size and colour (a key tell).

Properties and tests. (a) Hardness 10 — scratches glass, quartz and corundum (the scratch test). (b) Cleavage — despite its hardness, it cleaves easily along its cleavage plane (cutters exploit this). (c) Specific gravity 3.52 — about a third denser than typical rock. (d) Colour — all shades but mostly white, yellow or brown. (e) Lustre — brilliantly adamantine. (f) Repels water but readily accepts wax and grease. (g) Thermal conductivity — an excellent heat conductor (about 4× copper); touched to the lips it feels ice-cold because it draws heat away. The three field-test pillars are hardness, specific gravity and thermal conductivity.

Rough diamond shapes. Octahedron (eight-faced double pyramid), dodecahedron (twelve-faced), cube (rare in gem quality), whole (rounded modifications of the above), and irregular (elongated, rounded — common in river-bed/alluvial placers).

Fake-diamond field tests. (i) Newspaper test — a real diamond placed on newsprint does not magnify the text (it refracts, it does not act as a lens); a fake (glass) magnifies. (ii) Light test — focused light passed through a real diamond produces a halo; through a fake, the light passes straight through and is visible on the far side. Both rely on the diamond's refractive behaviour.

Customs significance. Diamonds are Chapter 71; rough-diamond export requires the MMCZ certificate plus the Kimberley Process certificate. The officer verifies both and tests the stones.

C.5 Emeralds

The word "emerald" derives from the Greek smaragdus, "green"; emeralds are green by definition. An emerald is a green variety of the mineral beryl, coloured green by trace chromium (and sometimes vanadium). Specific gravity ~2.6–2.8.

Field tests for a real emerald (from the source): (a) Water test — a real emerald in a glass of water radiates green light; an imitation does not. (b) Eye test — a real emerald placed on the eye gives a cool feeling; an imitation warms quickly. (c) Soft-wood test — rubbed slowly on soft wood, a real emerald shines; a fake shows no change. (d) Light reflections on a small white cloth, magnifying-lens inspection (for inclusions), and a water-drop test supplement these, with SG 2.6–2.8 as a confirmatory measure. Synthetic emeralds are increasingly common and often require laboratory confirmation (Pitfall H.3). Emeralds fall under Chapter 71 (precious/semi-precious stones) and are MMCZ-controlled.

C.6 Lithium-bearing minerals

Strategic importance. Lithium is the battery-era strategic mineral; Zimbabwe holds significant LCT-pegmatite resources, and lithium is squarely within the mineral export levy net (§ B.3). The officer must recognise the six economically relevant lithium-bearing minerals:

Mineral	Distinctive features
Lepidolite	Pink/red/purple mica (sheet-like cleavage); lithium-rich; commonly with rubidium/cesium; the most common lithium mineral
Petalite	Colourless/white/grey/pink; tabular prismatic; vitreous lustre
Spodumene (Triphane)	Pyroxene; colourless/yellowish/pinkish/lilac; large prismatic crystals
Amblygonite	Milky-white to salmon-pink; sub-vitreous to resinous lustre
Eucryptite	Lithium-aluminium silicate; less commonly economically mined
Zinnwaldite	Lithium-iron mica; intermediate between muscovite and biotite

Occurrence. About 44% of lithium minerals occur in LCT-pegmatites (LCT = Lithium-Cesium-Tantalum) and associated metasomatic rocks; others in non-LCT pegmatites, manganese deposits and large salt lakes. Associated elements in LCT-pegmatites include gallium (Ga), rubidium (Rb), niobium (Nb), tin (Sn), tantalum (Ta) and titanium (Ti) — and by analysing these (e.g. by µXRF), satisfactory lithium content can be predicted. Associated minerals include tantalite, pollucite, beryl, microlite and cassiterite — relevant because some are separately strategic/controlled. Lithium ores classify in HS Chapter 25 or 26 depending on processing; the species and Li₂O grade matter for both valuation and levy/royalty.

C.7 Coal and coke

Coal is a combustible raw mineral, typically black, low-value/high-volume, used for electricity and industrial heat. Coke is a by-product of coal — coal baked in ovens, heated in the absence of air (the coking process, >600 °C); it is grey, hard, porous, burns without smoke, has more energy than coal, and is used to smelt metals (copper, iron, steel, cobalt).

Identification and pricing. Run-of-mine product is crushed and screened by size, and priced by the percentage of chemical elements: moisture, calorific value, ash, fixed carbon, sulphur, phosphorus. Grades (sized in mm) include, for coal: Peas 7–40, Nuts 28–50, Large Cobbles 40–120, NPD Low Ash 0–50, Fines −5, Flints 3–10, Duff 4–10, Thermal 6–30, Slurry −5; and for coke: Coke Breeze −10, Coke Fines −5, Foundry Coke +80, Met Coke 40–80, Coke Nuts 20–60, Coke Peas 10–40. Because grade drives value, mis-declared grade produces under- or over-valuation (Pitfall H.5). Coal/coke classify in HS Chapter 27; coal carries 2% royalty (REV 5C) and the specified-minerals levy (§ B.3).

D.1 The general export-verification sequence

For a mineral consignment presented for export, the officer proceeds:

1. Documentary pre-check. Confirm the bill of entry (export) lodged in ASYCUDA World under the correct Customs Procedure Code (CPC) — the code that states the declaration's purpose (permanent export, temporary export for analysis, re-export). Confirm the supporting set: MMCZ permit/certificate (species, quantity, buyer, export window), commercial invoice and packing list, Bill of Lading/Air Waybill as applicable, the CD1 exchange-control declaration lodged with the authorised-dealer bank (the instrument by which export proceeds are tracked into the country), and — for diamonds — the Kimberley Process certificate; for gold — RBZ/Fidelity authorisation.
2. Species verification against documents. Inspect the mineral against the eleven physical properties, beginning with visual examination of colour, lustre, crystal form and habit, and match the visual identification to the declared species.
3. Field tests. Apply the basic kit — Mohs comparison (knife, glass, copper), streak plate, loupe, magnet, and, where warranted, acid chemistry — to confirm the key diagnostic properties (e.g. SG and acid behaviour for gold; hardness/SG/thermal conductivity for diamond).
4. Refer where critical. For high-value species or contested classification/grade, refer to MMCZ technical staff or an accredited laboratory (e.g. µXRF, or Li₂O assay) for definitive analysis. The consignment may be held, or released on bond pending the result under the deferred-clearance framework.
5. Risk lane and release. ASYCUDA risk-targets the declaration to a lane — Green (release, no intervention — rare for minerals), Yellow (documentary check), or Red (physical examination — the default posture for high-risk minerals). Assess any duty/levy/royalty obligations, take payment, and release.
6. Record and post-clearance. Record the verification result in the bill of entry documentary chain; the consignment remains within the post-clearance audit window, and the parallel levy/royalty returns (REV 5C; specified-minerals return) fall due on their own cycles.

D.2 Gold verification at the airport

Gold export is principally through RGM International Airport. The officer: (i) confirms RBZ/Fidelity involvement (export is generally restricted to the authorised gold channel); (ii) inspects against expected characteristics — yellow colour, distinctive density (~19.3 g/cm³), distinctive feel; (iii) verifies the form (bullion bars are normal in the formal channel; alluvial or concentrate forms presented for export suggest unauthorised movement); (iv) where suspicion arises, applies the acid-solubility test (gold resists nitric acid; brass dissolves) on a small sample, or refers for assay; (v) escalates commercial-quantity gold lacking authorisation to Investigations for seizure and prosecution.

D.3 Diamond verification

Rough-diamond export proceeds through MMCZ certification + Kimberley Process certificate. The officer confirms both certificates, inspects the stones against shape expectations (octahedron/dodecahedron/cube for mine deposits; rounded/irregular for placers), applies the hardness test (scratches glass), the thermal-conductivity test (cold to the touch), and the fake-diamond tests (newspaper, light) where appropriate, escalating discrepancies.

Because minerals are predominantly exported, the headline computations are levy and royalty (not import duty). A worked import example is added for the equipment side, where the full duty/VAT cascade applies. All rates must be confirmed against the current Finance Act / Tariff Notice for the period; figures below use the confirmed source rates and are flagged where a rate is period-sensitive.

E.1 Worked Example 1 — Coal exporter: royalty + specified-minerals levy (currency-of-trade)

Facts. Hwange Stone & Coal (Pvt) Ltd exports, in January 2026: coal, gross value USD 1,200,000; and sells coal locally, gross value ZiG 4,800,000. Compute the mining royalty (REV 5C) and the specified-minerals levy (Section 22P / Section 36P), keeping currency of trade separate.

ROYALTY (Mines & Minerals Act Section 245; Schedule to Chapter VII) — coal 2%
 Export leg : USD 1,200,000 x 2% = USD 24,000 (REV 5C, USD)
 Local leg : ZiG 4,800,000 x 2% = ZiG 96,000 (REV 5C, ZiG)

SPECIFIED-MINERALS LEVY (Section 22P Finance Act; 3% from 1 Jan 2026 on coal)
 Export leg : USD 1,200,000 x 3% = USD 36,000 (levy return, USD)
 Local leg : ZiG 4,800,000 x 3% = ZiG 144,000 (levy return, ZiG)

COMBINED STATE TAKE on the USD export leg
 Royalty USD 24,000 + Levy USD 36,000 = USD 60,000 on USD 1,200,000 (5.0%)

Notes. The royalty (REV 5C) and the levy (specified-minerals return) are separate returns for the same gross value — both are filed and paid. The levy return is monthly, due the 10th of the following month, in the currency of trade; USD pays in USD and ZiG in ZiG, with no cross-currency netting. Both charges are deductible for income tax (Section 15(2)(a) ITA) in the producer's ITF 12C. **

E.2 Worked Example 2 — Gold: price-tiered royalty (Twenty-Fourth Schedule)

Facts. A licensed producer delivers 20 kg of gold to Fidelity Gold Refinery in February 2026; the price realised is US$2,600/oz. Compute the gold royalty. (1 kg = 32.1507 troy ounces.)

Step 1 Quantity in ounces : 20 kg x 32.1507 oz/kg = 643.01 oz
Step 2 Gross value : 643.01 oz x US$2,600/oz = US$1,671,840
Step 3 Tier selection : price US$2,600/oz >= US$2,500 -> 10% tier
Step 4 Gold royalty : US$1,671,840 x 10% = US$167,184
 (withheld at source by Fidelity Gold Refinery and remitted to ZIMRA)

Contrast — the tier matters. Had the same gold sold at US$2,400/oz (US$1,543,234 gross), the 5% tier would apply → royalty US$77,162. At US$1,150/oz (US$739,733 gross), the 3% tier → US$22,192. The price band selected at the point of sale therefore changes the charge by a multiple — which is exactly why ZIMRA expects price-averaging guidance for batched shipments. **

E.3 Worked Example 3 — Lithium export: levy + transfer-pricing (QPM) adjustment

Facts. Pegmatite Resources (Pvt) Ltd exports 30 tonnes of spodumene concentrate to a related-party offshore buyer in March 2026. It invoices the related party at USD 900/tonne (USD 27,000). The active-market quoted price for equivalent spodumene concentrate on the transaction date is USD 1,100/tonne.

Step 1 Specified/mineral export levy (Section 22P, lithium, 3% from 1 Jan 2026)
 on gross value of the sale on export:
 Invoiced gross : 30 t x USD 900 = USD 27,000 -> levy = USD 810
 (>[VERIFY: confirm whether the levy base is the invoiced price or the
 arm's-length/quoted value where TP applies; conservative practice
 applies the levy on the higher transfer-pricing-adjusted value.])

Step 2 Transfer pricing — Quoted Price Method (35th Schedule, para 4(5)(f))
 Arm's-length gross : 30 t x USD 1,100 = USD 33,000
 Under-pricing : USD 33,000 - USD 27,000 = USD 6,000
 -> taxable income is INCREASED by USD 6,000 (the QPM adjustment),
 with tax, penalty and interest on the resulting shortfall.

Step 3 Levy on the adjusted value (conservative):
 USD 33,000 x 3% = USD 990 (i.e. USD 180 more than on the invoiced price)

Teaching point. The QPM removes the old room to argue the price down with thin related-party comparables: the publicly observable, time-stamped exchange price on the transaction date is the benchmark. Misidentifying the lithium species or grade would corrupt both the levy base and the quoted-price comparison — so identification underpins the whole computation. **

E.4 Worked Example 4 — Import side: assay/laboratory equipment (full cascade, VAT 15.5%)

Facts. A mine imports a µXRF mineral analyser for grade verification. FOB USD 40,000, insurance USD 600, freight to Beitbridge USD 2,400. Use an illustrative ZIMRA Rate of Exchange for Customs Purposes for the relevant fortnight; values here are USD-denominated, so conversion is shown symbolically. Assume the analyser's tariff line carries a duty rate to be confirmed from the Tariff Notice; surtax not listed; excise not applicable; VAT on importation 15.5% (Section 6(1)(b)/12A, from 1 January 2026).

Step 1 FOB = USD 40,000
Step 2 + Insurance USD 600 + Freight USD 2,400 = USD 43,000 (CIF)
Step 3 First Schedule adjustments -> Customs Value (VDP) = USD 43,000
Step 4 Customs duty = VDP x tariff-line rate
 Tariff Notice (SI 203 of 2022 and amendments); compute symbolically]
 = USD 43,000 x r% = USD (43,000 r%)
Step 5 Surtax (not listed for the line) = USD 0
Step 6 Excise (n/a) = USD 0
Step 7 DPV = VDP + duty + surtax + excise = USD 43,000 (1 + r%)
Step 8 VAT on importation = DPV x 15.5%
 = USD 43,000 (1 + r%) x 0.155 = USD 6,665 (1 + r%)
Step 9 Other levies (none applicable) = USD 0
 TOTAL TO ZIMRA = duty + VAT
 = 43,000 r% + 6,665 (1 + r%) USD

If, illustratively, the duty rate is r = 0% (many analytical instruments attract low/duty-free treatment — confirm), the import bears VAT only: USD 43,000 × 15.5% = USD 6,665. Capital equipment for mining may also qualify for a rebate under the Tariff Notice's capital-goods provisions — confirm the rebate item and conditions. This example shows the contrast with the export side: exports of the minerals themselves are zero-rated and bear levy/royalty, not duty/VAT, whereas imported equipment runs the full CIF → duty → VAT cascade.

F.1 Customs officers at the mineral export points

The identification function runs continuously at the country's mineral gateways. RGM International Airport is the primary gold and diamond point — high value, low bulk, intense smuggling pressure. Beitbridge and Plumtree handle bulk minerals by road (lithium concentrate, chrome, coal/coke, dimensional stone) to and through South Africa. Chirundu (the One-Stop Border Post on the Zambian corridor) and Forbes/Mutare (the Mozambican/Beira corridor) carry cross-border bulk. Officers at these posts receive MMCZ-coordinated training and maintain liaison with MMCZ technical staff for contested or high-value cases. The officer's daily reality is documentary verification plus a physical look-and-test against the eleven properties — the paper and the rock checked against each other.

F.2 MMCZ, RBZ/Fidelity, Kimberley Process and the mining industry

Mineral control is inter-agency by design. MMCZ is the principal export-control authority: it issues the export permit/certificate and coordinates royalty/marketing; ZIMRA verifies at the border. The relationship mirrors ZIMRA–EMA for hazardous substances and ZIMRA–ParksWildlife for CITES specimens (Green Customs module). For gold, the RBZ/Fidelity Gold Refinery monopsony adds a second authority; for diamonds, the Kimberley Process adds a third. The single most important operational truth is that a breakdown in any one of these verifications creates the gap a smuggler exploits — so routine information-sharing, joint operations and shared training are not optional niceties but the core of effectiveness.

F.3 Producers, exporters and their advisors

Large mining houses and exporters carry the heaviest compliance load: MMCZ permits per consignment, CD1 lodgement, royalty (REV 5C), the specified-minerals levy where applicable, gold tier checks per shipment, and transfer-pricing files documenting the quoted reference price for each export date. Small-scale and artisanal gold producers sell into the formal channel (Fidelity) and sit in the 5% or 10% gold tier depending on the realised price; their risk is diversion into informal smuggling channels. Cross-border traders moving small parcels face the gold-jewellery threshold question (personal vs commercial quantity). Tax practitioners advising mining clients must hold the identification framework alongside valuation, MMCZ regulation and the tax overlay — because misidentification by an exporter or its advisor produces both customs and regulatory consequences at once.

G.1 The Mohs Scale as an international standard

The Mohs Scale is the globally accepted reference for mineral hardness, used across customs administrations, geological services and the mining industry. Its strength is operational simplicity — comparison against ten reference minerals, needing no instrument — which makes it usable at the border. Together with specific gravity and streak/lustre, it gives the officer a reliable first-line identification without a laboratory.

G.2 The Kimberley Process Certification Scheme (KPCS)

The KPCS is the international framework governing the rough-diamond trade, created to keep "conflict diamonds" out of legitimate commerce. Zimbabwe is a participant; rough-diamond exports require a Kimberley Process certificate that supplements MMCZ documentation. The customs officer's duty is to verify both certificates and to confirm the stones match the certified description — the physical test backing the paper guarantee. (KPCS is a trade-control regime; it sits alongside the MEAs — Basel, Rotterdam, Stockholm, Montreal, CITES — covered in the Green Customs module, which control hazardous and endangered trade rather than diamonds.)

G.3 The HS and the valuation framework as classificatory authority

Identification feeds two international-standard frameworks already taught in this chapter: the Harmonized System (WCO HS Convention) — gold/diamonds/emeralds in Chapter 71, coal/coke in Chapter 27, lithium ores in Chapter 25/26 — and the WTO Valuation Agreement / GATT Article VII (First Schedule), under which the transaction value and its fallbacks fix the Value for Duty Purposes. For minerals, the active-market reference price now also anchors the transfer-pricing benchmark (QPM), tying identification to all three valuation logics.

H.1 Reliance on colour alone. Colour is variable — impurities shift one mineral's colour, and different minerals share colours. Combine visual inspection with physical tests (hardness, SG, streak); never conclude on colour.

H.2 Brass-for-gold confusion. Brass closely resembles gold and is a common disguise. The acid test (nitric/sulphuric dissolves brass; gold resists, dissolving only in aqua regia) is dispositive. Never assume yellow metal is gold without verification; remember pyrite ("fool's gold") is harder and brittle where gold is soft and malleable, and gold's density (19.3) is unmatched by substitutes.

H.3 Synthetic-versus-natural blindness. Synthetic diamonds and emeralds are increasingly common and often uniform in size/colour; distinguishing them can require laboratory analysis. Where customs/regulatory treatment or value differs by origin, the distinction matters — refer when in doubt.

H.4 Misclassification of lithium-bearing minerals. Lepidolite, Petalite, Spodumene, Amblygonite, Eucryptite and Zinnwaldite have different grades and values; declaring one as another (e.g. Petalite for Lepidolite) produces valuation errors and can be a false declaration. Use the visual tells (pink mica = Lepidolite; tabular = Petalite; large prismatic = Spodumene) and µXRF/Li₂O assay for grade.

H.5 Coal/coke grade mis-declaration. Pricing depends on chemical-element percentages and size grade; a mis-declared grade under- or over-values the consignment. Verify the grade against the apparent product where suspicion arises.

H.6 Under-declaration of gold quantity/value. The classic airport fraud: declaring commercial-quantity gold as low-value "jewellery". Test the plausibility of declared value against apparent quantity/density and escalate; the gold-smuggling enforcement priority means substantial gold without RBZ/Fidelity authorisation goes to Investigations.

H.7 Failure to coordinate with MMCZ (and RBZ/KPCS). Identification at the border depends on MMCZ liaison for contested/specialist cases. Proceeding without it risks mis-classification and missed enforcement; for gold, the RBZ/Fidelity check, and for diamonds the Kimberley Process check, are non-negotiable parallel verifications.

H.8 Treating the levy and the royalty as alternatives. They are cumulative for the listed minerals — a coal or dimensional-stone producer files both the REV 5C (royalty) and the specified-minerals levy return on the same gross value. Forgetting one understates the State take and exposes the producer to penalty and possible mining-title suspension (Section 245 Mines and Minerals Act).

Work through the questions one at a time. Choose an answer and it is graded immediately, with an explanation and the provision it comes from. Your progress is saved, so you can stop and resume.

• Minerals identification is the technical discipline — reading a mineral's physical fingerprint — that makes customs control of Zimbabwe's most valuable, most smuggling-exposed commodity class real rather than nominal. It serves classification, valuation, regulatory verification and anti-smuggling at once.
• A mineral is a solid, naturally occurring compound of defined chemistry and crystal structure; identify it by the eleven properties (crystal form, habit, hardness, SG, colour, streak, lustre, cleavage, fracture, fusibility, fluorescence; + magnetism) and the Mohs Scale (Talc 1 → Diamond 10). Colour alone is unreliable.
• Gold: seven forms (alluvial, concentrate, reef, nuggets, amalgam, retort, bullion); SG 19.3, hardness 2.5, dissolves only in aqua regia (distinguishes it from brass and pyrite). HS Chapter 71; export restricted to RBZ/Fidelity Gold Refinery; tiered royalty (3%/5%/10% by price, Twenty-Fourth Schedule, from 1 Jan 2026).
• Diamonds: hardest mineral (Mohs 10), SG 3.52, exceptional thermal conductivity; mine deposits are angular, placers are rounded; fake tests are the newspaper and light tests; export needs MMCZ + Kimberley Process certificates.
• Emeralds: green beryl coloured by chromium/vanadium, SG 2.6–2.8; field tests (water, eye, soft-wood, light). Lithium minerals: the six species (Lepidolite, Petalite, Spodumene, Amblygonite, Eucryptite, Zinnwaldite), mostly in LCT-pegmatites with Ga/Rb/Nb/Sn/Ta/Ti; grade by Li₂O / µXRF. Coal/coke: HS Chapter 27, priced by chemical elements and size grade.
• The legal hinge is Section 61(1) of the Customs and Excise Act [Chapter 23:02]: minerals are exportable only in conformity with the controlling enactment — MMCZ, RBZ/Fidelity (gold), Kimberley Process (diamonds), and the Mines and Minerals Act (royalty). The Customs Act supplies the examination power (Section 54(5)), the timing (Section 60) and the offences (Sections 61, 183, false-declaration family).
• The fiscal overlay (2026): mining royalty (REV 5C; coal/black granite/quarry/other dimensional stone 2%); the specified/mineral export levy under Section 22P Finance Act / Section 36P Income Tax Act — 2% from 1 Jan 2025, raised to 3% from 1 Jan 2026, payable in the currency of trade, monthly; tiered gold royalty; and the Quoted Price Method transfer-pricing rule for mineral exports (35th Schedule, para 4(5)(f), from 1 Jan 2026). Mineral exports are zero-rated for VAT; imported equipment runs the full CIF → duty → VAT 15.5% cascade.
• Mineral export enforcement is fundamentally inter-agency. The officer's identification skill is the physical verification that backs MMCZ, RBZ and Kimberley Process paper; the quality of inter-agency coordination is the single greatest determinant of enforcement effectiveness, and identification is the officer's irreplaceable contribution to it.

Table 1 — Diagnostic signatures of the key Zimbabwean export minerals

Mineral	HS chapter	Hardness (Mohs)	Specific gravity	Signature test / tell	Principal control
Gold	71	2.5	19.3	Aqua-regia-only solubility; weight-for-volume; malleable	RBZ / Fidelity Gold Refinery; tiered royalty
Diamond (rough)	71	10	3.52	Scratches glass; ice-cold (thermal); newspaper/light tests	MMCZ + Kimberley Process
Emerald (beryl)	71	7.5–8	2.6–2.8	Green (Cr/V); water/eye/soft-wood tests	MMCZ
Lepidolite (Li)	25/26	2.5–3	~2.8	Pink/purple mica, sheet cleavage	MMCZ; export levy
Spodumene (Li)	25/26	6.5–7	~3.1	Large prismatic crystals	MMCZ; export levy
Coal	27	low	~1.1–1.5	Black, combustible; graded by size/chemistry	Royalty + specified-minerals levy
Coke	27	low	porous	Grey, hard, porous; smokeless burn	Royalty + specified-minerals levy

Table 2 — The fiscal charges on a mineral export (who, what base, which return)

Charge	Legal source	Base	Rate (period)	Return / channel
Mining royalty	Mines & Minerals Act Section 245; Schedule to Ch VII Finance Act	Gross fair-market value	Coal/black granite/quarry/other dimensional stone 2%; others	REV 5C
Specified/mineral export levy	Section 22P Finance Act; Section 36P Income Tax Act	Gross value of sale/export	2% (1 Jan 2025) → 3% (1 Jan 2026)	Specified-minerals levy return, monthly (10th); currency of trade
Gold royalty (tiered)	Twenty-Fourth Schedule, Income Tax Act	Gross value of gold	3% / 5% / 10% by US$/oz band (from 1 Jan 2026)	Withheld by Fidelity Gold Refinery
Transfer-pricing (QPM)	35th Schedule para 4(5)(f); Section 31 FA No. 7 of 2025	Quoted active-market price	Adjustment to taxable income (from 1 Jan 2026)	Income tax assessment (ITF 12C)
VAT	VAT Act [Chapter 23:12]	Export zero-rated (Section 10); import equipment Section 6(1)(b)/12A	Export 0%; import 15.5% (from 1 Jan 2026)	VAT 7; bill of entry (imports)

Diagram 1 — Mineral export verification at the border (ASYCUDA + inter-agency)

flowchart TD
 A[Mineral consignment presented for export] --> B[Lodge bill of entry export in ASYCUDA World with CPC]
 B --> C[Attach docs: MMCZ permit, invoice, packing list, CD1, BL or AWB]
 C --> D{Mineral type}
 D -->|Gold| E
 D -->|Diamond| F
 D -->|Lithium / coal / stone| G
 E --> H[Physical identification and field tests]
 F --> H
 G --> H
 H --> I{Identification matches declaration}
 I -->|No| J[Hold - refer to MMCZ lab or assay - investigate]
 I -->|Yes| K{Risk lane}
 K -->|Red| L[Physical examination]
 K -->|Yellow| M[Document check]
 K -->|Green| N[Release]
 L --> O[Assess royalty, levy, gold tier]
 M --> O
 N --> O
 J --> P[Seizure and prosecution where breach found]
 O --> Q[Pay to ZIMRA - currency of trade] --> R[Release and post-clearance audit window]

Diagram 2 — Gold-or-brass field decision

flowchart TD
 A[Yellow metal presented] --> B{Density check - weight for volume}
 B -->|Very heavy ~19.3| C{Acid test}
 B -->|Light| X[Not gold - likely brass or base metal]
 C -->|Resists nitric / sulphuric| D[Consistent with gold - confirm form and authority]
 C -->|Dissolves| X
 D --> E{Hardness}
 E -->|Soft, malleable ~2.5| F[Gold - verify RBZ / Fidelity authorisation and quantity]
 E -->|Hard, brittle| Y[Likely pyrite - fool's gold]

Statutes & sections

• Customs and Excise Act [Chapter 23:02] — Section 16 (ports/routes), Section 47–48 (prohibited/restricted importation), Section 54 (exporter to deliver documents and produce goods; Section 54(5) examination power; Section 54(8) offence), Section 54A (vehicle report before departure), Section 55 (exportation/loading), Section 60 (time of exportation), Section 61 (restriction of exportation — the Section 61(1) conformity hinge; Section 61(2) offence; Section 61(3) deemed attempt), Section 183 (prohibited/restricted offence; penalty up to three times duty-paid value), Section 226 (rates in relation to time of export); First Schedule (valuation / GATT Art VII); false-declaration and seizure provisions (confirm section numbers in the Offences/Searches modules).
• Income Tax Act [Chapter 23:06] — Section 36P (levy on specified minerals), Twenty-Fourth Schedule (tiered gold royalty), Thirty-Fifth Schedule para 4(5)(f) (Quoted Price Method, inserted by Section 31 of Finance Act No. 7 of 2025), Section 15(2)(a) (deductibility of royalty/levy).
• Finance Act [Chapter 23:04] — Section 22P (mineral export levy; 2% from 1 Jan 2025, 3% from 1 Jan 2026; currency of trade), Schedule to Chapter VII (royalty rates).
• VAT Act [Chapter 23:12] — Section 10 (zero-rating of exports), Section 6(1)(b) read with Section 12A (VAT on importation; standard rate 15.5% from 1 January 2026).
• Mines and Minerals Act [Chapter 21:05] — Section 245 (royalty; mining-title suspension for default).
• Minerals Marketing Corporation of Zimbabwe Act [Chapter 21:04] — establishes MMCZ and the mineral-export-control framework.

Regulations & Statutory Instruments

• Customs and Excise (Tariff) Notice — SI 203 of 2022 (Tariff Handbook) and amendments — HS classification and rates for the mineral lines and for imported equipment.
• MMCZ export-control instrument — .

International instruments

• WCO Harmonized System Convention — Chapters 71 (precious metals/stones), 27 (mineral fuels), 25/26 (ores/industrial minerals).
• WTO Valuation Agreement (GATT Article VII) — transaction value and fallbacks (First Schedule).
• Kimberley Process Certification Scheme — rough-diamond trade control; Zimbabwe a participant.

Case law

• No on-point Zimbabwean minerals-identification case is contained in the sources read; the area is governed by statute and the controlling enactments above. Persuasive foreign authority on classification/valuation (South African SCA; UK; ECJ on the WTO Valuation Agreement) may be cited as non-binding where relevant, but no case should be asserted without confirmation.

ZIMRA guidance & source modules

• ZIMRA, "Comprehensive Guide to the Levy on Specified Minerals Return" (External Guide) — coal and cut/uncut dimensional stone; Section 36P/Section 22P; monthly return; REV 5C interaction; rate caveat.
• TaxTami, "Mineral Levy, Gold Royalty and Transfer Pricing under Finance Act No. 7 of 2025" (FA7.05) — Section 22P 2%→3%; gold royalty tiers; QPM.
• ZIMRA Customs, "Minerals Identification — Level 1" (Reviewed Oct 2024) and TaxTami Module 21 — Minerals Identification — the eleven properties; Mohs Scale; gold/diamond/emerald/lithium/coal identification; MMCZ/RBZ/Kimberley Process coordination; field procedures.
• ZIMRA Rates of Exchange for Customs Purposes — fortnightly; used to convert non-USD values (state the period).