The restriction on exporting unprocessed minerals is the clearest expression of the government's value addition agenda, and in gold it has worked: refining capacity has been built and high-purity metal now leaves the country in place of dore.
Where the policy outruns the plant
Elsewhere the picture is different. Iron ore has no domestic beneficiation at scale, 3T concentrate now has one smelter, and industrial minerals were largely processed locally already. Applying a single rule across these classes produces stalled shipments rather than new factories.
The definition problem
There is no published threshold specifying what constitutes sufficient processing per mineral. Licensees negotiate it case by case with the ministry, which is an obvious source of inconsistency and of pressure on officials.
Who absorbs the cost
Small producers do. A large licensee can finance a processing step or wait out a shipment freeze. An association in Ntungamo sitting on concentrate it cannot legally export and cannot afford to process simply stops mining.
What the amendment should carry
Mineral-class thresholds published in a schedule, with a transition period tied to the commissioning of specific plants, would preserve the policy's intent and remove most of its collateral damage.