Recycled but not responsible: loopholes in recycled gold from the Amazon

Recycling has the potential to make the gold supply chain more sustainable, but loopholes risk undermining environmental protection and social justice. As the 2025 OECD Forum on Responsible Mineral Supply Chains has been drawing attention to global mineral value chains this week, IUCN NL points to two key loopholes in recycled gold from the Amazon region: an ambiguous definition and weak traceability.

Header photo: Gold mining in Madre de Dios, Peru © Tom Laffay / IUCN NL

The urgent need to talk about recycled gold

Recycled minerals are widely talked about as an important steppingstone in building more sustainable value chains.^[1]CCSI Columbia. (2023). Circularity in mineral and renewable value chains: Overview of Technology, Policy, and Finance Aspects and OECD. Making critical minerals work for sustainable growth and … Continue reading While recycling minerals is vital, the term “recycled” can also become a convenient label – masking practices that continue to fuel environmental destruction, biodiversity loss, and social injustice in highly-biodiverse regions like the Amazon.

IUCN NL commissioned a study on recycled gold from the Peruvian and Colombian Amazon. Currently, recycled gold covers approximately 61% of the global gold market,^[2]LBMA. (2023). Sustainability and Responsible Sourcing Report 2023 making this study timely and relevant. Large volumes of recycled gold circulate through international supply chains, yet transparency and traceability have shown little progress over the past decade.^[3]ARM. (2023). 20 NGOs Call on the EU to Step Up Its Enforcement and Adopt New Measures At the same time, multiple investigations indicate that illicit gold often enters the formal gold supply chain disguised as recycled gold.^[4]Profundo. (2023). Gold supply chain From Brazil to the world and Global Witness. (2014). Revealed: Why Dubai’s first conflict gold audit never saw the light of day These concerns are driven by growing global demand for gold as a crisis-proof investment.^[5]Pulitzer Center. (2024). On the Trail of Gold

An ambiguous definition of recycled gold continues to enable greenwashing and the laundering of freshly mined or illicit gold.

Loopholes fuelling environmental destruction and social injustice

IUCN NL highlights two key loopholes in the recycled gold from the Amazon region, potentially driving environmental destruction and social injustice: an ambiguous definition and weak traceability. Without clear definitions and robust traceability systems, harmful environmental and social practices related to recycled gold may slip through unnoticed.

Ambiguous definition of recycled gold

An unclear definition of recycled gold creates a major risk for greenwashing and the laundering of illicit gold. Under current standards, gold can be misdeclared as “recycled” if it was transformed once after its initial refining – even if it originates from illicit sources and was recently mined.^[6]Pulitzer Center. (2025). Investigating How Illegal Gold Gets Into the Legitimate Supply Chain This means that newly mined gold can be quickly reprocessed and marketed as “recycled” without ever having entered the hands of a consumer.

The ambiguous definition of recycled gold may mislead consumers and buyers into believing the gold they purchase is more environmentally friendly and ethically sourced, when it possibly may still be linked to deforestation, criminal activities, and mining expansion in ecologically sensitive regions and biodiversity hotspots like the Amazon. Nevertheless, the definition is widely accepted by key actors along the gold value chain. More accurate terms such as “re-refined” or “reprocessed” would better reflect current market practices and avoid deceptive sustainability claims.

Weak traceability of gold

The weak traceability of gold is a second major loophole. This challenge stems from several interlinked factors. First, gold moves through a highly complex and fragmented network of actors – including miners, intermediaries, trading hubs, refineries, vaults, and banks – across both formal and informal markets. At each stage, effective traceability depends on transparent and accurate record-keeping, which is often inconsistent or entirely absent.^[7]ARM.(2023). 20 NGOs Call on the EU to Step Up Its Enforcement and Adopt New Measures

As a consequence, the true origin of gold often remains unclear, and the lack of public disclosure further complicates efforts to track its journey. Additionally, reporting on high-risk suppliers and transactions is often poorly implemented or not enforced.^[8]Global Witness. (2021). How gold trade data could be better used for due diligence and SWISSAID. (2024). On the trail of African gold: Quantifying production and trade to combat illicit flow Together, these factors make gold exceptionally difficult to trace – and this lack of oversight creates openings to use gold as a vehicle for illicit activities.

Traceability in the gold supply chain has stagnated, despite mounting evidence of illicit flows and environmental harm.

Accountability now: our eyes on recycled gold

An ambiguous definition of recycled gold continues to enable greenwashing and the laundering of freshly mined or illicit gold. Powerful interests in the gold value chain play an instrumental role in maintaining this status quo. Therefore, a coherent and enforceable definition of recycled gold that excludes reprocessed gold of unknown or harmful origin is urgently needed.

Traceability in the gold supply chain has stagnated, despite mounting evidence of illicit flows and environmental harm. Consequently, there is an urgent need for coordinated action to improve oversight and close the gaps that allow illegal gold to enter formal markets as recycled gold.

Efforts to improve traceability and accountability must be grounded in principles of environmental and social justice. Policies and definitions toward more sustainable gold supply chains must recognise structural inequalities and power imbalances, so that those in vulnerable positions, such as informal or small-scale gold miners, are not further excluded or criminalised in the name of reform.^[9]Ojo Publico. Dirty Gold Routes: a decade of illegal mining and laundering

Battling forest crime in the Colombian Amazon

To safeguard the Colombian Amazon, IUCN NL contributes to ending forest crime and to improve the territorial rights of Indigenous Peoples and local communities. Because these people are the forest’s best guardians. Amazon Rights in Focus is a collaboration of Fundacion para la Conservación y Desarrollo Sostenible (FCDS), Ambiente y Sociedad, and Mongabay, supported by the Norwegian Agency for Development Cooperation (NORAD).

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Strengthening environmental defenders in Peru

Every week people get killed because they stand up for nature and human rights. Women are often at the forefront of defending environmental human rights, while at the same time being more at risk. With the support of the French Development Agency (AFD), IUCN NL works together with Sociedad Peruana de Derecho Ambiental (SPDA), Federación Nativa del Río Madre de Dios y Afluentes (FENAMAD) and Comité de Gestión de la Reserva Nacional Tambopata (CDG) to strengthen the work of (women) environmental defenders in Madre de Dios, a major gold winning region in Peru.

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