Editor’s Note: This policy report is derived from the proceedings of a workshop entitled “Towards Ethical Mining and Transboundary Protection: Partnerships Across the Salween and Beyond” held in April 2026. Participants representing Kachin, Shan, Karen, and Karenni States came together with Thai experts to discuss challenges and opportunities related to mining governance, pollution mitigation, and reduction of health, disaster, and environmental risk within the context of transboundary rivers such as the Salween and Mekong. Most analyses are sourced directly from the workshop’s discourse. Additional external sources are referenced throughout the report for context. The authors of this policy report served as co-chairs of the workshop.
Surachanee “Hammerli” is the CEO of S&I Strategic Advisory, a boutique consultancy firm specializing in government affairs and strategic communication. Sriyai was a Visiting Fellow with the Media, Technology and Society Programme at ISEAS – Yusof Ishak Institute and the interim director of the Center for Sustainable Humanitarian Action with Displaced Ethnic Communities (SHADE) under the Regional Center for Social Science and Sustainable Development (RCSD), Chiang Mai University.
By Brian Eyler, Senior Fellow and Director, Southeast Asia Program
Find the full policy paper PDF here.
Introduction
Myanmar’s mineral wealth, ranging from precious stones and critical minerals to rare earth elements (REEs), has long been framed as a potential engine for development and a source of income to support the economies and security needs of ethnic armed organizations (EAOs) on Myanmar’s periphery. In practice, however, extraction has deepened armed conflict, weakened governance, and produced severe environmental and public health risks. Across the conflict-affected states, such as Kachin, Shan, Karen, and Karenni, mining has become both a consequence and a driver of political fragmentation, reinforcing cycles of violence while externalizing ecological and social costs onto some of the most vulnerable communities in Myanmar and neighboring Thailand.
Mining Governance and Conflict Dynamics Across Eastern Myanmar
Mining in Myanmar cannot be understood apart from the country’s protracted civil wars. Armed conflict is not an incidental backdrop to extraction; it is a structural condition that enables it. For over seven decades, chronic civil war and territorial contestation have allowed multiple actors, including state forces, military-affiliated businesses, and EAOs, to dominate decisions over land, licensing, and revenues. Formal legal frameworks exist at the national level and, in some areas, under EAO administration, but in practice they are often overridden by militarized control and informal permissions issued by local commanders or armed authorities rather than civilian institutions. In areas controlled by militias aligned with the Myanmar military, an implicit arrangement often prevails: Local militias support the military’s territorial objectives in exchange for monopolies over rent-seeking within their areas of control. As a result, the legal system rarely constrains extraction, particularly in border regions.
This fragmentation undermines accountability at every stage of the mining life cycle. Responsibilities over environmental protection, labor safety, fiscal management, and community engagements are diffused or ignored altogether. Communities living close to mineral deposits routinely lack the power to refuse projects or shape how extraction proceeds, even when local livelihoods and ecosystems are at stake. Where parallel governance systems exist, such as those run by certain EAOs, rules may appear sophisticated on paper, but implementation and enforcement are constrained by conflict, limited resources, and the enduring priority of revenue generation over environmental and social safeguards.
These structural dynamics manifest differently across Myanmar’s resource-rich frontier regions:
Kachin State stands as one of the country’s most resource-rich areas, with diverse deposits including jade, amber, gold, and REEs. Decades of intensive extraction have also produced a long history of environmental degradation, making local communities deeply familiar with the ecological costs of mining. However, the protracted armed conflict means that extractive activities must continue as one of the ways for armed actors to fund the fight against the military junta since the coup d’état broke out in 2021. Additionally, the New Democratic Army – Kachin, a junta-allied militia turned Border Guard Forces, had colluded with China to exploit rare earths extraction in Kachin with no regulatory guardrails for almost two decades (2010-2024) until the Kachin Independence Army (KIA) occupied and controlled all REE mining regions in the Irrawaddy River Basin in 2024 and paused exports for a period of time, before renegotiating arrangements with miners. Since then, the Kachin Independence Organization (KIO), KIA’s political wing, has been collecting taxes, providing security for mining operations, and attempting to establish sustainable mining practices in its territories. In 2025, KIO introduced the rare earth mining management regulation. However, those efforts are often hampered by Chinese economic pressure, as China has continued to apply immense economic and political leverage against KIO/A with restrictive trade agreements and forced border closure.
Shan State has seen a proliferation of mining activities, particularly gold, REEs, tin, and manganese alongside the territorial expansion of the United Wa State Army (UWSA) and entrenched control of the Mong La area by the National Democratic Alliance Army (NDAA) over the past decade. The opacity surrounding their operations leaves local communities uncertain about the scale and nature of extraction. A recent report from Shan Human Rights Group suggests slave labor could be used in REE operations. Data and insights are sporadic as they could undermine the safety of informants against the backdrop of mixed-control sensitivities. While some de facto groups have indicated their interest in the topic of responsible mining and environmental protection, it is unclear whether NDAA or UWSA have a similar interest at this stage. Moreover, reports of gold dredging boats along the Salween River, particularly in areas of Shan bordering Karenni State, and the Kok River, upstream of the Thai-Myanmar border, further highlight the difficulty of monitoring mobile and river-based mining operations. These vessels may traverse multiple contested territories, from Shan through Karenni and Karen areas down toward Mon State, making oversight nearly impossible while enabling continuous extraction beyond fixed regulatory zones.
Karenni State is notable for its tin and antimony deposits, with mining in Hpasaung Township, Mawchi region dating back over a century to the British colonial era. Recent shifts toward chemical-intensive processing methods have increased productivity but also significantly worsened environmental harm. Toxic runoff from these operations flows into Molo Creek and ultimately into the Salween River, with water contamination levels recorded at up to 55 times above safety standards. In response, Karenni’s de facto government, the Interim Executive Council, has issued safety warnings to residents and initiated efforts to develop a mining governance framework. Similar to Kachin State, Karenni armed forces were only able to gain substantive territorial control in Karenni State in 2021, leaving mining regulations and policy previously in the hands of the military-backed administrative offices and other armed groups. At this stage, while terms of reference outlining guiding principles have been established for mining and other extractive activities in Karenni State, comprehensive policies and legal instruments still require drafting and approval by the Karenni State Consultative Council and Karenni State Interim Parliament, reflecting an early-stage governance process.
Karen State, by contrast, presents a more developed governance trajectory compared to the three aforementioned states. Sharing a similar resource landscape with Karenni State, the Karen National Union (KNU) has had a longer time horizon to institutionalize mining oversight. Its Department of Mining was established in 1971 and is already on its third iteration of a mining policy (also known as “Mining Act”). While this indicates a relatively developed governance framework, the government’s inability to enforce existing laws, regulations, and decisions remains. This suggests a more mature, though still imperfect, approach to regulating extraction within a conflict-affected setting.
Regional dynamics also exacerbate these issues. Thailand functions as a key transit hub for both critical minerals and the chemicals used in extraction processes, indirectly contributing to environmental degradation within Myanmar and Thailand. At the same time, stakeholders consistently emphasize the need for technical support to improve understanding of responsible mining practices, reduce socio-environmental impacts of extraction, and lower mine-related natural disaster risks. Yet, as seen across all cases, the existence of policy frameworks does not guarantee effective implementation, particularly in contexts where conflict, capacity constraints, and economic imperatives intersect.
Environmental Destruction at Industrial Scale
The environmental footprint of mining across Myanmar’s peripheries is severe and widespread. In jade-producing areas of Kachin State, entire mountains have been flattened through open-cut extraction, leaving vast landscapes of destabilized and exposed earth prone to landslides and subsidence. Similarly, more than a decade of rare earth mining in Kachin State has likely devastated ecosystems due to the long-term impacts of unregulated chemical leachate injections into the earth, leading to widespread surface vegetation and plant die-offs. Such impacts were also witnessed in China when the same forms of mining were widespread. Access and ability to test impacts in Kachin are particularly constrained, and there is limited primary and baseline data on water, soil, and sediment quality. Gold, antimony, and tin mining in Shan, Karen, and Karenni States have similarly stripped forest cover, destabilized slopes, and accelerated natural disasters like landslides and flooding, especially during monsoon seasons. While some operations are formally classified as artisanal and small-scale mining (ASM), their cumulative impacts potentially rival those of large industrial mines.
Deforestation and habitat loss are particularly acute in northern and eastern border regions that overlap with global biodiversity hotspots. Mining has encroached on habitats of endangered species and disrupted ecological corridors linking the Eastern Himalayas to mainland Southeast Asia. Once cleared and contaminated, these ecosystems are unlikely to recover within human timescales, especially where regulations that would ensure proper mine closure and rehabilitation are absent.
Water Pollution as a Universal and Transboundary Crisis
Across all mining regions, water emerges as the most critical shared concern. Rivers and streams are central to household use, agriculture, fisheries, and sociocultural practices. However, mining waste and chemical effluents are routinely discharged into headwater streams and rivers, and subsequently groundwater systems, without proper treatment or monitoring. Reported contaminants include heavy metals like arsenic, mercury, cadmium, and lead, radioactive elements like uranium and thorium, and industrial reagents used in mineral processing.
Rare earth mining has intensified this crisis. In parts of Shan and Kachin States, in-situ leaching for rare earth extraction requires injecting chemical solutions, like ammonium sulfate and ammonium chloride, directly into hillsides to separate and extract rare earth elements. This method produces acidic waste water that contaminates soils and aquifers when it is discharged directly back into the river system and flows downstream. River discoloration, persistent turbidity, fish die-offs, and malodors have become common observations often linked to upstream mining.
While the severity of impacts is correlated to the proximity to mining activity, pollution does not remain confined to mining sites. Mining processes increase the possibility of landslides and flooding around mining sites. Importantly, contaminants travel downstream throughout Myanmar and into Thailand through river systems such as the Kok, Sai, Mekong, and Salween, affecting communities far beyond Myanmar’s borders. In northern Thailand, repeated testing has found arsenic and other heavy metals exceeding international safety standards, prompting health warnings and eroding river-based livelihoods. These dynamics illustrate how upstream extraction in conflict zones generates regional environmental insecurity without corresponding mechanisms for transboundary accountability or compensation.
Health Impacts Without Proof and Proof Without Protection
Mining-related health effects are widely known throughout Myanmar’s borderlands, but poorly documented. Communities describe skin rashes, respiratory illnesses, and suspected cancers linked to contaminated water, air, and soil. Workers face hazardous conditions with minimal protective equipment, while downstream communities experience chronic exposure through water use and food chains. Heavy metals persist in sediments and bioaccumulate in animals (such as fish, game, and livestock) and crops, creating long-term risks that may not manifest until years or decades later.
Yet, generating “acceptable” scientific proof is extraordinarily difficult in the Myanmar context. Environmental and biomedical testing is expensive, technically demanding, and often dangerous. Where testing of water, soil, and sediment does occur, it is typically episodic, reactive, and often occurs far downstream from multiple mining sites, making attribution difficult. Thus, the affected communities in Myanmar and Thailand find themselves trapped in a cruel paradox; they live with daily harm but lack the evidence required to demand accountability from local governance actors or even to stay informed about the situation that has a direct impact to their life and wellbeing. At the same time, their traditional uses of and reliance on surrounding natural resources such as rivers have become upended.
Furthermore, the sustainability of these monitoring efforts remains a significant constraint. Access to reliable laboratory testing is limited, costly, and often dependent on ad hoc arrangements. For instance, cross-border collaborations have enabled some samples from Myanmar to be analyzed through Thai research institutions, but these efforts are typically embedded within unrelated research grants and lack long-term funding security. Experts from Chiang Mai University suggest that even basic water testing can cost between approximately THB 1,500 ($50) for single-parameter analysis and up to THB 5,000 ($165) for full-panel testing of key contaminants such as lead, cadmium, mercury, arsenic, chromium, copper, and zinc. Testing biological samples, including fish and crops, is often more expensive. Moreover, this option might not be readily viable for groups located further away from the Thai-Myanmar border (e.g., Kachin) and is heavily contingent on the conflict dynamics that might add to logistical challenges and transportation costs.
Enforcement Gaps in Existing Regulations
Myanmar’s national legal framework includes numerous provisions that, if implemented, could mitigate harm. The amended Mining Law and 2018 Mining Rules introduced elements such as decentralization of certain permits to state governments, requirements for community negotiations, protections for water rights, mine closure funds, and worker safety obligations. Environmental laws mandate impact assessments and pollution control, while ethnic rights legislation requires that communities receive complete information and opportunities to negotiate.
The KNU’s commitment to self-determination extends to how it views minerals rights and operations through its Mining Act, which defines governance structures, mine operations, minerals trading, and licensing and permitting. While this puts Karen State in a stronger position to reduce harm and promote responsible mining, risk reduction policies are scant, and enforcement gaps remain. Past investigations, initiated based on community complaints brought to the central authorities, led to unenforceable mine closures, as upon returning to the area much later, officials from the KNU mining department discovered the mine had been reopened by workers from nearby communities.
In practice, these safeguards are rarely enforced in conflict-affected areas. Authority over mining has shifted not through legal decentralization, but through changes in territorial control. Even where local or ethnic administrations seek to apply operational and environmental rules, they face limited capacity, insecurity, and pressure from powerful economic and military interests. The result is a system where regulation exists largely as aspiration, while extraction proceeds with minimal oversight.
Global Demand and Externalized Responsibility
Myanmar’s mining crisis is inseparable from global supply chains. Demand for minerals used in electronics, infrastructure, clean energy technologies, and weapons systems continues to grow. China plays a dominant role, particularly in rare earths, and has shifted environmentally destructive extraction to neighboring countries when regulations tightened domestic production in China. From January to September 2025, Myanmar exported over 28,000 tons of rare earth oxides to China, accounting for over half of China’s rare earth imports over the nine months. Additionally, officials have noted Thailand’s role as a transit and processing hub for minerals and chemical inputs, linking upstream extraction to regional and global markets.
Global North consumers and governments benefit from these resources while the ecological and social costs are borne by countries and communities where mining is happening. This asymmetry raises profound questions of environmental justice as communities that have little voice in decision-making shoulder the burdens of global consumption while accountability dissipates across borders. The global economic structure has long allowed for seemingly marginalized areas such as Myanmar’s periphery to become sacrifice zones, where communities and peoples are disproportionately impacted by industrial activity.
Thailand as a Transit Hub in the Regional Mining Economy
Although the most acute environmental and social harms of unregulated mining occur in Myanmar, Thailand plays an important intermediary role as a logistics and transit hub within the regional mining economy. Workshop participants suggested that minerals such as gold, rare earth elements, tin, and antimony extracted in bordering states in Myanmar are routinely transported across the border into northern Thailand through both formal and informal routes. From there, they may be processed domestically, reexported via Thai ports, or moved onward to China and other markets.
The same trade corridors facilitate the import of mining inputs, including acids, flotation re-agents, and ammonium-based compounds, used in highly polluting extraction methods upstream. Much of this trade occurs in regulatory gray areas, weakening the traceability and severing links between extraction sites and accountability. As a result, minerals enter global supply chains with little visibility regarding their environmental origin or legal status.
Thailand’s role as a transit state has three key implications. First, it enables the continuation of unregulated extraction in Myanmar by providing physical and commercial infrastructure that conflict-affected areas lack. Second, upstream extractives pollution from Myanmar exposes Thai territory and communities to downstream pollution, particularly along rivers such as the Kok and Sai in the Mekong Basin and the Salween. Residents in northern Thailand have reported contaminated water, fish deaths, and health concerns linked to mining across the border despite having no control over the source of these impacts. Finally, this further complicates binary attributions of victims and perpetrators at the national/state level, which are not necessarily clear-cut, and calls for more nuanced approaches to understanding the global supply chain, which ultimately impact marginalized communities.
At the same time, water quality monitoring, public health advisories, and domestic legal actions in Thailand have generated visibility and, in limited cases, accountability. However, much of those efforts have been led by non-governmental actors like environmental groups, academics, community leaders, and citizen scientists. Muted reactions from the Thai government, outside of efforts by specific agencies like the Pollution Control Department, have fueled further suspicion of collusion between Thai government and private sector actors and the mining sector in Myanmar. Additionally, cross-border enforcement remains constrained by Myanmar’s fragmented authority and the prominence of non-state armed actors in mining areas. Notably, Thailand’s Ministry of Foreign Affairs reached an agreement with Myanmar’s military junta addressing the mining pollution issue in August 2025. However, as most, if not all, of the mines on transboundary river system operate within EAO-held territories, the agreement is unenforceable and ineffective. Without formal mechanisms to engage with EAOs, the Thai government remains restricted in how it can diplomatically respond to the growing crisis.
Emerging Responses and Policy Recommendations
Despite entrenched conflict and weak enforcement in Myanmar’s mining sector, a range of pragmatic responses are already emerging that focus on harm reduction, visibility, and leverage rather than idealized reform. At the community level, locally-led environmental monitoring using basic but standardized testing of water, sediment, and soil has become an essential entry point. These efforts are increasingly effective in documenting patterns of contamination, establishing baseline risks, and supporting advocacy and calls for more action across borders. River basin framing has proven especially powerful, as it links upstream extraction to downstream consequences and reframes mining pollution as a shared regional problem rather than a localized grievance.
After synthesizing the discussion points and inputs from the workshop, this paper proposes five recommendations as follows:
- At the regional level, there is growing recognition of the need to institutionalize cross-border collaboration on environmental and ecological impacts. Stakeholders from Myanmar and Thailand have called for a dedicated transboundary network of researchers and experts to address shared challenges such as water and air pollution. Such a platform could facilitate data sharing, standardize methodologies, and connect community-based monitoring efforts with academic and policy institutions. Currently, these linkages exist only in fragmented and informal ways, limiting their scalability and long-term impact.
- Thailand’s position as a downstream state and transit hub offers additional policy entry points that do not exist in conflict-affected mining areas in Myanmar. Thai government agencies can strengthen preventive controls by tightening oversight of chemical exports known to be associated with mining (although this might have an adverse effect on the economic and political viability of non-military aligned EAOs) and improving traceability requirements for commodities going in and out of Thai territory, especially those declared as transshipment (“transit goods”). Continued investment by national governments and development partners in water quality monitoring along transboundary rivers is also critical, not only for public health protection, but also for building an official record that can support diplomatic engagement and regional cooperation. While Thailand’s ability to directly regulate extraction in Myanmar is limited, its regulatory decisions can significantly influence the incentives that shape unregulated mining upstream.
- At the same time, Thailand’s ability to play this intermediary role is shaped by its own capacity constraints and evolving policy ambitions. While the country is increasingly positioning itself as a midstream actor in global critical mineral supply chains, evidenced by recent bilateral initiatives such as a recent memorandum of understanding with the United States, technical expertise in responsible mining and health and environmental exposure to mining contaminants remains limited. Past domestic experiences, including controversies surrounding gold mining operations, highlight gaps in regulatory capacity that extend to emerging sectors such as REEs. These limitations complicate Thailand’s dual role as both a potential regulator and enabler. On one hand, stronger traceability systems and import controls could significantly improve oversight of cross-border mineral flows. On the other, the absence of deep technical expertise risks reproducing governance gaps within Thailand itself. As the country advances its economic agenda and seeks alignment with international standards, including aspirations linked to OECD membership, strengthening regulatory capacity and committing to more rigorous traceability frameworks will be critical to ensuring that its intermediary role does not perpetuate upstream environmental harm.
- Thai non-government actors, including civil society organizations, research institutions, and community networks, play a complementary role in regional cooperation. By engaging and partnering with de facto governments in Myanmar’s periphery, they can help standardize citizen science methodologies, support data collection and analysis, and amplify findings in policy and market forums that are inaccessible to conflict-affected communities. Thai organizations are also well-positioned to engage industries, financiers, and international standard setting initiatives, translating localized harm into supply chain risk and reputational pressure. In this way, documentation generated in Myanmar can gain political traction through institutions and markets beyond its borders.
- At the governance level, there are also emerging openings for engagement with international standards. Some Myanmar-based actors have expressed interest in adapting elements of frameworks such as those developed by the Initiative for Responsible Mining Assurance (IRMA) and the Mining Policy Framework developed by the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development. In areas where regulatory systems already exist, such as in Karen State under the KNU, ongoing revisions to mining legislation present opportunities for incremental alignment with international best practices. Additionally, new channels to advocate for regional engagement and collaboration through intragovernmental platforms have started to form. In February 2026, the ASEAN Intergovernmental Commission on Human Rights agreed on the process of developing a Regional Plan of Action on the ASEAN Declaration on the Right to a Safe, Clean, Healthy and Sustainable Environment. A coordinated effort between Thai scholars, civil society, local communities and Myanmar counterparts to have an open dialogue with AICHR representatives about how ASEAN can meaningfully protect the rights of the affected communities should be considered. However, contextualizing these standards into conflict-affected environments and ensuring regulatory uptake by miners will require sustained technical support and careful adaptation to local political realities.
Conclusion
Myanmar’s mining sector reveals a deeply entrenched political economy in which conflict, fragmented governance, and global markets converge to promote and sustain extraction at the expense of environmental integrity and human security. Across Kachin, Shan, Karenni, and Karen States, persistent armed conflict and weak enforcement structures have allowed mining to function less as a pathway to sustainable and inclusive development than as a mechanism that entrenches factionalism, inequality, ecological degradation, and cross-border harm. The resulting impacts, particularly widespread water contamination and long-term health risks, extend far beyond mine sites, implicating regional actors such as Thailand and exposing the limitations of state-centric approaches to regulation and accountability. Yet, the emergence of community-led monitoring, transboundary collaboration, and downstream leverage points suggests that meaningful intervention remains possible. Rather than relying on comprehensive reform in an active conflict setting, progress is more likely to come through incremental harm-reduction strategies that enhance transparency, strengthen regional cooperation, and align supply chain incentives with environmental and social responsibility. Ultimately, addressing Myanmar’s mining crisis will require not only local and regional action, but also a reconfiguration of global accountability frameworks to ensure that the costs of extraction are no longer borne disproportionately by the most vulnerable.