International NGOs Criticize Japan's PAMCO for Ignoring Global Environmental Concerns
On July 28, 2025, the Asia-Pacific Resource Center (PARC) and FoE Japan, both NGOs based in Tokyo, issued a stern criticism of PAMCO, a major Japanese non-ferrous metal company, for its lack of responsiveness to international concerns over deep-sea mining operations. This followed the company's reply to inquiries about its mineral resource transactions from the seabed. The response suggested a troubling disregard for international norms, particularly concerning the Convention on the Law of the Sea (UNCLOS), which stipulates that deep-sea mineral resource exploration is to be managed by the International Seabed Authority (ISA) based in Jamaica. Notably, no recognized body exists to grant such permissions beyond national jurisdictions.
Adding to the complexity, on April 24, 2025, the U.S. Trump administration issued an executive order concerning the “Liberation of Marine Critical Mineral Resources,” indicating a willingness to authorize deep-sea mining operations outside U.S. territorial waters. This action blatantly undermines established international law that mandates a specific permitting framework governed by the ISA, which fundamentally challenges the legality of U.S. actions. While the United States is not a party to UNCLOS, it is argued that the treaty's principles should apply as customary international law, binding even non-signatories.
Furthermore, The Metals Company (TMC), a privately held mineral development firm based in Canada, announced that it would seek permissions for commercial mineral resource development in the Clarion-Clipperton Zone (CCZ) via its U.S. subsidiary, based on the same executive order. This decision raised eyebrows, as TMC routinely engages with ISA for standard exploration permits and should inherently understand its regulatory obligations. Critics assert that this move appears to intentionally contravene established laws to secure short-term profits, dramatically destabilizing international order.
TMC and PAMCO had previously established a partnership to develop refining technologies for deep-sea nodules, a business arrangement that PAMCO has leveraged to attract investment funding based on TMC's partnerships. However, PAMCO's claim that it views TMC's actions as compliant with international law starkly contrasts with global sentiment, further isolating the company in an increasingly critical international arena.
Leticia Carvalho, director-general of the ISA, lambasted the actions of both the U.S. government and TMC by emphasizing that no country can assert ownership over deep-sea mineral resources. In her statements, she reinforced that resource claims and transfers are outright prohibited under international law. Moreover, in July 2025, the ISA Council approved Resolution ISBA/30/C/19, officially designating TMC’s actions for examination. This decisively illustrates a potential breach of the multilateral legal framework established by UNCLOS, given that TMC sought permits from the U.S. while conducting explorations under ISA regulations.
In light of these legal implications, the ISA Council also postponed its anticipated agreement on international regulatory frameworks relating to deep-sea mineral exploitation, during a time when 38 nations proposed a moratorium on such activities. This collective decision signifies a growing consensus within the international community that current conditions do not support deep-sea mining, and provides a sobering reminder regarding the anticipated upheaval involved in pursuing such resource extraction.
Despite TMC and its proponents suggesting that commercial development of deep-sea minerals is imminent, ongoing international negotiations reveal a starkly different reality. As perceptions diverge, PAMCO’s international reputation inevitably suffers, but this problem is not confined to just PAMCO.
According to Japanese legislation, specifically the Deep Seabed Mining Interim Measures Act, any entity knowingly engaging with mineral resources obtained from the “deep seabed” without appropriate governmental approval may face significant penalties, including imprisonment. If TMC's exploitation of these resources occurs without ISA consent and PAMCO's involvement goes unpunished, it raises serious questions about tacit approval by the Japanese government. Such complicity could potentially subject Japan to international sanctions.
As global trade tensions rise, negative perceptions regarding mineral supply chains could severely impact Japan's key electric, electronic, and automotive industries. PARC's executive director, Shigeyuki Tanaka, expressed grave concerns that the ongoing development by TMC poses unprecedented risks of marine environmental degradation. He pointed out potential fishing impacts and violations of indigenous peoples' rights who revere the ocean as sacred. The fallout from actions undermining multilateral consensus will also carry profound environmental implications.
Mitsuki Matsumoto from FoE Japan's development and human rights team echoed this sentiment, criticizing PAMCO's apparent unresponsiveness to the growing international concerns. He warned that if TMC proceeds with its commercial mining plans, the repercussions on broad ecosystems could lead to significant biodiversity losses and urged PAMCO to recognize and address its corporate responsibilities amid these global environmental risks.