ESG & Responsible Sourcing

Sand in the Machine: OECD Extends Due Diligence Framework to the World's Most Overlooked Extractive Industry

May 6, 2026
10 min read
Sand in the Machine: OECD Extends Due Diligence Framework to the World's Most Overlooked Extractive Industry

The OECD has formally extended its minerals due diligence architecture to sand and silicates, the second most-extracted resource on Earth after water. A key findings brochure published April 27, 2026, summarises a 70-page report released in February, applying the same risk-based framework used for cobalt and gold to a sector consuming 50 billion tonnes annually. For companies across construction, electronics, and renewable energy, the implications are significant and largely unpriced.

Introduction

Most people think of critical minerals as the glamorous end of the extractive spectrum: cobalt from the DRC, lithium from the Atacama, rare earths from Inner Mongolia. Sand barely registers. It is everywhere, it is cheap, and it holds up the buildings we live in. That invisibility is precisely the problem.

On April 27, 2026, the OECD published a key findings brochure summarising its full report, released February 5, on due diligence for responsible sand and silicate supply chains. The 70-page report formally extends the organisation's established minerals due diligence architecture to a sector that extracts roughly 50 billion tonnes of material every year and generates an estimated USD 600 billion in annual market value. For context, that is more than 50 percent larger by value than annual global gold production, and roughly 70,000 times larger by volume than the combined annual output of gold, cobalt, lithium, tin, tantalum, and tungsten.

The report matters for three distinct audiences. Companies in construction, electronics, glass, ceramics, solar energy, and automotive manufacturing source sand and silicates either directly or embedded in their inputs. Investors need to understand that governance risks in this sector are material and largely undisclosed. And policymakers, particularly in the EU where due diligence regulation is rapidly evolving, will find the OECD framework a natural reference point for future rulemaking.

This is not a niche academic exercise. Sand underpins the physical infrastructure of the clean energy transition, from the quartz that becomes semiconductor-grade silicon to the aggregates that go into wind turbine foundations and solar farm access roads. Getting its governance right is, as the Coalition for Responsible Sand and Silicates puts it plainly, overdue.

What the OECD Has Actually Done Here

To understand why this publication is significant, it helps to understand what already existed. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, known as the Minerals Guidance, was adopted in 2011. It is the leading international standard for minerals due diligence and currently covers 15 minerals and metals. Its five-step framework asks companies to establish strong management systems, identify and assess risks in their supply chains, design and implement responses to those risks, carry out independent audits where appropriate, and report publicly on their due diligence findings.

Since 2011, the Guidance has been integrated into hard law in Europe, Central Africa, the Middle East, and the Americas, as well as into market and exchange requirements in Europe and Asia. It has shaped how the industry approaches gold from Venezuela, cobalt from the DRC, and 3TGs (tin, tantalum, tungsten, and gold) from conflict-affected regions globally. What it had not done, until now, is formally address sand and silicates.

The new report changes that. It applies the Minerals Guidance framework directly to sand and silicate supply chains, supplemented by the OECD Handbook on Environmental Due Diligence in Mineral Supply Chains and the broader suite of OECD Responsible Business Conduct standards. The methodology involved a comprehensive literature review of over 450 documents covering risks across more than 110 countries, complemented by cross-sectoral dialogue and expert interviews, yielding 461 individual cases of documented risk or impact.

Critically, the report does not invent a parallel system. It argues that sand and silicates should be understood as part of the same governance universe that already covers gold and cobalt, with the same analytical tools applied to a different set of materials. That consistency matters: companies already familiar with OECD due diligence processes will not face an entirely new compliance architecture.

Why Sand and Silicates? The Scale and Strategic Stakes

Fifty billion tonnes per year is a number that requires a moment to absorb. To put it in physical terms: the global demand for buildings and infrastructure over the past three decades has produced a fourfold increase in concrete production, reaching approximately 26 gigatonnes per year by 2020. Construction and infrastructure alone account for 30 billion tonnes of sand, gravel, and rock annually. The construction sector represents roughly 13 percent of global GDP. Sand is not peripheral to the modern economy; it is load-bearing.

Demand is not stable. The OECD projects consumption reaching 86 billion tonnes by 2060. Marine sand extraction from coastal ecosystems alone already accounts for an estimated 4 to 8 billion tonnes per year. In Sub-Saharan Africa, 90 percent of all sand mining originates from artisanal and small-scale operations, characterised by low mechanisation and limited regulatory oversight. In the United States, more than three thousand small and medium enterprises produced sand and silicates across all 50 states in 2023.

Then there is the strategic dimension. Sand and silicates are not simply a construction material. High-purity quartz, a member of the silicate family, is the feedstock for the silicon used in semiconductors and solar panels. The report flags this explicitly, noting that silicon derived from high-purity quartz has already attracted policy attention because of its geographical concentration at both the mining and processing stages. Building on my analysis of processing chokepoints in the critical minerals sector in April 2026, it is worth noting that the vulnerability here is structural: when a material is geographically concentrated and under-governed, it becomes a leverage point.

The silica sand market alone was valued at USD 14.1 billion in 2025 and is projected to reach USD 27.5 billion by 2034. Industrial silica sand is expected to grow from USD 17 billion in 2025 to over USD 29.6 billion by 2035. These are not small numbers, and they sit inside supply chains that the report characterises as often poorly regulated with little government oversight.

The Risk Landscape: What the Data Shows

The OECD report organises its risk analysis into four broad categories: environmental damage, human rights abuses, conflict finance, and financial crime. Each category carries its own geography and dynamics.

Environmental risk is the most pervasive and the most thoroughly documented in the literature. Sand and silicates are unique among extractive commodities in that a significant portion is extracted from what the report calls dynamic systems: rivers, coastlines, estuaries, and marine environments where sand plays active ecological roles. Remove enough sand from a river and you change its flow regime, degrade aquatic habitat, and alter the sediment balance that downstream communities depend on for fertile land. Remove enough sand from a coastline and you accelerate erosion, threatening both ecosystems and the infrastructure that humans built assuming stability. Static systems, quarries and open-pit mines on land, pose their own risks including habitat destruction, biodiversity loss, and tailings contamination, but the dynamic system risks are particularly acute because they are often irreversible at human timescales.

Conflict and community rights risks concentrate in the upstream segments of supply chains. Sand extraction frequently takes place in areas with profound cultural significance to Indigenous communities, and hydrological changes from mining can compound over time, affecting ancestral waters and traditional land use. Inter-state conflicts add another layer: the report cites the case of Ukraine and Russia as an example where conflict-related sanctions demanded that companies exit specific sand and silicate markets or supply chains entirely. The report is careful to note that most sand and silicate production will, at some point, relate to conflict-affected and high-risk areas given the global ubiquity of extraction.

Financial crime is perhaps the least visible risk category but potentially the most systemic. Illicit financial flows, including tax evasion, transfer pricing, and misallocation of mining revenues, destabilise government finances in producer countries. Political corruption distorts regulatory decisions and facilitates illegal activity. Complex sourcing and blending, a structural feature of sand supply chains, can render the origins of materials effectively untraceable. The report specifically warns about the risk of perfunctory, tick-the-box due diligence that satisfies formal requirements without meaningfully reducing harm.

What the Framework Asks of Companies, and Where the Objections Will Come

The OECD's core ask is an integrated, risk-based approach to due diligence, drawing on its five-step Minerals Guidance process adapted to the sand and silicate context. Companies should establish management systems that identify their exposure to sand and silicate supply chains, map those chains to understand where materials originate, assess risks using the OECD's Annex II categories (serious human rights abuses, conflict financing, financial crime) alongside the environmental due diligence handbook, and implement proportionate mitigation measures.

The framework explicitly encourages responsible engagement in conflict-affected and high-risk areas rather than blanket avoidance. This is a deliberate policy choice: withdrawal from difficult sourcing environments often harms the artisanal miners and local communities who depend on the sector for their livelihoods. The five-step model emphasises progressive improvement and continued engagement with suppliers to reduce risks, with exit reserved for situations where the severity of risk makes continued sourcing indefensible.

The objections are predictable and, in some cases, legitimate. The sand and silicate sector is structurally different from the minerals the OECD framework was originally designed for. Supply chains are often extremely short: a quarry delivers aggregate directly to a construction site in the same county. Asking a regional aggregate supplier to carry out formal supply chain mapping stretching back through artisanal mining in Sub-Saharan Africa may be technically appropriate but practically difficult to implement. The report acknowledges this, noting the heterogeneity of supply chain operators and the predominance of small enterprises.

There is also a sequencing question. The EU's Omnibus I Directive, which entered into force in March 2026 and dramatically narrowed the scope of mandatory supply chain due diligence under the CSDDD, has reduced direct regulatory pressure on precisely the mid-tier and smaller companies most active in sand sourcing. As I covered in May 2026, many companies that would previously have been subject to mandatory due diligence are no longer directly regulated. The OECD framework provides authoritative guidance, but without a hard regulatory mandate attached to it, uptake in the lower tiers of the sand supply chain may remain voluntary and uneven for years.

The Policy Environment: Momentum, Gaps, and What Governments Are Doing

A handful of governments have already moved. Belgium, China, the Netherlands, Malaysia, Singapore, Switzerland, and Vietnam have each taken separate actions to improve governance of sand and silicate production and trade. In the EU, efforts to integrate sand and silicates into circular economy policy and construction materials regulation are gaining momentum, though they have not yet coalesced into a single coherent framework comparable to the regulation that applies to 3TGs or battery minerals.

The Coalition for Responsible Sand and Silicates, based at the University of Queensland's Sustainable Minerals Institute, has played a meaningful role in bringing this issue to the OECD's attention. It convened the first session on responsible sand and silicate sourcing at the OECD Forum on Responsible Mineral Supply Chains in 2023, followed by a plenary session in 2024 and a closed-door stakeholder consultation in 2025. The OECD report published in February 2026 represents the culmination of that multi-year process.

The report itself acknowledges that governance is nascent and uneven. More research is needed, it notes, on how conflict, land rights, and natural resource pressures compound the adverse impacts of sand and silicate extraction. That honest uncertainty is useful: it signals that the OECD is establishing a framework rather than declaring a finished solution. The architecture is in place; the sector-specific evidence base is still being built.

What Comes Next

The practical implications of the OECD report will play out over several years. In the near term, the key findings brochure released April 27 is designed as an accessible entry point for companies, investors, and policymakers who are unlikely to read the full 70-page document. Its function is to shift the baseline: after April 2026, it becomes harder for a company to claim ignorance of the due diligence expectations that apply to its sand and silicate sourcing.

For the semiconductor and solar industries in particular, the flag on high-purity quartz is worth taking seriously now rather than later. As geopolitical competition over critical mineral supply chains intensifies and regulatory scrutiny of supply chain transparency increases, the governance status of upstream quartz and silicon feedstocks is likely to attract more attention. Companies that have mapped their quartz supply chains and can demonstrate responsible sourcing will be better positioned than those starting that process under regulatory pressure.

For the construction sector, the timeline is longer but the scale of potential impact is larger. Thirty billion tonnes of aggregate per year, much of it sourced through informal or weakly regulated channels in the Global South, represents an enormous liability if governance expectations harden. Proactive engagement with the OECD framework now, including supplier mapping and risk assessments, would reduce exposure to future regulatory and reputational risk.

The broader picture is one of gradual but real convergence. The OECD has now established that the same governance logic applies to sand as it does to cobalt: the size or ordinariness of a commodity does not exempt it from responsible business conduct obligations. Whether voluntary frameworks translate into binding regulation, and how quickly, will depend on political momentum in Brussels, Washington, and Canberra. But the intellectual and institutional groundwork is laid. Sand, the most ordinary material in the world, has entered the responsible sourcing agenda. It is unlikely to leave it.

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