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Writer's pictureNatalie Jessup

Sand is Not a Critical Mineral – Sustainable Economic Alternatives Exist

Tāngaro Tuia te Ora, The Endangered Species Foundation has today submitted strong opposition to the inclusion of sand on the government’s proposed Draft Critical Minerals List. The classification of sand as a critical mineral is unnecessary from an economic perspective and poses significant risks to marine ecosystems.

Why Sand Is Not a Critical Mineral

According to international guidelines and best practices, critical minerals are defined by their rarity and essential role in the production of high-value technology, often without sufficient substitutes. However, aggregate and sand don’t meet the criteria for critical minerals as outlined in the Wood Mackenzie Report[1] here in Aotearoa New Zealand. These materials are neither rare nor at risk of supply shortages, nor are they indispensable for producing critical products. Including aggregate and sand is inconsistent with established guidelines and lacks support from international practice.


Sand and aggregate have a low supply risk rating, with ample substitutes available. Their inclusion in the critical minerals list is unnecessary and could lead to over-extraction from sensitive environments when alternatives can be sourced without harming ecosystems. New, substitute supplies have opened at Brookby quarry and alternative, sustainable sources have been developed, for example Kayasands.


Sand and aggregates are also not included in the “International Partner Critical Minerals List” for the USA, UK, EU, Australia or Canada.


Alternatives Exist There are sustainable sand substitutes, including Kayasand, a Waikato company with innovative solutions to produce sand from quarry materials and waste products. Kayasand plants utilise a specialist crusher and air screen technology developed by KEMCO in Japan. This technology was originally developed because of a ban on dredging that severely disrupted concrete sand supply in Japan. Since its launch in early 2000s, there are now over 300 plants in Japan, China and India.


In 2023 Kayasand opened the first V7 high-technology demonstration plant in Waikato, New Zealand showcasing this revolutionary crushing technology which processes crusher dust, a by-product of quarries, to create quality sand aggregates that can be used in concrete production.


This process:

  • Recycles waste materials, turning glass, concrete, and quarry by-products into valuable sand for concrete production.

  • Produces high-quality sand from quarry materials like basalt and greywacke using advanced crushing and grading technology

  • Produces consistent quality – they cuboidal shape of Kayasand’s product allows for up to 20% less cement in concrete production, reducing material use and emissions.

  • Integrates recycled waste and cement substitutes like limestone filler and slag, contributing to a lower carbon footprint for the construction industry.


This is the type of innovative solution that needs government investment and support so that it can scale and grow. More plants could operate in other regions of the country, where there are existing quarries.


In regards to Bream Bay and Northland, there is the potential create new and sustainable jobs, employing local people, using waste product from existing quarries and providing local markets with quality concrete which will reduce transportation costs. It is a way of boosting economic opportunities for local communities, instead of running a mining barge out of Auckland Central.


Biodiversity at Risk With over 7,500 species in Aotearoa at risk of extinction, including 800 listed as high-risk by the Department of Conservation, Tāngaro Tuia te Ora believes the Draft Critical Minerals List ignores the pressing need to prioritise environmental health. Instead of promoting sustainable innovation, the list encourages mining practices that will exacerbate environmental degradation.


Tara iti, NZ Fairy Tern - Photo Darren Markin

Calls for Sustainable Solutions Tāngaro Tuia te Ora the Endangered Species Foundation, is calling on the government to revoke its classification of sand as a critical mineral, advocating for the promotion of recycled sand and quarry-manufactured alternatives like those offered by Kayasand. Supporting such innovation would reduce the need for harmful extraction practices while helping New Zealand meet its biodiversity and climate goals.


“We need to support sustainable alternatives and stop the unnecessary extraction of sand from our fragile ecosystems,” says Natalie Jessup, General Manager of Tāngaro Tuia te Ora. “We have the opportunity to embrace environmental innovation for sand aggregates, which could be scaled across the country to create local jobs and avoid damaging our endangered species, sea life and beaches.”


For comment and further information please contact:


Natalie Jessup

General Manager Tāngaro Tuia te Ora, Endangered Species Foundation



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