Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Mining · International waters (Pacific Ocean) · 2022–2026

Deep-sea mining: TMC, NORI, the NOAA permit and the ISA

Nature's voice · report
No measurement of the harm done to me here is on record.
Did nature suffer? Not measured. Disputed
What the record lacks: 4 none on record · 4 insufficient · 2 not measured · 5 disputed · 1 unclear See the gaps
Accounts of the harm differ
Does nodule mining cause less harm than land-based mining?
  • Company or project TMC: A Benchmark lifecycle assessment found the NORI-D nodule project could outperform land-based routes. The Metals Company
  • Company or project TMC: Its lifecycle assessment does not cover biodiversity or social impact. The Metals Company
  • Communities and civil society Planet Tracker: Two of three lifecycle studies were funded by mining companies; results ranged from 28% more to 76% less CO2-equivalent than land supply, and more than 70% of emissions came from processing. Planet Tracker
Do nodules produce oxygen at the seabed, and is the research sound?
  • Researchers Research team led by Andrew Sweetman: Reported in Nature Geoscience (July 2024) that oxygen is produced near nodules at about 4,000 metres in darkness; the mechanism is a hypothesis. Northwestern University
  • Company or project TMC: Called the results flawed; part of the research funding came through a TMC subsidiary. E&E News
  • Researchers Journal: Said the company's objection did not contain enough information to evaluate. E&E News

The Metals Company, through subsidiaries holding seabed exploration contracts in the Pacific, applied to a US regulator for a commercial recovery permit under a 1980 US law. The International Seabed Authority, which governs the area under the UN Convention on the Law of the Sea, has not adopted rules for commercial mining.

about 65,000 km²Area covered by TMC USA's consolidated application to NOAA
Area as reported by the company; NOAA's decision is expected in the first quarter of 2027.

Status As of October 2026: NOAA decision on TMC USA's consolidated application expected in the first quarter of 2027; the ISA has not adopted a Mining Code; proceedings by NORI, TOML and TMC USA against the ISA are unresolved.

What?
TMC USA applied to NOAA for an exploration licence and commercial recovery permit for seabed nodules in the Clarion-Clipperton Zone under a 1980 US law, while the ISA has not adopted rules for commercial mining. TMC via Nasdaq
Where?
Clarion-Clipperton Zone, Pacific Ocean between Hawaii and Mexico, at about 4,000 metres; applications filed with NOAA in the United States. TMC via Nasdaq
When?
Executive order 24 April 2025; application 29 April 2025; consolidated application January 2026; NOAA compliance finding April 2026; decision expected first quarter 2027. The Metals Company
Who?
Gained
  • TMC and its subsidiaries NORI, TOML and TMC USA — Would gain a commercial recovery permit if NOAA approves; none had been issued as of October 2026. The Metals Company
Lost
None on record
Harmed
  • Seafloor animals on the 2022 collector-trial tracks — Macrofauna abundance 37% lower and species diversity 32% lower two months after the trial. Smithsonian Magazine
Why?
The company says metals from nodules are needed for the energy transition and cause less harm than land mining; the executive order cited China's share of rare-earth supply, above 80%. The Metals Company
How?
Through the 1980 DSHMRA, under which NOAA can license exploration and commercial recovery, rather than through ISA rules, which have not been adopted. TMC via Nasdaq
6 of 6 questions answered from the record

What happened

The record, in order.

The Metals Company (TMC, formerly DeepGreen) wants to collect polymetallic nodules, metal-bearing rocks lying on the seafloor at about 4,000 metres in the Clarion-Clipperton Zone (CCZ) between Hawaii and Mexico, for nickel, cobalt, copper and manganese. The company says battery metals from nodules would cause less harm than metals from land mines. Its subsidiary NORI (Nauru Ocean Resources Inc.) holds an exploration contract sponsored by Nauru; a second subsidiary, TOML (Tonga Offshore Mining Ltd.), is sponsored by Tonga. TMC and Nauru announced an updated sponsorship agreement in 2025–26.

Seabed in international waters falls under the International Seabed Authority (ISA) under the UN Convention on the Law of the Sea, to which the United States is not a party. The ISA has been trying to write rules for commercial mining since 2014. On 24 April 2025 a US presidential executive order (No. 14285) called for faster permitting under the 1980 Deep Seabed Hard Mineral Resources Act (DSHMRA); the stated reason was China's share of rare-earth supply, above 80%. TMC's US subsidiary, TMC USA, applied to NOAA, the US ocean and atmosphere agency, on 29 April 2025. A NOAA final rule of 21 January 2026 allowed an exploration licence and a commercial recovery permit to be sought in one application, and in January 2026 TMC USA filed a consolidated application covering about 65,000 square kilometres.

NOAA found the application in full compliance with the law in late April 2026 (the records give 28 and 30 April) and published it in the Federal Register. The company said it expects a decision in the first quarter of 2027. In July 2026 the ISA Council again did not adopt a Mining Code but extended NORI's exploration contract by five years. According to the records, 45 countries then called for a moratorium or pause. NORI and TOML took the ISA to the International Tribunal for the Law of the Sea (ITLOS) over the ISA's compliance investigation, with an interim ruling dated 18 July 2026, and TMC USA brought a suit against the ISA.

Evidence on the seafloor is limited and partly funded by the industry. A study published in December 2025 compared the tracks of a 2022 collector trial in the NORI-D area with the surrounding seabed two months after the trial: macrofauna abundance on the tracks was 37% lower and species diversity 32% lower. The study's main funding came from the mining contractor. A July 2024 paper reported oxygen being produced near nodules at about 4,000 metres in darkness; TMC called the findings flawed, and the journal said the company's objection did not contain enough information to evaluate. TMC's own lifecycle assessment, prepared by Benchmark, says its nodule project could outperform land-based routes but does not cover biodiversity or social impacts.

Companies and governments are not aligned. BMW, Volvo Group, Google and Samsung SDI pledged on 31 March 2021 not to source deep-sea minerals. Korea Zinc invested $85.2 million in TMC in June 2025, taking about 5%. Norway's parliament postponed licensing in its own waters, with reports of a pause to about 2029. Zurich Insurance and Vienna Insurance Group have said they do not insure this activity. As of October 2026 no commercial recovery permit had been issued to TMC USA.

  1. 2019Allseas, a marine engineering firm, invests $150 million in TMC (as reported)
  2. 2021BMW, Volvo Group, Google and Samsung SDI pledge not to source deep-sea minerals (31 March)
  3. 2022Collector trial in the NORI-D area
  4. 2024Paper reports oxygen produced near nodules; TMC calls it flawed (July)
  5. 2025US executive order on seabed minerals (24 April); TMC USA applies to NOAA (29 April); Korea Zinc invests $85.2 million (June); 37 countries support a moratorium at the UN Ocean Conference (June); test-mining study published (December)
  6. 2026NOAA final rule allows single application (21 January); consolidated application of about 65,000 km²; NOAA finds application compliant (late April); ISA Council extends NORI contract by five years and does not adopt Mining Code (July); ITLOS interim ruling (18 July)
  7. 2027Company expects NOAA decision in the first quarter

What was said

Claims, in the words of those who made them.

“we do not have any appetite to insuring these types of mining activities”

Zurich Insurance, as cited from ShareAction, Insuring Disaster (2024), on a campaign page · 2024 · Deep Sea Mining Campaign

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Does nodule mining cause less harm than land-based mining?
Company or project
TMC

A Benchmark lifecycle assessment found the NORI-D nodule project could outperform land-based routes.

The Metals Company
Company or project
TMC

Its lifecycle assessment does not cover biodiversity or social impact.

The Metals Company
Communities and civil society
Planet Tracker

Two of three lifecycle studies were funded by mining companies; results ranged from 28% more to 76% less CO2-equivalent than land supply, and more than 70% of emissions came from processing.

Planet Tracker
Do nodules produce oxygen at the seabed, and is the research sound?
Researchers
Research team led by Andrew Sweetman

Reported in Nature Geoscience (July 2024) that oxygen is produced near nodules at about 4,000 metres in darkness; the mechanism is a hypothesis.

Northwestern University
Company or project
TMC

Called the results flawed; part of the research funding came through a TMC subsidiary.

E&E News
Researchers
Journal

Said the company's objection did not contain enough information to evaluate.

E&E News
Who governs commercial mining of the international seabed: the ISA or US national law?
Company or project
TMC USA

Applied to NOAA under the 1980 DSHMRA for an exploration licence and commercial recovery permit.

TMC via Nasdaq
Government and regulators
United States (executive order 14285 and NOAA rule)

Called for faster permitting under DSHMRA; a final rule of 21 January 2026 allows a single application.

International bodies
ISA

Has not adopted a Mining Code; opened an investigation after the US application; extended NORI's contract by five years in July 2026.

Mongabay
Company or project
NORI and TOML

Went to ITLOS against the ISA's compliance investigation; TMC USA sued the ISA.

Mongabay

How it looked

What was shown, beside what was recorded.

Shown

  • Battery metals from seabed nodules would cause less environmental harm than land-based mining; a Benchmark lifecycle assessment found the NORI-D nodule project could outperform land-based routes
    TMC · The Metals Company
  • A 2020 company-funded study found nodule metal would involve 70% less direct carbon emission and 94% less land use than land supply
    TMC-funded 2020 study, as described in the record · Planet Tracker
  • The energy transition needs metals that recycling cannot supply, and the seafloor is not pristine
    Gerard Barron, TMC chief executive, 2020 (as summarised in the record)

Recorded

  • Two months after the 2022 collector trial, macrofauna abundance on the tracks was 37% lower and species diversity 32% lower than in the surrounding area; the main funding came from the mining contractor.
    Smithsonian Magazine
  • TMC's lifecycle assessment excludes biodiversity and social impact.
    The Metals Company
  • Of three lifecycle studies, two were funded by mining companies; results ranged from 28% more to 76% less CO2-equivalent than land supply, and more than 70% of emissions came from processing.
    Planet Tracker
  • The ISA again did not adopt a Mining Code in July 2026 and extended NORI's exploration contract by five years.
    Mongabay
  • The ISA opened an investigation after TMC's US subsidiary applied to NOAA for two exploration licences and one commercial recovery permit.
    Inside Climate News

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: USD · Window: 2019–2025. All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • tmc (July 2024): Described the findings of the July 2024 paper on oxygen produced near nodules as flawed; the journal said the company's objection did not contain enough information to evaluate. · E&E News
  • tmc (2023-03): Commissioned a lifecycle assessment from Benchmark, which it said shows its NORI-D nodule project could outperform land-based routes. · The Metals Company
  • tmc (2026): Said it expects NOAA's decision on its consolidated application in the first quarter of 2027. · The Metals Company
  • noaa (April 2026): Determined that TMC USA's consolidated application was in full compliance and published it in the Federal Register. · The Metals Company
  • isa (July 2026): Extended NORI's exploration contract by five years and did not adopt the Mining Code. · Mongabay
  • zurich (2024): Said it has no appetite for insuring these types of mining activities. · Deep Sea Mining Campaign
  • vienna-insurance-group (2024): Said it provides no cover for all kinds of new deep sea mining projects. · Deep Sea Mining Campaign

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2025-04-29–Ongoing
    TMC USA application to NOAA under the Deep Seabed Hard Mineral Resources Act
    NOAA (US administrative licensing) · Administrative · TMC USA → NOAA (regulator)

    TMC USA applied in April 2025 and filed a consolidated application of about 65,000 km² in January 2026. NOAA found it in full compliance in April 2026 and published it in the Federal Register; the company expects a decision in the first quarter of 2027. The Metals Company

  2. 2026–Ongoing
    NORI and TOML v. International Seabed Authority
    International Tribunal for the Law of the Sea (ITLOS) · International court · NORI and TOML (TMC subsidiaries) → International Seabed Authority

    The subsidiaries went to ITLOS over the ISA's compliance investigation; an interim ruling is dated 18 July 2026, its content is not in the record.

  3. 2026–Ongoing
    TMC USA suit against the International Seabed Authority
    Not stated in the record · Civil · TMC USA → International Seabed Authority

    Reported in July 2026 coverage of the ISA Council session; forum and relief sought are not in the record. Mongabay

Insurers

  1. 2024Cover declined
    Zurich Insurance → Deep-sea mining activities (sector)
    Stated reason: Quoted: "we do not have any appetite to insuring these types of mining activities".

    Cited from ShareAction, Insuring Disaster (2024), on a campaign page. Deep Sea Mining Campaign

  2. Cover declined
    Vienna Insurance Group → Deep-sea mining activities (sector)
    Stated reason: Said it provides no cover for "all kinds of new deep sea mining projects".

    Cited on the same campaign page; the year is not stated. Deep Sea Mining Campaign

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Macrofauna abundance on test-mining tracks
−37%
Two months after the 2022 collector trial, NORI-D area; study published December 2025, mainly funded by the mining contractor
Species diversity on test-mining tracks
−32%
Same study and comparison
Biodiversity in the company's lifecycle assessment
Excluded
The Benchmark assessment commissioned by TMC does not cover biodiversity or social impact
Commercial recovery permit
Not issued
NOAA decision expected in the first quarter of 2027

What we don't know

Undisclosed, unproven, untried: recorded as data.
Case pending / contestedNo independent ecological evaluation

Nature

  • Not measured Harm to nature: No independent ecological evaluation is on record.
  • Disputed Does nodule mining cause less harm than land-based mining?
  • Disputed Do nodules produce oxygen at the seabed, and is the research sound?

Accounts

  • Disputed Who governs commercial mining of the international seabed: the ISA or US national law?

Record

  • None on record Outcome of the NOAA decision on TMC USA's consolidated application: expected in the first quarter of 2027; its status as of October 2026 is not known.
  • None on record Date NOAA found the application compliant: the records give both 28 April 2026 and 30 April 2026; both come from company releases and secondary reports.
  • None on record Outcome of the ITLOS proceedings brought by NORI and TOML (an interim ruling is dated 18 July 2026; its content is not in the record) and of TMC USA's suit against the ISA.
  • Disputed Number of countries seeking a moratorium: 37 (June 2025), more than 30 (March 2026) and 45 (July 2026) in different sources; the difference may reflect dates.
  • Disputed Number of species recorded in the CCZ: one record gives 5,142 unnamed species and about 88% of sampled species undescribed; another gives 5,578 species, about 92% new to science (the second). The figures conflict.
  • Unclear Whether oxygen is produced at the seabed by nodules is a hypothesis; the text of TMC's formal objection to the 2024 paper could not be read, and results of the research team's 2026 expeditions have not been published.
  • Insufficient Reported but not independently verified: under the revised sponsorship agreement Nauru receives $2 per tonne and rights to about 9.1 million shares in TMC; details were not checked against a primary document.
  • Insufficient Reported but not independently verified: Glencore put $5 million into the company in 2012 and holds a right to half of the nickel and copper from NORI's area.
  • Insufficient Reported but not independently verified: a link between TMC's chief executive and Nautilus Minerals, whose Solwara 1 project off Papua New Guinea ended with the company's bankruptcy in 2019; the Papua New Guinea government held 15% of the project. The link could not be confirmed on the page opened, and a reported 2025 interview remark about earnings from it comes.
  • Insufficient Reported but not independently verified: tracks from 1979 test mining still visible after 44 years.
  • None on record No information found on TMC's insurance.
  • Not measured No independent ecological assessment of commercial-scale mining is recorded; the company's lifecycle assessment excludes biodiversity.

Did the harm stop?

No commercial recovery permit had been issued as of October 2026. The collector trial of 2022 left tracks on which animal numbers were lower two months later.

Who paid?

Seafloor animals on the trial tracks; the record shows no payments by the company for environmental harm.

Sources

Voices on record: ✓ Company or project— Government and regulators— Courts✓ Press and investigations✓ Communities and civil society✓ Researchers✓ International bodies

Company or project

Press and investigations

Communities and civil society

Researchers

  1. Deep ocean floor produces its own 'dark oxygen'
    Northwestern University · 2024-07

International bodies

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.
Terms used on this page

Institutions

NOAA
The US National Oceanic and Atmospheric Administration, which leads damage assessment for coastal and marine spills.

Bonds and banking

Liquidation, insolvency, bankruptcy
Legal processes that apply when a company cannot pay its debts; its assets are sold and claims against it may go unpaid.

Law and courts

Arbitration
A private dispute process in which an appointed arbitrator, instead of a court, decides the case.
Trustees (natural resource)
Government agencies that act on behalf of the public to recover and spend damages for harm to natural resources.
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