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For most of mining history, tailings marked the end of the story. Ore went into the mill, metal came out, and whatever remained was pumped behind an earthen wall and largely forgotten. If tailings showed up in the financial statements at all, it was as the cost of closing the facility that held them.

Brazil ended that arrangement. After two tailings dam failures in Minas Gerais in 2015 and 2019, the country enacted Law 14.066 on September 30, 2020. It prohibits building or raising mining dams by the upstream method and required every existing upstream dam to be decommissioned, a process Brazilians call de-characterization, by February 25, 2022. The regulator can extend that deadline structure by structure where the work is technically unfeasible within the deadline, and the largest programs now run into the next decade. What had been inert waste became an engineering schedule with a budget attached.

The Bill for the Past

Vale S.A. (NYSE: VALE) carries the largest of those programs, covering 30 upstream structures. In December 2025, the company completed de-characterization work on the Campo Grande dam at its Alegria Mine in Mariana, which will be submitted to the authorities for final validation. The milestone brought the program to 19 structures and 63% progress on investment of R$12.7 billion, and Vale no longer has any structure at the maximum emergency level. The company expects to complete the program by 2035.

Nexa Resources S.A. (NYSE: NEXA) shows how tailings management has become a distinct capital allocation decision. Beginning in 2026, the zinc producer reclassified investments related to tailings dam management and mine development out of sustaining capital and into newly defined categories. Its 2026 outlook budgets US$89 million for tailings storage facilities, including US$13 million for dry-stack facilities at Cajamarquilla in Peru and Três Marias in Brazil. Separately, Nexa's sustaining capital includes US$8 million to expand tailings filtration capacity at Aripuanã in Mato Grosso.

The Value Left Inside

The other side of the ledger is what old material still holds. Earlier generations of miners left metal behind because their recovery methods were cruder or prices were lower, and some of those piles can now pass the industry's most demanding test. Avino Silver & Gold Mines Ltd. (NYSE American: ASM) (TSX: ASM) reported its inaugural consolidated mineral reserves on April 16, including Proven and Probable reserves at its Oxide Tailings Project in Durango, Mexico, of 6.7 million tonnes containing 12 million ounces of silver at 54 grams per tonne and 102,000 ounces of gold at 0.47 grams per tonne. The estimate rests on a 2024 pre-feasibility study. Tailings that once marked the end of a mine's life are carried as reserves for its next one.

Where the Two Ledgers Meet

JZR Gold Inc. (TSX-Venture: JZR) (OTCPK: JZRIF) works on a different part of that ledger. Rather than retiring a regulated dam, it is recovering gold from material left behind by earlier mining. Its Vila Nova Gold Project in Amapá State, Brazil, is processing surface material that, according to the company, accumulated over more than six decades of hand mining. JZR estimates that material at roughly nine million tonnes averaging 2.7 grams per tonne gold. That estimate is not a mineral resource or reserve, and further systematic sampling, quality-control work and metallurgical testing are required.

The processing approach relies on gravity rather than chemical extraction. JZR's June corporate presentation describes a circuit that moves material through desliming in a trommel, hammer crushing, screening, ball-mill grinding and dewatering to produce a gold concentrate, and specifies that no chemicals are used in crushing, grinding or centrifugation. The presentation also lays out environmental commitments to revegetate degraded areas around old dams, restore water quality in historical tailings dams and monitor turbidity and pH under the guidance of environmental agencies. Under the project's profit-sharing arrangement, 15% of net profit is allocated to the local miners' cooperative, COOPGAVIN.

The plant is permitted at the state and federal levels and has run on a regular schedule since August under JZR, which assumed operatorship on May 28. After working through equipment repairs and component replacements in the early weeks, the company reported in mid-September that approximately 11 tonnes of concentrate had been shipped toward São Paulo, and it is now focused on adding operating hours and improving reliability.

What Moves the Ledger

Each of these companies measures its legacy material differently. Vale counts structures and reais spent. Nexa budgets tailings facility by facility. Avino has converted tailings into reserves. At Vila Nova, the near-term measures are operating hours, tonnes processed and, ultimately, concentrate sales, and over time, the systematic sampling that could turn a company estimate into a defined resource.

Every tonne processed at Vila Nova is an attempt to recover value from material an earlier generation of miners left behind. In a country that has spent the past six years paying to retire its old tailings, it reflects a broader shift in how mining's legacy material is judged: not only by what it costs to manage, but by what it may still contain.

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