Should Your Business Comply with EU Conflict Minerals Regulation?

After years of negotiations between the EU Commission, EU Parliament, & the EU Council, and pressure from NGO’s and special interest groups, the European Union agreed on legislation to regulate the usage of 3TG (tantalum, tin, tungsten, and gold) in their member states. The law applies to importers of 3TG into the EU effective January 1, 2021.

Is My Business in EU Conflict Minerals Scope?


The EU regulation on conflict minerals is actually split between mandatory reporting for upstream actors of the supply chain and voluntary disclosures for downstream companies.


The regulation affects importers into the European Union of 3TG ores, concentrates, and metals whether to sell to smelters or refiners or to use in their manufacturing processes. Metals imported in the form of bars, rods, sheets, and other “raw” parts also fall under the scope of the reporting requirements.


Manufacturers who source finished components and companies that import or distribute end-user products containing any of the 3TG are not required to comply, although a proactive due diligence approach would go a long way, if only for brand management purposes.


Take This Short Quiz to Evaluate Your Risk Level and Need to Comply with EU Conflict Minerals Regulation 


Recommended EU Conflict Minerals Compliance Action Plan


Are you required to comply with EU Conflict Minerals Regulations? If yes, keep reading. If not, keep reading. It is a commonly encouraged best practice to always be prepared.


Source Intelligence has spent years working closely with the EU conflict minerals regulation actors since the inception of the program. This has led us to create a compliance solution that leverages technology and industry collaboration, thereby significantly minimizing legwork and increasing suppliers’ engagement.


  1. Update your list of suppliers with current information. Lucky you, the days of sending forms by fax are over (right?). Source Intelligence’s proprietary algorithm and unique database will help you clean your supplier list.
  2. Conduct an RCOI. The Reasonable Country of Origin Inquiry (RCOI) determines whether a supplier is in-scope for 3TG content originated in any of the covered countries and regions or is recycled from scrap sources.
  3. Map out your due diligence process. Regardless of what you have accomplished so far, chances are you are due for a refresh. Why? Because risks migrate or expand, suppliers change sometimes unbeknownst to you, and data is dynamic.
  4. Knowledge is power. Validated information is gold. Our team of experts act as an extension of your procurement, financial, policy, and technology departments to unify your efforts and keep suppliers engaged.
  5. Develop a reporting process. Actually, you don’t have to. Our conflict minerals solution includes a report-ready scheme: a set of complete, consistent documents that detail the efforts made by all parties and offer comprehensive compliance information.


The one last item you should consider adding to your action plan is adopting a program that can bridge numerous compliance requirements so there is no need to multiply the workload, but rather leverage efficiencies.


Are you meeting European Conflict Minerals compliance requirements? If you’re behind schedule, don’t have the resources, or are overwhelmed, we can take it off your plate. Let us show you how we can ensure compliance in time for the deadline and beyond so you can continue to focus on your core business functions.

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