European Union (EU) Conflict Mineral Rule

What is the European Union (EU) conflict mineral rule?

Due to enter into force in January 2021, the EU conflict mineral rule (EU 2017/821) obliges EU importers of tin, tungsten, tantalum and gold (3TGs) to undertake due diligence to ensure their supply chains are not contributing to armed conflict and instability in the Democratic Republic of the Congo (DRC) and surrounding countries. In-scope companies must maintain documentation demonstrating compliance and the results of mandatory, independent third-party audits of their supply chain.

Who is in scope of the European Union (EU) conflict mineral rule?

The EU conflict mineral rule places due diligence obligations on union importers. In the context of EU conflict minerals, a union importer means any natural or legal person declaring minerals or metals for release for free circulation, or any natural or legal person on whose behalf such declaration is made. Enforcement will occur at the Member State level, with each state responsible for assigning an authority to conduct on-the-spot inspections of importers and review five years’ worth of mineral and metal import data.

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