EU Conflict Minerals - End User Obligations

Question:

I purchase my goods from an EU-based distributor. What obligations do I face with regards to the EU conflict minerals regulation and how does it affect me overall?


Answer:

As long as the 3TG has already been cleared for free circulation into the EU market, the reporting obligations are solely for the importers. You will not have the legal obligation but will still need to flow the question of compliance to the distributor since they may be a risk for supply chain interruption (i.e., their supply becomes unavailable due to non-compliance with the law).


Reference: http://trade.ec.europa.eu/doclib/docs/2017/march/tradoc_155423.pdf

 

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