EU Conflict Minerals - EU Enforcement Measures and Smelter List Action


Once the EU conflict minerals regulation is promulgated will there be any enforcement measures at customs or various point of entry into the region? Will EU regulators maintain a list of smelters and will reporting be done annually?


Enforcement of the EU conflict minerals regulation will be the responsibility of each Member State (e.g. France, Germany, etc) and they will each determine how they enforce the regulation within their respective national jurisdictions. Due to the scope being closely defined within customs codes, the expectation is that a significant amount of enforcement will occur at customs. In addition, there will be after markets inspections and evaluation of facility records.

The EU Commission will create a list of responsible smelters and refiners.

Importers of minerals or metals shall publicize reports as widely as possible, including on the internet, and on an annual basis on their supply chain due diligence policies and practices for responsible sourcing.

In addition, those in scope of the EU non-financial reporting, will be expected to report yearly on their human rights programs which will include conflict minerals.


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