We import fasteners which sometimes are tin-plated. Does the EU conflict minerals regulation affect us as downstream users?
The scope of the EU conflict minerals regulation will apply to the various forms of 3TGs as imported and not if they are part of downstream products (like fasteners). The specific nomenclature defining the customs codes for which imports are in scope are captured in Annex I of the Regulation. Downstream companies will be under pressure to use tools allowing them to demonstrate due diligence, and if companies fail to voluntarily adopt measures to comply in a sufficient manner, it will become mandatory in the future.