It doesn't seem apparent to me that an importer of product such as tube, pipe, fabricated steel structures would be impacted by the EU conflict minerals regulation. Only those that import more basic components incorporated into finished products might be the ones in scope. Is this understanding correct?
Products in scope are captured in Annex I of the Regulation:
The EU Conflict Minerals Regulation will be mandatory for importers of the above products but downstream companies who use those products in their products will be pressured to adopt voluntary due diligence programs.
The list is available in Annex I in the provided link and the definitions are also specified in the law on conflict minerals and metals:
(a) 'minerals' means the following as listed in Part A of Annex I:
– ores and concentrates containing tin, tantalum or tungsten, and
(b) 'metals' means metals containing or consisting of tin, tantalum, tungsten or gold as listed in Part B of Annex I;