Regarding the Scope of EU Conflict Minerals


  1. Will EU Conflict Minerals only apply to publicly-traded companies based in the Common Market, similar to how the US Conflict Minerals Final Rule applies to publicly-traded companies based in the U.S.? More specifically, thinking of how the SEC filing requirement has been the primary mechanism of ensuring compliance for US companies, will there be a similar process or requirement that companies based in the EU have to face?
  2. Who has to comply with the regulation? What are the key criteria determining who needs to comply? Are there applicable thresholds, such as the volume of product exported into the USA, or does everyone have to comply irrespectively?


  1. No. EU Conflict Minerals applies to importers and smelters/refiners of products included in the harmonized tariff schedule. Here is the guidance website:
  2. The CFSI (now called the Responsible Minerals Initiative) has played a big role in the way companies have conducted their supply chain data collection process to comply with conflict minerals legislation. While a U.S. regulation may only directly apply to U.S. filers, this, like much regionally-based legislation, impacts companies around the globe. Regardless of your filing status, as an organization, there is a very good chance your organization is impacted by this and several other regulations around the globe.


**Article contents valid as of 2018-01-10


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