EU Conflict Minerals Regulation - What Are My Obligations?

Question: What are my current obligations under the European Union (EU) Conflict Minerals Regulation? How do I know what is required and if it affects my company?

Answer: A company has legal reporting obligations under EU Conflict Minerals Regulation only if they are importers of raw materials such as tin ingots, solders, sheet metals and powders. The regulation is expected to have the most effect on companies that voluntarily step up to demonstrate due diligence, rather than the few companies that actually import the in-scope raw materials. The issue is already drawing significant attention in Europe, even with the business changes brought about by the COVID-19 pandemic.

It is also important to note that direct legal obligations are not the only factor in EU Conflict Minerals Regulation compliance. Market expectations are likely to be significant and companies may face pressure from customers, peers and other external stakeholders to broaden their corporate social responsibility (CSR) programs to champion ethical business practices in every part of their business. This pressure stems from a growing belief that companies cannot choose to complete due diligence activities in some high-risk areas but not others, as it undermines the legitimacy of existing CSR programs.

Article is current as of 2020-05-29.

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