EU importers must disclose the results of their third-party audits to member-state competent authorities and publicly report the results of their due diligence practices
Due Diligence
EU importers must ensure their supply chain policy standards, contracts and agreements are consistent with the OECD Due Diligence Guidance (Conflict Minerals Due Diligence)
Includes risk management obligations requiring EU importers to identify and assess risks of adverse impacts in their supply chains and implement a strategy to respond to the identified risks
Normative scope
Human Rights
Environment
Other social matters
Illegal commodities
Broad ranging
Concerns only conflict minerals - tin, tantalum, and tungsten in addition to ores and gold originating from conflict-affected and high-risk areas)
Value chain scope
Own Operations
Subsidiaries
Direct Suppliers
Applicable to suppliers of minerals from conflict affected and high-risk areas
Indirect Suppliers
Full Value Chain
Due diligence requirements apply to importers of raw materials, but not for downstream companies
Company scope
Large Companies
SMEs
Other
Indirectly affects about 500 smelters and refiners whether they are based in the EU or not
All Sectors
Directly affects 600-1000 importers of conflict minerals as defined in the Regulation
Administrative enforcement
Monitoring
Authorities’ post-checks, third-party audits with possibility for third parties to refer to the competent authority
Administrative Sanctions
Member states must set the rules applicable in cases of infringement/non-compliance
There is no explicit enforcement mechanism in the law
Other
Judicial enforcement
Civil Liability
The regulation does not include company duty of care or parent company liability
Facilitating Access to Justice
Other
More information
Most provisions applied as of 1 January 2021
Law
Regulation 2017/821 of the European Parliament and of the Council (EU Conflict Minerals Regulation)
European Union
May 17, 2017
AreaEU Administrative Law
Reporting
Due diligence
Due diligence and remedy
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