Conflict Minerals Regulation: Tin, Tantalum, Tungsten, and Gold
Quote from chief_editor on June 26, 2026, 5:30 pmHow conflict minerals regulations—EU Regulation 2017/821 and US Dodd-Frank Section 1502—apply to importers of tin, tantalum, tungsten, and gold, and what due diligence supply chain programs require.
Conflict minerals are natural resources extracted in conditions of armed conflict and used to finance insurgency groups or government forces that commit human rights abuses. The four minerals most associated with conflict financing—tin (and its ore, cassiterite), tantalum (coltan), tungsten (wolframite), and gold, collectively known as 3TG—are commercially important materials used in electronics, automotive components, aerospace, and jewelry, sourced in significant quantities from conflict-affected regions of sub-Saharan Africa, particularly the eastern Democratic Republic of Congo (DRC) and adjacent countries.
Two major regulatory frameworks govern 3TG supply chain due diligence: the US Dodd-Frank Wall Street Reform and Consumer Protection Act Section 1502, and the EU Conflict Minerals Regulation (EU) 2017/821. Both require companies in scope to conduct and document due diligence over their 3TG supply chains aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
The Two Regulatory Frameworks
US Dodd-Frank Section 1502 applies to SEC-registered companies that manufacture or contract to manufacture products for which 3TG are necessary to the functionality or production of those products, and where those minerals originated or may have originated in the DRC or an adjoining country. Covered companies must conduct OECD-aligned due diligence, file annual Conflict Minerals Reports with the SEC, and disclose the results of their supply chain investigation. The disclosure is a transparency requirement rather than a product ban; a company that sources from conflict-affected areas and discloses this accurately is compliant.
The EU Conflict Minerals Regulation (effective from January 2021) applies to EU importers of 3TG above defined annual import volume thresholds. Unlike the US regulation—which focuses on manufacturing companies using 3TG in products—the EU regulation targets the import side, applying to companies that are smelters, refiners, or importers of the minerals themselves or their ores and concentrates. EU importers above the thresholds must implement OECD due diligence systems, be audited by a third party against the OECD framework, and report annually to their national competent authority.
The OECD Due Diligence Guidance provides a five-step framework: establish strong company management systems (policies, supply chain data, risk management), identify and assess risks in the supply chain, design and implement a strategy to respond to identified risks, carry out independent third-party audit of supply chain due diligence practices at identified critical points (smelters and refiners), and report annually on supply chain due diligence.
Smelter and Refiner Programs
Smelters and refiners—the processing facilities that transform mineral ores and concentrates into refined metals—are the critical control points in the 3TG supply chain because they aggregate material from multiple mining sources. Due diligence at the smelter level can effectively trace the mineral origin across the upstream supply chain more efficiently than tracing each downstream product separately.
The Responsible Minerals Initiative (RMI) operates the Responsible Minerals Assurance Process (RMAP), an industry program that audits smelters and refiners against 3TG due diligence standards. Companies seeking to verify the conflict mineral status of their supply chains typically require their direct suppliers to source exclusively from RMAP-conformant smelters and refiners, as inclusion on the conformant smelter list indicates a third-party-verified due diligence program.
For commodity buyers—traders and industrial purchasers of tin, tantalum, tungsten, and gold—the practical compliance steps are: mapping which specific smelters and refiners process the 3TG in their supply chain, verifying those smelters' RMAP conformance status, collecting country of origin data for each shipment, and documenting the due diligence program maintained annually.
How conflict minerals regulations—EU Regulation 2017/821 and US Dodd-Frank Section 1502—apply to importers of tin, tantalum, tungsten, and gold, and what due diligence supply chain programs require.
Conflict minerals are natural resources extracted in conditions of armed conflict and used to finance insurgency groups or government forces that commit human rights abuses. The four minerals most associated with conflict financing—tin (and its ore, cassiterite), tantalum (coltan), tungsten (wolframite), and gold, collectively known as 3TG—are commercially important materials used in electronics, automotive components, aerospace, and jewelry, sourced in significant quantities from conflict-affected regions of sub-Saharan Africa, particularly the eastern Democratic Republic of Congo (DRC) and adjacent countries.
Two major regulatory frameworks govern 3TG supply chain due diligence: the US Dodd-Frank Wall Street Reform and Consumer Protection Act Section 1502, and the EU Conflict Minerals Regulation (EU) 2017/821. Both require companies in scope to conduct and document due diligence over their 3TG supply chains aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
The Two Regulatory Frameworks
US Dodd-Frank Section 1502 applies to SEC-registered companies that manufacture or contract to manufacture products for which 3TG are necessary to the functionality or production of those products, and where those minerals originated or may have originated in the DRC or an adjoining country. Covered companies must conduct OECD-aligned due diligence, file annual Conflict Minerals Reports with the SEC, and disclose the results of their supply chain investigation. The disclosure is a transparency requirement rather than a product ban; a company that sources from conflict-affected areas and discloses this accurately is compliant.
The EU Conflict Minerals Regulation (effective from January 2021) applies to EU importers of 3TG above defined annual import volume thresholds. Unlike the US regulation—which focuses on manufacturing companies using 3TG in products—the EU regulation targets the import side, applying to companies that are smelters, refiners, or importers of the minerals themselves or their ores and concentrates. EU importers above the thresholds must implement OECD due diligence systems, be audited by a third party against the OECD framework, and report annually to their national competent authority.
The OECD Due Diligence Guidance provides a five-step framework: establish strong company management systems (policies, supply chain data, risk management), identify and assess risks in the supply chain, design and implement a strategy to respond to identified risks, carry out independent third-party audit of supply chain due diligence practices at identified critical points (smelters and refiners), and report annually on supply chain due diligence.
Smelter and Refiner Programs
Smelters and refiners—the processing facilities that transform mineral ores and concentrates into refined metals—are the critical control points in the 3TG supply chain because they aggregate material from multiple mining sources. Due diligence at the smelter level can effectively trace the mineral origin across the upstream supply chain more efficiently than tracing each downstream product separately.
The Responsible Minerals Initiative (RMI) operates the Responsible Minerals Assurance Process (RMAP), an industry program that audits smelters and refiners against 3TG due diligence standards. Companies seeking to verify the conflict mineral status of their supply chains typically require their direct suppliers to source exclusively from RMAP-conformant smelters and refiners, as inclusion on the conformant smelter list indicates a third-party-verified due diligence program.
For commodity buyers—traders and industrial purchasers of tin, tantalum, tungsten, and gold—the practical compliance steps are: mapping which specific smelters and refiners process the 3TG in their supply chain, verifying those smelters' RMAP conformance status, collecting country of origin data for each shipment, and documenting the due diligence program maintained annually.