Understanding Conflict Minerals Regulations
Conflict minerals regulations represent one of the most significant compliance frameworks affecting the global metals and mining industry. These regulations aim to prevent the trade in minerals that finance armed conflict, human rights abuses, and environmental destruction — particularly in the Democratic Republic of Congo (DRC) and surrounding countries.
For any business involved in sourcing, trading, or manufacturing with metals and minerals, understanding and complying with these regulations is essential — both legally and ethically.
What Are Conflict Minerals?
The term "conflict minerals" typically refers to four specific minerals and their derivatives:
Tin (cassiterite) — Used in solder, tin plating, and electronics
Tantalum (coltan) — Used in capacitors for electronics
Tungsten (wolframite) — Used in electronics, cutting tools, and ammunition
Gold — Used in electronics, jewelry, and investment
These are commonly referred to as **3TG** (tin, tantalum, tungsten, and gold). However, modern regulations are expanding beyond 3TG to cover additional minerals and metals as due diligence expectations evolve.
Key Regulations
Dodd-Frank Act Section 1502 (United States)
Enacted in 2010, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires publicly traded companies to:
Determine whether their products contain 3TG minerals
Conduct due diligence to determine the country of origin of those minerals
File annual reports with the SEC disclosing their findings
Make their Conflict Minerals Report publicly available
While Section 1502 applies directly to SEC-reporting companies, its requirements cascade through the supply chain — meaning even private companies that supply publicly traded manufacturers must be able to provide sourcing information.
EU Conflict Minerals Regulation (Regulation 2017/821)
The EU regulation, which became mandatory on January 1, 2021, takes a different approach:
Applies to **EU importers** of tin, tantalum, tungsten, and gold above specified volume thresholds
Requires importers to conduct **OECD-aligned due diligence** on their supply chains
Covers minerals originating from **any conflict-affected or high-risk area** (not just the DRC region)
Includes **third-party audit requirements** for smelters and refiners
The EU regulation is generally considered more stringent than Dodd-Frank because it requires proactive due diligence rather than just disclosure.
OECD Due Diligence Guidance
The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provides the internationally recognized framework for mineral supply chain due diligence. It includes:
**Five-Step Framework:**
**Establish strong company management systems** — Adopt and commit to a supply chain policy
**Identify and assess risks** — Map the supply chain and identify risk factors
**Design and implement a strategy to respond to identified risks** — Create risk mitigation plans
**Carry out independent third-party audit** of supply chain due diligence
**Report annually** on supply chain due diligence
This OECD framework is referenced by both the Dodd-Frank Act and the EU regulation as the standard for adequate due diligence.
Compliance in Practice
For metals buyers and traders, compliance means implementing practical measures:
Supply Chain Mapping
Document every link in your supply chain from mine to end-product. Know where your minerals originate, which smelters/refiners process them, and which intermediaries handle them.
Smelter/Refiner Verification
Verify that your smelters and refiners participate in recognized conformance programs:
RMI (Responsible Minerals Initiative) Responsible Minerals Assurance Process (RMAP)
LBMA Responsible Gold Guidance
RJC (Responsible Jewellery Council) Chain of Custody Standard
Risk Assessment
Evaluate country-of-origin risk using:
OECD Annex II risk factors
International sanctions lists
Conflict-affected and high-risk area (CAHRA) classifications
Human rights and environmental risk indicators
Record Keeping
Maintain comprehensive records of:
Supplier due diligence questionnaires (DDQs)
Smelter/refiner audit reports
Country-of-origin declarations
Risk assessment results and mitigation actions
How IGTC Ensures Conflict-Free Sourcing
At Integrity Global Trade, conflict-free sourcing is embedded in our business model:
100% UN Certified mine sources — We do not source from artisanal or unverified operations
OECD five-step framework — Fully implemented across our supply chain
ComplyAdvantage AI screening — Every counterparty screened against 200+ sanctions lists
Complete chain-of-custody — Mine-to-delivery documentation for every shipment
Annual compliance audit — Independent review of our due diligence practices
No conflict-affected sourcing — Zero tolerance for material from CAHRA regions without verified legitimate origin
Partner with Integrity Global Trade for conflict-free, fully documented metals sourcing. Our OECD-aligned due diligence framework and UN Certified mine sourcing ensure your supply chain meets the highest international standards.