How the EU Responsible Minerals Regulation impacts 3TG minerals and supply chain compliance
The EU Responsible Minerals Regulation addresses the sourcing of 3TG minerals—Tantalum, Tin, Tungsten, and Gold—ensuring companies prevent conflict minerals from entering the EU market. Since January 1st, 2021, EU importers of these minerals must conduct strict due diligence to avoid contributing to armed conflicts and human rights abuses. This article outlines the regulation’s purpose, scope, and key compliance challenges for businesses.
Conflict minerals refer to minerals extracted under conditions of armed conflict and human rights abuses, often by forced labour. The 3TG minerals—Tantalum, Tin, Tungsten, and Gold—are widely used in consumer goods like mobile phones, cars, and jewellery. Without responsible sourcing, these materials can fund armed groups and fuel instability.
The EU Conflict Minerals Regulation came into effect on 1 January 2021. It aims to:
▪️ Stem the flow of conflict minerals into the EU
▪️ Encourage global smelters and refiners to source responsibly
▪️ Support local community development and reduce the abuse of mine workers
The regulation applies to:
▪️ EU importers of 3TG minerals and metals
▪️ Smelters and refiners operating in the EU
▪️ EU manufacturers and companies conscious of ESG obligations
▪️ Entities sourcing minerals from high-risk areas (currently 27 regions)
While both frameworks address conflict minerals, the Dodd-Frank Act (2010) mainly focuses on minerals sourced from the Democratic Republic of the Congo and surrounding countries. In contrast, the EU Regulation has a broader geographical reach, covering all conflict-affected and high-risk areas worldwide.
Finding conflict-free minerals is complex. Companies must move beyond relying solely on conformant lists and prioritise responsible, traceable sourcing.
Common obstacles include:
▪️ Over-reliance on paper trails without field verification
▪️ Variations in audit quality and due diligence interpretation
▪️ Gaps in communication between upstream and downstream supply chain actors
Sustainable sourcing requires practical on-the-ground efforts, not just maintaining perfect documentation.
Factlines' Supplier Relationship Management (SRM) platform offers over 30 ready-to-use supply chain assessment questionnaires (SAQs) to help companies meet responsible sourcing and compliance requirements. Built-in risk scoring, AI summaries, and chain survey capabilities make it easier to collect, manage, and verify supplier data, including compliance with regulations like the EU Responsible Minerals Regulation.
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(Sourced only from official EU page)
The regulation aims to promote responsible sourcing of 3TG minerals and to stop conflict minerals from entering the EU market.
The EU regulation covers Tantalum, Tin,Tungsten, and Gold—the so-called 3TG minerals.
EU companies that import 3TG minerals or metals above specified annual thresholds must comply with the regulation.
CAHRAs are regions affected by armed conflict, weak governance, or widespread human rights abuses. Companies must bee specially diligent when sourcing from these areas.
No, downstream companies are not directly obliged to comply but are encouraged to support responsible sourcing practices.
Companies must conduct due diligence according to the OECD Due Diligence Guidance to ensure their sourcing does not contribute to conflict or abuses.
EU member states are responsible for monitoring compliance, with penalties for non-compliance decided at national levels.
Yes, the European Commission maintains a public list of global smelters and refiners deemed responsible under the regulation.
