Glossary term

chain of custody or supply chain traceability system

EU Conflict Minerals Regulation record of the sequence of economic operators with custody of minerals and metals through the supply chain.

1 official sourceSingle-source term

What does chain of custody or supply chain traceability system mean?

This term anchors traceability to a custody sequence. It should not be replaced by a single certificate, supplier name, or shipment record unless the economic-operator custody chain is represented.

Official definitions by source

EU Conflict Minerals

Regulation (EU) 2017/821 laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas

a record of the sequence of economic operators which have custody of minerals and metals as they move through a supply chain

Article 2 definitions for EU conflict-minerals due diligence. Source-specific to tin, tantalum, tungsten, their ores, and gold.

Reference: Article 2, point (e)

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Practical application

Implementation records should capture mineral or metal scope, actor role, source location, conflict-affected/high-risk area assessment, chain-of-custody or traceability record, due-diligence scheme or policy, risk-management decision, audit/disclosure evidence, and relevant OECD Guidance link where applicable.

Minespider commentary

For Minespider, conflict-minerals terms should route sourcing claims into auditable objects: mineral/material scope, importer declaration, smelter/refiner identity, custody sequence, area-risk classification, due-diligence policy, grievance/risk records, and recycled-metal or by-product evidence where relevant.

Common confusions

  • Treating conflict-minerals terms as generic ESG due-diligence language outside tin, tantalum, tungsten, ores, and gold scope.
  • Collapsing Union importer, smelter/refiner, and downstream product actors into one responsibility role.
  • Using chain-of-custody or traceability labels without sequence-of-custody and economic-operator evidence.

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